It is not an everyday occurrence to see the President of the United States wade into an eight decade long debate in a niche scientific field. And yet, in an executive order announced in mid-May, the Trump administration explicitly called out the Linear No-Threshold (LNT) model of risk management as “flawed” and in need of replacement.

Linear No-Threshold might be one of the most contentious phrases in the world of nuclear science and safety. However, nuclear safety does not have a unique claim to LNT. LNT models exist throughout the safety world, applying to environmental exposures and even some chemotherapeutic drugs.

LNT models assume that there is a linear relationship between the dose or exposure to a hazard and health risks. The problem with LNT for nuclear applications is that it implies that there is no safe level of radiation, no matter how small. The LNT model, like all risk models, makes assumptions based on existing data to try to make realistic claims that insurance companies, economic planners, and public health policy makers can use. Scientific debate about using the LNT model for radiation exposure has and will continue for decades.

LNT is trans-scientific and even the International Atomic Energy Agency’s Basic Safety Standards note that LNT is “ probably not provable.” Yet, replacing LNT would require significant effort and funds over several decades, while not actually resolving the policy debate about appropriate risk levels. Instead of simply choosing a different, equally unverifiable method of determining risk, the near-term focus should be how policy and regulation manage the risk appropriately.

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What is LNT?

LNT is a linear model used for estimating the risk of radiation exposure. The model is used by the U.S. Nuclear Regulatory Commission, the Environmental Protection Agency, as well as the United Nations Scientific Committee on the Effects of Atomic Radiation and the International Commission on Radiological Protection.

Regardless of what hazard you are looking at, a linear no-threshold model, by definition, is a straight line from zero exposure until the risk is 100%. The “no-threshold” part of the name indicates that there is no level above zero where a dose does not represent “risk.” A LNT model for nuclear regulation means that any amount of radiation produced by a reactor, input, or anything, is subject to oversight because, according to the model, even the smallest amount of radiation increases the risk of cancer. But, thresholds exist for pretty much every health outcome: the hot water from a tap will not burn your hand, but boiling water will.

The more hazardous the substance is, the steeper the line will be in an LNT model. A steeper line means that the health risk increases very rapidly as exposure increases. If that steep line is also linear, that means that the health risk begins increasing rapidly even with small increases from low exposures. Vaping, for example, is weakly associated with lung cancer, while cigarette smoke is strongly associated. So the slope of an LNT model for vaping would be shallower than the slope of one for cigarettes. That doesn’t mean that it is ever easy to determine the slope of the line, or to ensure it is actually straight and not curved in some way. This takes a lot of research and data to determine. In the absence of sufficient data to make that determination, public health exposure models often take the most conservative approach. Because the dose exposure relationship is much easier to observe and quantify at high doses, these models assume a linear relationship and extrapolate dose/exposure relationship observed at high doses to low doses. A linear dose/exposure model is the simplest model, and in the absence of sufficient data to observe non-linearity, the most defensible approach is to assume linearity rather than making assumptions about non-linearity or thresholds that are essentially arbitrary. For this reason, LNT is the default risk model for all environmental hazards regulated by the EPA, not just ionizing radiation.

What are Naturally Occurring Levels of Radiation?

The executive order specifically claims that the NRC uses models that “lack sound scientific basis and produce irrational results such as requiring that nuclear plants protect against radiation below naturally occurring levels.“

But, what are naturally occurring levels? The most recent comprehensive analysis found that the average background dose is 3.1 millisievert (mSv) with a standard deviation of 3.69. Negative radiation levels are not possible, but the standard deviation illustrates the wide range of background radiation levels across the US. This dose comes from many sources: radon gas permeating from the ground into the lowest level of a house, naturally radioactive potassium inside of our muscles, cosmic radiation hurtling straight through the atmosphere. Radon is the largest contributor by far (68%) and houses directly next to one another can have wildly different concentrations.

Radiation from nuclear energy is relatively easy to measure, but it's a drop in a very large bucket when it comes to radiation exposure overall. The very low levels of exposure from nuclear power are dwarfed relative to both the magnitude and variation of normal background radiation. Medically-necessary imaging contributes as much as background radiation to the entire US population, and both are more than 10,000x the dose from nuclear power. The exposure from nuclear power is so small that it doesn’t even have a separate category in Figure 1 and is instead lumped in with other industrial sources.

Radiation risk models attempt to estimate how many cases of cancer are caused by exposure to a given dose of radiation and how many subsequent deaths result. This is not easily done. Roughly 4 out of 10 people will develop cancer in their lifetimes. The causes of these cancers are incredibly varied and multifaceted. At the cellular level, all cancers result from at least two mutations, one that cuts the brakes and the other that hits the gas on cell growth. But the causes of these mutations are incredibly complex. Different genetic factors, diets, habits, and environmental exposures can cause cancers or be protective against them.

At high doses, ionizing radiation is a known carcinogen. So are many other things though—from alcohol and tobacco to viruses and industrial chemicals to seemingly benign nutrients like beta-carotene. At low doses, we are constantly exposed to so many other carcinogens, which constantly interact with so many other cancer risk factors, and cancer is so ubiquitous in the human population that quantifying cancer risk from low-dose exposure to radiation, at levels well below background radiation, is functionally impossible.

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If not LNT, what else?

So, what would happen if LNT were no longer used to evaluate the risk of radiation exposure?

Well, there has to be some kind of model, and an alternative would face the same scrutiny that LNT has faced thus far, but without the benefit of decades of precedence. This could mire the NRC and EPA in years of litigation. If there weren’t a model, each exposure would have to be individually calculated for the distinctive risk to the person, which isn’t a feasible endeavor even past a few tens of people.

