Faculty and researchers from the University of Illinois Urbana-Champaign have submitted a public comment to the U.S. Nuclear Regulatory Commission (NRC) addressing the agency’s proposed rule on “Part 57,” a major regulatory initiative that attempts to modernize U.S. nuclear regulation by creating a dedicated licensing framework for new nuclear technologies, including microreactors and certain advanced nuclear reactors.
The submission reflects a unique collaboration between researchers at the University of Illinois College of Law and the Grainger College of Engineering, bringing together nationally recognized strengths in both engineering and administrative law to address complex regulatory questions with substantial societal consequences.
Led jointly by Professor Arden Rowell of the College of Law and Professor Zahra Mohaghegh of the Department of Nuclear, Plasma and Radiological Engineering (NPRE), the comment combines administrative law, statutory interpretation, engineering risk analysis, and regulatory economics to evaluate the NRC’s proposed framework. George Joslin, a Ph.D. student in NPRE and graduate researcher in Mohaghegh’s Socio-Technical Risk Analysis (SoTeRiA) Research Laboratory, also contributed to the effort.
The proposed Part 57 rule was developed pursuant to Section 208 of the ADVANCE Act and represents a significant step in U.S. nuclear policy. The Illinois team’s submission evaluates whether the NRC’s proposal satisfies the requirements of the Atomic Energy Act, the ADVANCE Act, and the Administrative Procedure Act while also providing a technically and legally defensible foundation for future advanced-reactor licensing.
The comment addresses two central questions: whether the NRC’s proposed safety framework adequately supports the agency’s statutory obligations concerning safety, efficiency, and reasoned decision-making, and whether the agency’s regulatory analysis provides a sufficiently evidence-based assessment of the rule’s costs, benefits, and alternatives. The submission recommends that the NRC continue developing cost-benefit analysis as an important component of implementing the ADVANCE Act’s efficiency mandate while strengthening the evidentiary basis for key safety and regulatory determinations. It also calls for additional legal and technical justification regarding accident-analysis methodologies, cumulative impacts associated with multi-reactor deployment, and the treatment of uncertainty in the agency’s regulatory analysis.
The collaboration reflects a broader research partnership between the College of Law and the SoTeRiA Research Laboratory focused on the future of risk-informed and performance-based nuclear regulation. The work forms part of a larger NRC-funded research initiative examining how developments in reactor technology, probabilistic risk assessment, and administrative law are reshaping the governance of emerging energy systems.
At a time when advanced reactor deployment, administrative law doctrine, and federal regulatory policy are evolving simultaneously, the project demonstrates how interdisciplinary engagement can contribute to more durable and analytically rigorous approaches to public governance.
The comment was submitted to the NRC on June 15, 2026, and is now part of the agency’s public administrative record as the Commission evaluates comments and develops the final Part 57 rule.
