Small Modular Reactors: A Realist

Approach to the Future of Nuclear Power

ROBIN GASTER | APRIL 2025

Standard large nuclear reactors won’t achieve scale or cost competitiveness with alternative
energy sources. DOE should focus its resources on small modular reactors, which are a more
promising technology with the potential to achieve price and performance parity.

KEY TAKEAWAYS

 Small modular reactors (SMRs) are the future of nuclear power, and they could become
an important strategic export industry in the next two decades.

 SMRs must get to sufficient scale so they can become cost competitive with other energy
sources including large reactors, renewables, and fossil fuels.

 DOE needs to develop independent assessment capabilities for SMRs (and other
technologies) that focus on the pathway to price and performance parity (P3). All major
investments must be reviewed through the P3 lens (see box).

 DOE should maintain and expand its strong support for basic and applied nuclear
research through the Advanced Reactor Development Program (ARDP) and DOE’s GenIII+
program, including new test and demonstration sites at INL.

 DOE’s Office of Clean Energy Demonstrations (OCED) must provide critical funding to
help provide commercial viability, and the Loan Program Office (LPO) will need reform
and restructuring to focus specifically on scale-up.

 Nuclear Regulatory Commission (NRC) reform is under way, but more is needed.
Innovation requires iteration, and that requires new thinking. NEPA reform is also
needed, and so is improved interconnection of new energy sources to the grid.

 SMR markets will be global, so NRC and DOE must not ignore international regulation.
United States, Europe, Japan, and other allies can align their regimes to help counter
competition from Chinese and Russian state-backed enterprises.

itif.org
CONTENTS
Key Takeaways ................................................................................................................... 1
Executive Summary ............................................................................................................ 3
Introduction: Why SMRs Could Be Important ........................................................................ 8
What Are SMRs? ............................................................................................................. 9
The Potential for SMRs ..................................................................................................... 11
New Markets for Nuclear................................................................................................ 11
Manufacturing and Economies of Scale: Getting to P3 ...................................................... 15
Shorter and Potentially More Predictable Construction Timelines ....................................... 17
Lower Up-Front Capital Costs ......................................................................................... 18
Low Operational Costs ................................................................................................... 18
Low Life-Cycle Emissions ............................................................................................... 19
Firm Power, Reliability, High Capacity Factors, and Low Systems Costs .............................. 19
Footprint and Siting Flexibility ....................................................................................... 20
Longevity ..................................................................................................................... 20
Avoiding Costly New Transmission Lines.......................................................................... 21
Nuclear Power and National Security .............................................................................. 21
Risks for SMRs ................................................................................................................ 22
Technology Risks for SMRs ............................................................................................ 22
Market Risks ................................................................................................................ 29
Political Risks............................................................................................................... 39
Regulatory Risks ........................................................................................................... 40
Derisking SMRs ............................................................................................................... 46
Nuclear R&D in the United States...................................................................................... 51
Conclusions: Defending and Expanding the Innovation Agenda for SMRs ............................... 55
Innovation .................................................................................................................... 56
Risk and Derisking ........................................................................................................ 57
Regulation.................................................................................................................... 60
Policy Recommendations .................................................................................................. 61
Supporting Further Basic and Applied R&D (TRL 1-3) ...................................................... 61
Supporting Technology Validation, Further Development, and Testing (TRL 3-6) ................. 62
Demonstration and Deployment (TRL 7-9) ....................................................................... 63
Scale-up ...................................................................................................................... 64
Endnotes ......................................................................................................................... 67

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 2

EXECUTIVE SUMMARY
If nuclear power is the future, small modular reactors (SMRs) are the pathway, potentially
offering a flexible, scalable, always-available, potentially cost-effective means of generating clean
energy. U.S. companies are currently at the cutting edge of SMR development and deployment,
but competition from China, Russia, South Korea, and certain European companies is
intensifying. For SMRs to achieve widespread adoption, they must eventually reach price and
performance parity (P3) with conventional energy sources, especially fossil fuels. And to do that,
they need to scale.
Unlike large reactors, initially high SMR costs may fall because they are designed to be built—
partly or completely—in a factory, rather than constructed on-site. Large-scale factory production
can exploit economies of scale and can also lead to faster production, another key advantage.
That is the endgame for SMRs. The question is how to get there, and the role the U.S.
government should play along the way.

It’s useful to think of technology development as following a four-phase pathway, although, of

course, all the boundaries are fuzzy, and not all technologies go through all four phases:

▪ Initial basic and applied research eventually leads to a prototype or the equivalent.
▪ Testing and further development leads to a fully complete design whose components have
been successfully tested.
▪ First-of-a-kind deployment demonstrates that the protype and related components can be
scaled up to commercial size, and the first reactor of its kind can be built.
▪ During the scale-up phase, multiple copies are produced and sold, allowing costs to fall
and eventually the technology to become competitive with existing energy sources. Scale-
up requires finally settling on a design, developing a fully functioning factory, and
building an order book deep enough to support production at scale.
Today, large reactors have reached the scale-up phase but have largely stalled there, and show
no sign yet of successfully reaching P3. There are simply not enough orders in the United States
to generate sufficient scale economies. Proponents hope that a coalescence of orders around the
Westinghouse AP1000 design (which is now a standard model for large reactors) will get large
reactors to scale, but that seems unlikely. SMRs are at a much earlier stage, only now reaching
the end of the testing and further development phase, with leading-edge designs preparing for
first-of-a-kind deployment in the United States and elsewhere.
As a result, we don’t yet know whether SMRs will crack the scale-up problem; that question
cannot be answered for at least a decade. But we can say that unlike large reactors, there is a
greater possibility that SMRs will indeed scale, costs will fall, and P3 will be achieved. This is in
part because SMRs have significant advantages, including that they may be able to expand the
market for reactors very substantially. Because they can be sized from 1 megawatt (MW) to 300
MW or more, they can meet very different needs in different markets. Because some designs at
least are well suited to the production of thermal energy, they can play a role in industrial
decarbonization, and could also align well with desalination. Also, because they are modular,
they can be aggregated to meet the specific amount of energy required. Some designs, for
example those using molten salt and thorium promise cheaper fuel, lower refueling downtime

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 3

requirements and have enhanced passive safety features that further reduce costs. In some
cases, they use different fuels that are less expensive and easier to produce. And in contrast to
wind and solar, they generate energy 24/7. That, combined with being clean, has attracted
significant attention from Big Tech firms looking for power for their rapidly growing data centers.
Of course, first-of-a-kind SMRs are going to be expensive. They will likely cost more per
megawatt hour (MWh) than existing large reactors, and certainly more than competing fuels
(solar, wind, and natural gas). Expensive new technologies that will take a decade or more to
reach scale (if they ever do) are very high risk, and SMRs face four distinct kinds of risk:

▪ Technology risks. Until the reactors are up and running, we won’t know whether in
practice they meet the anticipated specs. Because we don’t have operational experience
yet, SMR technology could fail to translate from the drawing board on pilot projects to full
commercial operation in multiple ways—they could generate less power, use more fuel,
require more downtime; there is a long list of things that could go wrong.
▪ Market risks. SMRs as a business face risks on both the supply side and the demand side.
Aside from the technical risks, SMR companies may find that the competition is more
intense or effective than anticipated; that some assumptions about their supply chain are
wrong; or even that key patents don’t hold up. And of course—as with large reactors—
companies may simply find that producing and siting SMRs is much more expensive than
expected, or takes much longer, or that interest rates shift sharply upward, or indeed that
inflation suddenly hits key inputs. On the demand side, it may be that expected markets
simply don’t materialize, or that there is no market for SMR energy at the price it needs
to charge. It’s hard to predict energy markets a decade out.
▪ Regulatory risks. SMRs must navigate multiple layers of regulation. They need to get their
designs certified for safety (in the United States, by the Nuclear Regulatory Commission
(NRC)). They need to get NRC safety approval for their operating plan for a specific site.
They then need to get site approval via the National Environmental Protection Act (NEPA)
process to ensure that environmental issues have been addressed. That may well also
involve a defense against NIMBY (“not in my backyard”) lawsuits. And as SMRs will need
to scale globally, they will also need to address regulators in other countries.
▪ Political risks. The reality is most nuclear reactor purchases involve national governments
in some way (the United States is perhaps an outlier here, although the U.S. Department
of Energy’s (DOE’s) Office of Nuclear Energy (ONE), Office of Clean Energy
Demonstrations (OCED), Loan Program Office (LPO), and other programs will still be key
enablers for nuclear). Government commitments to nuclear power have been subject to
intense political conflict in some countries, leading to reversals, as in Germany, and to a
double reversal and then reapproval in Japan. Government support will likely be critical,
but governments can also be fickle. And in the United States, while there now appears to
be a growing bipartisan consensus at the federal level in support of nuclear power, that is
not the case at the state level, where environmental concerns, NIMBY issues, and waste
management continue to generate opposition.
It is therefore not surprising that derisking has been at the heart of policy discussions. How can
governments mitigate or perhaps even eliminate these risks in ways that don’t simply shift them
entirely onto the backs of taxpayers?

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 4

It’s helpful to consider risk mitigation in terms of financial and nonfinancial risks, as the related
policies are quite different.

Financial risk mitigation means finding ways to share risks between different stakeholders,
including vendors (that sell reactors), constructors (that build plants), utilities (that usually own
them), lenders, ratepayers, large end users, state and local governments, and national
governments (and their taxpayers). Just listing the stakeholders indicates the complexity of
possible risk-sharing models.