Presidential administrations have changed pollution limits and oversight before, but changing the paradigm of risk calculation affects the very base of safety and management practices. Starting from the ground up could yield some more efficient solution, but in all likelihood, there will just be a drawn-out fight to end at the same point.

The data on dose response can be interpreted to support many different versions or models, such as the existence of a threshold before effects begin, that low doses might be beneficial (hormesis), or even that we could be more sensitive to low doses (hypersensitivity). For example, the hormetic model is based on a select few studies of radioprotective effects that demonstrate some benefit for low doses of radiation. The fundamental idea of hormesis, though, is that because of the ubiquity of background radiation, humans and other species have evolved to live with, and in some cases, benefit from exposure to radiation.

But hormesis, or any other option, is no more provable than LNT. The range at which hormesis might exist would require even more data than LNT to prove, since the margin of benefit is smaller than the range of possible detriment. Further, lots of factors could be considered to improve the current model, such as incorporating estimates of how well DNA can be repaired at low doses or better aligning LNT with international standards, which suggest that long-term low doses only appear to be half as damaging as acute ones.

How to Improve LNT

Arguing over which model should be used isn’t a near-term solution because conclusive data isn’t currently available. Instead, the focus should be on how policy appropriately manages the risk through regulations. Risk management can be updated much more quickly to align with policy and the current state of science. In an ideal world, science is continually adjusted with increasing data and analysis. This then informs how to best assess risk and build better models. Using models allows for a defensible means of managing risk through policies and practices. These means of management are determined by what society deems permissible both through social acceptance and tangible legislative declarations.

One way that the NRC has long applied the LNT model is through the establishment of the “As Low as Reasonably Achievable” (ALARA) principle. ALARA proposes that, since there is no risk-free exposure to radiation, doses must be limited as much as is possible and economically feasible to do so. ALARA was intended to balance benefits with costs in risk-informed decisions but currently results in minimizing dose without regard to the actual amount of risk mitigated, which can lead to more harm than benefit.

In a broad sense, safety regulations try to reduce harm. If mitigating a risk is more beneficial than the costs, then it should be mitigated. For example, if a worker is performing a test and could either be exposed to a dose or avoid it altogether by leaving the area, the obvious choice is to leave the area. However, in many cases, money is being spent on reductions in dose that are unlikely to ever save a single person from getting cancer. The probability is just too low, the effect wouldn’t be observable epidemiologically if it did occur, and the LNT model is already more conservative in its risk estimation than reality.

One might consider this where the principle of what is “reasonable” should come in, but the NRC has become incredibly risk-averse and even the smallest bits of mitigation are sought.

In the 1987 decision in Union of Concerned Scientists v. NRC the court agreed with the NRC that “’Adequate protection’ is not absolute protection.” Former Commissioner Bill Ostendorff also noted that “the responsibility on us as Commissioners to decide how much risk is acceptable,” even though Congress already determined how much risk is acceptable. Despite this noted flexibility, throughout the NRC’s history the focus has been on effectively protecting the public from nuclear technologies, not enabling safe nuclear power. Keeping doses ALARA is, by rule, supposed to be countered “in relation to the utilization of nuclear energy and licensed materials in the public interest.” This has been part of the ALARA regulation for decades, but the NRC does not have a framework to compare benefits to society with perceived risk. Whereas LNT allows the NRC to make explicit and quantitative claims about risk, they have no equivalent model to quantify societal benefits like abundant electricity or reduced emissions. This is because the NRC previously held the position that considering benefits to the public was not part of its mission.

The ADVANCE Act clarified that enabling “the benefits of civilian use of radioactive materials and nuclear energy technology to society” has always been the NRC’s mission, and those benefits should not be unnecessarily limited. Regulating doses below a level that has observable health effects is an unnecessary limitation. Without a threshold under which radiation is deemed safe, the licensees need to identify every exposure, spend resources on evaluating it, provide justification for offsetting economic, environmental, or other factors, and hedge against the potential for the work to be considered insufficient by the NRC. To avoid this, licensees have to add many very small protections or safety protocols to avoid the cost of this process, even if no increase in safety is achieved. In other words, because the NRC doesn’t appropriately manage the lower range of risk, it “costs less” to add unnecessary layers of protection than not to add them.

There are many other hazards that use LNT, but the risks aren’t managed to near zero. Regulations often set reasonable thresholds on exposure to the hazard, based on acceptable risk. For example, benzene is a ubiquitous industrial chemical used throughout the world and its risks (primarily leukemia) are calculated with an LNT model. However, it is fully managed under the EPA standard of acceptable risk with standard maximum concentrations that need to be met for exposures, regardless of public or occupational status, and without the need to drive it to zero in every possible manner.

Several approaches could modernize radiation protection while working within the existing LNT framework:

1. Risk-informed regulation: Agencies could implement more flexible risk thresholds that better balance safety against other societal benefits, rather than adopting extremely conservative lifetime risk standards. Current implementation of ALARA principles heavily leans towards ambiguous definitions of “adequate protection” which assume risks should be near zero by default, instead of “ample margin of safety” which has quantitative definitions.

2. Contextual dose limits: A tiered system of radiation thresholds would reflect a reasonable balance of safety without undue burden. This includes setting a higher limit when doses under natural variation are not regulated and a slower increase when protective actions are required within the dose rates that show the highest likelihood of not being harmful. A tiered system can be implemented in the near term since it would not require a change of rule-making within both the NRC's and EPA's discretion. The first tier, up to the current public dose limit, would be exempt from regulation since it is less than the dose from someone moving from one house to another or from a low elevation to a high elevation. The second two tiers would progressively increase protection for the public and then workers. Beyond that would be an occupational limit within any one year. This both reduces regulatory burden and creates a more flexible but science-based safety regime.

