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Data Centers and Digital Assurance Workshop 3 – Mitigations for Digital Assurance Risks

The third session of the TADA (Technical Assistance for Digital Assurance) Data Centers Cohort, held on November 18, 2025, focused on developing mitigation strategies for digital assurance risks identified in previous workshops. Hosted by Idaho National Laboratory (INL) and ScottMadden, the session emphasized the application of Cyber-Informed Engineering (CIE) to data center infrastructure, particularly at the utility–data center interface. Participants revisited and ranked key digital assurance risks, including architecture and interface weaknesses, governance gaps, and AI-enabled threats. The workshop introduced the 12 principles of CIE, advocating for consequence-focused design, engineered controls, and secure information architecture to proactively reduce cyber-physical vulnerabilities. These principles were applied to critical data center systems such as power distribution, UPS, cooling, SCADA/BMS, and grid-forming batteries. The session also addressed governance challenges at the interconnection boundary, highlighting the need for clear roles in telemetry sharing, firmware management, and trip settings. Special attention was given to emerging risks from behind-the-meter (BTM) generation, including reverse-power flow and the integration of small modular reactors (SMRs), which shift data centers from large loads to complex generation nodes. Participants explored how interconnection agreements can serve as enforceable instruments for digital assurance, and reviewed gaps in current standards such as NERC CIP, IEC 62443, and IEEE 1547. The workshop concluded with pathways to standardization, including model agreement language, state-level programs, and expanded NERC guidance. INL also presented tools and frameworks for secure procurement and supplier risk management, reinforcing the need for integrated engineering and policy solutions to secure the evolving data center–grid ecosystem. Session 3 of 3.

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Safety-Related Instrumentation and Control Pilot Upgrade: Initial Scoping Phase Implementation and Lessons Learned

In May 2016, the U.S. Nuclear Regulatory Commission (NRC) staff provided a digital instrumentation and control (I&C) regulatory infrastructure integrated action plan to the NRC for approval. One of the objectives of that plan was to establish a clear regulatory structure with reduced regulatory uncertainty to enable the expanded safe use of digital I&C in commercial nuclear reactors while continuing to ensure safety and security. To achieve this end, the NRC, with collaboration from industry, developed a streamlined License Amendment Request Alternate Review (AR) process for safety-related (SR) digital I&C upgrades. In spite of this effort, the industry has remained reluctant to perform such I&C upgrades because of perceived regulatory and financial risks associated with being the first or an early adopter of the AR process for SR I&C upgrades. The U.S. Department of Energy Light Water Reactor Sustainability Program at the Idaho National Laboratory performed Initial Scoping Phase research to help break this impasse by supporting a SR I&C Pilot Upgrade, working with MPR Associates, ScottMadden Inc., and Exelon Generation. Exelon’s Limerick Generating Station (LGS) was selected as the target for this research. This paper summarizes the Initial Scoping Phase engineering and operations, licensing, and project management activities necessary to bound the scope, schedule, and estimated cost of the project sufficiently to enable utility management authorization of Conceptual Design Phase activities. These efforts and associated products are intended to provide a template to support larger industry efforts to perform similar upgrades as a foundation stone for a digital transformation that will improve plant safety, reliability, and operational performance while lowering plant total cost of ownership. As a result of the combined effort of Exelon Generation and research participants, Conceptual Design Phase activities for the subject upgrade at LGS were approved by Exelon. Further, the U.S. Department of Energy also awarded a $50 million cost share award to Exelon in order to pave the way for SR I&C modernization and associated control room upgrades across the U.S. nuclear fleet. Additional research reports are planned for the Conceptual Design Phase, Detailed Design Phase, and the Implementation Phase of the LGS project to document the process followed and promulgate lessons learned to industry.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Advanced Transmission Technologies – GETs and HPCs Session 2: Advanced Power Flow Control and Transmission Topology Optimization

