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Foreign Entity of Concern Requirements in the One Big Beautiful Bill Act

The One Big Beautiful Bill Act (OBBB), enacted July 4, 2025, makes billions of dollars in federal energy tax credits conditional on supply chain independence from China and other foreign entities of concern. The OBBB simultaneously creates powerful economic incentives to reshore energy supply chains to the United States and allied nations. Through such incentives, the OBBB elevates digital assurance and supply chain verification from voluntary best practices into critical capabilities for demonstrating tax credit eligibility. The OBBB uses tax credit eligibility requirements to simultaneously address national security concerns regarding foreign supply chain dependencies and incentivize domestic energy manufacturing. This brief details how organizations should operationalize these requirements through baseline compliance audits, interim documentation systems, supply chain diversification strategies, and long-term institutional integration of digital assurance capabilities that turn compliance burdens into competitive advantages

29 - ENERGY PLANNING, POLICY AND ECONOMY

American Made Infrastructure: Evolution of Federal Incentives and Requirements

Foreign Entity of Concern (FEOC) restrictions in the One Big Beautiful Bill Act (OBBB) represent the latest evolution of a multi-year legislative trajectory responding to national security concerns about foreign control – and particularly FEOC control – of energy infrastructure. Beginning with Executive Order 14017 (February 2021), which initiated comprehensive federal review of critical supply chain vulnerabilities in semiconductors, battery energy storage systems, and critical minerals, policymakers have progressively expanded restrictions on foreign participation. The National Defense Authorization Act (NDAA) 2019 established precedent for component-level prohibitions on foreign information and communications technology procurement, while NDAA 2024 extended these restrictions to six major People’s Republic of China (PRC) battery manufacturers. Complementary measures such as the Build America, Buy America (BABA) Act and the Infrastructure Investment and Jobs Act (IIJA) introduced domestic content thresholds and FEOC eligibility criteria for federal funding programs. The Inflation Reduction Act (IRA) 2022 further operationalized FEOC restrictions through electric vehicle tax credit requirements, creating a scalable framework for excluding foreign-controlled components. Recent executive actions and state-level policies have reinforced this trajectory, reflecting sustained alignment across federal and state governments. Collectively, these developments demonstrate a bipartisan policy approach that pairs incentives for advanced energy deployment with safeguards designed to prevent subsidizing adversaries or entities that present foreign-sourcing risk.

99 - GENERAL AND MISCELLANEOUS

Organizational Influence on Supply Chain for Digital Energy Infrastructure: Business Models, and Policy Landscape

Significant investment is driving the essential modernization and digitization of U.S. energy infrastructure, but the United States faces a key challenge in this grid transformation: our renewable and clean energy supply chains have limited capacity to source necessary digital assets through U.S. or allied sources. Batteries and their associated power electronic interfaces are key components to delivering clean and more resilient energy delivery, providing much-needed fast ramping, emergency discharge, generation, and operations support to the electric grid. These services have grown to be invaluable over the past 10 years and will soon be an irreplaceable component of energy delivery. While there have been significant strides to move supply chains for raw and critical materials to U.S. and allied nations, the control and power electronic industry has lagged, in part because of lower cost margins. For example, the United States now has growing capacity to manufacture solar photovoltaic (PV) panels, but 90% of the inverters—which are essential to the conversion of DC to AC for grid connection and controls—are made in or source parts from the People’s Republic of China (PRC). While a global supply chain is beneficial for many economic and supply diversification reasons, presence of foreign entities of concern (FEOC) in a dominant role in this supply chain brings additional concerns for national security of infrastructure. The BESS relationship and new clean energy have features that warrant discussions and additional focus on impact for technology security, given their critical role. This review considers the impact and solutions for complex business and policy landscapes in clean energy supply chain, and the benefit trade-offs, focusing on the Battery Energy Storage System case study, and its complex organizational relationships across both the US, Allied countries and Foreign Entities of Concern. While many examples in this paper are presented on PRC focused manufacture, this could apply to any potentially adversarial relationship

25 - ENERGY STORAGE

American Made Energy Infrastructure - Evolution of Federal Incentives and Requirements

This presentation, "Evolution of Federal Incentives and Requirements," explores the development and impact of federal cybersecurity regulations, tax credits, and domestic content requirements on the energy sector. It covers key legislation such as the ARRA of 2009, IIJA, and IRA, and their implications for grid modernization, manufacturing, and deployment of energy technologies. The presentation also addresses definitions and restrictions related to Foreign Entities of Concern (FEOC) and their impact on federal procurement. Additionally, it introduces the DOE's cybersecurity framework for energy supply chains and practical actions for compliance planning.

