On July 28, 2021, President Biden issued a “National Security Memorandum on Improving Cybersecurity for Critical Infrastructure Control Systems” (the “ICS Memo”). The ICS Memo—a product of the 100-day cybersecurity initiative we covered here—is a further step by the Biden-Harris administration to safeguard United States’ critical infrastructure, including that of the electric power sector, from “growing, persistent, and sophisticated cyber threats” that could have “cascading physical consequences [and] . . . a debilitating effect on national security, economic security, and the public health and safety of the American people.”¹