The INL TADA GETs Cohort Session 2, held on November 7, 2025, conducted in collaboration with ScottMadden, focused on two core Advanced Transmission Technologies (ATTs): Advanced Power Flow Control (APFC) and Transmission Topology Optimization (TTO). These technologies are pivotal in enhancing grid flexibility, reliability, and cybersecurity resilience. APFC, particularly through modular FACTS devices like Modular Static Synchronous Series Compensators (M-SSSCs), enables dynamic voltage injection to reroute power flows. The session highlighted the deployment benefits of APFC, such as rapid installation, minimal civil works, and re-deployability. Regulatory drivers like FERC Order 2023 mandate the inclusion of Grid-Enhancing Technologies (GETs) in interconnection studies. Case studies from Central Hudson, CAISO, and National Grid (UK) demonstrated APFC’s effectiveness in congestion relief and cost savings. The session also addressed cybersecurity concerns, including firmware vulnerabilities, SCADA integration risks, and supply chain dependencies. Participants engaged in interactive exercises to rank cybersecurity and supply chain risks, emphasizing the need for robust digital assurance strategies. TTO involves software-based reconfiguration of transmission networks to optimize power flow without new infrastructure. The session showcased its operational value, with examples from SPP, PJM, and MISO showing significant congestion cost reductions. Cybersecurity vulnerabilities were discussed, particularly in API security and software supply chains, referencing incidents like SolarWinds and attacks on Danish utilities. Digital assurance exercises explored worst-case scenarios, attack paths, and mitigation responsibilities between vendors and utilities. Reliability challenges such as algorithm stability, vendor dependency, and operator trust were also examined. Cross-cutting themes emphasized the importance of digital assurance tools, including Software Bills of Materials (SBOMs) and hardware-in-loop testing. Human performance, training, and operational confidence were identified as critical enablers of technology adoption. The session concluded with a preview of Session 3, which will focus on High Performance Conductors (HPCs) and risk-based cybersecurity tools. Session 2 of 3.

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Securing the Modern Grid: Federal Investments, Digitization, and Supply Chain Strategy

Across the United States (U.S.) grid expansion and modernization is underway, paving the way for accelerated load growth and intelligent resource management. Digitization of the grid is supported by several state and federal programs, providing support for utilities installing advanced metering infrastructure (AMI), AI-powered analytics systems, battery energy storage systems (BESS), and distributed energy resource management systems (DERMS) to transform the grid from a one-way power delivery system into an intelligent, responsive network that will enable faster load growth and power expansion of data centers for advanced artificial intelligence (AI) applications. The digital transformation of America's grid presents opportunity for increased efficiency and resiliency but also introduces new digital risks that require careful management. Digital equipment often contains several vulnerabilities such as unencrypted communication protocols, and persistent remote access capabilities that could be exploited to manipulate device settings, coordinate service disruptions, or inject false data into grid operations. These digital risks become particularly important as the grid must rapidly scale to support AI-driven data centers, which the administration has identified as essential for maintaining U.S. technological leadership and economic competitiveness. These vulnerabilities are compounded by supply chain realities: Chinese manufacturers currently produce 70-90% of essential grid components including inverters, batteries, and control systems, with the U.S. lacking domestic manufacturing capacity for critical assets like extra-high voltage transformers. Recent federal legislation has established Foreign Entity of Concern (FEOC) restrictions to address these risks, requiring projects to achieve escalating thresholds of non-FEOC content to receive tax credits while utilities work to expand sourcing channels for their supply chains and strengthen security measures. These restrictions arrive precisely when utilities face unprecedented electricity demand growth driven by the rapid growth in data centers, creating a considerable challenge: rapidly expanding infrastructure while navigating complex compliance requirements while lacking viable alternatives for many critical components. Idaho National Laboratory (INL) and its partners have developed practical approaches to help utilities navigate these intersecting challenges as they leverage federal investment to strengthen and grow the grid. These solutions include Cyber-Informed Engineering (CIE) principles that build resilience directly into systems, the Cirrus tool for secure cloud migration, and enhanced procurement guidance that embeds security requirements throughout equipment lifecycles. Federal initiatives, such as the Technical Assistance for Digital Assurance (TADA) project, provide direct support to utilities implementing these approaches while facilitating knowledge sharing across the industry. While these tools and frameworks cannot eliminate all risks inherent in foreign supply chain dependencies, they offer pragmatic pathways for strengthening security posture without sacrificing the deployment momentum essential to meeting surging electricity demand. Ultimately, securing America's digital energy infrastructure demands dedicated coordination across multiple fronts: building domestic supply chains, implementing robust digital assurance practices, and maintaining the aggressive modernization timeline necessary for reliability, resilience, and energy independence.