3. Recognition of comparative risks: Despite the administration's normal defense of fossil fuels, even the executive acknowledges that “the reality that substitute forms of energy production also carry risk, such as pollution with potentially deleterious health effects.” These other risks, like particulate matter (PM) are weighed against their ubiquity, relative risk, and their emissions from industries and technologies that are otherwise beneficial for society. Regulations must consider the impact of alternatives that will be used in place, or potentially result in increasing risk from more harmful sources of energy.

LNT and Regulation Must Evolve to Meet the Regulatory Needs of the 21st Century

There are real-world costs to regulating dose rates to very low levels that pose small and very uncertain levels of risk. It involves cleaning up waste sites to levels that require decades of human labor and hundreds of billions of dollars to achieve unnecessary safety margins unlikely to save a single human life. It makes people concerned about potentially life-saving medical treatments because they imply uncertain risks. It hinders the deployment of technologies that can create small radiological exposures, even when those technologies can create real benefits for society .

Moving nuclear regulation forward doesn't require abandoning LNT as a scientific model. Instead, the NRC must pursue regulatory approaches that reflect current scientific understanding, acknowledge uncertainty, and achieve more balanced risk management. Doing so would maintain public health protection while enabling the nuclear technologies needed to address the energy security and climate goals that Congress has clearly prioritized in recent legislation.

Last week, President Trump signed four executive orders aimed at moving the United States’ nuclear industry forward. The executive orders (EOs) push for more efficient licensing at the NRC, building a resilient domestic supply chain, and advancing the deployment of nuclear energy in the US. Many of the directives align with the bipartisan policies set forth in the ADVANCE Act of 2024, and are already in process at the NRC. Not all of the provisions are feasible, and some are even contradictory, but others are informative and helpful because they reduce policy uncertainty by stating the administration’s support for many of the changes already underway. Overall, the EOs represent a real commitment to support a large scale-up of nuclear energy.

In many cases, the executive orders say the quiet part out loud. Nuclear power is the largest source of firm, clean energy in the United States, and further growth of the industry will reduce overall electricity system costs. Regulation should not be one-sided and must consider benefits to society in balance with the risks and impacts of other energy sources. Nuclear energy helps to avoid thousands of pollution-related deaths a year in the United States, and millions more worldwide.

The administration’s stated goal of 400 GW of nuclear capacity by 2050 is laudable and supports national security, but achieving that goal will require comprehensive and complementary strategies and ample resources. A series of executive orders is just a start. The administration must look not only to support the nuclear technologies but also provide an environment that enables the efficient deployment of nuclear energy.

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The executive order entitled Reinvigorating the Nuclear Industrial Base supports an American nuclear ecosystem by enabling a domestic fuel supply chain, expanding workforce development programs, and prioritizing funding for nuclear plant uprates and restarts, among other steps.

The EO also calls for increased support for nuclear deployment through the Department of Energy and the Department of Defense. Both agencies can provide real benefits to the nuclear industry, but it is unclear that licensing under DOE would be any easier than licensing a large reactor under the NRC. Similarly, the Department of Defense has no recent experience in deploying nuclear reactors and technology. Additionally, the EOs’ call to restart shutter to promote 5 GW of uprates, and build 10 new large reactors by leveraging the DOE’s Loan Programs Office. But the Loan Programs Office must be properly staffed and empowered to realize these goals.

The executive order, Ordering the reform of the Nuclear Regulatory Commission, and fact sheet, President Donald J. Trump Directs Reform of the Nuclear Regulatory Commission, directly call on the NRC to reform its overly risk-averse culture, structure, and regulations, setting an 18-month limit for licensing new reactors, 12-month limit for license renewals for existing reactors, and implement many of the provisions in the bipartisan ADVANCE Act of 2024.

These EOs will push the NRC to become more efficient in its licensing, but it also threatens to reduce the NRC’s workforce, independence, and resources. To enable high-volume licensing to meet the administration’s goal of 400 GW of new nuclear plants by 2050, the NRC will need at least 350 staff members whose full-time focus will be on licensing—even if licensing becomes twice as efficient as it is now. The order correctly identifies that increases in staffing in certain areas, particularly licensing, may be necessary.

But, a broad reorganization of the NRC could cause significant attrition of the highest-performing staff, further reducing the efficiency of the agency. A wholesale review and revision of the regulations within 9 months would significantly divert resources from existing projects, and finalizing new regulations in 18 months would likely be too rushed to design a well-thought-out regulatory paradigm that will last a generation. (It has taken 6 years to get this far with Part 53. If the first version was finalized, it would be useless now.) Implementation of this directive will take careful consideration and strategy to avoid unintended consequences and actually improve the regulatory paradigm to achieve the NRC’s mission.

It also asks the NRC to reconsider, not outright eliminate, the linear-no-threshold radiation exposure model and As-Low-As-Reasonably-Achievable (ALARA) regulation. This is consistent with Congressional expectations for the NRC, stated in the ADVANCE Act, to not unnecessarily limit benefits to society while ensuring safety. However, it is a missed opportunity to finally align the NRC with a modern, risk-informed approach that directly reflects Congress’s 1990 Clean Air Act amendments that emphasize an “ample margin of safety” as a numerical threshold that is consistent for radiological health risk and other regulated hazards. Reconsideration of safety and risk thresholds must consider what is in statute.

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The executive order titled Reforming Nuclear Reactor Testing at the Department of Energy advocates for speeding up the development of advanced nuclear through pilot programs and streamlining environmental reviews. The order specifically asserts that advanced reactors that are not used for commercial electricity generation are collectively for “research purposes” and can be licensed by DOE. The DOE is required to set up a licensing and permitting process to approve these “qualified test reactor” applications within 2 years of submission and is charged with demonstrating at least three reactors by mid-2026.