25 - ENERGY STORAGE

IEEE PES GM Poster - Cyber-Informed Engineering Approach to Mitigating BESS Supply Chain Concerns

Battery energy storage systems (BESS) are increasingly important to meet the needs of grid resilience and reliability. BESS provide critical grid services, maintaining stability of the grid with increased variable conditions. However, there are significant geopolitical and security concerns regarding their operation in critical infrastructure, due to lack of a domestic supply chain and prevalence of foreign entity of concern (FEOC) components in BESS and associated inverter-based resources. The supply chain challenge is dually exacerbated by a lack of alternative suppliers who can meet the economic targets for energy delivery and a potentially adversarial supply chain. Solutions are needed to secure components, addressing mixed layers of risk and engineering controls. This paper presents a specific application of Cyber-Informed Engineering (CIE) principles for BESS and recommends an alternative strategy to blocking the supply chain, ensuring that grid modernization targets can be met despite lack of a validated or secure supply chain. This study focuses on the United State (U.S.) use case, but the process can be applied globally to address supply chain security challenges. CIE practices represent the next step in functional assurance and risk mitigation, ensuring optimal resource allocation and enhancing security measures to safeguard the future of energy in the U.S. and beyond.

25 - ENERGY STORAGE

Securing the Modern Grid: Federal Investments, Digitization, and Supply Chain Strategy

Across the United States (U.S.) grid expansion and modernization is underway, paving the way for accelerated load growth and intelligent resource management. Digitization of the grid is supported by several state and federal programs, providing support for utilities installing advanced metering infrastructure (AMI), AI-powered analytics systems, battery energy storage systems (BESS), and distributed energy resource management systems (DERMS) to transform the grid from a one-way power delivery system into an intelligent, responsive network that will enable faster load growth and power expansion of data centers for advanced artificial intelligence (AI) applications. The digital transformation of America's grid presents opportunity for increased efficiency and resiliency but also introduces new digital risks that require careful management. Digital equipment often contains several vulnerabilities such as unencrypted communication protocols, and persistent remote access capabilities that could be exploited to manipulate device settings, coordinate service disruptions, or inject false data into grid operations. These digital risks become particularly important as the grid must rapidly scale to support AI-driven data centers, which the administration has identified as essential for maintaining U.S. technological leadership and economic competitiveness. These vulnerabilities are compounded by supply chain realities: Chinese manufacturers currently produce 70-90% of essential grid components including inverters, batteries, and control systems, with the U.S. lacking domestic manufacturing capacity for critical assets like extra-high voltage transformers. Recent federal legislation has established Foreign Entity of Concern (FEOC) restrictions to address these risks, requiring projects to achieve escalating thresholds of non-FEOC content to receive tax credits while utilities work to expand sourcing channels for their supply chains and strengthen security measures. These restrictions arrive precisely when utilities face unprecedented electricity demand growth driven by the rapid growth in data centers, creating a considerable challenge: rapidly expanding infrastructure while navigating complex compliance requirements while lacking viable alternatives for many critical components. Idaho National Laboratory (INL) and its partners have developed practical approaches to help utilities navigate these intersecting challenges as they leverage federal investment to strengthen and grow the grid. These solutions include Cyber-Informed Engineering (CIE) principles that build resilience directly into systems, the Cirrus tool for secure cloud migration, and enhanced procurement guidance that embeds security requirements throughout equipment lifecycles. Federal initiatives, such as the Technical Assistance for Digital Assurance (TADA) project, provide direct support to utilities implementing these approaches while facilitating knowledge sharing across the industry. While these tools and frameworks cannot eliminate all risks inherent in foreign supply chain dependencies, they offer pragmatic pathways for strengthening security posture without sacrificing the deployment momentum essential to meeting surging electricity demand. Ultimately, securing America's digital energy infrastructure demands dedicated coordination across multiple fronts: building domestic supply chains, implementing robust digital assurance practices, and maintaining the aggressive modernization timeline necessary for reliability, resilience, and energy independence.

24 POWER TRANSMISSION AND DISTRIBUTION

Data Centers and Digital Assurance Workshop 2 – Prioritizing Digital Assurance Challenges, Session 2

The second session of the TADA (Technical Assistance for Digital Assurance) Data Centers Cohort, held on November 10, 2025, focused on prioritizing digital assurance challenges at the intersection of data centers and the electric grid. Building on the foundational concepts introduced in Workshop 1, this session deepened the application of the Threat–Vulnerability–Consequence (TVC) framework and emphasized the urgency of addressing cybersecurity, supply chain integrity, and operational reliability. Participants explored the growing convergence of digital and physical systems, the expanding attack surface due to global supply chain dependencies, and the implications of AI-driven load behavior. Real-world incidents—including the Volt Typhoon campaign and vulnerabilities in Solarman and Deye platforms—were analyzed to illustrate the risks of unpatched systems, insecure APIs, and inadequate vendor oversight. Key themes included architecture and interface weaknesses, governance gaps, and human and procedural shortcomings. The workshop also examined the evolving regulatory landscape, highlighting new federal mandates around Foreign Entity of Concern (FEOC) compliance and large-load reliability standards. Through interactive exercises, stakeholders ranked and mapped digital assurance risks from their respective perspectives—utilities, operators, and vendors—laying the groundwork for mitigation strategies and shared accountability models to be developed in Workshop 3. Session 2 of 3.

24 - POWER TRANSMISSION AND DISTRIBUTION