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Virtual Power Plant Architecture and Resilient Design

Virtual Power Plants (VPPs) represent a fundamental shift in electric grid operations, aggregating distributed energy resources (DERs) such as solar panels and battery storage to deliver utility-scale grid services traditionally provided by centralized power plants. This report examines the unique architectural, operational, and digital assurance considerations that distinguish VPPs from conventional utility infrastructure as they scale from pilot projects to mainstream deployment across the United States. While VPPs offer significant opportunities for grid modernization and enhanced flexibility, their distributed, multi-stakeholder architecture introduces distinct security challenges that differ fundamentally from traditional generation facilities. The analysis identifies risks in VPP operations, including device-level security gaps, platform vulnerabilities, and communication protocol weaknesses that create expanded attack surfaces compared to centralized power plants. Through examination of real-world incidents and emerging threat patterns, the report demonstrates how some VPPs' reliance on consumer-owned devices, public internet infrastructure, and complex vendor ecosystems require new approaches to digital assurance and operational security. The findings provide practical guidance for utilities, regulators, and aggregators to implement robust security frameworks and operational best practices essential for maintaining grid reliability as VPP deployment accelerates under the Federal Energy Regulatory Commission (FERC) Order 2222 and related regulatory initiatives.

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Digital Assurance for Grid Reliability in the Era of Large Load Growth

The rapid expansion of large electric loads is reshaping the operational and regulatory landscape of the U.S. electric grid. These facilities are reaching new scales of expansion, now exceeding a gigawatt per site, and their highly sensitive, digitally driven behaviors introduce new reliability risks. Recent grid events, including large load losses following routine transmission disturbances, highlight the consequences of limited ride-through capability, inconsistent protection settings, inadequate modeling, and lack of behind-the-meter visibility. Parallels to earlier integration challenges of new grid technologies suggest that the grid’s existing processes, standards, and interconnection frameworks are no longer adequate for emerging large loads. This brief synthesizes lessons from the evolution of inverter-based resource regulation and applies them to large-load integration. It identifies critical gaps in modeling accuracy, interconnection processes, performance standards, and compliance mechanisms. Technical recommendations emphasize advanced monitoring, improved modeling, coordinated communication protocols, modernized substations, and structured behind-the-meter control schemes. Collectively, these measures provide a roadmap to maintain bulk power system reliability while enabling the continued growth of large, electrified digital infrastructure.

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Securing Grid Communications Infrastructure: Addressing Gaps Beyond NERC CIP Facility Perimeters

The North American electric grid relies on a complex communications infrastructure that extends beyond facility perimeters traditionally covered by NERC Critical Infrastructure Protection (CIP) standards. While CIP requirements have significantly strengthened cybersecurity within Electronic Security Perimeters, many operational communications—such as those between control centers, substations, and third-party networks—fall outside current regulatory scope. As grid modernization introduces new technologies and connectivity models, these external pathways present evolving security challenges. This brief explores the nature of these challenges, including emerging attack vectors and supply chain considerations, and highlights how ongoing grid transformation increases exposure to sophisticated threats. It outlines practical strategies and policy options to complement existing standards, such as expanding secure communications practices, enhancing supply chain transparency, and fostering collaboration among federal, state, and industry stakeholders. Near-term actions like encryption, authentication, and contractual safeguards can help reduce risk while longer-term frameworks are developed to ensure resilient and secure grid operations.