Finally, the executive order titled Deploying Advanced Nuclear Reactor Technologies for National Security acknowledges the important role that nuclear energy plays in national security. It designates electricity generation facilities that power national security AI facilities as defense-critical infrastructure. The EO also directs the DOE to site advanced reactors and make fuel available for the purposes of powering AI and other national security infrastructure. According to the EO, the first of these advanced reactors should be operational in 30 months.

Overall, the executive orders take important steps to accelerate the deployment of nuclear energy in the United States, and look to implement many of the steps first established by the bipartisan ADVANCE Act to modernize the NRC and align regulations with the agency’s recently updated mission. However, a comprehensive strategy is still needed to bring the parts together. The clear negative health and environmental effects and risks of other energy sources should no longer be ignored when considering innovation, licensing, and deployment of nuclear energy.

However, despite the usual caveat that orders “shall be implemented consistent with applicable law,” some provisions are in untested legal areas and are clearly intended to push the boundaries. This increases uncertainty in which provisions can be implemented, and what the final outcome will be.

There are several issues that these executive orders don’t address that are left to the market or Congress. Developers need to fill order books to get to scale instead of one-off projects. Buyers consortia are needed to share risk across multiple projects and build a supply chain, workforce, and fuel supply base. Congress needs to provide some support to achieve provisions in the executive orders, such as a general license class for high-volume licensing of commercial reactors, focusing the Advisory Committee on Reactor Safeguards (ACRS) on new and novel issues. Congress can also restore market confidence by preserving LPO, the investment tax credit, allowing reasonable FEOC, and policies that focus on addressing the underlying drivers of past project overruns.

In the Atomic Energy Act of 1954 Congress declared that “the development, use, and control of atomic energy shall be directed so as to make the maximum contribution to the general welfare.” The nation needs a nuclear regulator that can license new nuclear reactors, and a federal government capable of enabling the industry to grow and maximize benefits to society—a position Congress reaffirmed in the bipartisan ADVANCE Act last year. These executive orders are a positive sign that the Trump administration understands both the value of nuclear power and the important role that the federal government must play in its resurgence, but are not sufficient to reach that goal in isolation.

The Trump administration has announced, through multiple executive orders and statements, its intention and goal to ensure energy dominance through enabling nuclear energy. But the goal of deploying nuclear energy and having policies in place to ensure its success are not the same. On Monday, the House Ways and Means Committee released “The One, Big, Beautiful Bill,” detailing its plans to phase out many of the tax credits and subsidies originating in the 2022 Inflation Reduction Act. Many of these credits, including Sections 45U, 45V, 45Y, 48C, and 48E, benefited nuclear energy directly. Senate Republicans have already signaled that this bill would need changes to pass.

Regardless, it raises the question:

Would the end of the IRA credits end all hope of building new nuclear energy?

The repeal of the existing tax credits would not ring the death knell for a nuclear resurgence, but it would remove the scaffolding supporting its construction.

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The Role of Tax Credits and Monetary Incentives

The preservation of IRA credits is synonymous with maintaining momentum in the fight against climate change. The IRA credits, particularly the Production Tax Credit (PTC) and Investment Tax Credit (ITC) applicable to nuclear, help level the playing field against subsidized renewables and compete against historically cheaper fossil fuels by lowering the cost of nuclear projects. They provide the financial certainty needed for the long and capital-intensive process of developing new nuclear projects, including next-generation small modular reactors (SMRs) and other advanced designs. With these credits, the pathway to achieving ambitious decarbonization goals by mid-century appears more viable, supporting a diverse clean energy portfolio where nuclear plays a foundational role in grid stability and emissions reduction.

First-of-a-kind (FOAK) technologies almost always need early support as they are in direct competition with established technologies. This is an area where the government can and has historically contributed to the advancement of technological innovation. Early support, especially in the realm of basic research, provides multiplying and sometimes compounding benefits to society. Private firms do not always have the large amounts of capital or the long time horizons necessary to engage in basic research; Bell Labs was an exception among firms, but that was predominantly due to its monopoly status, resulting in excess profits.

Government support for research can come in a variety of forms, ranging from grants to subsidies to tax credits. Grants tend to be the earliest stage of support and are more focused than later forms of support. Applicants apply for such programs, and the federal agency chooses the winners. Grants usually have specific criteria and expectations for their dispersal; the federal agency awarding the grant expects to have some oversight when it provides funds. Demonstration plants for TerraPower X-Energy are supported by grants under the Advanced Reactor Demonstration Program. Recently, the current administration celebrated new grants for HALEU research and production, and Gen 3+ SMRs. Subsidies vary in specificity and government involvement. Tax credits tend to shift more control to the market and significantly shorten or eliminate approval timelines.

As long as the technology is young and continues to show signs of potential benefits, it makes sense for the government to continue subsidizing and engaging in research, but as the technology matures, firms begin to make investments and the technology becomes commercially viable, the government should pare back its subsidies. Subsidizing mature technologies distorts market signals, creates inefficiencies, and chooses winners. This reduces innovations that might have otherwise happened and constrains the path of technological progress.

Solar and wind credits have persisted over the past two decades, even as the technologies have matured and pushed out investment for other forms of energy generation. Nuclear does not need subsidies to operate effectively, but it is unclear whether FOAK nuclear will be competitive with natural gas, regardless of renewable subsidies. In some markets, especially those whose interconnection queues are filled with renewables, nuclear subsidies are needed because wind and solar subsidies have continued even after they became commercially competitive, and those subsidies create an anticompetitive playing field within the market. Efficient price signals are no longer being sent out; the price signals have been distorted. The distortion makes it difficult to extract a signal from the noise.

