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August 24, 2020

### ESA Seeks Greater Clarity in DOE Implementation of Bulk Power System Supply Chain Controls

ESA filed comments requesting that the Department of Energy (DOE) implement the Executive Order on Securing the Bulk Power System in a manner that focuses on reducing regulatory uncertainty and the cost to compliance faced by U.S. businesses. ESA notes that, while energy storage systems are not specifically listed in the Executive Order, significant uncertainty remains for U.S. industry members (see ESA’s summary). Specifically, ESA recommends that DOE re-orient to defining included equipment, rather than defining excluded equipment. Additionally, ESA recommends that DOE clearly delineate the aspects of compound products, such as battery packs, that trigger compliance requirements, and ESA asks DOE to rely on existing cybersecurity and related standards where possible.

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