Dear Deputy Assistant Secretary Kosak:
The U.S. Chamber of Commerce (“the Chamber”) appreciates the opportunity to submit these comments in response to the Request for Information (“RFI”) issued on July 8, 2020, by the Office of Electricity, Department of Energy (“DOE”).1 The RFI, entitled “Securing the United States Bulk-Power System,” was issued to seek information related to the energy industry’s current practices to identify and mitigate perceived vulnerabilities in the supply chain for bulk-power system components. DOE is soliciting comments pursuant to the RFI in order to inform its efforts to implement the directives set forth in Executive Order 13920 (the “BPS EO”), issued on May 1, 2020.2
In order to assist DOE with its development of a notice of proposed rulemaking or other implementing guidance responsive to the BPS EO, the Chamber immediately convened an informal working group representing the majority of the primary participants in the electric sector supply chain for the United States bulk power system (the “Supply Chain Working Group”). The Supply Chain Working Group intends for its efforts to supplement the contributions of electric utility interests providing feedback via the Electricity Subsector Coordinating Council, or otherwise, to ensure that DOE has a robust understanding of the full breadth of stakeholders and associated interests that are impacted by, and will be required to achieve compliance with, the BPS EO. The comments below reflect the extensive collaboration and agreement of these bulk power system supply chain participants.