Securing America's Electric Grid: Public Power's Recommendations for a More Secure, Reliable, and Affordable Supply Chain
As the electric industry undertakes historic investments to modernize and expand the nation's grid, securing the supply chain for critical infrastructure has become increasingly important to national security, grid reliability, and customer affordability.
The Large Public Power Council (LPPC) and American Public Power Association (APPA) submitted joint comments to the U.S. Department of Energy (DOE) on implementing Executive Order 14421, Declaring a National Emergency to Secure the United States Bulk-Power System.
The comments outline public power's recommendations for reducing foreign adversarial threats to critical grid infrastructure while avoiding unnecessary costs, equipment shortages, and delays to essential investments. LPPC and APPA share DOE's goal of keeping foreign adversaries out of the bulk-power system, and the comments are meant to make that goal workable for the utilities that must carry it out.
LPPC and APPA recommend a practical, risk-based approach focused on five priorities:
- Prioritize critical infrastructure: Focus security requirements on equipment and facilities posing the greatest risks to national security and grid operations.
- Protect existing investments: Prioritize cybersecurity mitigation over costly equipment replacement when appropriate, informed by threat information that DOE and other federal agencies share with utilities. Utilities report replacement timelines of 24–48 months, compared to months for many mitigation measures.
- Strengthen supply chain transparency: Build a certification framework, set by DOE and NERC and carried out by industry, to show who makes the critical components inside equipment and who owns those suppliers.
- Leverage existing reliability standards: Build on NERC's established cybersecurity and supply chain standards to avoid duplicative compliance requirements.
- Prevent unnecessary delays: Protect existing procurement commitments and establish emergency exemptions to ensure utilities can rapidly restore service following storms, fires, and equipment failures.
The filing lays out two stages: what DOE can do by December 24 with information utilities have today, a risk-based restriction on new purchases from their own suppliers, and what would require new capabilities, built through existing NERC frameworks, if DOE chooses to go further.
For not-for-profit public power utilities, supply chain security and customer affordability must go hand in hand. Every additional dollar spent on equipment, compliance, or project delays is ultimately borne by the communities they serve.
