Ampyx Cyber Blog
The Intersection of Regulation & Resilience
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
Reinforcing the U.S. Grid: The 2025 USCC Report on Chinese Energy Influence
The 2025 USCC Annual Report outlines national security risks from PRC-linked technologies in the U.S. energy sector. It offers clear, field-informed recommendations, including testimony from Ampyx Cyber’s CEO, on supply chain threats, OT device transparency, and cyber response. Read the full analysis and policy roadmap.
Cybersecurity Performance Goals 2.0: Governance First, Outcomes Always
CISA’s Cybersecurity Performance Goals 2.0 reshape baseline expectations for critical infrastructure. The update elevates governance, strengthens OT-specific requirements, and shifts from checklist controls to outcome-driven resilience. This Policy Pulse post breaks down what changed, why it matters, and how operators should prepare.
Cybersecurity Signals in the 2025 National Security Strategy
The 2025 National Security Strategy weaves cybersecurity into every major national priority, from resilient infrastructure and protected supply chains to technology leadership and secure global partnerships. This overview highlights the core cyber related themes and what they signal for critical infrastructure and industry.
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.
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.