The U.S. bulk-power system faces an “unusual and extraordinary threat” from foreign supply of electric equipment, according to an emergency Executive Order issued by President Donald Trump last week. Certain bad actors are “increasingly creating and exploiting vulnerabilities,” prompting the White House to prohibit the acquisition, importation, transfer, or installation of stuff that could be subverted for grid sabotage. The order does not apply to distributed energy facilities and equipment that come into contact solely with local power lines, but anything that interacts with transmission at 69 kV or higher is fair game.

The affected equipment is broadly defined to include transformers, inverters, battery energy storage systems (BESS), backup generators, turbines, circuit breakers, measurement tools, and much more. Basically, if you were planning to order anything that connects to the grid from a company with ties to one of the 24 countries designated as Covered Foreign Entities (CFEs), you should consider other options. Scanning the CFE list, that shouldn’t be a problem (you see, there aren’t many developers clamoring for exported electric equipment from Iran and North Korea these days), outside of the elephant in the room: China.

China has a thumb on myriad global supply chains relevant to the energy industry, and is only increasing its market share. China exported $37.4 billion worth of power equipment in 2025, including $9.3B in transformers alone, extending a three-year growth streak spurred by emerging economies in Africa and Asia. A previously issued-but-never-implemented order to address security concerns in the U.S. bulk-power system triggered a “modest pullback” in short-term purchases of Chinese offerings in 2020, but the U.S. still imported at least $3.5B in grid equipment from China last year, and closer to $10B if you include all of Southeast Asia.

So what happens now? Well, nothing yet, officially. While the order applies to transactions initiated after August 26, 2026, no equipment is specifically prohibited until the Department of Energy (DOE) determines that it poses a risk to the U.S. electricity grid or broader national security.

The agency has until Christmas Eve to figure out which ghosts are worth chasing and the rules for busting them. According to Keith Martin at law firm Norton Rose Fulbright, the DOE is also tasked with making recommendations on how to isolate, monitor, or replace affected equipment “as soon as practicable.” That may entail an index of pre-approved grid gear and/or a licensing process for the use of otherwise blackballed equipment, as well as what we should do about potentially malicious items already online.

While it’s unlikely anyone will start ripping stuff out of the walls just yet, some lenders and tax equity investors have previously drafted clauses requiring project developers to cover the cost of replacing any equipment the government later deems a threat to the grid, and many such provisions remain, per Martin. If this executive order has more teeth than Trump’s previous try in 2020, it might be another bag to hold for the same group of stakeholders currently beleaguered by disappearing tax credits, back-and-forth tariffs, murky foreign entity of concern (FEOC) guidance, stalled federal permitting, and much more.

They’re making a list, and I hope they check it twice.

Welcome to the Factor This Brief, a weekly collection of energy industry finance and development updates, delivered straight to your inbox on Monday mornings and hosted in a not-so-brief fashion here on Factor This, featuring the people, projects, and technology driving our electric future. Thanks for checking it out, and props to Sean Wolfe for holding down the fort last week while I soaked in some Michigan sunshine. Pro tip: If any of you are considering taking your 10-month-old to a baseball game, don’t.

If you like what you see or want to recommend a story for next week, drop me a line. Here’s one for the road- when quittin’ time comes around, crank that recliner back all the way for me.

Thanks for your Flexibility

NVIDIA-backed technology company Emerald AI has raised $150 million in an oversubscribed Series A financing round at a $1.05 billion valuation to scale worldwide commercial deployment with customers including AI companies, data center operators, and electric utilities. The round was co-led by Energize Capital and DCVC.

Rather than treating data centers as inflexible consumers of electricity, Emerald AI envisions them as flexible assets for the power grid, using software to transform them into intelligent, responsive tools that are good “grid citizens” and protect energy affordability and reliability for local communities. The Emerald Conductor platform, now deployed commercially at a multi-megawatt scale, dynamically orchestrates AI computational workloads and on-site energy resources to control a facility’s power draw when the grid is stressed while protecting the performance of critical AI workloads, resulting in AI infrastructure that strengthens the electric grid rather than straining it.

According to Emerald AI, data centers running its software can connect to the grid faster and at larger scale, support grid reliability during periods of stress, and help hold down energy costs for the communities around them. Applied across the AI build-out, the company figures such an approach can unlock more than 100 gigawatts (GW) of untapped capacity in the U.S. alone.

“We founded Emerald AI on the conviction that the intelligence driving the AI revolution could solve its own greatest bottleneck: power,” asserted Emerald AI Founder and CEO Dr. Varun Sivaram. “Our demonstrations around the world proved that data centers can adjust their power use precisely when the grid needs relief, without compromising critical computing workloads. Today that technology runs commercially at full data center scale, and this financing lets us take it everywhere AI is built, so the AI era can accelerate while the grid becomes more reliable and more affordable for the communities it serves.”

“The binding constraint on AI is no longer chips or capital; it is power, and software is the fastest way through it. Emerald AI has converted world-class research into commercial deployments faster than any company we have seen in this category,” added John Tough, managing partner at Energize Capital.