These stakeholders can also support nuclear construction through a wide variety of mechanisms.
In the United States, funding comes from three primary sources: government grants for research
and development (R&D) and eventually deployment; tax credits for either investment or
production (Investment Tax Credits (ITC)/Production Tax Credits (PTC), with the latter currently
set at $30/MWh; and—potentially though not yet in reality for SMRs—loan guarantees from LPO.
Other countries are using or exploring quite different approaches. The U.K. government has
effectively been forced to become the owner of a plant being built at Hinkley Point, so taxpayers
are largely on the hook there. The United Kingdom is also exploring rate-asset-based support,
where ratepayers are required to pay a contribution during the construction period rather than
just paying for electricity. In Finland, cooperative structures link vendors, construction
companies, utilities, and large end users. In several European countries, Contracts for Difference
(CfD) provide flexible operating subsidies that are tied tightly to market conditions, offering
government subsidies where operating costs are higher than market prices. Many government
have provided loans at below-market rates, while in Asia in particular, China has offered very
attractive funding packages for new nuclear plants. The United States could clearly benefit from
reviewing these options in a systematic way and aligning them with a much stronger emphasis on
P3 assessment.
On the demand side, risk mitigation usually involves a long-term power purchase agreement
(PPA), wherein a utility or large end user will agree to buy power at a more or less fixed price for
a fixed number of years (often as long as 20 years). PPAs are effectively mandatory for large
reactors; lenders will not take the risk of simply funding a huge speculative project. They will
likely be mandatory for large SMRs, for the same reason. Microreactors—20 MW or less—may
however be different; the amounts at stake are smaller and some microreactor companies aim to
build and operate reactors themselves, simply delivering energy to clients.

The U.S. model for financial risk mitigation emerged largely because it was the approach that
could get through Congress at the time, not because it was clearly the best approach. Indeed, it
has many weaknesses especially over the long run, if only because it is exceptionally vulnerable
to political risk.
Mitigating nonfinancial risks is also important. Technological risk is being mitigated by the close
alignment between SMR companies and the National Labs, which provide critical expertise and
capabilities in the form of facilities that can be shared by different SMR companies. Simulation,
modeling, and physical test sites are all important, and can play especially helpful roles both at
earlier stages of R&D and later in preparing designs for NRC certification. While this work is not
glamorous or particularly visible, it is an important building block for the U.S. nuclear sector,
and it would be devastating over the medium term if this work were not fully supported. Indeed,

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 5

as SMR opportunities expand, it is likely that more SMR companies and designs will emerge, and
they too will need access to and support from Idaho National Laboratory (INL), Oak Ridge
National Laboratory (ORNL), Pacific Northwest National Lab (PNNL), and Argonne National
Laboratory (ANL).
There are nonfinancial production risks to consider also. For example, many SMR designs require
enriched uranium fuel (High-Assay Low-Enriched Uranium (HALEU)), and that supply chain is
both global and insufficient. DOE is working on this, but other companies will likely have to
follow TerraPower and cut their own deals with foreign entities and governments.
Regulatory risk is still substantial, despite recent efforts at NRC, where a new rulemaking aims to
provide an optional alternative path for safety and operational certification for advanced reactors,
replacing the existing model designed for existing GenIII large reactors. This pathway will
however not be operational until at least 2027, although the current exemption-based process
seems to be working better than SMR companies initially expected. More worrying, there has
been no public discussion of a pathway for iteration: innovative products do not usually reach the
market without substantial iteration and tweaking, or even full-scale pivots, and we simply have
no idea how NRC will address a world that is so different from the “design once, build often”
world that it is encouraging for large nuclear reactors. And regulatory risk is not limited to NRC:
NEPA plays a significant role in delaying infrastructure projects (including SMRs), although fairly
radical amendment is increasingly likely. State policy too impacts deployment, although
antinuclear feeling is reversing, and this is being reflected in changes in state regulations for
nuclear.
There are plenty of other regulatory concerns as well. SMR transportation and siting will be
regulated and will likely need different approaches than those used for large reactors, and so will
waste streams, all of which are in some state of flux.

Based on this analysis, the U.S. government has plenty still to do to support SMR development.
Key recommendations cover the following areas:

▪ Expanded funding for basic and applied research. The Advanced Reactor Demonstration
Program (ARDP), which spans several phases of development, has clearly been successful
in supporting SMRs. Early funding—through this program or others—is critical, especially
for a newly emerging sector such as SMRs; the discovery phase for this technology will
require significant help in the form of grant funding and access to National Labs
expertise and capabilities.
▪ Testing, certification, and further development. At this stage of development, new nuclear
technologies are a decade or more from deployment at scale. They are therefore high-risk
technologies, and federal funding in the form of matching grants will be crucial, as will
access to testing and validating facilities at the National Labs and support for beginning
the regulatory pathway.
▪ First-of-a-kind commercial deployment. This critical step marks the conclusion of the
research and testing phase and the beginning of commercialization. Despite the missteps
of OCED under the Biden administration, OCED funding will be absolutely critical for
SMR deployment at this stage. We strongly recommend that OCED be reset to focus only
on technologies that have reasonable prospects of reaching P3, but that support should

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 6

 be renewed and possibly expanded. DOE must also fully accept the need for much
improved transparency across contracts, milestones, and both technical and economic
outcomes from supported projects. Public funding should generate publicly available
results.
▪ Scale-up. Here too existing mechanisms will play a key role. LPO should also be
reoriented, mandated to focus explicitly on scaling up promising new technologies that
are within reach of P3. It should avoid funding projects on either the supply or demand
side that have no pathway to sustainability, and subsidies should be explicitly designed to
support projects in reaching scale and hence P3. Subsidized loans and tax credits are,
however, not the only mechanisms available; the administration should explore multiple
alternatives including, for example, risk tiering, the use of CfD, and vertically organized
consortia.
▪ Regulation is key to SMR success. NRC must both find ways to reduce the time lag before
designs are certified and—especially critical for SMRs—develop ways to support design
iteration, a key feature of innovation. Distinguishing between iteration that has safety
impacts and those that don’t will be central, and NRC will also have to make significant
strides in certifying factory-built reactors (and components) and addressing the need for
new approaches to waste management and the transportation of SMR reactors,
components, and fuel. SMRs will also need resolution of the current problems with
interconnection, but it seems likely that these may be addressed before SMRs reach
scale-up. Finally, international regulation matters; SMRs must work within global markets
to achieve scale, so DOE should work to align certifications and safety regulations with
other regulators.
SMRs are a promising technology with the potential to reach P3, in contrast to standard large
nuclear reactors, which will not achieve scale or cost competitiveness with alternative energy
sources. DOE should therefore focus its nuclear resources primarily on SMRs.

Box 1: Price/Performance Parity: “P3”

Climate change is global, so solutions must be global. In particular, they must meet the needs of
low-income countries where demand for energy is rising fastest, and where ability and willingness
to pay a green premium is low to nonexistent.
There is no evidence that forcing change with regulation, subsidies, or exhortation will work.
Low-income countries will not adopt clean energy at the expense of growth. Neither will richer
countries.
The market is the only lever powerful enough to drive the transition at the scale needed—and it
will only work when clean energy technologies can outcompete dirty ones without subsidies or
regulations. They must reach P3. 1
Renewable energy is inherently variable. To succeed, especially in lower-income countries,
Variable Renewable Energy (VRE) must deliver with reliability and costs that are broadly similar
to fossil-generated energy. The United Kingdom recently announced that it is the first
Organization for Economic Cooperation and Development (OECD) country to halve its emissions
by effectively replacing coal-fired power generation with wind and solar. Nuclear and gas have
remained largely constant over the past decade, but gas has now become the backup to VRE.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 7

INTRODUCTION: WHY SMRS COULD BE IMPORTANT
SMRs are clearly having a moment. Publicly traded companies such as Oklo and NuScale have
seen both recent stock booms and several major investment announcements, and Big Data
companies are buying into or supporting a range of SMRs as a partial solution to their energy
needs. The new secretary of Energy, Chris Wright, is an investor in and board member of Oklo,
and is clearly a fan of growing nuclear, having written when he was CEO of Liberty Energy,
“Nuclear appears to be the most viable option to add sizable new energy resources in the coming
decades.” 2
DOE’s liftoff report is remarkably optimistic, and more generally, nuclear proponents have argued
that using a standardized design (e.g., Westinghouse’s AP1000) and building a series of reactors
using that design will reduce costs, as a trained construction workforce can be employed for
multiple projects, and projects benefit from learning by doing across an increasing number of
projects. 3 DOE’s report also notes other potential cost drivers such as reduced capital costs and
of course clean energy subsidies from Biden administration programs.

These arguments, however, fly in the face of experience with the construction of large reactors.
Between 2002 and 2017, 11,833 MW of U.S. nuclear generating capacity closed or announced
retirement (11.9 percent of U.S. nuclear capacity), mostly because of unfavorable market
conditions. 4 There are no major new reactors under construction or in review by regulators in the
United States today, and the most recent completed plant, at Vogtle in Georgia, came in years
late and massively over budget. 5 More generally, the cost of constructing large nuclear reactors
has increased significantly in recent decades, partly because components have become much
more expensive (notably steel and concrete), partly because no settled design has emerged, and
partly because safety regimes and regulatory burdens expanded sharply after Three Mile Island
and Chernobyl. 6 But the fact is recent construction of large nuclear plants in the United States
and elsewhere has suffered from dramatic cost overruns and delays. As a result, no large nuclear
plants are planned or under construction in the United States. Planned nuclear plants in Europe,
meanwhile, are a response to the need for energy security in the face of Russian aggression, plus
a stronger commitment to clean energy even if it costs more.
Initially, SMRs will likely cost as much per kilowatt as large reactors do, or perhaps even more.
But SMR companies have developed to the point that they are close to commercial deployment
in the United States (and elsewhere). Investment is pouring into the sector, and innovative new
SMR companies are popping up like mushrooms after a rainstorm. Why?

