Dear Secretary Bose: The U.S. Chamber of Commerce (“the Chamber”) appreciates the opportunity to submit these comments in response to the Notice of Inquiry (“NOI”) issued on September 17, 2020, by the Federal Energy Regulatory Commission (“FERC” or “Commission”).1 The NOI, entitled “Equipment and Services Produced or Provided by Certain Entities Identified as Risks to National Security,” was issued by FERC to seek comments on the potential risks to the bulk electric system posed by the power sector’s use of equipment and services produced or provided by entities identified as risks to national security. FERC has chosen to solicit comments from industry on this topic in the wake of, among other things, Presidential Executive Order 13920, issued on May 1, 2020.2
In the immediate wake of the issuance of the Bulk-Power System Executive Order (the “BPS EO”), and in order to provide comprehensive feedback and guidance with respect to its implementation, 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 electric 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 with respect to perceived electric sector supply chain vulnerabilities – and the rectification thereof – via the Electricity Subsector Coordinating Council, the Edison Electric Institute, or otherwise. As a subgroup of the Chamber, however, the Supply Chain Working Group has also welcomed input from members operating in other industry sectors, such as those within the oil and gas industry. The Supply Chain Working Group seeks to ensure that the Department of Energy (“DOE”), and now FERC, have a robust understanding of the full breadth of stakeholders and associated interests that are impacted by, and would be required to achieve compliance with, any regulatory or rulemaking activities relating to the vast range of components manufactured for and integrated within the bulk electric system. The comments set forth herein reflect the extensive collaboration and agreement of these bulk electric system supply chain entities and other impacted industry participants.