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Dear Sir:

In a well-sourced article entitled “If Radical Innovation Makes Nuclear Power Expensive, Why Do We Think It Will Make Nuclear Cheap,” Mr. Michael Shellenberger posits the thesis that the nuclear industry’s attempts to innovate are responsible for its present travails. I submit that his narrative of nuclear energy’s ascent and decline, while based on factually accurate strands of logic, leads to a conclusion that does not do justice to the range of issues that afflict the industry.The underlying reasons for the industry’s problems are far too complex.

The author cites the innovations introduced by Westinghouse in its AP-1000 reactor to be behind its spiraling cost. This is only partially true; the major cause is the new regulatory regimen known as 10CFR52 adopted by the government which, while well intentioned, has failed to streamline the nuclear plant regulation process in practice. Much of the delay in completing the AP-1000 plants can be attributed to the untested “Part 52” regulations. Imperfect innovations, to the extent they have played a part, can be traced to the erosion of practical know-how which occurred because of nearly three decades of hibernation that the industry suffered in the wake of TMI and Chernobyl.

On a more fundamental level, the safety regulation of nuclear power plants has been on national level with each country’s regulator reigning as its uncontested sovereign. There is no global regulator like there is the International Court of Justice in The Hague. This is peculiar for an industry where a mishap in for instance, Chernobyl, affected millions of citizens in far-away countries in central and Western Europe. This fragmentation of regulatory control has led to uneven regulations and their enforcement. Thus, while the AP-1000s in China are smartly coming on line, the ones in the United States lumber along.

A pernicious offshoot of the uncertainty in regulations is the “cost plus” culture for building nuclear power plants. It is not hard to deduce that “cost plus” contracts dampen the drive for, yes, innovations! Contrast the paucity of robots in the nuclear plant construction industry to the automotive manufacturing industry which is swimming in robots.

There are many drivers behind the nuclear industry’s present difficulties but the quest to innovate is not one of them. Our company, unconstrained by the quarterly report pressure of Wall Street, has invested hundreds of millions of dollars in a new innovative 160 MW reactor we call SMR- 160. Our reactor is brimming with innovations with unconditional safety as its core mission. Our belief in success through innovation is so firm that we are soldiering on without a dime of funding from any government. We are among the small coterie of entrepreneurial companies who believe that creative ideas and innovations tempered with lessons learned from seven decades of nuclear plant operations will deliver bounteous amounts of competitively priced carbon-free energy to a world desperately in need of it.

Very truly yours,

Dr. Kris P. Singh, President & CEO

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