“The One, Big, Beautiful Bill” calls for the phase-out of investment and production tax credits across renewable and clean-energy technologies, not just nuclear. The phase-out reduces the price signal distortion at the electricity market level, but without another policy driver, investments may be more muted. That will slow deployment significantly. We will still have first movers that are procuring due to their own goals, but without the PTC and ITC, nuclear has less of an advantage moving forward.

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Non-Monetary Policy Drivers

Not all industrial and innovation policy is based on economic incentives.

Before the IRA was passed and the tax credits implemented, Breakthrough Institute published the Advancing Nuclear Report, exploring how advanced nuclear could reach scale. The study found that a large scale up of nuclear energy would result in a lower-cost and reliable energy system, and was robust across a range of costs. However, those results were in the context of decarbonizing the grid, and there is no current federal mandate to hit a net-zero emission energy system to provide the necessary market driver. There is similarly no direct mandate at the federal level for national security, energy dominance, or fuel with regards to a nuclear energy resurgence. Although there is a small mandate for the federal government to buy renewable energy.

The Inflation Reduction Act, while having many subsidies and pecuniary mechanisms, was largely a symbolic piece of legislation announcing the United States’ commitment to clean energy investments and emissions reductions. With the reconciliation bill removing key parts of the IRA and sunsetting the LPO, the central policy driver is also being gutted; the vision is being erased.

PUCs have been hesitant to approve new nuclear in regulated markets, and utilities have been leery of potential impacts to credit ratings when announcing new projects, in part because of overruns experienced at Vogtle 3 & 4. Without a government program aimed at addressing cost overruns, it is unlikely that projects can move forward in regulated markets.

In some States, energy policy provides opportunities for nuclear investment in the absence of federal support. Many states have deviated from Renewable Energy Portfolios and switched to Clean Energy Standards, which include nuclear. In some cases, like Colorado, acknowledging nuclear as clean energy makes it eligible for low-interest financing programs and counts toward requirements for utilities.

There is a wide range of additional state-level policies that impact new nuclear construction. Some states have policies that support coal for jobs, which compete with new nuclear for capacity. Other states have moratoriums on building new nuclear plants or arbitrary limits on the size or location of new plants. Some have conflicting rules, such as supporting new nuclear power but banning the inevitable spent fuel from any facilities that don’t currently exist. States can support nuclear power through feasibility studies, site characterization, and direct grants, but to a lesser extent than what the federal government could provide.

Without significant amendments, the “One, Big, Beautiful Bill” will be ceding the federal government’s role in innovation and industrial policy to States and private firms. States with regulated markets will be in a better place to direct and provide incentives for nuclear deployment. States with deregulated markets will face other constraints.

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Market Realities

The issue is not whether nuclear can compete in a completely free market. The majority of nuclear plants in the U.S. were built without the advantage of tax credits after all. Only, there is no such thing as a free market for electricity. Electricity markets began deregulating in the 1990s, and the process continued through the 2000s. The regional transmission operators CAISO, ISO New England, MISO, NYISO, and PJM are all outcomes of the deregulation movement, but none of them is a free market. The deregulated markets are considered competitive, but that competition is constrained by the semi-unique rules of each system operator. Because of these constraints, nuclear and other generation sources are not compensated for all of their attributes. Nuclear’s contributions to grid resilience, fuel security, and land-use efficiency, alongside its zero-emission profile, are often undervalued or entirely unmonetized in standard market designs. This means the markets are not dynamic in competition—the product is commoditized, while production is not. Competition exists at the level of the larger market, but the topology of the grid plays a larger role than the market as a whole. There is no market for decarbonization. “Cap and trade” and other tax schemes set on accounting for the social cost of carbon have failed in the past.

The topology of the grid defines the ability of any generator to compete. The location of a generating resource relative to transmission infrastructure and other generating resources impacts its ability to sell its power on the marketplace. Areas having more generation than demand and not enough transmission infrastructure to send power to load centers result in congestion. Prices to send electricity over transmission lines increase as congestion increases; this is called locational marginal pricing (LMP) or nodal-based pricing. The grid operator is constantly trying to commit the cheapest energy sources to match demand. However, if too many very cheap energy generators are located in the same place, getting that power out of the region becomes difficult. Transmission lines can only transport a limited amount of electricity flow. The closer the electricity flow gets to the transmission line’s limit, the more expensive it is to send an additional unit of electricity across the line. Think of it as highway congestion pricing, except electrons are moving at the speed of light. If a line reaches its carrying capacity and gets too congested, it could trip a breaker, and the line will stop transporting electricity. This will cause a flurry of activity and emergency actions to reroute power around the inoperable line. To avoid this, grid operators monitor congestion at nodes across their entire region, committing resources and shutting down others to maintain electricity production while including both the costs of generation and transmission in mind.

Investment decisions for new generation in deregulated markets are influenced by expected prices of generation and other non-energy products. Subsidies and tax credits can artificially lower the price of energy generation for new and existing projects. The phase-out of tax credits and the sunsetting of the Loan Program Office will increase the expected costs that new nuclear projects will incur. This new set of expectations will affect the makeup of the next cohort of generation being added. As data centers, cryptomining operations, and electrification increase demand for electricity, nuclear will be less desirable from a cost perspective than natural gas.

Strategic grid planning, or lack thereof, can mean that previously competitive plants, including nuclear facilities, can be undercut on a single grid node by new, often subsidized, entrants or transmission congestion that disadvantages them. Even existing, fully amortized nuclear plants don't always compete effectively on price alone in wholesale markets, particularly in regions with low natural gas prices or high renewable penetration that suppresses market-clearing prices. The Quad Cities nuclear power plant houses two reactors that were planned to be shut down due to the economics of their grid location. Sandwiched between wind turbines and an inadequate transmission system, the Quad Cities reactors often faced negative energy prices, meaning the plant would have to pay to send its energy to the grid. The reactors were scheduled to be decommissioned in 2018, but were saved by the Illinois legislature’s passage of the “Future Energy Jobs” bill in 2016. Other reactors were not as fortunate; twelve reactors shut down between 2012 and 2021, most of which were in competitive markets where renewables and cheap natural gas put downward pressure on generation prices. With the resurgence of electricity demand, Palisades, one of the previously shut-down reactors, is planning to be restarted and recently received funding from the LPO to help move the process forward.

