Defense Federal Acquisition Regulation Supplement
Energy, power, and commodities companies holding or pursuing Department of Defense contracts operate under the Defense Federal Acquisition Regulation Supplement, a body of procurement rules that extends well beyond standard Federal Acquisition Regulation compliance and carries direct implications for supply chain security, cybersecurity certification, and domestic sourcing requirements. The U.S. Department of Defense and the Defense Contract Audit Agency enforce DFARS obligations with increasing scrutiny on energy sector contractors, particularly around DFARS 252.204-7012 cybersecurity safeguarding clauses and Cybersecurity Maturity Model Certification alignment. For in-house counsel and compliance teams in this sector, the gap between FAR familiarity and full DFARS readiness is where enforcement exposure sits.
Watch
- DFARS 252.204-7012 safeguarding requirements applying to energy sector subcontractors and vendors
- CMMC 2.0 final rule: phased contractor certification deadlines beginning in 2025
- Defense Contract Audit Agency scrutiny of cost accounting on energy-related defense supply contracts
- Domestic sourcing restrictions under DFARS 252.225 series for power generation components
- DoD proposed rules on operational technology security in critical infrastructure contractor systems
Recent material activity in Energy, Power & Commodities
A selection of recent published briefs; this is not a complete archive.
NRC and DOE issue joint environmental clearance for Three Mile Island Unit 1 restart under federal loan guarantee
The NRC, as lead agency, and the DOE Office of Energy Dominance Financing, as cooperating agency, issued a joint environmental assessment and finding of no significant impact on September 25, 2026 for proposed federal ac…
Read a full sample brief →NRC considers license amendment allowing Alternate Concentration Limits at Homestake uranium mill reclamation site in New Mexico
The NRC published notice on September 25, 2026 of an application by Homestake Mining Company of California to amend License No. SUA-1471 for the Grants Reclamation Project near Grants, New Mexico. The amendment would rep…
Read a full sample brief →EPA final rule redefines scope of applicable requirements under Clean Air Act title V operating permit program
EPA's final rule, published September 25, 2026, revises title V operating permit program regulations to codify the agency's existing interpretations of which Clean Air Act requirements qualify as applicable requirements.…
Read a full sample brief →FERC opens scoping period for Tres Palacios Smith Cavern natural gas storage expansion in Texas
FERC opened a scoping period on September 25, 2026 for the proposed Tres Palacios Smith Cavern Expansion Project, a natural gas storage facility in Texas. The notice solicits public and agency comments on environmental i…
Read a full sample brief →FERC opens scoping period for Natural Gas Pipeline of America and Horizon Pipeline North Extension Project
FERC opened a scoping period on September 25, 2026 for the proposed North Extension Project, involving Natural Gas Pipeline of America, LLC and Horizon Pipeline Company, LLC. The notice solicits public and agency comment…
Read a full sample brief →DOE / EIA Energy Policy & Data release pending Cresthaven Analytics full analysis: Energy Department Announces Speed to Power Investments Across 26 States to Lower Electricity Costs and Improve Grid Reliability
DOE / EIA Energy Policy & Data published a regulatory release titled 'Energy Department Announces Speed to Power Investments Across 26 States to Lower Electricity Costs and Improve Grid Reliability'. Cresthaven Analytics…
Read a full sample brief →NRC proposes wholesale revision of reactor licensing, decommissioning, and operational oversight regulations under Executive Order 14300
On September 24, 2026, the NRC published a proposed rule to revise its reactor licensing, decommissioning, and operational oversight regulations. The proposal implements Section 5 of Executive Order 14300, which directs …
Read a full sample brief →EPA reopens public comment on 2024 Texas SIP disapproval covering emissions during power plant maintenance activities
The EPA granted reconsideration on May 11, 2026 of its December 20, 2024 disapproval of a Texas state implementation plan governing visible emissions and particulate matter during planned maintenance, startup, and shutdo…
Read a full sample brief →EPA proposes consent decree setting deadlines for overdue California and Colorado ozone SIP final actions
The EPA published notice on September 24, 2026 of a proposed consent decree in Center for Biological Diversity and Center for Environmental Health v. Lee Zeldin, No. 4:25-cv-10007-JST. The decree would resolve citizen-su…
Read a full sample brief →FERC opens intervention window on Transcontinental Gas Pipe Line Company natural gas pipeline application
FERC published a notice on September 24, 2026 opening the intervention deadline period for a Transcontinental Gas Pipe Line Company, LLC certificate or abandonment application. The notice establishes the procedural windo…
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