On March 13, 2026, President Trump issued an Executive Order (EO) titled “Adjusting Certain Delegations Under the Defense Production Act.”  As we have covered in prior blog posts, the Defense Production Act (DPA) has traditionally been considered the primary federal means to manage and support defense production. 

The March 13th EO seeks to clarify and define certain aspects of two prior DPA-related EOs—EO 13603, “National Defense Resources Preparedness,” dated March 16, 2012, and EO 14156, “Declaring a National Energy Emergency,” dated January 20, 2025.  As such, the new EO is best understood in light of these two prior, related EOs.


EO 13603:  The Government’s DPA Operating Manual

EO 13603 is essentially the Government’s longstanding operating manual for using the DPA.

The DPA gives the President a number of powerful authorities to ensure that the United States maintains an industrial and technological base capable of meeting national defense requirements in both peacetime and national emergencies.  These authorities include the ability to prioritize contracts, allocate materials, and support expansion of industrial capacity.  But those authorities would be impractical if the President had to exercise them personally.  EO 13603 solves that problem by delegating those authorities across the executive branch.

In practical terms, EO 13603 authorizes officials to use the DPA’s “priorities and allocations” authorities to require companies to prioritize government contracts or allocate scarce resources in support of national defense programs. 

For purposes of exercising those authorities, the EO assigns responsibility for different sectors of the economy to designated executive branch departments:

  • The Secretary of Agriculture receives authority over food resources.
  • The Secretary of Energy receives authority over energy resources.
  • The Secretary of Transportation receives authority over civil transportation.
  • The Secretary of Health and Human Services receives authority over health resources.
  • The Secretary of Defense receives authority over water resources.
  • The Secretary of Commerce receives authority over most other industrial materials and services.

EO 13603 also delegates the President’s authorities under Title III of the DPA, which allows agencies to strengthen industrial capacity.  Agencies can use those authorities to make and guarantee loans, provide purchase commitments, and fund expansion of production capabilities when necessary to address national defense-related supply chain shortfalls.

In addition to delegating operational authorities, EO 13603 establishes a broader coordination framework for industrial mobilization.  Among other things, it creates the Defense Production Act Committee, assigns analytical responsibilities across agencies for assessing industrial capacity, and establishes mechanisms such as the National Defense Executive Reserve for mobilizing private sector expertise during national defense emergencies.

The key point is that EO 13603 is not itself an emergency measure.  Instead, it is a standing delegation framework.  It determines who within the federal government can exercise DPA authorities when they are needed.

EO 14156:  Accelerating Domestic Energy Production

EO 14156, issued in 2025, operates at a different level.  It declares that weaknesses in U.S. energy production and infrastructure (defined as including critical minerals production and refining) constitute a national emergency.  Accordingly, the EO directs agencies to take steps to accelerate domestic energy development and infrastructure.

Importantly, EO 14156 encourages agencies to consider using emergency authorities—including those under the DPA—to address energy supply constraints.  However, the EO also suggests that agencies should recommend certain actions to the President before exercising those authorities.

This suggestion created some ambiguity, because EO 13603 had already delegated many DPA authorities to agency heads.

What the March 13, 2026, EO—“Adjusting Certain Delegations”—Does   

Against this backdrop, the March 13th EO addresses two primary issues.  First, it modifies the delegation structure established by EO 13603, particularly with respect to energy-related authorities.  EO 13603 concentrated certain authorities related to maximizing domestic energy supply at the Department of Commerce.  The new order adjusts those delegations so that the Secretary of Energy may exercise those authorities directly as well.  See EO Sec. 2.

Legally, this means that the Department of Energy now has clearer and more direct authority to invoke relevant DPA tools to address energy-related supply chain issues, such as those involving energy infrastructure, grid equipment, or energy-related industrial capacity.  Over time, this could contribute to a gradual reorientation of energy‑focused DPA industrial policy from the Department of Commerce toward the Department of Energy, a shift that—if it materializes—would carry important consequences for critical minerals, grid infrastructure, and AI/data‑center energy supply chains.