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Business Case Analysis for Artificial Intelligence-Large Language Model Technology Integration

AI-assisted processes are expected to enhance operational efficiency and improve decision-making, supporting the long-term economic viability of nuclear power plants. However, detailed business analyses of AI-generated cost savings are rarely performed. Given the recent industry interest in Large Language Model (LLM), the U.S. Department of Energy (DOE) Light Water Reactor Sustainability (LWRS) Program has conducted a comprehensive business case analysis of LLM Artificial Intelligence (AI) implementation in nuclear plant engineering workflows. The research employed three complementary business case approaches to evaluate impact of an LLM, using three representative engineering processes as use-cases: Boric Acid Corrosion (BAC) Evaluations, Maintenance Rule Evaluations, and 10 CFR 50.59 Screenings. Through detailed workload analyses and structured interviews, the study quantified significant efficiency improvements ranging from 11% to 59% across these processes. The research further considers how these efficiency gains could translate into tangible reliability improvements through enhanced engineering capacity. Analysis of historical plant trip data indicates that enabling engineers to focus on proactive reliability activities could provide substantial financial benefits through avoided outages, potentially generating greater value than the direct efficiency improvements alone. By documenting successful applications, implementation challenges, and strategic opportunities, this research provides nuclear utilities with a practical framework for evaluating the value of AI technology to support long-term operations through advanced digital technologies.

97 MATHEMATICS AND COMPUTING↗

Cyber-Informed Engineering (CIE) Guide for States

The Cyber-Informed Engineering (CIE) Guide for States provides state energy offices, public utility commissions, and partner organizations with a structured framework for integrating cyber-resilient engineering practices into energy planning, grantmaking, interconnection processes, and workforce development. As grid digitalization and the adoption of distributed energy resources accelerate, states face expanding cyber-physical risks that traditional cybersecurity measures alone cannot fully address. CIE offers a proactive, consequence-focused engineering methodology that emphasizes eliminating or mitigating high-impact failure modes through design, physical controls, and operational safeguards. The guide outlines the 12 core CIE principles, demonstrates their application through state-focused use cases—including grant evaluation rubrics, interconnection reviews, allow-list development, and training programs—and provides practical tools such as scoring frameworks, impact assessment methods, and implementation checklists. It also highlights pathways for state–utility collaboration and opportunities for technical assistance from national laboratories. By adopting CIE, states can enhance grid reliability, reduce lifecycle costs, strengthen supply-chain assurance, and foster a security-aware engineering culture that aligns with broader resilience and modernization goals. November 2025

29 ENERGY PLANNING, POLICY, AND ECONOMY↗

Navigating United States Standards and Regulation for Digital Energy Systems

This report provides an analysis of the U.S. standards and regulatory landscape for digital energy systems, focusing on cybersecurity, safety, and reliability requirements. It examines the interplay between federal mandates, state regulations, voluntary industry standards, and utility-specific policies, highlighting critical gaps between compliance and real-world risk mitigation. While NERC CIP standards enforce cybersecurity for Bulk Electric System assets, distribution-level infrastructure and emerging technologies often fall outside mandatory oversight, creating vulnerabilities. The report identifies systemic challenges such as reliance on self-attestation, uneven state adoption of safety codes, and lagging standards for advanced technologies like battery energy storage and inverter-based resources. Through a detailed gap analysis, it underscores the urgency of proactive risk-based approaches, independent verification, and strategic engagement with state and federal entities. Recommendations include adopting tiered security frameworks, strengthening procurement practices, and addressing emerging technology risks to ensure resilient and secure digital energy infrastructure. This guidance is intended for utilities, regulators, and stakeholders navigating compliance obligations and seeking to enhance cybersecurity and safety beyond minimum standards.

