CFACT Collegians know that while nuclear energy may be complicated, unnecessary bureaucracy doesn’t have to be. CFACT Collegians Jonathan Cha from the University of Texas at Austin and Zackary Whitworth-Painter-Swayze from Linfield University made that case in public comments to the Nuclear Regulatory Commission (NRC).
The NRC recently proposed several administrative revisions designed to tidy up and simplify internal rules. These changes deal primarily with technicalities: paperwork, advisory committees, sensitive information handling, and employee security standards. The proposal doesn’t approve shiny new nuclear plants or make major changes to reactor safety regulations. Instead, the proposal aims to bring outdated procedures up to speed to allow for more operational efficiency.
While NRC paperwork might not be the flashy side of nuclear energy, cutting red tape is critical, particularly as U.S. electricity demand rapidly continues to grow. Drawn out and outdated processes take precious time away from the NRC’s greater responsibilities. Jonathan’s personal tie to Texas allows him to see first hand his state’s skyrocketing energy needs, and how these small changes can be a much larger step in the right direction:
“I strongly support this direct final rule, and urge the Commission to allow this rulemaking, as scheduled for October 26th, 2026, to go into effect.
As an economics major studying at the University of Texas at Austin, I’d like to make my position clear about the rulemaking being proposed; and why I believe complicating a procedural rulemaking doesn’t help the Commission. This rulemaking doesn’t authorize the operation of a nuclear reactor, alter a safety requirement, nor shorten the time allowed for a licensee’s review process. Rather, this rulemaking makes changes to 10 CFR Parts 2, 7 & 10 to modify informational withholding procedures, to ensure the NRC Advisory Committee Regulations are in line with GSA (General Services Administration) regulations established in December 2025 regarding FACA (Federal Advisory Committee Act); and to incorporate Security Executive Agent Directive 4 as the NRC’s personnel security requirements. As noted in the Commission’s own Regulatory Analysis, these changes represent “administrative”,”procedural” or “conformity” actions that impose no new substantive requirements upon a Licensee. These characterizations appear to me to be correct and therefore I don’t feel obligated to characterize this rulemaking as anything more than it is.
Regardless, one important point is, if an agency carries unnecessary procedural processes, the agency will have less capacity and move more slowly including those items that are critical to the success of the agency. Rulemakings related to housekeeping issues can assist an agency rebuild capacity, and capacity is what the NRC is going to require. Why does this matter to me as it relates to where I live? On April 15, ERCOT submitted their Preliminary Long-Term Load Forecast with the Public Utility Commission of Texas, forecasting a peak demand level as high as approximately 367,790 MW by the year 2032. ERCOT’s All-Time Peak Demand Level was 85,508 MW, which occurred during August of 2023.
ERCOT has also advised that they believe the projected levels may be higher than actual levels due to forecasted growth. Even when reduced down from the estimated maximum, the forecast still represents the largest growth in peak demand levels within ERCOT’s history. The EIA estimates that natural-gas based generation within ERCOT will grow by approximately 7% in 2026, and another 18% in 2027 in order to accommodate the expected growth in load. Texas has two functioning nuclear plants and has not licensed a new reactor in over thirty years. This lack of new reactor licenses has not occurred because of physics or the cost of capital, but mainly because of the time and money involved in obtaining a federal license. Each year the The Commission must spend time on procedures that Congress never mandated. As a result, for every year that the Commission wastes unnecessary time on procedures, the nation misses this benefit. This lost capacity is used in additional gas combustion.Regarding the specific changes being made to the amendments. The change to 10 CFR 2.390 is appropriate because there is no longer a need for competitive harm. This is a result of the Supreme Court’s invalidation of the substantial-competitive-harm test in Food Marketing Institute v. Argus Leader Media (2019). Making the change is a step in the right direction in order to deal with the restrictions imposed by the old case law. The amendments to part 7 and the codification of SEAD 4 in part 10 are also beneficial.
Imposing the requirements discussed above regarding NRC advisory committee personnel security safeguards and implementing personnel security safeguards already being used through Management Directive 12.3 would promote transparency without changing practices in any way. One suggestion. The amended section 10 CFR 2.804(e) changes the language used from “shall” to “may” making this post-promulgation comment period optional for the NRC. The Commission is right in that the Administrative Procedure Act does not require the period where an exception to notice and comment already applies. This is the only element of the rulemaking that reduces instead of expanding public visibility into the Agency’s actions, though I do not consider this as an objection to the rule.
Ultimately, I am in favor of adopting these new rules. The ultimate future success of America’s ability to build new nuclear reactors at a rate proportional with our nation’s current energy demands will depend upon how successful we are in modernizing the way we do things.”
For Zackary, the stakes are personal. His generation are the ones who will ultimately inherit the energy decisions being made today:
“To Whom it May Concern,
My name is Zackary Whitworth-Painter-Swayze, and I am a college student writing in support of the NRC’s proposed rule to modernize and simplify portions of the agency’s internal regulations.
I support this proposal because an effective nuclear regulator is essential to the future of the American nuclear energy industry. Nuclear power provides reliable, affordable, and clean energy while strengthening America’s energy security for the future. However, duplicative procedures and unnecessary requirements can make nuclear development slower and more expensive without providing a corresponding improvement in safety.
The NRC’s core responsibility should be maintaining strong and effective nuclear safety standards. At the same time, the agency should be able to regularly examine its own procedures to determine whether outdated, duplicative, or unnecessarily burdensome requirements remain necessary for future development. So, modernizing the internal rules surrounding paperwork, advisory committees, sensitive information, and employee security standards is a practical step toward accomplishing that goal.
One example of a rule that the NRC is planning to update is the provision in 10 CFR 2.804, which states the following:
Second, the NRC is revising a provision in 10 CFR 2.804 that established procedural requirements related to post-promulgation comment periods. This provision is not statutorily required and thus imposes unnecessary administrative burdens. Revision of this provision provides additional flexibility to rulemaking processes.
This means that the proposed changes will reduce the administrative burdens and procedural delays that serve to only lengthen the process and not strengthen the process towards nuclear energy.
I recognize that this proposed rule does not directly reform reactor licensing or approve the construction of new nuclear facilities across the U.S. Nevertheless, improving the NRC’s administrative efficiency is an important part of broader regulatory reform to keep up the nuclear energy momentum in the U.S. For instance, the Department of Energy has a new goal of 10 new large nuclear reactors under construction by 2030 (McDermott), while the same department is committing over $17.5 billion towards low-interest loans to different nuclear power companies for development(McDermott). Therefore, in order to keep that momentum, the NRC should continue to modernize while getting rid of more bureaucratic red tape that hinders the nuclear industry.
Furthermore, a regulator that operates with greater clarity, consistency, and efficiency will be better positioned to focus its resources on its most important responsibility: protecting public health and safety while allowing safe nuclear energy to be built in greater numbers to achieve a faster shift towards a more sustainable American energy system
As a college student, I believe this issue is particularly important because the decisions made today will influence America’s energy system for decades to come. Younger Americans will inherit the consequences of both our energy choices and our regulatory choices. We should not allow outdated bureaucratic procedures to unnecessarily limit access to a powerful source of American energy.
For these reasons, I encourage the NRC to finalize this proposed rule to change the standards. The Commission should continue pursuing reforms that reduce unnecessary administrative burdens while maintaining rigorous safety standards. Modernizing the NRC is not about weakening nuclear safety; it is about making the agency more focused, effective, transparent, and capable of fulfilling its mission to make America energy independent again.”