SMRs do have plenty of potential ancillary advantages—site flexibility, size flexibility,

modularity, possible new markets—and of course, like big reactors, they offer reliable baseload
energy 24/7. But most important of all, SMRs could generate clean reliable power much more
cheaply than large reactors if major components or the entire reactor (for smaller SMRs) can be
manufactured in a factory, not on-site, which could open the door to economies of scale and
declining costs. That promise is driving interest in SMRs, and Deloitte has identified more than
150 SMRs in development around the world. 7
However, right now, there are only two commercially operating SMRs, one in Russia and one in
China. Only three designs have been approved for construction by NRC. Investments and hype
are fueled by the promise of SMRs, not the current reality. However, innovative new designs are

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 8

emerging very rapidly, ranging in size from 1 MW to more than 300 MW, including new
technologies, new configurations, new fuels, and new production systems.

This report explores the case for and against SMRs, and offers policy pathways that would give
SMRs their best shot at making it to scale in the United States, becoming relevant in reality and
not just in theory. Even though public views on nuclear are getting steadily more popular, they
have a long way to go, and they will need a lot of help along the way, but it is potentially a very
important technology.

What Are SMRs?

SMRs generate power just like other reactors—by using a nuclear reaction to heat a liquid that
then generates steam, which in turn powers a turbine that creates electricity (see box 2). Today,
SMRs are being developed with different technologies that offer variations on this theme, using
different fuels, different coolants, and new safety features.
All SMRs have three key characteristics that differentiate them from standard large reactors: they
generate lower levels of energy (usually defined as 20–300 MW, compared with large reactors
that typically generate 1,000 MW or more) (reactors generating 20 MW or less are
“microreactors”); they are modular in that multiple SMRs can be hooked together to provide the
necessary level of power for a particular application; and they are designed to be made at least
partly in a factory, rather than completely built on-site like large reactors.
Smaller scale and modularity make SMRs more flexible and hence a potential option for different
applications, while factory production offers the tantalizing prospect of mass production and the
potentially radical decline in cost that might bring.

Although there are around 150 SMR companies worldwide, most offer no more than designs on
paper. To become relevant globally, the SMR sector must go through the discovery phase to
figure out which technologies and business models are winners and which are not, and both are
still in flux. For example, at least six quite different designs are being developed (figure 1).
SMRs have plenty of promise, which is why Google, Meta, and Amazon are all exploring their use
to power data centers. To become fully relevant in the green transition, SMRs will need to
traverse the discovery phase of technology development quite quickly, settling on only a few
dominant designs and companies. That’s necessary if SMRs are to exploit the promise of factory
production, and perhaps then generate true economies of scale. But as shown later in this paper,
getting to scale will take time, lots of investment, and plenty of government help.

Box 2: Generating Nuclear Power Using Pressurized Water Reactors

Pressurized Water Reactors (PWRs) operate on two isolated coolant loops. In the primary loop,
water under intense pressure (15–17 megapascals (MPa)) flows through the reactor core, heating
from 290°C to 325°C while remaining liquid. Main coolant pumps circulate this water through
steam generators, where heat is transferred via tube walls to a separate secondary coolant loop.
In this secondary loop, the water boils into steam at 6 MPa, then expands through the turbine to
near vacuum (0.008 MPa). This pressure drop drives the movement of steam through the
turbine-generator assembly, producing electricity.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 9

Figure 1: SMR Reactor Types 8

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 10

THE POTENTIAL FOR SMRS
SMRs are a powerful energy source that generate no carbon emissions from operations; they are
energy dense; they can be constructed flexibly; and—like wind and solar—costs could decline
significantly as they gain scale. But that’s just the start. This section describes in more detail
some of the advantages that SMRs might develop over both large reactors and competing
energy sources.

New Markets for Nuclear

Because they are smaller and modular, SMRs may be able to expand into or develop new
markets, across several dimensions:

▪ Geography. SMRs can go where large nuclear cannot. They could be used for off-grid and
remote applications, for sites close to population centers, for locations where other clean
power sources would require a lot of expensive transmission infrastructure. Atomic Energy
of Canada Limited, for example, is developing a very low-powered SMR that can run for
15 years without refueling. 9
▪ Industries. SMRs could support industrial decarbonization applications across many
industries, as they can be located closer to existing industry clusters or—for
microreactors at least—actually on-site. Entire new industry segments with distinct
energy needs could open up: data centers, for example. And new approaches to existing
needs are also potentially significant: SMRs could, for example, provide district heating,
and could also power container ships. 10
▪ Scale. SMRs can operate at scales from 1 MW to 1,000 MW or more because they are
modular and hence stackable. Therefore, SMRs could work for applications that require
300 MW, for example, while standard large nuclear plants are usually around 1,000 MW.
▪ Existing infrastructure. SMRs don’t need a strong existing grid to distribute power, so they
have applications in regions with weak or nonexistent grids, or where demand is growing
faster than the grid can manage (especially in fast-growing low-income countries).
▪ Load following power. TerraPower emphasizes that, unlike large PWR reactors, which
provide baseload power, its Natrium reactor uses molten salt energy storage; that could
open the door to use as variable power, especially as a complement to wind power. That
is in part the motivation for its first plant in Wyoming.
Some of the relevant potential markets are shown in table 1, although all of these are just
“potential” markets right now, and SMRs will need to avoid the “Swiss Army Knife” problem:
being the second- or third-best solution everywhere. But there are significant opportunities.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 11

Table 1: Potential markets for SMRs

Potential Markets Examples

Developing economies with ▪ India, Indonesia, Philippines, and South Africa are attracted to
growing energy needs SMRs’ lower up-front capital costs, limited infrastructure demands,
smaller physical footprint, and potential for incremental expansion.

Maritime and transportation ▪ Floating nuclear power plants, maritime propulsion systems
applications
▪ E.g., Russia’s floating nuclear power plant and emerging designs for
maritime nuclear propulsion.
▪ Nuclear submarines have demonstrated some options.

Countries seeking energy ▪ Countries around Russia seeking to avoid dependence on Russian gas
security and oil

Countries needing to ▪ Countries such as Japan and the United Arab Emirates
diversify energy sources

Big data ▪ SMRs are a potentially important option for owners of data centers
that require large amounts of very reliable energy, clean if possible.

Industrial process heating ▪ SMRs generate heat as well as power and can be located close to end
users or on-site.
▪ E.g., desalination, synthetic and unconventional oil production, oil
refining (for use in >700°C)

Remote communities and ▪ Remote mining operations

off-grid applications
▪ Military bases and installations
▪ Off-grid communities
▪ Island nations

Developed economies ▪ U.S. utilities may see SMRs especially as a way to replace coal with
seeking green transition low emissions while maintaining grid stability.
▪ E.g., the Tennessee Valley Authority and NuScale Power.

A 2014 study in the United Kingdom estimated that the global market for SMRs could be 65–85
gigawatts (GW) annually by 2035 (assuming that they are economically competitive). 11 And
TerraPower’s vision is explicitly focused on bringing competitive SMR power to developing
countries: “This century, we would expect to see hundreds of Natrium reactors deployed around
the world in nations that don’t even have nuclear today: nations in sub-Saharan Africa, where
there’s tremendous population growth, or in Indonesia where we think Gen IV technology will
be ideal.” 12

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 12

SMRs for Data Centers
Much of the recent excitement around SMRs is built on the rapidly growing demand for firm,
reliable energy for data centers. Even before the explosion of demand for artificial intelligence
(AI), data centers were growing rapidly in the United States (and elsewhere), helping to transform
electricity trends from decades of flat demand to significant projected growth. Demand from data
centers is now expected to turbocharge that growth, and major data center owners are scrambling
to find the substantial new electricity supply that will be needed.

The structure of electricity markets in the United States makes nuclear an attractive proposition,
for two main reasons. First, it seems unlikely that huge new demand from data centers can be
accommodated by existing sources of electricity supply. Amazon’s efforts to acquire priority
access to the Susquehanna nuclear plant has been rejected by the Federal Energy Regulatory
Commission (FERC), and while lawsuits are ongoing, it appears that Big Tech companies and
other data center owners have accepted that they will likely have to bring their own power
sources rather than simply using electricity from the grid, as regulators will likely not allow
utilities to disadvantage existing customers in favor of this new demand, so new generation must
be built. In tight electricity markets, the sudden withdrawal of a significant part of electricity
supply for data center use would cause substantial and persistent spikes in the price of grid
electricity, and that will likely not be permitted.

Second, grid interconnection is a problem on two fronts. It currently takes on the order of five
years for FERC approval for interconnection to the grid. And grid connections carry a substantial
per-MWh cost in terms of fees and taxes. So avoiding interconnection where possible is
attractive—and SMRs or nuclear more generally offers a good solution if nuclear can provide
electricity at a reasonable price and within a reasonable timeframe. Evidence so far suggests that
data center operators are willing to pay a substantial but not exorbitant premium for new nuclear
energy, whether it is SMRs that will enter service in the next decade or refurbished existing large
reactors that can be reactivated for use more quickly.
All the Big Tech companies have signed nuclear power agreements of some kind. Amazon is
investing $700 million in X-energy and SMR deployment in the Northwest United States; Google
is funding Kairos; Microsoft has agreed to a 20-year PPA that will pay for the restart of a reactor
at Three Mile Island. Meta has released a Request for Proposal seeking 1–4 GW of nuclear
power. Google, Microsoft, and Nucor are working with Duke Energy to build a data center next to
Duke’s Surry nuclear plant. Oklo is partnering with RPower to provide a hybrid solution that
offers gas generation until Oklo’s SMRs can be deployed.
Moreover, data center buyers seem especially likely to fund innovative new ideas. They may offer
a uniquely helpful combination of very deep pockets, need for reliable 24/7 clean power, long
timeframes, and a willingness to accept risks. Endeavor Energy, for example, has signed a deal
with Deep Fission to power its expanding fleet of data centers with energy from 2 GW of SMRs
located one mile underground. 13

Markets for Thermal Power

Unlike wind and photovoltaic (PV) solar, nuclear power generates heat as well as electricity. That
heat can be used directly in various industrial processes, or perhaps for district heating, and is
especially relevant to SMRs, which could be sited near industrial end users, opening up potential

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 13

new markets. Figure 2 shows both the range of potential heat industrial processes that could use
nuclear power and the temperature range of existing and emerging nuclear technologies.