Second, the new EO clarifies how EO 14156 should be interpreted, presumably in an effort to remove potential procedural uncertainty.  Specifically, it explains that when an agency already has delegated authority under EO 13603, the agency head may exercise that authority directly, as appropriate.  A recommendation to the President is required only where the relevant authority remains reserved to the President by statute or has not been delegated.

While it remains to be seen whether the new EO will meaningfully streamline the national defense resource preparedness framework, its issuance reflects the administration’s broader and recurring emphasis on effective, decisive, and timely execution. 

The President appears intent on signaling that the authorities delegated under the DPA are not merely available in principle, but are expected to be affirmatively exercised by agency heads where appropriate.  Against this backdrop, federal contractors and grant recipients should closely monitor how and by whom these authorities are operationalized in practice, particularly as agencies clarify sector-specific roles and priorities. 

Photo of Stephanie Barna Stephanie Barna

Stephanie Barna draws on over three decades of U.S. military and government service to provide advisory and advocacy support and counseling to clients facing policy and political challenges in the aerospace and defense sectors.

Prior to joining the firm, Stephanie was a senior…

Stephanie Barna draws on over three decades of U.S. military and government service to provide advisory and advocacy support and counseling to clients facing policy and political challenges in the aerospace and defense sectors.

Prior to joining the firm, Stephanie was a senior leader on Capitol Hill and in the U.S. Department of Defense (DoD). Most recently, she was General Counsel of the Senate Armed Services Committee, where she was responsible for the annual $740 billion National Defense Authorization Act (NDAA). Additionally, she managed the Senate confirmation of three- and four-star military officers and civilians nominated by the President for appointment to senior political positions in DoD and the Department of Energy’s national security nuclear enterprise, and was the Committee’s lead for investigations.

Previously, as a senior executive in the Office of the Army General Counsel, Stephanie served as a legal advisor to three Army Secretaries. In 2014, Secretary of Defense Chuck Hagel appointed her to be the Principal Deputy Assistant Secretary of Defense for Manpower and Reserve Affairs. In that role, she was a principal advisor to the Secretary of Defense on all matters relating to civilian and military personnel, reserve integration, military community and family policy, and Total Force manpower and resources. Stephanie was later appointed by Secretary of Defense Jim Mattis to perform the duties of the Under Secretary of Defense for Personnel and Readiness, responsible for programs and funding of more than $35 billion.

Stephanie was also previously the Deputy General Counsel for Operations and Personnel in the Office of the Army General Counsel. She led a team of senior lawyers in resolving the full spectrum of issues arising from Army wartime operations and the life cycle of Army military and civilian personnel. Stephanie was also a personal advisor to the Army Secretary on his institutional reorganization and business transformation initiatives and acted for the Secretary in investigating irregularities in fielding of the Multiple Launch Rocket System and classified contracts. She also played a key role in a number of high-profile personnel investigations, including the WikiLeaks breach. Prior to her appointment as Deputy, she was Associate Deputy General Counsel (Operations and Personnel) and Acting Deputy General Counsel.

Stephanie is a retired Colonel in the U.S. Army and served in the U.S. Army Judge Advocate General’s Corps as an Assistant to the General Counsel, Office of the Army General Counsel; Deputy Staff Judge Advocate, U.S. Army Special Forces Command (Airborne); Special Assistant to the Assistant Secretary of the Army (Manpower & Reserve Affairs); and General Law Attorney, Administrative Law Division.

Stephanie was selected by the National Academy of Public Administration for inclusion in its 2022 Class of Academy Fellows, in recognition of her years of public administration service and expertise.

Photo of Victoria Skiera Victoria Skiera

Victoria Skiera is an associate in the firm’s Government Contracts Practice Group, advising contractors on a range of regulatory and compliance issues. She has experience assisting clients with unique issues arising in government contracts transactions and related due diligence processes, as well as…

Victoria Skiera is an associate in the firm’s Government Contracts Practice Group, advising contractors on a range of regulatory and compliance issues. She has experience assisting clients with unique issues arising in government contracts transactions and related due diligence processes, as well as in compliance counseling, investigations, and disputes. Victoria also has experience assessing the impact of executive order and litigation activity in the context of federal procurement and financial assistance. Victoria maintains an active pro bono practice.