Procurement & Compliance

Compliance is a procurement & engineering discipline — not a clearance step.

For federal-adjacent work, IRA bonus credit qualification, and bankability, documentation discipline applied at project initiation determines whether the project qualifies, performs, and closes. Aurevia treats it that way.

01 / FEOC & NDAA Section 841

Foreign Entity of Concern exclusion.

Reference Framework
  • NDAA Section 841FY2024 National Defense Authorization Act — FEOC battery procurement restrictions for DoD applications
  • 26 U.S.C. § 30D(d)(7)FEOC definitions adopted into IRA tax credit framework
  • 10 U.S.C. § 4872Restrictions on the acquisition of certain items from prohibited sources

Aurevia's BESS, PCS, and inverter procurement is screened against NDAA Section 841 and the broader FEOC framework. Suppliers identified as Foreign Entities of Concern under the statutory framework are excluded by Aurevia procurement policy — not as a project-by-project decision, but as a standing supplier qualification rule.

FEOC analysis runs at the cell, module, and rack level. Country-of-origin documentation is captured at the bill-of-materials level and maintained as part of the project record. Where the customer is DoD or DoD-adjacent, the FEOC documentation package is structured to support government acceptance review.

What's in the FEOC documentation package
  • Approved supplier list with FEOC qualification status
  • Country-of-origin certificates at cell, module, and rack level
  • Beneficial ownership disclosures from suppliers
  • Subcontract flowdown of FEOC compliance obligations
  • Disqualified-supplier registry maintained as a standing procurement document
02 / IRA Domestic Content

Bonus credit qualification at the BOM level.

Reference Framework
  • 26 U.S.C. § 45 / § 48Renewable energy production and investment tax credits
  • IRS Notice 2024-41Domestic content bonus credit safe harbor
  • IRS Notice 2023-29Energy community bonus credit definitions
  • 26 U.S.C. § 45(b)(7)-(8)Prevailing wage & apprenticeship requirements

Domestic content qualification is calculated and documented at the BOM level for solar modules, inverters, racking, BESS containers and components, and balance-of-system equipment. The qualification path — adjusted percentage method or elective safe harbor — is selected per project based on equipment availability and timing.

Energy community and prevailing-wage / apprenticeship bonus credit pathways are evaluated at the same time, so the procurement strategy is aligned to the full credit stack the project can capture — not engineered around a single bonus.

What we track per project
  • BOM-level cost basis for adjusted percentage calculation
  • Manufacturer attestations and supporting documentation
  • Energy community eligibility analysis at COD
  • Prevailing wage and apprenticeship recordkeeping
  • Safe harbor election documentation, where used
03 / Buy American & FAR/DFARS

Federal procurement flowdowns.

Reference Framework
  • 41 U.S.C. § 8301-8305Buy American Act
  • FAR Part 25Foreign Acquisition
  • DFARS Subpart 225DoD Buy American implementation
  • BABA / IIJABuild America, Buy America for federally-funded infrastructure

Where federal funding or federal customers apply, Buy American Act and Build America, Buy America (BABA) flowdowns are tracked through procurement and embedded in subcontract agreements. Waiver pathways are pursued only where compliant supply does not exist at the required cost or schedule.

FAR and DFARS clauses applicable to the prime contract are flowed down to subcontractors through Aurevia's standard subcontract template, which is maintained with outside counsel and updated as regulatory guidance evolves.

Compliance posture
  • FAR / DFARS clauses flowed through Aurevia-issued subcontracts
  • Country-of-manufacture documentation for every BAA-covered item
  • Waiver tracking for components without compliant U.S. supply
  • Subcontract template reviewed and updated with counsel
04 / Engineering Standards

UL, IEEE, and NFPA standards verified at commissioning.

Standards Set
  • UL 1741 / 1741 SAInverter and grid support utility-interactive equipment
  • UL 9540 / 9540AEnergy storage system listing & thermal runaway test
  • IEEE 1547Distributed resource interconnection
  • IEEE 519Harmonic distortion limits
  • NFPA 855Stationary energy storage system safety
  • NEC Article 690 / 706PV and energy storage installation

UL, IEEE, and NFPA standards applicable to solar, BESS, and microgrid systems are referenced in equipment specifications and verified through commissioning. Documentation is produced at the level federal acceptance testing requires — not the level commercial work tolerates.

Where state or local AHJs have adopted modified versions of these standards, the project-specific standards set is documented at engineering kickoff and tracked through commissioning. Listed equipment is required for all critical components; field-modified equipment is the exception, not the default.

Acceptance package contents
  • UL listing documentation for inverters, BESS, and PCS
  • IEEE 1547 conformance test records
  • Harmonic distortion measurement reports per IEEE 519
  • NFPA 855 spacing, ventilation, and life-safety documentation
  • Commissioning test protocols mapped to applicable standards
05 / Cybersecurity

Operational cybersecurity as an engineered requirement.

Reference Framework
  • NIST SP 800-82Industrial control systems security guidance
  • NIST SP 800-171Controlled unclassified information protection
  • IEC 62443Industrial automation and control systems security
  • NERC CIP (where applicable)Critical infrastructure protection for bulk electric system facilities

SCADA, plant controllers, and microgrid controller architectures are designed with cybersecurity as an engineered requirement — network segmentation, access control, patch management, and audit logging are part of the controls scope, not added during commissioning.

Project data handling — drawings, specifications, controls configurations, and operational data — is governed by access control and information handling practices appropriate to the customer environment. For federal-adjacent work, controls and project data handling are aligned to applicable NIST 800-series guidance.

Cybersecurity scope
  • Network segmentation between OT and facility IT
  • Role-based access control on controls platform
  • Patch management plan for SCADA and microgrid controller
  • Audit logging on controls system access events
  • Information handling procedures for project data

A compliance posture built for institutional review.

If you'd like to walk through how Aurevia's procurement and compliance posture applies to a specific project, we'll respond directly.

Discuss Your Project