DOE Has Until Dec. 24 to Rewrite What Can Go Inside a U.S. Substation

President Trump signed Executive Order 14420 on August 26, declaring a national emergency over foreign-made equipment in the U.S. bulk-power system and giving the Department of Energy 120 days, until December 24, to publish the rules that will decide what can be bought and installed inside American substations.

The order reaches the transmission grid, not the local distribution system. It applies to facilities rated at 69,000 volts and above and to the equipment that fills substations, control rooms and generating stations: substation transformers, reactors, capacitors, high-voltage circuit breakers, protective relaying, metering, utility-scale and other grid-connected inverters, battery energy storage systems, uninterruptible power supply systems, and the industrial control systems that run them, including remote terminal units, programmable logic controllers and intelligent electronic devices. Software, firmware, maintenance service and remote-access capability tied to that equipment are covered as well. Facilities used in the local distribution of electric energy are explicitly excluded.

Nothing is banned yet. The prohibitions are not self-executing. They apply only after the Energy Secretary designates a covered foreign entity or determines that a particular transaction qualifies. A covered foreign entity is one owned by, controlled by or subject to the jurisdiction of a government designated under U.S. arms embargo and export control rules, or one the Secretary finds is engaged in conduct detrimental to national security or foreign policy. The order builds on and expands Executive Order 13920 from 2020. It reaches transactions initiated after August 26, and it authorizes DOE to impose conditions on equipment installed before that date, including identifying, isolating, monitoring, securing or replacing it. A second deadline, February 22, 2027, covers recommended changes to federal acquisition regulations.

The order landed on a market that was already short. Wood Mackenzie survey data from the second quarter of 2025, cited by POWER, put lead times at 128 weeks for power transformers and 144 weeks for generator step-up units. Switchgear ran 44 weeks. Prices moved with the queue: power transformers up 77 percent since 2019, certain distribution transformer classes up as much as 95 percent, medium-voltage switchgear up 50 percent and circuit breakers up 47 percent since 2021. Wood Mackenzie counted a 30 percent supply shortfall in power transformers in 2025 and a 10 percent shortfall in distribution transformers.

The immediate consequence is procurement uncertainty rather than a wave of federal removals, according to a client analysis published August 31 by Davis Wright Tremaine. Owners, developers and contractors now have to trace manufacturers, ownership, country of manufacture, critical components, firmware, maintenance providers and remote-access rights for equipment already on order, and rewrite supply agreements around change-in-law clauses, substitution rights, schedule relief and who absorbs replacement and delay costs.

Substitutions at the equipment level rarely stay at the equipment level. A switchgear lineup from a different manufacturer changes bus arrangement, dimensions, conduit stub-up locations, control wiring and relay panel layout. A different inverter or battery enclosure changes pad design, conductor sizing and grounding details. Every one of those changes moves through submittals, coordination studies and as-built drawings before it reaches the field, and it moves through crews who then re-terminate and retest to a new set of prints.

The retrofit exposure is the second half. DOE's authority over equipment already in service means that isolating, monitoring, replacing or removing installed gear is now on the table for substations that are energized and load-bearing. That is outage-window work, which is night and weekend work, and it is testing-heavy, which favors electricians with relay, controls and acceptance-testing experience.

Domestic capacity has been building toward this for three years. Roughly $1.8 billion in North American manufacturing expansions has been announced since 2023, including more than $1 billion from Hitachi Energy, $340 million from Eaton in South Carolina, more than $300 million from Prolec GE across multiple sites and $150 million from Siemens Energy in Charlotte. Hitachi Energy broke ground June 29 in South Boston, Virginia, on what the company calls the nation's largest facility for producing large power transformers, a $457 million project expected to add about 825 long-term jobs on a campus that has operated since 1968 with roughly 850 employees.

For commercial and industrial electricians, factory expansions of that size are electrical construction jobs before they are manufacturing jobs. A transformer plant needs service entrance and medium-voltage distribution, motor control centers, crane and furnace power, test bay feeders, instrumentation and controls, and a commissioning phase. That work sits in the same skill set as substation and data center electrical scope, and it is located in states where the plants are going, not where the design offices are.

Trade groups want the details. The Edison Electric Institute said utilities are committed to working with DOE on reliability and affordability. The National Electrical Manufacturers Association said the industry needs considerably more clarity, particularly on how the origin of software will be determined and which suppliers will count as covered.

The rules arrive December 24. The purchase orders are being written now.