Executive order reaches grid equipment already contracted and installed

The White House declared a national emergency over foreign-produced grid equipment on August 26. Executive Order 14421 names inverters and battery storage directly, and gives the Department of Energy 120 days to write the rules.

FERC opened a comment window on the paperwork burden for EOP-004-5, a revision to NERC's event reporting standard. It adds a reporting trigger for fast generation loss from inverter-based resources (IBRs), and brings Category 2 Generator Owners and Generator Operators into scope.

And... The ballot pool for NERC's computational load standards closes September 3.

Product Update

SharePoint Integration

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How to enable it: Organization Admins can visit the Integrations page to enable the SharePoint integration. You'll need a Microsoft Admin to do this for you. After this, you'll see the option to "Upload from SharePoint" when you upload a file to the Policies or Evidence modules.

Manage each tier of program documentation

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Industry Update

Executive Order 14421 Reaches Grid Equipment You Already Own

President Trump signed Executive Order 14421 on August 26, declaring a national emergency over foreign-produced bulk-power system equipment.

The order names the equipment directly: "utility-scale and other grid-connected inverters," battery energy storage systems, substation transformers, and large, small and backup generators, among others. Its bulk-power system definition covers transmission rated at 69 kV or above and excludes local distribution.

This one binds by equipment and transaction, not by NERC registration, so it reaches Generator Owners, Generator Operators, Transmission Owners and Transmission Operators alike.

Scope runs past the hardware. The order reaches "any critical component, software, firmware, digital service, maintenance service, or remote-access capability" associated with that equipment.

A prior contract is not shelter. Section 2(a) covers transactions initiated after August 26, and Section 2(d) applies that "notwithstanding any contract entered into or any license or permit granted prior to the date of this order."

Equipment already in the ground is reachable separately. On the same determinations, Section 2(b) lets the Secretary of Energy impose conditions on equipment "acquired or installed before the date of this order," including requirements to "identify, isolate, monitor, secure, disconnect, replace, or remove" it.

Nothing is prohibited yet. The order directs the Secretary to publish implementing rules within 120 days, which lands on December 24, 2026. Ampyx Cyber has a detailed read of where the order meets CIP-013-2 and CIP-003-9, including what to inventory before then.

Event Reporting Is Being Revised, and Category 2 IBRs Are In Scope

FERC published a notice on August 25 opening comment on the paperwork burden of EOP-004-5, the revised Event Reporting standard, in Docket No. RD26-8-000. It makes two changes.

• New Attachment 1 trigger: "an unexpected loss of generation within a Balancing Authority Area from IBR(s) in a period of 30 seconds or less following a disturbance." The current standard, EOP-004-4, measures generation loss over one minute.

• Who has to report. FERC's notice says "a new classification for generator owner category 2 and generator operator category 2 will now be applicable" to event reporting.

FERC estimates 8 hours a year for a GO or GOP and 4 hours for a Balancing Authority, or 2,268 hours and $189,128 across the industry.

Comments on the information collection are due October 26, 2026. The standard itself still needs a FERC order before any of this binds anyone.

Compliance Resources

Last Call to Join the Computational Load Ballot Pool

Registered Ballot Body members have until 8:00 p.m. Eastern on Thursday, September 3 to join the ballot pool for Project 2026-02 Computational Loads. Members who join by then can vote. After that, they can still comment, but not vote. The initial ballot runs September 9 to 18 and comments close on September 18.

Under the proposed CLO-001-1, a Generator Owner is reached by having a Computational Load Site interconnection, or a fully executed Agreement to study one, at a site with 50 MW or more of total connected Load supplied at 100 kV or above. NERC's proposed Rules of Procedure revisions creating the Computational Load Owner and Computational Load Operator entity types are out for comment on the same September 18 date.

Important Dates

• September 3, 2026: Ballot pool closes for Project 2026-02 Computational Loads, 8:00 p.m. Eastern. Registered Ballot Body members must join by this date to vote on CLO-001-1, CLO-002-1, CLO-003-1, FAC-001-5 and FAC-002-5.

• September 15-16, 2026: NERC Load Modeling Working Group workshop on data center load modeling, 12:00 p.m. to 5:00 p.m. Eastern each day, on Microsoft Teams.

• September 18, 2026: Comments close on Project 2026-02 Computational Loads and on the Rules of Procedure appendices, 8:00 p.m. Eastern. Same day, comments due on FERC-725U, the CIP-014-3 information collection (Docket No. IC26-29-000), which reaches Transmission Owners and Transmission Operators.

• October 1, 2026: PRC-024-4, PRC-029-1 and PRC-030-1 become effective. Design requirements for BES IBRs come due on this date; applicable non-BES IBRs run to January 1, 2027.

• December 24, 2026: Department of Energy implementing rules due under Executive Order 14421, 120 days from signing.