Read this post on Josh’s Substack: Powering Spaceship Earth.
Neil Chilson and I submitted comments to the Office of Science and Technology Policy’s (OSTP). Neil covered the extensive opportunities within artificial intelligence policy, and I added some energy topics.
Our core argument is that the US needs a robust AI Action Plan focused on removing barriers. Here’s the section devoted to nuclear:
Problem: The U.S. builds nuclear power generation at a glacial pace. The Connecticut Yankee nuclear plant, which began operating on January 1, 1968, took five years and $1 billion (in today’s dollars) to permit and build. In contrast, Vogtle’s nuclear reactor in Georgia took 14 years and over $30 billion to fully come online in 2024. Poor regulation is the problem—particularly the “As Low as Reasonably Achievable” (ALARA) standard and the linear no-threshold (LNT) model. These lack well-defined limits, ignore radiation dosage and timing, and force excessive mitigation efforts. These rules have stifled nuclear expansion since the mid-to-late 1980s, creating skyrocketing costs and halting additional capacity. ALARA prevents cost reductions because regulators could interpret cost savings and profitability to imply that additional radiation emission reduction efforts could have been done.
Action: Direct the Nuclear Regulatory Commission (NRC) to replace linear no-threshold modeling with standards that account for dosage and timing. Specifically, the NRC must:
Clarify ALARA guidelines to establish reasonable, cost-conscious thresholds rather than open-ended requirements.
Replace the LNT model with a more risk-informed framework that considers dosage and timing for radiation exposure.
Refine and streamline the NRC’s rules created under the direction of the 2019 Nuclear Energy Innovation and Modernization Act (NEIMA). NEIMA required the NRC to establish new licensing processes for nuclear reactors and advanced reactors, but its proposals have been unwieldy and failed to create the NEIMA authors’ envisioned and intended surge of small modular reactor (SMR) companies or deployment of SMRs or advanced reactors.
Supercharge Small Modular Nuclear in the US by Settling the Lawsuit Against the NRC Brought by Utah, Texas, and Last Energy
For anyone reading Jack Devanney at Gordian Knot News, Grant Dever 🌄, or Adam Stein’s leading work on nuclear policy for the Breakthrough Institute, this is old news. Devanney, in particular, has made several recent efforts to get alternatives to LNT noticed—running two separate letters to Elon Musk and Energy Secretary Chris Wright on his pages.
Avoid the nirvana fallacy since all energies have risks
Something that I wish I’d included is a reminder that all energy technologies pose risks. An important blind spot in current nuclear regulation is that other energy sources imply risks of the types that nuclear regulation is meant to prevent. That is, coal, gas, and oil all have emissions with different health effects. Even the mining for minerals inside wind and solar technologies implies environmental tradeoffs.
The failure to enable nuclear means these competing energy sources continue operating. The right question for policymakers is about balancing the risks of not using nuclear alongside the real but manageable risks of nuclear power.
Nuclear can play an important role in a world of abundant and affordable energy. The OSTP comments Neil and I submitted focus on artificial intelligence, but there are many opportunities for nuclear to revitalize industries of all kinds. Policymakers need only to rationalize the rules that nuclear developers must follow. We can return to a world where nuclear is safe, low-cost, and common.