Over the past year, Emerald AI has completed five successful demonstrations at commercial data centers in Arizona, Illinois, Virginia, Oregon, and London, working alongside partners including NVIDIA, EPRI, Oracle, Nebius, and National Grid as well as regional utilities and grid operators, proving at live commercial sites that AI data centers can flex their power use on the grid’s schedule. Emerald AI has also partnered with Silicon Valley Power to launch its first-in-the-nation Flexible Load Interconnection Program, which grants data centers expanded grid access in exchange for verified, dispatchable flexibility. And in Manassas, Virginia, Emerald AI is working with Digital Realty and NVIDIA to bring online the world’s first power-flexible AI factory, the nearly 100-megawatt (MW) Vera Rubin AI Research Factory, which is slated to come online later this year.

A 30-Rack of Community Solar

Aspen Power, Basis Climate, and Excelsior Energy Capital have announced a tax capital commitment covering the Investment Tax Credits (ITCs) generated by Aspen’s 2026-2027 community solar portfolio, consisting of up to 30 projects across multiple states.

The transaction is the first to be originated and structured through the Basis Climate–Excelsior partnership, which was formed to deploy up to $150 million of minority equity in distributed-generation solar and battery storage projects. Basis Climate’s diligence platform will underwrite the portfolio on an accelerated timeline, enabling a streamlined investment diligence and closing process.

Aspen Power’s 2026-2027 community solar portfolio delivers affordable, reliable power to residential and commercial subscribers. Aspen Power owns and operates the projects and will hold the assets long term, making predictable tax credit monetization central to how the company funds construction and keeps capital moving.

“Tax credit monetization timing and certainty are important components of Aspen’s financial planning. Just as speed to power is important, so is the ability to convert tax credits to cash in an efficient manner,” said Michael Sheehan, CEO of Aspen Power. “Basis and Excelsior underwrote 30 projects on one timeline through a single process, which is the commercial discipline we look for in a capital partner.”

“Aspen brought a 30-project portfolio to our platform, and we were able to underwrite it quickly, match it with a qualified buyer, and close with integrated insurance—all through a single process. That’s exactly the kind of frictionless execution that leading distributed generation platforms like Aspen need to finance their businesses at scale,” added Erik Underwood, co-founder of Basis Climate.

Learn more: Aspen Power co-founder and CEO Jorge Vargas joins the Factor This podcast to discuss how community solar is ‘powering on’ in a challenging environment.

Snow No Match for EPC

Solar and storage engineering, procurement, and construction (EPC) firm Northern Sun Energy recently started construction on two solar projects for developer Seaboard Solar in Waterford and Boonville, New York. Totaling 23 MWdc, both are supported by NYSERDA grants and are employing local labor throughout.

Northern Sun and Seaboard Solar, a small, family-owned community solar farm development and farmland conservation firm based in rural western Connecticut, have worked together for nearly a decade. The tandem has already overcome substantial logistical challenges working on the two Upstate New York projects. For example, the two-parcel Waterford site is only accessible via a bridge with a 20-ton weight restriction. The Boonville site’s updated snow load requirements, which rank among the highest in the nation, posed another challenge.

Northern Sun says it worked closely with racking partner GameChange Energy to engineer a resilient system that met the updated code while keeping construction on track.

“These two sites tested us in different ways,” reported Chris Balogh, VP and co-founder of Northern Sun Energy. “Waterford’s bridge restrictions meant rethinking how we would get equipment onsite, and Boonville’s heavy snow load pushed our structural engineers to ensure that the system would remain productive and reliable throughout severe upstate New York winters.”

“Neither site was straightforward, and the Northern Sun team brings deep experience and creative problem-solving to difficult terrains and extreme climates,” chimed Shawn Brazo, president of Seaboard Solar.

Run it Back

Clean energy owner and operator Avantus has secured a $300 million tax equity commitment from Truist Bank to bolster the development of the Aratina 2 solar and battery energy storage project in Kern County, California. The influx of fresh cash follows more than $525M in construction financing secured for the endeavor from CIBC, BBVA, and Santander, which we wrote about in a previous edition of the Factor This Brief.

Consisting of 150 MW of solar generation paired with 452 megawatt-hours (MWh) of battery storage, Aratina 2 is under construction and is expected to begin operations by the end of the year. It has 15-year power purchase agreements (PPAs) with California utility Southern California Edison.

Last month, Avantus marked its transition to an independent power producer (IPP) with the commercial operation of sister site Aratina 1, which is now delivering 200 MW of solar and 500 MWh of energy storage to the grid.

Avantus celebrated the start of commercial operations at Aratina 1 in Kern County, CA, in July 2026. Courtesy: Avantus

Combined, the Aratina Solar Center phases will account for 350 MW of solar power and 952 MWh of storage capacity.

Avantus recently announced the closing of an upsized $1.05 billion corporate credit facility, a massive upgrade from the $522 million facility previously put in place in July 2024. The expanded facility will advance Avantus’ independent power producer (IPP) strategy and accelerate the execution of its portfolio across core markets in California and the Desert Southwest, according to the company. Avantus boasts a development pipeline totaling at least 24 GW of capacity, including 13 GW of solar integrated with 44 gigawatt-hours (GWh) of storage.