Ryan Last, an associate in Troutman Pepper Locke’s Tariff + Trade Task Force, was quoted in the August 27, 2026, Recharge News article, “Trump Grid Crackdown Raises ‘Rip and Replace’ Risk for US Wind, Solar and Storage.”

  • Its sweep and the possibility of it being retroactively applied make it potentially “the most consequential regulatory development for operating clean energy infrastructure since the investment tax credit, and the industry has not yet fully absorbed what it means,” said Ryan Last, attorney with law firm Troutman Pepper Locke with extensive experience in regulatory compliance.
  • “Developers must now price supply-chain uncertainty into procurement strategies, construction schedules, lender covenants, and tax-equity assumptions from the earliest stages of project development,” Last told Recharge.
  • Last notes however that the order identifies any grid-connected equipment operating at 69kV or above as “squarely within scope.” That encompasses “utility-scale solar farms, wind projects, standalone battery storage facilities, and conventional generation,” he said.
  • “Developers and lenders should treat any equipment manufactured by a Chinese-linked company, or any company with Chinese state ownership even at a minority level, as presumptively within scope until implementing rules provide clearer guidance,” Last said.
  • Last however is less sanguine, noting this latest executive action “layers a new and open-ended screening regime on top of a stack of existing legal obligations that already make importing clean energy components among the most legally complex procurement exercises in American industry.”
Insight Industries + Practices