Ampyx Cyber Blog

The Intersection of Regulation & Resilience

What DOE's EO 14421 FAQ Puts in Writing
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

What DOE's EO 14421 FAQ Puts in Writing

The Department of Energy (DOE) published a 22-question frequently asked questions (FAQ) document on Executive Order (EO) 14421 on October 6, three days before its request for information closed. Most of it puts on paper what DOE said at the September webinar, and a few answers go further, on data centers, on reliability standards, and on when a transaction counts as initiated.

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 When AI Changes Without a Change Request
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

When AI Changes Without a Change Request

On September 28 and 29 I will be at The Utility Change Conference West 2026 in Phoenix to talk about the artificial intelligence (AI) changes that never enter a utility's change process. A vendor feature toggle or a model update can alter what a tool reaches and how it behaves while the configuration baseline shows nothing. This preview walks through the questions those changes raise under the North American Electric Reliability Corporation (NERC) Critical Infrastructure Protection (CIP) standards, using three recent incidents outside the utility sector as context.

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Four Things in the EO 14421 Webinar That Aren't in the RFI
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

Four Things in the EO 14421 Webinar That Aren't in the RFI

The Department of Energy (DOE) held its public webinar on the Executive Order (EO) 14421 request for information (RFI) on September 16. Most of the hour restated the notice, but four things came up that aren't in the RFI text at all. The one with the shortest fuse is that a phone call to DOE about this proceeding puts a memo in the public docket, and you're the one who has to write it.

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Who Owns the Risk? The AI Reliability Boundary Assessment Questions
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

Who Owns the Risk? The AI Reliability Boundary Assessment Questions

An AI decision-support platform fails at 2:07 on a weekday afternoon. At 2:22 the fifteen-minute reliability window closes and the vendor is still investigating. This is the full question set from the CYBR.SEC.CON talk, forty questions across four NERC CIP standards plus the ownership map behind them. You score your own answers, and nothing on this page collects anything.

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Question H-3: DOE Asks Whether Industry Should Execute the Bulk-Power Order
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

Question H-3: DOE Asks Whether Industry Should Execute the Bulk-Power Order

DOE's Request for Information on Executive Order 14421 includes one question, H-3, asking whether industry standards bodies and third-party labs can execute the order instead of the federal government. The electric sector ran something close to this before, under the Electric Reliability Organization. This post looks at what changes when the statute is IEEPA, not the Federal Power Act, and what a working precedent outside the sector suggests.

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Nothing Is Grandfathered: The EO 14421 RFI on Existing Equipment
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

Nothing Is Grandfathered: The EO 14421 RFI on Existing Equipment

DOE has opened a 30-day request for information on how it will implement Executive Order 14421, the order restricting foreign-produced bulk-power system equipment. The most consequential questions concern equipment already installed, since the order does not grandfather it, and how DOE will define "foreign-produced" in the first place. Comments are due October 9, with a public webinar on September 16.

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Executive Order 14421 and the Bulk-Power System Supply Chain [Updated]
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

Executive Order 14421 and the Bulk-Power System Supply Chain [Updated]

An executive order signed August 26, 2026 declares a national emergency over foreign-produced bulk-power system electric equipment. It reaches 69 kV and above, adds software, firmware, a list of OT/ICS gear, and vendor remote access to scope, and creates authority to condition or remove equipment already installed. Here is what changed since the 2020 order, where it meets CIP-003-9 and CIP-013-2, and what to do before December 24.

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Your Environment, Your Risk: Building an OT Risk Management Program You Can Defend
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

Your Environment, Your Risk: Building an OT Risk Management Program You Can Defend

There is no rulebook for securing an OT environment, and there never could be. Two utilities can make entirely different choices and both be defensible. Here is how to build an OT risk management program you can stand behind: map your environment, rank the consequences you will not tolerate, choose controls deliberately, and document why, so you can defend every decision an auditor asks about.

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Cloud Comes to NERC CIP: The 100-Series and Project 2023-09
Deep Dive Patrick Miller Deep Dive Patrick Miller

Cloud Comes to NERC CIP: The 100-Series and Project 2023-09

NERC did not revise the CIP Standards for the cloud. It forked them. Project 2023-09 introduces a parallel 100-Series, an entity can elect into per system, built on a new foundation called BES Cyber Services and Systems (BCSS), with System Security Plans replacing asset lists and Cyber Security Zones replacing the Electronic Security Perimeter. Here is how the parallel track works, what the first drafts actually say, and the open problems worth commenting on before August 21.

