The Office of Manufacturing and Energy Supply Chains (MESC) and Grid Deployment Office (GDO) at U.S. Department of Energy (DOE) on May 15, 2025, issued a large data request to 179 projects, including some under conditional awards. Additional DOE offices will likely issue similar requests soon.
The data request follows the policy, "Ensuring Responsibility for Financial Assistance," issued by DOE Secretary Chris Wright on the same day, which indicates DOE's intent to conduct "focused reviews" of awards for "large-scale commercial projects" using already‑available information and information obtained through data requests. The policy aims to ensure that award recipients and projects are financially sound and economically viable, aligned with national and economic security interests, and consistent with federal law, the administration and the program's policies and priorities.
According to the policy, after the review, if DOE determines that a project meets those goals, then the project will proceed. If not, "DOE may modify the project or, DOE in its discretion, may terminate the project based on the outcome of DOE's evaluation, as allowed by law."
Of note, recipients that received the data request on May 15 must sign an award modification incorporating the new policy into their existing awards by May 25, 2025, and respond with all requested information by June 16, 2025. The new policy states that "if a recipient of financial assistance fails to respond to information requests within the provided timeframe, does not respond to follow-up questions in a timely manner, or offers incomplete responses that do not reasonably facilitate DOE's review, DOE may treat as the recipient's refusal to cooperate as grounds for termination of the award or the withholding of funding."
Because the data request is for a voluminous amount of information regarding projects, it is advisable to begin reviewing and completing the data request immediately.
Holland & Knight is available to assist with the data request process, including consulting on the scope of required information, writing/editing substantive narrative responses, coordinating with internal teams responsible for different portions of the request, reviewing documents and spreadsheets for completeness, providing strategic guidance and advising on how to mark the deliverables and data to protect your confidential and proprietary financial and commercial information.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