Some high-temperature applications will probably not be served by nuclear energy (e.g., glass
and cement manufacturing), but others are potentially accessible targets, especially for high-
temperature gas reactors (HTGRs), which generate very high levels of heat. Emerging new
technologies—gas-cooled fast reactors (GFRs) and molten salt reactors (MSRs) in particular—
may operate at high enough temperatures to be useful for the chemicals sector, petroleum
refining, and pulp and paper production. Both GFR and MSR technologies have been proposed
for SMRs.
Figure 2: Temperature ranges of heat application processes and types of nuclear power plant 14

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 14

Desalination
Given the obvious need for clean water in many parts of the world and the growing pressure on
water resources, desalinization will be a critically important technology. SMRs and desalination
could be a very good fit.
Most analysis of SMRs is based on the assumption that they will provide firm baseload energy.
That is a natural consequence of SMR economics: because reactors are so capital intensive and
so reliable, it makes sense to run them at the highest possible capacity factor. That’s why
nuclear power plants usually run at well over 90 percent capacity today. But SMRs could work
differently: They could be linked both to a grid and to a desalinization plant, supplying energy to
the grid when demand (and hence prices) is high, and redirecting energy to the desalinization
plant when demand (and grid prices) is low. The desalinization plant could also be the offtaker
for energy when the grid has no use for it at all (i.e., when the grid curtails the flow of energy
from the plant to the grid). This alignment would put a floor under the price for reactor energy
(the price at which desalination makes sense) and guarantee high capacity utilization even if grid
demand fluctuates.
In effect, the desalinization plant would be an economic battery attached to the SMR, storing
excess energy in the form of clean water when grid prices are low. Of course, the same strategy
could be applied to other energy technologies such as solar or wind, and the growing curtailment
of clean energy in California may provide a real-world test of this opportunity. However, the siting
advantages and other flexibility features of SMRs mean that if this model works out
economically, it could be applied in areas where excess solar, wind, or both are not so easily
found, and especially where water is a scarce resource. For example, a Texas consortium is
exploring nuclear for desalination at the Texas Tech SMR cluster. 15
Several new technologies are also emerging for desalinization, some of which use heat-based
desalination (evaporating water to lose contaminants such as salt). It seems quite plausible that
nuclear plants—especially those using high-temperature technologies—could be well suited for
this approach. 16

Manufacturing and Economies of Scale: Getting to P3

Factory manufacturing and scale are critical SMRs: Without reaching scale and driving down
costs, they have no future. Getting there involves settling on a technology, finding enough
customers initially willing to pay a premium, and then successfully exploiting factory production,
which does not necessarily require millions of units annually. Boeing builds approximately 500
planes per year on its production lines, and can build them vastly cheaper than if it built them
one at a time.
Because SMRs have not yet been produced in a factory, we have only educated guesses about
cost savings. And because many variables play a significant role in eventual costs—including the
technology adopted, the size of the plant, and financing methods and costs—estimates are
unlikely to be accurate.

Wright’s Law
Still, in the context of SMRs, the literature provides useful estimates of potential learning effects
from scale. In the 1930s, Theodore Wright found that the cost of aircraft production at Boeing
fell 10–15 percent each time production volume doubled. 17 This is known as Wright’s Law. It

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 15

has held up fairly well (to different degrees) across other industries (e.g., solar and batteries) and
seems a reasonable rule of thumb for scaling nuclear as well; the United Kingdom’s National
Nuclear Lab used it in a report for the U.K. Parliament in 2014, for example. 18 Other studies,
however, offer more pessimistic conclusions, as Wright’s Law is not a fixed constant, and
doubling the installed base for a technology does not inevitably reduce costs by a fixed
percentage. 19
The potential impact of Wright’s Law on the cost of SMR electricity is shown in figure 3, which
shows two hypothetical learning rates (LRs)—at 10 percent and 4 percent—for an SMR starting
at $0.14/kilowatt (KW), with one initial unit deployed. The chart shows hypothetically that a 10
percent learning curve reduces the cost of electricity by around two-thirds as deployment reaches
256 units, at which point SMRs would be a competitive energy source. These curves show just
how important the learning rate will turn out to be—something we won’t know for at least two
decades. They also underscore the critical role of scale in cost reduction.
Figure 3: Hypothetical scale economy curves for SMRs
16

14
4% LR
Cost of electricity (cents/KWh)

12

10

8 10% LR

0
1 2 4 8 16 32 64 128 256
Number of 100 MW units produced

How Quickly Can Demand Scale?

We are really talking about two distinct markets at least, one for quite large SMRs (perhaps 100
MW+), where costs and deployment limitations suggest that it will take several decades before
256 units are deployed, and smaller SMRS and microreactors, where take-up could be much
faster and where companies are planning to roll out large numbers of units annually (Copenhagen
Atomics, for example, anticipates that it will be building plants in multiple countries; each plant
is expected to produce more than 300 units annually, and the company aims to eventually
deliver reactors at a levelized cost of energy of $20/MWh—well below the cost of competing
technologies for new build plants, including gas). 20

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 16

Even if we hypothetically begin rollout with three SMRs deployed in their first year of operation,
30 years of 10 percent compounded growth in deployment will generate a total of only 53
deployed units; growth rates would have to reach more than 15 percent annually to 256 units
within 30 years. Of course, early-stage growth could be much faster—the current excitement
suggests that it will be. So, while sufficient scale is possible, it could take considerably longer
than a decade of rapid growth for SMRs to reach P3 with competing fuels, especially for
larger SMRs.

What Will the Rate of Cost Decline Turn Out to Be?

Looking directly at the process improvements available, several detailed studies show how
different components of SMRs can be modularized for factory production. One study, for
example, estimates that full modularization alone can reduce overnight capital costs by more
than 40 percent—and also that the opportunities are greater for smaller reactors. 21
Another detailed analysis suggests that 60–80 percent of SMR production by value could be
accomplished with a factory. 22 That in turn could allow for the application of advanced
manufacturing techniques such as electron beam welding and diode laser cladding. 23 It has also
been claimed that because SMRs are smaller, they can become more standardized in that there
is less need to adapt to local conditions. But this remains unproven.
It’s worth noting that larger SMRs likely will to be completely built in a single factory.
TerraPower’s 345MW Natrium reactor will have all its large components built by fabricators in its
factories, and those components will then be assembled on-site and lowered into the ground to
their final position. TerraPower still expects to build hundreds of reactors, so component-level
economies can become substantial if they succeed. 24
A high rate of production has other advantages. Workers (both white collar and blue collar)
remain employed, and their experience will help drive learning rates. And SMRs can design in
features that could reduce the cost of production in other ways. Passive safety features enabled
by SMRs (which have a higher surface-to-volume ratio than large reactors do and consequently a
lower need for additional features such as large cooling towers) could cut containment costs
substantially, while fuels can be designed to be lower costs (e.g., molten salt using thorium).
It’s also worth noting that because SMRs are still in the discovery phase, we don’t even know
what factory production will look like. For example, both Core Power in the United Kingdom and
Blue Energy in the United States are looking at converting shipyards to SMR production, aiming
to build reactors for sea-based deployment. 25
To summarize, we do not yet know how all the excitement about declining cost curve and factory
production will translate to the real world. But low-cost nuclear power via SMRs has a foundation
both in the history of technology and in the specifics of SMR production, and is a tantalizing
possibility.

Shorter and Potentially More Predictable Construction Timelines

If SMR production can become standardized to include a substantial factory-built component,
that should shorten construction timelines significantly. Optimistic SMR companies claim to
expect deliveries and operations in 2–4 years, not the 7–10 years or more that’s now standard
(at best).

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 17

Lower Up-Front Capital Costs
While SMRs have not yet proven that they can generate energy at a lower levelized cost (per
MWh) than large nuclear plants (or other competing energy sources), they will definitely require
less capital expenditure up front. First-of-a-kind construction is expensive, but even so, a 300
MW SMR facility will require much less up-front capital than a standard 1,000 MW nuclear plant
will. Even if overnight costs for first-of-a-kind construction are $10,000/KW (similar to the cost
of recent large plants in the United States and Europe), a 100 MW SMR would require on the
order of $1 billion in overnight costs, rather than the $10 billion potentially needed for a 1,000
MW plant. 26 Lower capital investments mean lower risks, and create opportunities for projects
financed from a wider range of partners.

