Rainey Center Freedom Project Urges DOE To Base Grid Security Rules On Demonstrated Risk And Verifiable Standards
(MENAFN- EIN Presswire)
Comments on Executive Order 14421 urge independent testing, scrutiny of foreign access pathways, and security standards beyond country of origin.
WASHINGTON, DC, UNITED STATES, October 10, 2026 /EINPresswire / -- The Rainey Center Freedom Project today submitted formal comments to the U.S. Department of Energy on implementation of Executive Order 14421, Declaring a National Emergency To Secure the United States Bulk-Power System.
The Rainey Center Freedom Project supports the President's emergency declaration and the Administration's effort to address foreign threats to critical energy infrastructure. Its comments urge DOE to implement the Order through a clear, administrable framework that focuses on whether equipment presents an actual security risk and whether that risk can be independently verified and mitigated.
“Foreign access to America's electric grid is a serious national-security threat, and the Administration is right to act,” said Sarah E. Hunt, President of the Rainey Center Freedom Project.“But the strongest rule is one that measures the actual security risk. Meeting rigorous, independently verified security standards should matter more than country of origin alone.”
Executive Order 14421 does not impose a self-executing ban based solely on where equipment was made. The Order requires DOE to determine both that a transaction has a Covered Foreign Entity nexus and that it presents an undue or unacceptable risk. The Rainey Center Freedom Project urges DOE to preserve that structure in its implementing regulations.
The comments recommend that DOE:
Judge equipment by whether it meets the security standard, not simply by where it was made. Country of origin should inform scrutiny, but the decisive question should be whether the equipment's access, software, communications, and control pathways can meet rigorous security requirements.
Focus on whether a Covered Foreign Entity can reach the equipment. DOE should examine whether a manufacturer or vendor can remotely access, monitor, control, update, diagnose, or communicate with equipment without the asset owner's authorization.
Recognize when the access pathway has been closed. Equipment should receive different treatment where update, diagnostic, and commissioning authority has been transferred to the asset owner or another non-covered party and that handoff has been independently verified.
Use existing NERC frameworks for system consequence. DOE should distinguish among equipment based on how its compromise could affect the bulk-power system rather than treating every device as presenting the same risk.
Require independent testing. Prequalification should include verification of access architecture, firmware controls, signing keys, and cybersecurity protections by qualified laboratories.
Avoid duplicative federal processes. DOE should allow one security evidence package to support DOE review and related federal Conditional Approval processes where the underlying security showing is the same.
Mitigate before removing installed equipment. Network segmentation, monitoring, disabling vendor access, owner-controlled updates, and independent testing should be used where they can close the risk pathway without unnecessarily taking equipment offline.
Apply new requirements prospectively where appropriate. DOE should avoid stranding contracted projects where secure alternatives are not yet available at scale and should consider reliability and replacement timelines before requiring removal.
The Rainey Center Freedom Project's comments propose three questions to guide DOE's review: Can a Covered Foreign Entity reach the equipment without the owner's authorization? What would happen if the equipment were compromised? Where was the equipment manufactured, produced, or assembled?
The comments argue that origin is an important factor, but it should not substitute for the risk determination required by the Executive Order. Equipment manufactured in the United States can still present a cybersecurity vulnerability if a foreign entity retains access or control, while foreign-produced equipment may present a different risk profile where that access pathway has been closed and independently verified.
The Rainey Center Freedom Project also urges DOE to recognize the practical realities of the U.S. energy supply chain. More than 90 percent of photovoltaic inverters supplied to U.S. commercial, industrial, and utility-scale markets over the past decade were imported, and domestic capacity cannot expand overnight. The comments argue that DOE should secure existing supply while domestic manufacturing expands rather than make new domestic production the only pathway for equipment to remain available.
“A clear standard gives manufacturers something they can design to and gives utilities something they can rely on,” Hunt said.“If a foreign actor can still reach the equipment and the consequence is unacceptable, DOE should restrict it. If that pathway has been closed and independently verified, DOE should recognize that security showing.”
The Rainey Center Freedom Project concludes that DOE should restrict equipment where a Covered Foreign Entity retains an access pathway that creates an undue or unacceptable risk, while allowing equipment to remain available where that pathway has been closed and independently verified.
As the comments state:“Secure the pathway, and keep the capacity the country has contracted to build.”
About the Rainey Center Freedom Project
The Rainey Center Freedom Project advances freedom, security, and a reliable, affordable power grid through public-policy advocacy. Rainey Center Freedom Project.
