For a cleaner, more prosperous world, ACC mobilizes conservatives around environmental issues, fostering collaboration in the pursuit of environmental conservation.
March 4, 2026
U.S. Department of Energy
1000 Independence Ave SW
Washington, DC 20585
Response to DOE Categorical Exclusion for Advanced Nuclear Reactors
Docket: DOE-HQ-2025-0405
The American Conservation Coalition (ACC) appreciates the opportunity to comment on the Department of Energy’s (DOE’s) Notice of New Categorical Exclusion for Advanced Nuclear Reactors. ACC is a nonprofit organization dedicated to building the conservative environmental movement, with more than 100,000 grassroots members nationwide. Specifically, we write to commend the DOE for recognizing the expected safety of advanced nuclear reactors and for appropriately streamlining the environmental review process to facilitate their timely deployment.
Introduction
As the largest conservative environmental organization in the country, ACC has long advocated for nuclear energy as one of the safest, cleanest, and most reliable forms of power available today. Meeting the nation’s rapidly rising energy demand, ensuring affordable access to reliable electricity, and reducing pollution will require a renewed embrace of nuclear energy. While preserving existing reactors and restarting retired units where feasible will be important in the near term, it is equally critical to construct new reactors. DOE plays a central role in enabling the construction of advanced reactors, and by swiftly demonstrating and deploying these technologies, the United States can begin to build its nuclear energy future.
Safety Features of Advanced Reactors
One of the primary barriers to deploying new nuclear energy in the United States remains regulatory delay. DOE’s proposed categorical exclusion (CX) for advanced nuclear reactors appropriately reflects the expected safety and environmental performance improvements incorporated into modern reactor designs. Under the National Environmental Policy Act (NEPA), a categorical exclusion is appropriate when a class of actions does not individually or cumulatively have a significant effect on the environment. DOE’s written record demonstrates that, when reactor designs limit the amount of radioactive material on site, incorporate advanced fuel and operational safeguards, and ensure waste is managed in accordance with applicable federal requirements, advanced reactors meet this standard.
Historically, NRC licensing reviews of nuclear projects have rarely found “large adverse” environmental impacts. Where “moderate adverse” effects were identified, they were typically unavoidable construction-related impacts common to large infrastructure projects, rather than risks intrinsic to nuclear technology itself.
Modern reactor technologies incorporate passive and inherent safety features that substantially reduce both the probability and potential consequences of severe accidents. Many designs rely on natural physical processes, such as gravity and passive heat removal, rather than active mechanical intervention. Advanced fuel forms are more resistant to radiation damage, corrosion, and high temperatures, further limiting potential release pathways and extending operator response times in the unlikely event of an incident.
Importantly, the proposed CX is not automatic. DOE must determine that a reactor’s design, fuel characteristics, and operational plans sufficiently limit offsite risk and that no extraordinary circumstances are present. The CX also requires that any radioactive or hazardous waste, including spent nuclear fuel, be managed consistent with existing regulatory frameworks, ensuring that waste considerations remain fully governed by federal law.
Safety improvements in modern reactor designs are well documented. For example, the NRC-certified AP1000 design developed by Westinghouse demonstrates a core damage frequency approximately two orders of magnitude lower than earlier generations of reactors and well below safety goal thresholds established by the U.S. Nuclear Regulatory Commission. This reflects a broader industry trend toward dramatically reduced accident probabilities in newer reactor technology.
Extraordinary Circumstances
While the proposed CX appropriately reflects reactor safety, DOE’s application of the “Extraordinary Circumstances” review warrants clarification. We recommend that DOE clarify how the review will be applied to advanced reactors to ensure it does not function as a backdoor environmental assessment. This should include clear guidance on what qualifies as an extraordinary circumstance and publishing these determinations alongside CX determinations to promote consistency and establish precedent.
Conclusion
ACC appreciates the opportunity to comment and commends DOE for its leadership in advancing a new era of nuclear energy in the United States. By expediting the review of next-generation nuclear technologies, DOE can ensure that these safe and innovative reactors are quickly and safely deployed to secure America’s energy future.