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Data Centers and Digital Assurance Workshop 2 – Prioritizing Digital Assurance Challenges, Session 2

The second session of the TADA (Technical Assistance for Digital Assurance) Data Centers Cohort, held on November 10, 2025, focused on prioritizing digital assurance challenges at the intersection of data centers and the electric grid. Building on the foundational concepts introduced in Workshop 1, this session deepened the application of the Threat–Vulnerability–Consequence (TVC) framework and emphasized the urgency of addressing cybersecurity, supply chain integrity, and operational reliability. Participants explored the growing convergence of digital and physical systems, the expanding attack surface due to global supply chain dependencies, and the implications of AI-driven load behavior. Real-world incidents—including the Volt Typhoon campaign and vulnerabilities in Solarman and Deye platforms—were analyzed to illustrate the risks of unpatched systems, insecure APIs, and inadequate vendor oversight. Key themes included architecture and interface weaknesses, governance gaps, and human and procedural shortcomings. The workshop also examined the evolving regulatory landscape, highlighting new federal mandates around Foreign Entity of Concern (FEOC) compliance and large-load reliability standards. Through interactive exercises, stakeholders ranked and mapped digital assurance risks from their respective perspectives—utilities, operators, and vendors—laying the groundwork for mitigation strategies and shared accountability models to be developed in Workshop 3. Session 2 of 3.

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Data Centers and Digital Assurance Introduction to Supply Chain and Cybersecurity for Data Centers, Session 1

The first session of the TADA (Technical Assistance for Digital Assurance) Data Centers Cohort Workshop, held on October 30, 2025, introduced foundational concepts of Digital Assurance in the context of data center and grid integration. Sponsored by the U.S. Department of Energy, the workshop brought together utilities, data center operators, developers, and vendors to address cybersecurity and supply chain vulnerabilities. The session emphasized the growing criticality of data centers within the electric grid and the need for secure, real-time, bidirectional communication. Participants explored the principles of Digital Assurance, including cybersecurity, cyber-informed engineering (CIE), and lifecycle security, and applied a threat-vulnerability-consequence framework to identify and mitigate risks at the data center–grid interface. Discussions covered a range of threats such as spoofed dispatch signals and insider threats, architectural vulnerabilities like SCADA interfaces and insecure protocols, and potential consequences including cascading grid failures. The session also raised strategic questions about business value, vendor assurance, and defining cyber boundaries and responsibilities. This foundational workshop set the stage for deeper technical analysis and the development of actionable frameworks in subsequent sessions. Session 1 of 3.

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Advanced Transmission Technologies (ATTs) Supplier Cohort Workshops Cohort Summary [Slides]

This Summary slide deck summarizes the key outcomes of the Advanced Transmission Technologies (ATTs) supplier cohort, part of Idaho National Laboratory’s (INL) Technical Assistance for Digital Assurance (TADA) program. The program aimed to strengthen grid resilience through cybersecurity controls, supply-chain security, and Cyber-Informed Engineering (CIE) for advanced transmission technologies. The cohort brought together vendors representing the full range of Grid-Enhancing Technologies (GETs), including providers of Dynamic Line Ratings (DLR), Advanced Power Flow Control (APFC), Transmission Topology Optimization (TTO), and High-Performance Conductors (HPCs). Discussions focused on institutional, integration, and operational barriers limiting GET adoption; cybersecurity risks at EMS/SCADA, cloud, and network integration points; and supply-chain transparency issues such as semiconductor dependence and SBOM/HBOM expectations. Participants also addressed operator trust, human-in-the-loop requirements, and challenges with utility adoption, while exploring how CIE can support secure deployment of GETs. This deck represents a consolidated summary of challenges and risks identified by vendors, cross-cutting themes and technology-specific insights from three cohort workshops, and actionable mitigations to guide utilities, vendors, and the Department of Energy in advancing secure, trusted deployment of GETs.

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Data Center Cybersecurity, Supply Chain Risk Management, and Emerging Regulation Cohort Summary: Takeaways and Action Plans

This report summarizes the outcomes of the Data Center Cohort under the Department of Energy’s Technical Assistance for Digital Assurance (TADA) initiative, aimed at enhancing grid resilience through cybersecurity, supply chain risk management (SCRM), and Cyber-Informed Engineering (CIE). The cohort engaged 17 organizations across utilities, data center operators, vendors, and technology providers in three sessions combining presentations, discussions, and exercises. Key topics included AI-driven load behavior, cybersecurity vulnerabilities in UPS/BESS and cooling systems, governance gaps at utility–data center boundaries, and supply chain integrity. Five cross-cutting themes emerged: interconnection architecture vulnerabilities, fragmented governance, AI-driven stability risks, lack of regulatory frameworks, and long-term supply chain concerns. Actionable recommendations were developed, including implementing DMZ segmentation, formalizing vendor access agreements, designing AI workload limits, and advancing standards through NERC and state-level programs. These strategies aim to strengthen resilience, clarify responsibilities, and ensure secure integration of data centers into the grid.