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Return of the Demand

The U.S. electricity market had flat demand for decades. Recent projections for soaring demand, driven in part by data centers and AI, have taken a lot of headlines. It is fair to ask if market pull, driven by growing demand, will be sufficient to support energy abundance and a buildout of new nuclear energy.

Figure 2: Historical and projected electricity use in TWh. Sources: EIA, NREL, and S&P

Some utilities, mostly in cost-recovery regulated markets, are considering new nuclear in integrated resource plans (IRPs). These typically 5-year plans are a necessary step in the public utility commission (PUC) approval process for regulated utilities. IRPs are often represented as multiple pathways and are not firm commitments. For example, Duke, Dominion, Southern, and Florida Power & Light all have experience operating nuclear plants, expect dramatic demand growth, and are in regulated cost-recovery markets. They have hinted at building new plants at existing sites, but have yet to fully commit. TVA, which has been working toward building a 300 MW SMR for years, previously stated that the goal would be to build 20 reactors, not one, but still hasn’t given final approval for the first reactor.

In response to expected demand growth and increasing prices caused by scarcity, industries are trying to solve their own supply problem. Many first-movers are tech companies like Google or Amazon that support new advanced reactor designs. These initial agreements are largely predicated upon the existence of the tax credits, and will evaporate if the credits disappear.

Even if these early projects are built without tax credits, their demand alone is insufficient to achieve scale. The industry will build a few one-off projects and fizzle out. There needs to be a pathway to get utilities that serve most of the load in the U.S. to commit to order books of multiples, very likely through a consortium approach, to ever get to scale and down the cost curve.

Utilities know that long-term operation of nuclear plants provides low-cost, firm, reliable, and abundant electricity. Due to a combination of timing and availability to start building new nuclear, licensing timelines, and first-of-a-kind price point and project risk, there is no guarantee that new demand will simply result in significantly more new nuclear. Most likely, fossil fuels, particularly gas, will scale up faster due to availability and price. Delivery of new gas turbines due to high demand from utilities is now pushed out to 2030.

Dramatic increases in projected electricity demand, and likely rising electricity prices, will result in some market pull for new nuclear deployment. The market will likely wait to see if the demand is durable before committing to a very long-lived nuclear power plant. The result of relying on demand growth alone will be, at the very least, a delay to large-scale deployment.

Resetting the Market, or Failure to Plan?

The last time we were on the threshold of a so-called nuclear renaissance, gas was super cheap and became the primary energy source being built, undercutting and killing nuclear projects. One goal of the current administration’s “energy emergency” is to increase production of fossil fuels and further reduce gas prices. The proposed phase-out of investment tax credits increases the cost for new nuclear builds, driving investment away from nuclear and towards fossil fuels. The IRA credits and the LPO’s loan authority were always going to sunset. This would have moved investments away from nuclear anyway, but the reconciliation bill has an effect far greater than just the money.

It is common to hear people hypothesize that Trump's disruption of markets with tariffs or other EOs will shake things out and settle to a new normal with better terms. This implies some strategy, or at least a fundamental reworking through cutting, slicing, and taping back together.

We actually have a good idea of how the story will end if we return to business as usual for electricity markets of a decade ago. The energy market before the credits and other policy drivers was not conducive to a nuclear build-out. The one project that was completed only did so with the benefit of the 45J credit and LPO. Removing the credits and threatening the capabilities of the LPO reset the market to one that is less amenable to a nuclear buildout. Utilities and RTOs, already slow to commit, will be less likely to assume the risks and costs associated with nuclear. States, and potentially hyperscalers, will assume the mantle of decarbonizing through the deployment of nuclear energy.

Executive orders and declarations of “energy dominance” are not enough to manifest a nuclear fleet. A goal of 400 GW of new nuclear power is unattainable without a strategy, and not just a willing but an eager market. Meanwhile, the U.S. is falling behind international competitors. Instead of plans for plans, nuclear power in the United States needs a dedicated set of policies and an environment that enables the growth of the industry and the deployment of new reactors.

By Spencer Toohill and Adam Stein

On January 20th, Donald Trump returned to the White House as president, marking a new chapter for U.S. energy policy. With growing concerns over energy security, the future of decarbonization, and global competitiveness, nuclear energy sits at an important crossroads.

While Trump has historically championed deregulation and energy independence, his positions on nuclear power have been inconsistent—at times supportive, yet often vague or contradictory. But there are some clear advocates for nuclear power in his inner circle. His pick to lead the Department of Energy, Chris Wright, is notably pro-nuclear. Wright, a longtime oil and gas executive, served on the board of directors of Oklo, a microreactor company, prior to his confirmation. Vice-President J.D. Vance publicly supports nuclear energy—framing it as a reliable and innovative energy solution. And Elon Musk, a long-time supporter of nuclear power but a relative newcomer to Trump’s entourage, has publicly advocated for nuclear power in an interview with Trump himself.