Low Operational Costs

A survey from the Nuclear Energy Institute indicates that both operational and fuel costs for
nuclear reactors have been falling fairly steadily in the United States, and amounted to about
$24/MWh in 2022. 27 That’s similar to data from the U.S. Energy Information Administration
(EIA), which compares operating costs for nuclear, gas, and hydroelectric power (see figure 4).
Fuel and operating costs for combined cycle gas turbines (CCGTs) (the most widely used and
cheapest gas technology) vary based on factors such as the price of gas, the turbine technology
being used, the maintenance schedule, and even the ambient temperature. Typically, fuel
accounts of 60–70 percent of CCGT operating costs, and fuel costs—perhaps especially gas—
can spike unexpectedly, as they did in Europe after the Russian invasion of Ukraine. Operating
costs for gas have historically been at least $4/MWh more expensive than nuclear (and are
currently just over 20 percent more expensive). However, it is also possible that new kinds of fuel
for SMRs will be more expensive, at least initially, especially ais most currently propose to use
HALEU, which requires more-expensive processing.
Figure 4: Operating costs per MWh for selected technologies in the United States 28
$50

$45

$40

$35 Gas turbine and small-scale

$30

$25

$20 Nuclear

$15

$10
Hydro-electric
$5

$0
2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 18

Low Life-Cycle Emissions
SMRs produce zero greenhouse gases from operations, so their life cycle emissions come from
mining and enriching uranium and also the construction of SMRs. Emissions from large nuclear
reactors are far lower than those for fossil fuels, and are around one quarter those of solar. It’s
reasonable to expect that life cycle emissions for SMRs will be roughly similar. Critically,
therefore, SMRs offer clean power—much cleaner than fossil fuels do (see figure 5). If they
didn’t, there would be little reason to pursue them.
Figure 5: Average life cycle of carbon dioxide (CO2) emissions (grams of CO2 equivalent per KWh) 29

Wind (onshore) 11

Nuclear 12

Wind (offshore) 12

Hydropower 24

Concentrated solar power 27

Geothermal 38

Solar PV (rooftop) 41

Solar PV (utility scale) 48

Biomass (dedicated) 230

Gas (combined cycle) 490

Coal (PC) 820

Firm Power, Reliability, High Capacity Factors, and Low Systems Costs
In sharp contrast to wind and solar, nuclear plants are extremely reliable—they provide firm
power that’s available almost all the time: their capacity factor averages 92.5 percent in the
United States, far higher than other energy sources (see figure 6). 30 That offers certainty about
electricity supply, which is especially important for certain users. Data centers offer their
customers contracts that guarantee more than 99.9 percent uptime; they will need
correspondingly reliable energy sources to meet that level of performance.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 19

Figure 6: Capacity factor by U.S. energy source 31

Solar 25%

Wind 34%

Coal 40%

Hydropower 42%

Natural gas 57%

Geothermal 74%

Nuclear 93%

Downtime for reactors is almost entirely predictable. (Almost! France recently suffered
unexpected problems with some of its reactors, as did TVA in the United States.) Downtime is
usually caused by scheduled maintenance or refueling time (about every 18 months for large
reactors, lasting about a month). SMRs are designed to require less-frequent refueling (or swap
out): mostly every three to seven years, depending on the design. Refueling outages should
therefore be less frequent, and capacity utilization correspondingly higher.
Further, unlike wind and solar, power output from nuclear is highly predictable. Adopting
nuclear—either large reactors or SMRs—can reduce the need for balancing capabilities such as
banks of lithium-ion batteries for short-term storage, or the use of natural gas to address long-
term variation. 32 The additional system costs for nuclear are much lower than those of wind and
solar as well, especially as transmission costs may be lower because of siting flexibility.

Footprint and Siting Flexibility

Both wind and solar require a large land footprint. Of course, the United States has a lot of land,
but a PV solar plant generating 1,000 megawatt electrical (MWe) would require 5–10,000 acres,
depending on location, according to the National Renewable Energy Laboratory (NREL). 33 A
similar-scale nuclear plant would require only about 640 acres. And SMRs have a much smaller
footprint than large reactors; for example, a proposed NuScale 920 MW plant would require
about 35 acres. 34 A radically smaller footprint also opens the door to a much wider array of
potential sites.

Longevity
Nuclear plants last far longer than any other source of energy except possibly hydro. We are
seeing plants lasting beyond 60 years now, and it seems likely that, for some at least, the
operating lifetime is 80 years or more, based on research on nuclear plant sustainability
conducted by DOE. In December 2019, NRC staff approved a renewal application for Turkey
Point Nuclear Units 3 and 4 in Florida, allowing operations until 2052 and 2053, respectively—
the first time NRC extended a plant lifetime to 80 years. 35 This could transform the financing of
nuclear plants; longer lifespans reduce the average lifetime cost of energy by spreading the heavy

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 20

capital costs of nuclear plants over a much longer period of operation. In contrast, CCGT gas
plants have a nominal lifetime of 25–30 years. 36 However, it remains to be seen whether SMRs
last as long, especially as there may be trade-offs between longevity and higher temperatures.

Avoiding Costly New Transmission Lines

The need for new transmission lines has become a major concern in the United States as well as
other countries such as the United Kingdom, where curtailment caused by lack of transmission
has become a real problem. The United Kingdom generates most of its wind energy—which is
quickly becoming the dominant source of power for the grid—in Scotland and the north of
England, while most demand is in the south. As a result, Scottish wind farms were paid £1.4
billion in 2023 to not produce electricity because there was no room on transmission lines to the
south. The new state-owned U.K. grid operator estimates the cost of grid expansion to fix this at
£40 billion pounds annually through 2030 (the gross domestic product (GDP) equivalent of
about $360 billion annually in the United States).

New transmission lines are needed for many reasons: they make the grid more reliable and
resilient by interconnecting regional grids, and that could also help to balance the variability of
wind and solar, and to provide markets for variable power that may be produced hundreds of
miles away from eventual users (as in the United Kingdom). But the United States currently
builds only a fraction of the transmission lines it already needs for these purposes. The
interconnection queue waiting for approval at FERC is currently five years long, while the UK
example shows how expensive building out sufficient transmission might be. 37
SMRs could avoid both the cost of transmission, by collocating them with end users such as data
centers, and by avoiding the FERC interconnection queue by locating them “behind the meter”
(i.e., entirely off the public grid). Those avoided costs are major benefits not captured in simple
formulations focused on the immediate levelized cost of energy production. 38 Hence, the interest
from data centers.

Nuclear Power and National Security

Civilian nuclear power plays a minimal role in U.S. national energy security; domestic fossil fuel
reserves are enormous, and the United States has substantial (and by global standards,
reasonably efficient) wind and solar resources as well. Civilian nuclear power plays a much more
prominent role in national security for other countries, as it offers the promise of independence
from energy sources that can become too expensive or unreliable. The Russian gas crisis after the
invasion of Ukraine underlines the fragile state of energy security in much of Europe.
Unsurprisingly, countries around the periphery of Russia—Romania, Poland, Hungary, Czech
Republic, Finland, Slovakia—are exploring or building new nuclear reactors. Slovakia, Czechia,
and Hungary already depend on nuclear for at least one-third of their energy supply.
▪ Poland is buying three reactors from Westinghouse (at $16 billion), and three more from
South Korea’s KHNP. It aims for a 30 percent nuclear share in the energy supply mix.
▪ Hungary is building on nuclear links to Russia, expanding the Russian-built Paks site
with two new 1,200 MW reactors (estimated cost: €12 billion, but now years behind
schedule). This is partly a like-for-like replacement for existing capacity.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 21

 ▪ Czechia aims to phase out coal by 2033, replacing it in large part with nuclear by adding
one or possibly two reactors to the existing Dukanovy plant, plus two more reactors at
Temelin. The first contract has been let to KHNP.
▪ Slovakia recently completed a new 471 MW reactor at Mochavce (under construction
since 2008), and another unit is planned this decade.
▪ Romania is adding two 700 MW units at Cernavoda (estimate cost $8 billion), for
completion in 2031. The engineering contract has been signed with Canyu. The
Romanian state is providing a full guarantee of costs, as well as operating subsidies via a
contract for difference. A joint venture with NuScale is exploring an SMR at Doicesti.
In this context, it is perhaps not surprising to hear that “Romania is taking firm steps towards
energy independence and becoming a net energy exporter,” according to then-PM Nicolae
Ciuca. 39 More generally, provided that the nuclear supply chain can be globalized away from
dependence on Russia, nuclear power offers significant national security benefits: the energy
effects of Russia’s invasion demonstrate to these countries the need for more energy autonomy
very clearly. Those benefits could apply to SMRs once they are price competitive with large
nuclear reactors.

RISKS FOR SMRS

The dramatic cost overruns and delays on recent large nuclear projects in the United States,
United Kingdom, France, and Finland explain why building nuclear is regarded as a high-risk
operation. A lot can go wrong, and capital costs are huge to begin with. Risk therefore provides a
useful lens through which to explore the challenges facing SMRs.
Investors in SMRs face four kinds of risk:

1. Technology risks are inevitable as companies introduce new technologies to the market.
Sometimes technologies just don’t work as expected.
2. Market risks can be divided into supply-side risks (the possibility that a company will be
outcompeted, or that critical supply chains will fail, for example) and demand-side risks
(e.g., the possibility that expected markets will not materialize at the right price, or
perhaps at all).

3. Political risks reflect the reality that—as Germany and Japan demonstrate—the political
appetite for nuclear power can change, sometimes dramatically.

4. And because nuclear power is tightly regulated, there are substantial regulatory risks as
well, especially as the regulatory pathway for SMRs is not yet well defined.
All these risks are real, as the main U.S. nuclear contractor (Westinghouse) can confirm (it went
bankrupt in 2017).

Technology Risks for SMRs

SMRs have already divided into two broad technology pathways. Some companies, such as
NuScale, have decided to use existing technology scaled to the needs of their smaller reactors; it
uses existing PWR technology. That’s partly why NuScale has already had its design certified by
NRC. Others (e.g., Copenhagen Atomics) have opted for more innovative non-PWR designs

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 22

(Copenhagen is based on molten salt as a coolant). However, even reactors using PWR
technology will need significant innovation such as helical coil steam generators, internal control
rod drive mechanisms, new in-vessel instrumentation, and perhaps new fuel combinations and
configurations. 40
In contrast, alternative technologies offer a range of potentially significant performance benefits
beyond possibly lower long-run costs:

▪ Higher operating temperatures potentially increase efficiency (reducing fuel costs and
increasing output per reactor) and could allow for more uses for industrial heating and
thermal applications more generally.
▪ Potential for improved fuel utilization that would reduce fuel consumption, which in turn
reduces fuel costs and—perhaps more important—extends the period before refueling
(and hence downtime) is needed. Innovative SMRs may use different fuels altogether:
molten salt breeder reactors can for example use thorium instead of uranium, and can act
as a breeder reactor using spent nuclear fuel (SNF) from other reactors.
▪ Lower operating pressures would potentially reduce containment requirements and hence
both construction costs and perhaps regulation-related compliance costs.
▪ Some designs offer inherent proliferation resistance by using fuel formulated in ways that
are resistant to easy extraction and would require considerable further processing before
they could be used for weapons.
These new designs are likely to be higher risk. They do not have decades of use behind them,
and the technology trade-offs pale in comparison to the primary risk: that the design will not
work as expected, and will either fail or require substantial revision (and associated delays). That
risk is lower for SMRs based on well-understood existing technology; advanced design SMR
companies are betting that the benefits of new designs will outweigh the additional risks. We will
find out who was right sometime in the mid-2030s.