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Foreign Entity of Concern Requirements in the One Big Beautiful Bill Act

The One Big Beautiful Bill Act (OBBB), enacted July 4, 2025, makes billions of dollars in federal energy tax credits conditional on supply chain independence from China and other foreign entities of concern. The OBBB simultaneously creates powerful economic incentives to reshore energy supply chains to the United States and allied nations. Through such incentives, the OBBB elevates digital assurance and supply chain verification from voluntary best practices into critical capabilities for demonstrating tax credit eligibility. The OBBB uses tax credit eligibility requirements to simultaneously address national security concerns regarding foreign supply chain dependencies and incentivize domestic energy manufacturing. This brief details how organizations should operationalize these requirements through baseline compliance audits, interim documentation systems, supply chain diversification strategies, and long-term institutional integration of digital assurance capabilities that turn compliance burdens into competitive advantages

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Advanced Transmission Technologies – GETs and HPCs Session 1: ATT Foundations and Dynamic Line Ratings (DLRs)

The INL TADA GETs Cohort Session 1, held on November 4, 2025, convened experts to address the integration of advanced transmission technologies, including Grid-Enhancing Technologies (GETs) and High Performance Conductors (HPCs), with a focus on digital assurance challenges. The session highlighted the growing importance of cybersecurity, supply chain transparency, reliability, and business risk management in deploying GETs, especially Dynamic Line Ratings (DLRs). Participants examined how expanded attack surfaces, limited vendor pools, and new regulatory requirements—such as FERC Orders 881, 2023, and 1920—are influencing utilities and technology providers. The workshop underscored the need for cyber-informed engineering, secure-by-design principles, and practical risk management strategies, while fostering collaboration and knowledge sharing among industry peers. Technical discussions covered the evolution from static to dynamic line ratings, complexities of cloud-based architectures, and NERC CIP compliance challenges. The session concluded with a collaborative risk exercise and a preview of future workshops on advanced power flow control and transmission topology optimization, reinforcing the cohort’s commitment to advancing digital assurance in the energy sector.

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Advanced Transmission Technologies –GETs and HPCs Session 3: HPCs and Building Actions Plans to Digital Assurance Risks

The third session of the Idaho National Laboratory’s (INL) Technical Assistance for Digital Assurance (TADA) program, held on November 11, 2025, centered on High Performance Conductors (HPCs) and the formulation of action plans to address digital assurance risks associated with Grid-Enhancing Technologies (GETs). This session convened experts from utilities, vendors, and government agencies to examine the technical, operational, and cybersecurity aspects of HPC deployment. Discussions highlighted the benefits of HPCs, such as their ability to rapidly increase transmission capacity using existing corridors, improve grid resilience, reduce system losses, and align with FERC Orders 2023 and 1920. Participants evaluated supply chain and digital assurance risks, including reliance on imported materials, limited domestic manufacturing capacity, workforce shortages, and traceability issues. The session also emphasized the importance of digital trust, integration-layer cybersecurity, and unified risk frameworks, introducing tools like intrusion detection systems, encryption, zero trust networking, and firmware integrity. Recaps of earlier workshops on Dynamic Line Ratings (DLRs), Advanced Power Flow Control (APFC), and Transmission Topology Optimization (TTO) underscored institutional barriers and integration challenges. Action plans were proposed to mitigate issues such as inconsistent cybersecurity practices, SBOM usage, supply chain visibility, operator trust, and misaligned incentives. Additionally, INL presented its supply chain risk management tools and Cyber-Informed Engineering (CIE) principles to support secure procurement and system design. The session concluded with a commitment to share key takeaways, incorporate cohort feedback into future policy development, and continue collaborative engagement through upcoming pilot activities. Session 3 of 3.

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