The Rainey Center Freedom Project supports the President's emergency declaration and the Administration's effort to address foreign threats to critical energy infrastructure. Its comments urge DOE to implement the Order through a clear, administrable framework that focuses on whether equipment presents an actual security risk and whether that risk can be independently verified and mitigated.
“Foreign access to America's electric grid is a serious national-security threat, and the Administration is right to act,” said Sarah E. Hunt, President of the Rainey Center Freedom Project.“But the strongest rule is one that measures the actual security risk. Meeting rigorous, independently verified security standards should matter more than country of origin alone.”
Executive Order 14421 does not impose a self-executing ban based solely on where equipment was made. The Order requires DOE to determine both that a transaction has a Covered Foreign Entity nexus and that it presents an undue or unacceptable risk. The Rainey Center Freedom Project urges DOE to preserve that structure in its implementing regulations.
The comments recommend that DOE:
Judge equipment by whether it meets the security standard, not simply by where it was made. Country of origin should inform scrutiny, but the decisive question should be whether the equipment's access, software, communications, and control pathways can meet rigorous security requirements.
Focus on whether a Covered Foreign Entity can reach the equipment. DOE should examine whether a manufacturer or vendor can remotely access, monitor, control, update, diagnose, or communicate with equipment without the asset owner's authorization.
Recognize when the access pathway has been closed. Equipment should receive different treatment where update, diagnostic, and commissioning authority has been transferred to the asset owner or another non-covered party and that handoff has been independently verified.
Use existing NERC frameworks for system consequence. DOE should distinguish among equipment based on how its compromise could affect the bulk-power system rather than treating every device as presenting the same risk.
Require independent testing. Prequalification should include verification of access architecture, firmware controls, signing keys, and cybersecurity protections by qualified laboratories.
Avoid duplicative federal processes. DOE should allow one security evidence package to support DOE review and related federal Conditional Approval processes where the underlying security showing is the same.
Mitigate before removing installed equipment. Network segmentation, monitoring, disabling vendor access, owner-controlled updates, and independent testing should be used where they can close the risk pathway without unnecessarily taking equipment offline.
Apply new requirements prospectively where appropriate. DOE should avoid stranding contracted projects where secure alternatives are not yet available at scale and should consider reliability and replacement timelines before requiring removal.
The Rainey Center Freedom Project's comments propose three questions to guide DOE's review: Can a Covered Foreign Entity reach the equipment without the owner's authorization? What would happen if the equipment were compromised? Where was the equipment manufactured, produced, or assembled?
The comments argue that origin is an important factor, but it should not substitute for the risk determination required by the Executive Order. Equipment manufactured in the United States can still present a cybersecurity vulnerability if a foreign entity retains access or control, while foreign-produced equipment may present a different risk profile where that access pathway has been closed and independently verified.
The Rainey Center Freedom Project also urges DOE to recognize the practical realities of the U.S. energy supply chain. More than 90 percent of photovoltaic inverters supplied to U.S. commercial, industrial, and utility-scale markets over the past decade were imported, and domestic capacity cannot expand overnight. The comments argue that DOE should secure existing supply while domestic manufacturing expands rather than make new domestic production the only pathway for equipment to remain available.
“A clear standard gives manufacturers something they can design to and gives utilities something they can rely on,” Hunt said.“If a foreign actor can still reach the equipment and the consequence is unacceptable, DOE should restrict it. If that pathway has been closed and independently verified, DOE should recognize that security showing.”
The Rainey Center Freedom Project concludes that DOE should restrict equipment where a Covered Foreign Entity retains an access pathway that creates an undue or unacceptable risk, while allowing equipment to remain available where that pathway has been closed and independently verified.
As the comments state:“Secure the pathway, and keep the capacity the country has contracted to build.”
About the Rainey Center Freedom Project
The Rainey Center Freedom Project advances freedom, security, and a reliable, affordable power grid through public-policy advocacy. Rainey Center Freedom Project.
Megan Sibley
Joseph Rainey Center for Public Policy
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Rainey Center Freedom Project Urges DOE to Base Grid Security Rules on Demonstrated Risk and Verifiable Standards News Provided By Joseph Rainey Center for Public Policy, Inc October 10, 2026, 17:20 GMT Share This Article Distribution channels: Electronics Industry, Energy Industry, IT Industry, Technology, U.S. Politics
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