Is Enough Iteration Possible?

Today, SMRs are at a stage of development roughly analogous to the U.S. auto industry in
1900—when there were more than a thousand companies making autos, using multiple
technologies, in a frenzy of experimentation. By the early 1930s, internal combustion engines
(ICE) had won out over electric and steam, the industry had consolidated into three dominant
companies (Ford, GM, and Chrysler) plus a handful of others, and mass production led by Ford
had opened the door to the cheap cars that drove the American Dream. To get there, the 1,000-
plus auto companies operating in 1900 raced to iterate—new designs, new technologies, new
ways of manufacturing, new marketing strategies.

In SMRs, not only are there no clear winning companies yet, but also the basic technology has
not yet been defined. In 1900, steam-powered cars outsold ICE and electric vehicles, but we all
know what happened after that. 41 Today, SMR designs include at least four different kinds of
coolants, for example, and multiple different fuels among many other varying design choices. We
still don’t know what the SMR equivalent of internal combustion will be.

Further, there are clear tensions between innovation and cost certainty. In order to find the best
technologies, markets, and solutions, SMRs will need to innovate—probably many times. But

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 23

innovation is the enemy of replication and hence scale: Building the first of a kind is both more
expensive and riskier. The experience with nuclear more generally shows that the path to reduced
cost is through focused exploitation of a selected technology which can be replicated and (for
SMRs) manufactured rather than stick built.
Clients have clearly gotten the message, and nuclear power suppliers are now being forced to
address this tension. EDF, the French national champion in nuclear energy, has now abandoned
years of work on innovative SMR designs and will return to PWR technology to meet the demands
of its customers who require certainty that energy will be produced at a levelized cost of €70–
€100/MWh. To do that, it will use only proven technologies. 42

Box 3: Early Auto Industry Technology Innovations in the United States

In the first three decades of the 20th century, the auto industry developed and then adopted
scores of important innovations, including the following:
 Electric ignition starters: Invented in 1911 and made standard by the late 1920s, these
allowed drivers to start the engine with a button instead of a manual hand crank.
 Drive-in service stations: The first drive-in opened in Pittsburgh in 1913, offering services
such as lubrication, tire repairs, and washing.
 Automatic transmission: The Sturtevant brothers of Boston developed an early automatic
transmission in 1904.
 Air-cooled engine: General Motors developed an air-cooled engine with copper fins to
disperse heat for the 1923 Chevrolet.
 All-steel body: This innovation was adopted by the Dodge Brothers in 1914.
 Hydraulic brakes: These were invented in 1919 and first adopted by Duesenberg in 1921 to
replace mechanically actuated drum brakes.
 Synchromesh transmission: This easier-shifting device was invented in 1924.
 New pyroxylin-based paints, eight-cylinder engines, four-wheel brakes, and balloon tires:
These innovations were the biggest trends for 1925. 43

Iteration is also difficult in a tightly regulated environment, as every significant design change
will presumably need to be approved by the NRC, and could potentially reopen NEPA litigation
pathways. This will tend to make SMR iteration slooooow. And because it takes many years to
deliver even first-of-a-kind reactors, cross-pollination between companies is also drastically
slowed. Hydraulic brakes were invented in 1918, and had become industry standard a decade
later. It’s hard to believe anything similar will occur so quickly for SMRs.
Finally, it is not clear how the NRC will handle iteration. In general, reactor designs are tightly
specified, and only those exact designs are approved when replicating. It is not obvious how the
NRC would even begin to think about what is a “significant” design change and what is not,
especially as regulation has moved toward a probabilistic model where cascades of small
problems are seen as important. However, if all design changes are important, then any change
could perhaps trigger the need for NRC review and potentially recertification. Of course, firms
will need to do their own due diligence on safety, but we don’t know how much extra work will be

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 24

demanded by the NRC. It’s also possible that AI will play an important role in the development
of simulations to carry some of the regulatory burden.

Transporting SMRs
The point of SMRs is that they are at least in part built in a factory. Smaller microreactors could
perhaps be built entirely in a factory and then loaded onto a large tractor-trailer for transport.
Larger ones will be partly built on-site. Rolls Royce’s huge 470 MW SMR is in part built using
Rolls’s turbine manufacturing skills and technologies in a factory. But it will require 2,000
container loads to deploy, and will then be assembled on-site. Microreactors, in contrast, can be
designed around the limitations of a single large container-sized truckload.

Transportation for small nuclear reactors is not new. Eighty-three nuclear powered ships and
submarines are currently operated by the United States, for example. Submarines seal radiation
behind a heavyweight barrier at an aft bulkhead while allowing radiation to escape in other
directions (into the sea—hence, divers cannot safely operate while the reactor is running).
Nuclear powered aircraft carriers are essentially small floating cities, big enough to accommodate
the enormous amount of shielding and the multiple layers of safety provisioning that are
required. 44 There have been smaller experiments as well: The U.S. Army built truck-mounted
reactors in the 1960s (the ML-1), but that project failed. It is now trying again with Project Pele.

Box 4: The U.S. Army’s Portable Nuke: The ML-1

The ML-1 was an experimental mobile nuclear reactor developed by the U.S. Army in the early
1960s, featuring a unique design: a nitrogen-cooled, water-moderated reactor with a nitrogen
turbine energy conversion system.
It was engineered to be highly portable, transportable in six containers weighing approximately
38 tons total. It could be moved by C-130 aircraft, trucks, or rail. Its low weight, however, meant
reduced protection, and it required humans to stay 500 feet away.
The ML-1 project faced significant technical challenges. The experimental heat engines
generated only two-thirds of planned power output. There were other issues as well: poor
compressor performance, cracked moderator water tubes, and failure of internal regenerator
insulation. The project was ultimately abandoned due to increasing Vietnam War expenses,
budget constraints, technical difficulties, and caution regarding premature field testing. 45

SMRs face several transportation challenges, including:

▪ potential mechanical stress during transportation;
▪ radiation shielding during transit;
▪ securing nuclear materials against potential accidents or external threats; and
▪ maintaining reactor integrity during movement.
The physical challenge of transporting reactors. SMRs range from 20 to 300 MW—one third to
1/50th the size of large reactors. 46 But even the smallest are still large pieces for equipment.
Trucks are the most flexible and cheapest form of transportation for reactors but face significant
size constraints. 47 Trains and barges can handle much bigger equipment in one trip, but are far
less flexible. Barges can work only where the infrastructure is available to offload heavy
machinery. Trains work only where there are train tracks. 48 Both still require additional

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 25

transportation after delivery, in most cases. Vessel size determines whether a reactor can be
transported in one piece. The 77 MW NuScale VOYGR SMR modules are smaller than many SMR
designs, but will still weigh 700 tons in total, and must be shipped in at least three different
segments. 49
DOE’s nuclear fuel management program has funded development of new railcars for
transporting SNF to the consolidated interim storage facility. The railcar project took 10 years to
complete and cost approximately $33 million before receiving regulatory approval. 50 It is also
providing $16 million for R&D of containers specifically designed for transporting HALEU fuel.
Presumably, this research will be completed in time to meet demand when HALEU SMRs
become commercially available. 51

Security in transit. The transportation of a nuclear reactor presents new security vulnerabilities.
SMRs may be fuel loaded before transit, and there will (if successful) be many SMRs on the
move, so there will be a lot more nuclear material in transit to protect.

Radiation leakage is the greatest risk from the transportation of SMRs. While most SMRs will be
transported in pieces and fueled on-site, some will be fabricated and fueled in a factory. 52
Radiation exposure for those reactors must be limited to safe levels throughout transit, but the
NRC and the International Atomic Energy Agency (IAEA) have yet to provide meaningful
guidance, and DOE does not appear to have committed to following IAEA’s international
standards on nuclear packaging covering its composition, material categorization,
documentation, and labelling. 53
The U.S. Environmental Protection Agency (EPA) is the regulator for nuclear transportation (once
it meets a threshold of radioactivity). Highly radioactive packages must be encased in specially
designed casks that are tested against extreme accident conditions (e.g., being dropped from 30
feet in the air, or onto a steel spike, or burned in a gasoline fire for 30 minutes, or submerged in
water for eight hours). 54 However, EPA has not yet offered even draft regulations for SMRs, and it
is not even clear whether a fully fueled reactor should be regulated as a reactor (and hence
perhaps by NRC) or as a fuel package to be regulated by EPA. The former would be a new
approach for regulators.
The transportation of SMR fuel is a source of additional concern. Because the HALEU fuel
required by most new SMRs is more highly enriched than fuel used in large PWR reactors, new
packaging for that fuel will likely be necessary. 55 It is not yet clear how IAEA—or U.S.
agencies—plan to adjust existing transportation regulations for these new more radioactive
technologies. 56
Transportation issues have been largely avoided by SMR companies in their public statements,
while regulatory agencies are just beginning to address SMR-specific issues in transportation.
Radiation risks, size and mobility, security, cost implications, and regulatory peculiarities are just
the tip of the iceberg, suggesting that there will be a lot of work to do, even though nuclear fuel
and nuclear waste have been transported across the United States for many years, and the
absence of nuclear incidents suggests that these regulations are effective.

How Will SMRs Handle Their Waste?

