Comment on FR Doc # 2026-09877, NRC-2025-1205-0001, from Amanda Greene

Amanda GreeneOpposeAcademic
Summary: An independent researcher and environmental policy consultant with a background from the Harvard Kennedy School expresses concern that the proposed rule's cumulative regulatory relaxations will result in insufficient oversight. They specifically argue that these changes could negatively impact the safety profile of emerging technologies like commercial fusion energy by locking in weakened protections.
I am writing as an independent researcher and environmental policy consultant (Harvard Kennedy School, 2007) with professional experience in water and environmental regulation. While individual provisions in this proposed rule may represent reasonable modernization, I am concerned about the cumulative effect of simultaneously reducing reporting requirements, lowering financial assurance thresholds for decommissioning, extending testing and calibration intervals, eliminating notification requirements, and creating new licensing pathways with reduced oversight - all under a compressed timeline mandated by Executive Order 14300. This concern is heightened by the fact that the byproduct materials framework is also the regulatory classification being proposed for commercial fusion energy technologies. Relaxing this framework now, before fusion technology is proven or its full safety profile understood, risks locking in insufficient oversight for an emerging energy technology with novel safety considerations including tritium handling and neutron activation of structural materials. The historical precedent of the 2005 Energy Policy Act, which exempted hydraulic fracturing from Safe Drinking Water Act protections and resulted in well-documented community harm with limited accountability, is evidence of the long-term consequences associated with weakening regulatory frameworks to accommodate industry timelines rather than public health needs. I urge the Commission to consider the downstream implications of these changes - not only for the existing uses addressed in this rulemaking, but also for emerging technologies such as commercial fusion — and to ensure that sufficient public health protections remain in place before finalizing these amendments.

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