Dear Director Coe: 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 April 20, 2021, by the Office of Electricity, Department of Energy (“DOE”)¹. The RFI, entitled “Ensuring the Continued Security of the United States Critical Electric Infrastructure,” was issued to seek stakeholder input to inform the next steps from DOE and the Administration as they consider the potential issuance of a new executive order to replace Executive Order 13920, “Executive Order on Securing the United States Bulk-Power System” (the “BPS EO”), which was issued by the prior administration on May 1, 2020.²
Consistent with the Chamber’s previous comments on and communications with DOE regarding bulk electric system supply chain security, these comments leverage the broad knowledge base and real-world experiences of the Chamber’s working group representing the majority of the primary participants in the electric sector supply chain for the United States bulk electric system (the “Supply Chain Working Group”). Through its interactions with other stakeholder groups, DOE, and the broader Administration, 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. The working group also aims to ensure that DOE has a robust understanding of the indispensable stakeholders and associated interests that are directly impacted by, and will be required to achieve compliance with, any forthcoming directives or orders relevant to the bulk electric system supply chain. The comments below reflect the extensive collaboration and agreement of these bulk electric system supply chain participants, while simultaneously attempting not to oppose or otherwise be adverse to the views held by the other key stakeholders to the bulk electric system.