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Using the Work of Others in NERC CIP and O&P Compliance
Deep Dive Patrick Miller Deep Dive Patrick Miller

Using the Work of Others in NERC CIP and O&P Compliance

The work of others lets you lean on someone else's assessment as compliance evidence. It does not transfer accountability. This breakdown maps the ERO guidance stack, the two-part test auditors apply, worked examples for CIP-013 vendor assessments and BCSI in the cloud, the FERC FY2025 findings on delegation gone wrong, and the audit prep questions to answer first.

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Protocol Converters: The 2023 SAR Just Got Validated (Again)
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

Protocol Converters: The 2023 SAR Just Got Validated (Again)

The 2023 NERC SAR asked whether protocol converters belong inside CIP-002. A new disclosure of 22 CVEs in serial-to-Ethernet hardware, set against a decade of advisories across the category, settles the question. The categorization debate now has its empirical record, and asset owners have CIP-007 R2 and CIP-013 work to do that does not wait for the standard.

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Funded, Not Secured: The April 20 DPA Determinations & the Bulk Electric System
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

Funded, Not Secured: The April 20 DPA Determinations & the Bulk Electric System

Two April 20 Defense Production Act determinations expand domestic capacity for grid components and large-scale energy infrastructure. Neither addresses cybersecurity. For the electric sector, NERC CIP and Order 693 standards still apply. A practitioner's view of intersections with CIP-013, CIP-014, PRC, FAC, and TPL, and why domestic capacity is not domestic assurance.

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National Cyber Strategy: What It Means for Critical Infrastructure
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

National Cyber Strategy: What It Means for Critical Infrastructure

The Trump administration released its long-awaited National Cyber Strategy. Six pages, six pillars, and a clear signal that federal cyber policy is shifting toward offensive posture and regulatory streamlining. For critical infrastructure operators, the document raises more questions than it answers. Here is what it says, what it doesn't, and what you should do about it.

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Humans, Engineering Shifts, Required Investment, and Commitment for Operational Security
Deep Dive Patrick Miller Deep Dive Patrick Miller

Humans, Engineering Shifts, Required Investment, and Commitment for Operational Security

New secure connectivity guidance describes a greenfield target architecture, but most OT environments are brownfield reality. True resilience isn't achieved through technology alone. Human expertise, manual operating capability, physical engineering controls, and sustained investment are equally critical. Without these foundations, digital security layers risk becoming expensive new failure modes.

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New NSA UEFI Guidance: Trust Starts Before the OS
Deep Dive Patrick Miller Deep Dive Patrick Miller

New NSA UEFI Guidance: Trust Starts Before the OS

UEFI Secure Boot is widely assumed to be enabled and enforcing, yet recent vulnerabilities show how easily trust at boot time can silently fail. NSA’s new guidance breaks down how Secure Boot actually works, where configurations commonly go wrong, and how organizations can validate and recover trust in the earliest stages of system startup.

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Closing the Gaps: FERC Order 912 and the Future of Supply Chain Risk Management
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

Closing the Gaps: FERC Order 912 and the Future of Supply Chain Risk Management

FERC Order 912 marks a shift in supply chain cybersecurity for the Bulk-Power System. It directs NERC to strengthen supply chain protections by closing gaps in risk identification, reassessment, and response, and by extending coverage to Protected Cyber Assets. Vendor data validation is encouraged but not mandated, and NERC has 18 months to deliver new or revised standards.

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Securing Tomorrow’s Grid: FERC Acts on Low Impact, Virtualization, and Supply Chains
Policy Pulse Patrick Miller Policy Pulse Patrick Miller

Securing Tomorrow’s Grid: FERC Acts on Low Impact, Virtualization, and Supply Chains

FERC’s September 2025 actions reshaped grid reliability standards by tightening security requirements for low-impact assets, adding authentication, encryption, and monitoring; new requirements and new definitions to support secure adoption of virtualization technologies; and expanding supply chain protections to cover Protected Cyber Assets and other connected systems.

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