Overall, there are solid signs for a pro-nuclear Trump administration. Trump’s campaign website includes a commitment to modernizing the Nuclear Regulatory Commission (NRC), keeping existing nuclear plants operational and investing in small modular reactors (SMRs). Subsequently, a commitment to shifting energy policy from Biden’s climate-centric priorities to a focus on energy security and competitiveness—as already seen in the pullout from the Paris climate agreement, the pause of IRA and IIJA funds, and the declaration of a “national energy emergency”—will likely privilege nuclear energy in the Trump administration. These signs are now solidified by one of Trump’s most recent executive orders to establish The National Energy Dominance Council, in which Trump has set his sights specifically on SMRs.

But while Trump’s rhetoric about "rapid approvals" and nuclear modernization sounds promising, it is unclear how they will translate into action. The biggest challenge at this moment remains uncertainty. Signals from key political figures and campaign promises offer optimism for new nuclear development, but the lack of detailed policy commitments and clarity on execution leaves stakeholders grappling with questions. Will his administration support or even expand programs like the Advanced Reactor Demonstration Program (ARDP) and those building a domestic nuclear fuel supply chain? How will regulation change at the NRC? Will incentives from the Inflation Reduction Act (IRA) remain intact or be carved up under a Republican majority? Will policy and workforce changes undermine the implementation and execution of the “energy dominance” agenda? Can the nuclear industry actually make significant headway under this administration?

The industry is optimistic but has already put the brakes on several projects due to uncertainty. A rapidly changing landscape doesn’t encourage investment in an 80-year asset. Until at least some of these questions are answered and policy stabilizes, announcements and PR may accelerate, but real progress will slow.

Continued approval and execution of programs in DOE is critical. Alternatively, efforts to cut agency employment—a priority of the newly created Department of Government Efficiency—will slow down the federal support that the industry desperately needs. Federal funding and incentives aimed at new projects could aid deployment exponentially. However, budget priorities are non-specific and the administration is not likely to advocate for federal handouts. These contingencies—coupled with remaining indecision, implicit policies, and implied long-term goals for nuclear energy—could delay critical progress if not addressed swiftly.

In short, the tone from key figures in the administration is promising for nuclear energy, but the lack of specificity and Trump’s track record of unpredictability leave much up in the air. Unpredictability is not what the nuclear sector needs to get moving and may negatively impact private investment in nuclear more than good policy can encourage it. The next few months will be critical in determining whether this moment becomes a turning point or a missed opportunity for nuclear energy in the United States.

Can Improving Efficiency Make Nuclear Great Again?

The Trump administration’s most significant influence will likely come through attempts to improve governmental “efficiency” overall. This could resemble indiscriminate clear-cutting of federal staffing—which would be a bad thing—or a more legitimate reform that modernizes outdated processes and expedites regulatory approvals. If the latter efforts succeed, they could unlock faster deployment of advanced nuclear energy, reduce costs, and position the U.S. as a global leader in nuclear innovation.

When it comes to continued public investment, federal support for nuclear energy programs like the Advanced Reactor Demonstration Program (ARDP) and High-Assay Low-Enriched Uranium (HALEU) development is more likely to survive than the broader clean energy programs. These programs, launched under Trump’s first term, align with Republican priorities around energy security and American industrial strength.

However, it’s unlikely that support under a second Trump administration will match the levels provided by Biden’s Department of Energy. Funding could be reduced, and the scope of federal programs may shift to emphasize more traditional financing mechanisms, like loans or public-private partnerships, rather than outright grants and purchase of fuel using a federally operated HALEU bank.

But make no mistake, the industry cannot afford to lose these programs entirely. The ARDP is critical to getting first-of-a-kind reactors deployed, and HALEU supply remains an urgent issue for the industry. Ensuring continuity in these programs—even at reduced levels—will be a key priority for the nuclear sector in 2025 and beyond.

Still, ARDP and HALEU are more likely to survive than the Inflation Reduction Act’s nuclear incentives—which could still be modified rather than eliminated outright.

Republicans have long criticized the IRA as a bloated spending package, but there’s growing recognition that the nuclear provisions directly contribute to energy security and economic resilience. That said, any disruption to the IRA’s tax credits will have ripple effects across the industry, creating financial uncertainty for advanced reactor developers, slowing deployment timelines, and potentially killing projects outright. The nuclear sector must make a strong case that these incentives aren’t just about clean energy—they’re about securing the nation’s energy future.

But where the Biden administration focused on funding energy technologies, Trump could make progress on improving the regulatory process for new nuclear energy.

If Trump delivers on his promise to modernize the NRC, the time and cost required to get new projects approved could be significantly reduced. Secretary Wright said that the biggest hold-up to building more nuclear energy, by far, has been regulatory. A streamlined, modernized regulatory process would reduce approval timelines, cut costs, and attract more private sector investment. Notably, achieving regulatory efficiency at the NRC does not mean compromising safety—it means focusing resources on measures that demonstrably enhance public safety. Regulatory delays have long been a bottleneck for the nuclear industry; fixing this would be a game-changer.

As an independent agency, it is the NRC Commission that has authority to make changes, not the President directly. The composition of the NRC will, therefore, play a crucial role in shaping the future of nuclear energy. Matthew Marzano was sworn in as a new Democratic commissioner at the end of December, giving Democrats a 3-2 majority on the commission. That, however, may not last long.

President Trump has been busy already. He named David Wright as the new Republican chair to replace outgoing Chair Christopher Hanson. A Republican chair will almost certainly push for changes aimed at making the NRC more efficient and predictable in its licensing process—a long-standing industry demand. Republican commissioners Wright and Annie Caputo both supported the implementation of provisions of the ADVANCE Act. Caputo, in particular, has a strong track record of advocating for risk-informed, performance-based regulation. Wright has signaled firm support for reforms that reduce unnecessary regulatory delays.