Nuclear waste will vary substantially depending on the nuclear technology used and a company’s
design (see figure 7). Broadly, nuclear waste is divided into three categories: low-level nuclear

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 26

waste (LLW or Class C); intermediate-level waste (known as “greater than class C waste” or
GTCC); and high-level nuclear waste (HLW). 57 LLW can include protective clothing and
equipment (e.g., gloves, coveralls, and shoe covers); filters used to clean air and water systems;
tools and instruments used in reactor maintenance (e.g., wrenches, gauges, and monitors); and
materials from decommissioning as plant systems, structures, and components are removed,
including concrete, piping, wiring, and metal structures, all of which may become contaminated.
GTCC waste includes used fuel from commercial nuclear power plants, from radioactive medical
waste, industrial and research activities, and from DOE itself (especially from nuclear armaments
and the cleanup of legacy facilities).
Figure 7: SNF generated by different kinds of reactors 58

As of 2024, there were four U.S. intermediate disposal sites that could take LLW that is not
suitable for local disposal. LLW from advanced reactors (including SMRs) should be
accommodated within these four sites. In May 2024, NRC issued a proposed rule that would
authorize the near-surface disposal of some GTCC, but there has been strong political opposition
to constructing a facility, particularly from the governors of Texas and New Mexico. Currently,
DOE needs congressional action before it can move forward on GTCC disposal, under the Energy
Policy Act of 2005. 59
HLW includes both SNF and waste products from the reprocessing of that fuel. 60 The United
States, under intense political pressure, has abandoned efforts to build an HLW facility at Yucca
Mountain in Nevada. However, other countries are moving forward.

Finland’s Onkalo repository is the first HLW site to begin trial operations. Originally designed to
accommodate 6,500 tons of SNF, it has since increased capacity to 9,000 tons, and new

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 27

tunnels will be constructed in parallel with operations. 61 In France, the Cigéo project aims to
store waste in a 500-meter-deep clay layer, and should be operational by the late 2030s. 62
Canada’s Nuclear Waste Management Organization is developing a repository expected to open
by the 2040s, with site selection now completed in partnership with local communities. 63
Sweden’s Forsmark repository will encapsulate waste in copper canisters and then store it in
bedrock. It will have 500 tunnels at 500-meter depth, with the capacity to store 12,000 tons of
SNF. It is designed to last 100,000 years. Construction has been approved, but will take
approximately 70 years to complete. Other countries such as Slovakia are looking to Sweden’s
approach as a model. 64
Hungary, Bulgaria, and the Czech Republic are also making progress. Hungary is expanding its
geological disposal plans, while Bulgaria is exploring deep borehole technology. 65 The Czech
Republic is reviewing sites for a final repository, with a decision expected by 2030. 66
In contrast, Germany and Belgium are struggling. Germany is looking for ways to store
approximately 28,000 cubic meters of HLW. A search for a final repository began in 2013, but a
location decision is not expected until at least 2074, with construction expected to take another
20 years. 67 Belgium has begun construction of a surface disposal facility in Dessel for LLW and
GTCC but has not found permanent storage for more hazardous materials. 68 The Netherlands is
not expected to commit to a final disposal site until around 2100, focusing instead on storing
HLW from its Borssele nuclear power plant in solidified glass containers. 69
China has 46 nuclear reactors currently operating, with 11 more under construction. It will store
high-level waste in a stable geological formation 500–1,000 meters underground, and is
expecting construction of a final repository around 2050. 70 Industrial-scale disposal of LLW and
GTCC occurs at three sites, the first phase of five planned regional disposal facilities. 71
China is also exploring a closed nuclear fuel cycle strategy wherein SNF is first stored and then
reprocessed for use in fast reactors. It operates a pilot reprocessing plant in Gansu, and is
partnering with France to build a new plant capable of producing mixed oxide fuel for PWRs.
China is also exploring fast (breeder) reactors; construction of the first commercial unit (1,000–
1,200 MWe) could start in December 2028, with operations expected in 2034. 72
In the United States, NRC is still seeking a deep geological repository for permanent storage. But
no such facility exists for commercial nuclear waste, and none is currently under development
since the collapse of the Yucca Mountain project in 2010. The only operating deep geologic
disposal site in the United States is the Waste Isolation Pilot Plant (WIPP) in New Mexico,
created to store defense-related transuranic waste. WIPP experienced a major accident in 2014,
leading to significant delays and repair costs. Estimated costs to fix the facility are up to $2
billion, and full operations cannot resume until a new ventilation system is completed—perhaps
in 2026. 73
In the absence of any permanent deep geologic sequestration site, SMR companies are
developing plans to store SNF indefinitely in interim storage facilities that they will build on-site.
TerraPower and X-energy have both submitted relevant plans to NRC for approval, which suggests
that this could be a model at least for larger SMRs. 74 DOE has also announced plans to develop a
federal consolidated interim storage facility for SNF, with an initial capacity of 15,000 metric

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 28

tons (with expansion potential). 75 However, it is much less clear how SNF will be managed for
much larger numbers of microreactors.

Overall, while significant progress has been made in certain countries, the safe, permanent
disposal of nuclear waste remains a pressing challenge across Europe as facilities fill up and new
solutions are developing slowly. The United States has essentially abandoned efforts to find a
permanent deep geological storage facility for HLW, and is focusing instead on intermediate
storage.

For SMRs in particular, there appears to have been minimal thinking about waste disposal, in
part because locations have not yet been decided on. SMRs that use standard fuel will
presumably fit within the basic schema currently being operated by DOE, with waste stored at
interim facilities. Some more-innovative designs may generate substantially less waste, and in
particular less HLW. MSRs, for example, could be designed as breeder reactors.

SMRs and Security

The cost of security for nuclear reactors is nonlinear. Protecting a 1,000 MW site is not 10x
more expensive than protecting a 100 MW site, and that in turn is not 5x the cost of protecting a
20 MW site. Some critics have argued that these nonlinear costs will make SMRs relatively more
expensive. While most site-level security costs are hidden behind corporate privacy, analysis
suggests that for large nuclear sites, direct security costs account for roughly 5 percent of annual
operating expenses. 76
Aside from providing for physical security, SMRs can also be less-attractive targets for
acquisition and capture—they can use lower levels of uranium enrichment and can also make
fuel extraction very difficult (e.g., by integrating fuels into other materials). But they may still be
targets for destruction, acting as a kind of radiation bomb for bad actors. Site-level security is
therefore another area where regulators and companies will have to develop suitable programs
and metrics specifically for SMRs.

Market Risks
SMEs face substantial risks on both the supply and the demand side of the market.

Supply Side
Supply-side risks encompass all the possibilities on the production side that could lead an SMR
company to be outcompeted and eventually fail. In part, these risks are a story about the
competition, to which we will return shortly. But they is also a story about construction.

Construction Risks
Bluntly, the construction of large nuclear plants has been a story of relentless overpromising and
under-delivering, of construction that takes much longer and costs much more than expected.
The time to construct a large reactor grew from around 5 years during the 1960s nuclear boom
to more than 10 years. That led to a tripling of overnight CapEx in real terms. 77 It is now
estimated that Sizewell C in the United Kingdom will cost £40 billion for 3.2 GW of power—up
from £16 billion at inception. French, Finnish, and U.S. plants have suffered similar though not
as extreme delays. Even in France, where nuclear is the largest source of power and where EDF
has been building plants for decades, costs have ratcheted up significantly. More broadly, a 24-
month delay in plant construction is associated with about a 10 percent increase in the levelized

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 29

cost of energy. 78 Thus, SMRs operate in a world where the likelihood that nuclear construction
will be delivered late and well over budget is a very present risk.

SMRs should avoid some of this construction risk, as they are partly or wholly built in a factory
and then simply delivered and installed on-site. This process should be much shorter overall than
large nuclear construction. Of course, SMRs still need containment and control structures, and
connection to the grid, but the cost of the actual reactor might be cut substantially. However,
that does not mean SMRs can entirely avoid construction risks: the failure of NuScale’s pilot
project in Utah is explicitly tied to inflation in construction costs (see box 5).

Box 5: NuScale’s Failure in Utah

NuScale’s proposed flagship SMR project in Utah has closed because it became uneconomic, as
the projected cost of construction increased by 75 percent (to $9.3 billion) between 2021 and
2024. As a result, the estimated cost of electricity per MWh increased from $58 to $89, even
after including a $30/MWh subsidy under the Inflation Reduction Act (IRA).
NuScale is seen by industry critics as the canary in the SMR coal mine, arguing that the most
advanced commercial deployment for SMRs in the United States has failed, and therefore SMRs
are a failure. This seems premature at best.

Scaling Risks
For SMRs to reach P3, they must scale, and costs of production must fall dramatically. One
primary market risk is that this promise simply will not be fulfilled. Any of the following could
happen:
▪ No single company gains enough market share to build an order book sufficient to justify
factory production. It’s also possible that the SMR market as whole will not reach that
level of production.
▪ Factory production doesn’t generate the necessary savings. Just saying “factory” isn’t
sufficient. Production lines don’t have to churn out millions of copies to be efficient at
reducing costs—Boeing only makes about 500 planes a year. But companies do need
enough throughput to justify setting up a production line. And then that production line
has to generate real cost reductions.
▪ Learning by doing—one important component of cost reduction—delivers less savings
than expected. We won’t know until we get there, but the assumptions and related results
in DOE’s Liftoff report seem ambitious. 79
▪ The factory-built share of total cost doesn’t contribute enough to cut overall costs
sufficiently. Ironically, as the cost of factory-built reactors falls, the importance of other
costs rises. It was massive increases in the cost of cement and steel that primarily sank
NuScale’s first-of-a-kind demonstration project in Utah.
▪ Supply chain problems derail production. DOE is well aware that constricted supply of
uranium could squeeze out SMRs. TerraPower, for example, has already delayed
deployment because it could not get sufficient access to HALEU fuel (it has since made
new agreements with South African sources). 80

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 30

In short, factory production is doing a lot of heavy lifting in the anticipated reduction in SMR
costs; so far, there is no data against which to assess these projections.