The future of the NRC remains in flux, with an updated mission, ongoing efforts to modernize, and many rulemakings behind schedule. Republicans may push for Commissioner Hanson’s departure, allowing Trump to appoint a third Republican and shift the Commission to a 3-2 conservative majority, accelerating regulatory reform. Beyond personnel changes, Trump is pursuing structural reforms—moving independent agencies under his direct control—to drive a more centralized agenda. Currently, the NRC Chair has limited unilateral authority. The priorities of the Chair can be delayed or voted down by a Commission majority. While a move to restructure the agency would require congressional approval, it aligns with Trump’s deregulatory approach. It would also make the agency much more politically volatile, providing Trump more direct influence over regulatory decisions.

Regardless of the outcome, a Republican-led NRC is likely to prioritize efficiency and reducing regulatory barriers, while maintaining the mandate to protect people and the environment. If there is any chance of getting steel in the ground for new nuclear builds during this Trump term, other than ARDP projects that have been in the works for years, then regulators simply cannot take more than three years to issue an operating license.

But will efficiency move the nuclear industry forward? For nuclear energy to truly thrive in the next four years, the United States needs to establish a robust pipeline of projects—what the industry often refers to as an "order book."

An order book isn’t just about new plants on paper—it represents real commitments to build facilities that justifies investment in manufacturing, creates a clear demand signal for the supply chain, and attracts external investment. It is the necessary step to provide the certainty required to move from concept to construction. From paper reactors to steel reactors.

Without an order book, the broader goals of deploying advanced reactors, revitalizing the domestic supply chain, and solidifying nuclear energy’s role in U.S. energy security will remain unrealized.

Let’s Get to Work

Republicans generally favor nuclear energy. Its alignment with their broader goals—energy independence, economic growth, and national security—makes it a natural fit for Trump’s administration.

While the role of nuclear power in decarbonization is significant, its broader strategic value should not be overlooked. Nuclear energy is essential to achieving energy security, safeguarding against geopolitical threats, and enhancing American technological leadership and competitiveness on the global stage. It is fundamental to U.S. energy security and must be treated as a national priority.

Nuclear energy creates jobs, stabilizes energy costs, increases electricity reliability, and reduces reliance on critical minerals. To secure its future, policymakers must prioritize investments that support its long-term growth, ensuring nuclear energy remains a pillar of American economic and strategic strength.

There is an opportunity to advance policies that strengthen nuclear supply chains, accelerate reactor deployment, and expand domestic HALEU enrichment—critical steps for reducing dependence on foreign energy sources and reinforcing national security.

While these arguments are not new, a Republican-led administration may create an environment more conducive to bold action. Despite broad bipartisan support, advancing meaningful nuclear policy in this Congress may require moving beyond a climate-first narrative, which has been polarizing for some.

States—notably, many Republican-led states—are already embracing nuclear energy as a key component of their energy strategies. From Wyoming to Tennessee, red states are leading the way in hosting advanced reactor projects, fostering a culture of nuclear innovation that aligns with their priorities. This state-level enthusiasm is a significant opportunity for the federal government to build upon.

However, this momentum risks being squandered if action is not taken at both the state and federal levels. States must continue to advance supportive policies, such as streamlined permitting processes and incentives for advanced nuclear projects, while the federal government plays a critical role in providing resources and aligning its priorities with those of state governments. Federal support in areas like HALEU enrichment, regulatory modernization, and project funding can amplify state efforts, ensuring that innovative projects move from concept to reality.

The alignment of state and federal goals offers an opportunity to create a unified framework for expanding nuclear energy. Without this coordination, the enthusiasm seen in states may falter, leaving promising projects stranded in red tape or stalled by funding gaps. The path forward requires a partnership that leverages state-level leadership and federal resources to solidify the role of nuclear energy in America’s energy future.

To achieve this alignment, industry leaders, utilities, advocacy groups, and policymakers must use their collective voices to ensure that the NRC develops and implements efficient regulation. With the passage of the ADVANCE Act, there is an opportunity to modernize the regulatory framework for advanced nuclear energy. Success, however, will depend heavily on how stakeholders, industry leaders, and policymakers engage with the NRC.

Regulatory reforms are most effective when informed by those directly involved in the effort to deploy advanced technologies. This includes providing detailed feedback during rulemaking processes, highlighting where current regulations unnecessarily limit public benefits, and demonstrating how alternative approaches can maintain public safety while enabling efficiency. Collaborative efforts among these groups can identify best practices and offer data-driven examples to guide the NRC toward policies that reflect the realities of modern nuclear technologies.

Clear, unified messaging is critical. Stakeholders, alongside policymakers' efforts, can underscore the importance of regulatory consistency and alignment between state and federal priorities, creating momentum for an environment that supports innovation and deployment. Stakeholders must articulate how reforms will maintain rigorous safety standards while addressing urgent challenges like high costs and lengthy timelines. By framing regulatory modernization as a win for energy security, economic development, and global competitiveness, stakeholders, industry, and policymakers can help build a consensus that strengthens public and political support for nuclear energy.

Parting Thoughts

The future of nuclear energy under the Trump administration faces a pivotal moment. Will Trump seize the opportunity to grow the U.S. nuclear industry, or will his administration prove too unpredictable? The outcome over the next four years will have long-lasting implications for energy security, economic strength, and America's role as a leader in nuclear innovation.

For stakeholders in the nuclear energy sector, this is a moment of both promise and peril. Success will depend on turning rhetoric into reality—moving beyond campaign slogans and high-level plans to deliver tangible results. An order book is the starting point, but collaboration among policymakers, industry leaders, and the public will be equally essential.

Ultimately, the nuclear industry must be ready to adapt. Whether it’s navigating regulatory changes, securing funding, or building public trust, this period demands strategic vision and unified action. Now is the time to focus on what can be controlled: creating the conditions for success by advocating for clarity, consistency, and commitment in U.S. nuclear policy.

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