The Competition Is Too Strong

Beyond costs, competitive energy technologies offer a different supply-side challenge. In the
United States, that competition comes from multiple directions:

▪ Gas. Natural gas is by far the cheapest source of firm 24/7 power in the United States.
It’s relatively quick and simple to build more CCGT and peaker plants, and natural gas is
almost ubiquitous. However, this is largely a U.S. phenomenon. Europe is suffering
because gas is expensive and it is largely dependent on flows from Russia. The latter may
be mitigated by more liquefied natural gas imports, especially from the United States,
but those won’t be cheap.
▪ Coal. While coal is cheap, it is clearly on the way out—but only in the United States and
perhaps Europe. Germany is turning to coal for dispatchable power when its wind-based
generation fails. In India and China, coal use is growing rapidly, and remains the
cheapest form of energy—and hence the most formidable competitor—in much of the
developing world.
▪ Large nuclear reactors. It’s possible that, in the end, SMRs won’t have significant cost
advantages over large reactors. Big reactors do have economies of scale in site
construction and operations. Those could perhaps more than balance out reactor cost
advantages for SMRs, even if cheaper factory-built reactors become a reality.
▪ Other clean energy. Wind and solar are widely expected to eventually dominate the energy
matrix. While their total system costs must include necessary storage and often new
transmission (both costs that are often ignored by wind and solar enthusiasts), energy
from wind and solar is cheap now, and getting cheaper.
▪ New technologies. There are promising new technologies on the horizon that could provide
firm dispatchable energy, notably geothermal and fusion. Geothermal could become
important within a decade, if the initial results from Fervo prove out.
▪ Transmission. If out-of-area energy from across the grid became cheaper and more
available, the need for localized firm power would decline, reducing the market incentives
for SMRs.
▪ Batteries. Similarly, continued rapid cost declines and capacity growth for batteries—
perhaps especially in combination with improved transmission—might also make SMRs
less competitive.
▪ International competition. Nuclear construction is currently dominated by China (CNNC),
Korea (KEPCO), and Russia (Rosatom). China currently has 58 reactors built and 29
under construction. Rosatom is expanding into 13 countries. And KEPCO is building
plants in the UAE and countries near the border with Russia. These are all large reactors;
Russia and China are working hard on SMRs as well. 81
It’s worth noting that the competition in each of these areas is not standing still; wind and solar
and batteries, for instance, are all still getting cheaper. And evidence from the U.S. nuclear

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 31

investment winter of the late 1990s indicates that financial investors seek to avoid exposure to
performance risk for nuclear plants. 82

Can Costs Fall to P3?

The eventual sustainability and success of SMRs hinges on the cost of the energy they can
eventually provide. The promise of SMRs is that they will become cheaper at scale via a
combination of factors: 1) multiple production of essentially identical units; 2) increased factory
production and learning; 3) reduced construction schedules; 4) plant design simplification; and
5) unit timing. 83 We hope that those factors do drive down SMR costs. But because only two
SMRs are currently operating at commercial scale, and they are in Russia and China, we have no
actual operating data with which to work.
We do know a few things though:

▪ Diseconomies of small scale. While the case for SMRs is based on the potential to make
all or large parts of each reactor in a factory, thereby generating genuine economies of
scale, existing large nuclear plants will in some ways be cheaper than SMRs. The cost of
control, operating, and safety does not scale linearly; it is not 10 times more expensive
for a 1,000 MW reactor than for a 100 MW reactor. So per unit of energy, these nonlinear
costs are higher for SMRs. 84
▪ First-of-a-kind penalty. All the companies currently racing to get operational must pay the
additional cost for implementing a first-of-a-kind reactor. The academic literature says
that this is likely to be around 20 percent, but it could be much higher, especially if
genuinely new designs are being implemented (e.g., not using pressurized water
technology). 85 And costs do not magically then sink to nth of a kind (NOAK) as some
proponents seem to suggest: costs decline along a curve as scale increases, steeply at
first and then more gradually. The 2nd of a kind reactor will be cheaper, but probably still
a lot more expensive than the 10th and then the 100th.
▪ The baseline cost of nuclear. SMRs will not just need to match the costs of large nuclear
plants; they will have to become much less costly. Large plants have become more
expensive in recent years—cost disasters have struck in the United States, United
Kingdom, Finland, and France; only Chinese and Korean firms seem able to build large
reactors at an overnight cost of approximately $4,000/KW, or $4 billion for a standard
1,000 MWe reactor. And even that is not directly price competitive—building equivalent
gas generation costs around $775/KW, while similar costs for solar are $1,500/KW (not
including batteries and other system costs), although assessing the levelized cost of
energy for any fuel is an exceedingly inexact science once the cost of required
complementary system investments are included. 86 And SMRs face an obvious chicken
and egg problem: costs must come down very quickly to attract customers, but they can
only become cheaper through scale, which requires sales.
▪ Contingency costs. Because construction costs for large nuclear plants have massively
exceeded estimates, and SMRs are in any event a new approach, there are real risks that
costs of construction and deployment will balloon, and deadliness will be missed. There
are ways to insure against this, but the experience to date on contingency costs and
delays with large nuclear has made it very unattractive to investors. 87

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 32

 ▪ Transitioning from a project to a product basis will be critical for cost reduction. Once
projects are completed, project teams typically dissolve. Products are managed
differently, with sustained management and workforces. SMRs will need to get beyond
project structures into products as quickly as possible.
▪ Cost of capital. Nuclear plants are highly capital intensive, so their overall costs are
sensitive to the cost of capital. The Nuclear Energy Agency (NEA) estimates the projected
impact of interest rate changes on the eventual cost of electricity produced, and it
substantial. For example, a shift in interest rates from 4 to 8 percent leads to an increase
in levelized cost of energy from <$60 MWh to more than $90 MWh. 88
▪ Getting to scale. Any detailed cost estimates at this stage of development are on shaky
ground. But there are some indicators. A well-designed effort to estimate first-of-a-kind
costs, using a set of 16 industry experts, produced overnight costs for a NuScale-type
reactor that ranged from $4,000/KW to $16,300/KW. 89 A 2016 report to the U.K.
Parliament developed estimates for “optimism bias” in the anticipated overnight capital
costs submitted by SMR vendors ranging from 54 percent to 200 percent (varying also by
technology). 90 The uncertainty increases substantially when considering Nth-of-a-kind
costs decades into the future.
More generally, nuclear costs are uncertain, as nuclear power construction times and costs have
grown, not declined.
Bearing all this in mind, the following is true:
▪ SMRs could become cheaper than large reactors, but will initially most likely be at least
as expensive per MWh.
▪ Wright’s Law suggests that learning curves could eventually bring SMRs down to the
region of P3, but this will require substantial scale. The standardization, modularity, and
factory production of SMRs open the door to lower costs, but they have yet to be
demonstrated.
▪ Scale will require that specific technologies win out (as the e.g., the ICE did in autos). It
also requires that at most a few companies become dominant.
▪ There will be a tension between the need to get to scale and the need to innovate. MSRs,
for example, have some significant advantages but are also more corrosive, while SMRS
based on existing PWRtechnology s may get to market faster and hence damage the
chances of other technologies reaching scale.
▪ Overall, initial costs of a first-of-a-kind reactor, plus increases in the cost of materials and
the lack of an experienced workforce, mean that SMRs will initially be at best on par with
the costs of large reactors. It is still too early to determine how costs will evolve from that
point, although production at scale, use of passive safety features, an experienced
workforce, and modularity will all tend to reduce costs. 91
Can SMRs Build a Robust and Cost-Effective Fuel Supply Chain?
There will be challenges both in sourcing uranium and in enriching it so it can be used by SMRs,
especially if SMRs do in fact scale.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 33

 ▪ Sourcing. Russia, Kazakhstan, and Uzbekistan account for 48 percent of total uranium
sourcing for the United States (see figure 8). Building a strategic industry on the back of
this supply chain seems risky. But finding alternatives will take time—especially given
the difficulties of developing domestic uranium resources. TerraPower, for example, has
announced that it will delay its Natrium SMR project in Wyoming because it’s been
forced to switch its supply chain from Russia to new sources in South Africa. 92
▪ Enrichment. Most planned SMRs will use more highly enriched uranium known as HALEU,
which is enriched to between 5 and 20 percent. Centrus—the main U.S. producer—has
noted, “A full-scale HALEU cascade, consisting of 120 individual centrifuge machines,
with a combined capacity of approximately 6,000 kilograms of HALEU per year, could be
brought online within about 42 months of securing the funding to do so.” 93 But that’s
less than 15 percent of the amount DOE says would be needed in 2030. 94 Of course, that
demand does not yet exist, and Centrus is expanding.
Figure 8: Sources of uranium for U.S. reactors, 2023 95
United States
Other
5%
8%
Uzbekistan
9%

Canada Russia
25% 12%

51.6M pounds
U3O8 equivalent

Australia
Kazakhstan 21%
21%

Looking forward to 2050, the fuel supply issue is a potentially formidable problem. DOE
estimates that HALEU production will need to ramp up from near zero in 2030 to 520 metric
tons annually by 2050. Finding both the uranium and the processing capability at that scale will
be a challenge; Russia currently controls 44 percent of global enrichment capacity, and U.S.
firms are currently blocked from accessing that capacity by the ADVANCE (Accelerating
Deployment of Versatile, Advanced Nuclear for Clean Energy) Act.

China plans to source one-third of uranium domestically, one-third from Chinese-owned foreign
mines, and one-third from the open market. However, domestic uranium production uses low-
grade ores often in remote mining locations, so Chinese nuclear power companies are ramping up

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 34

international arrangements to obtain fuel. 96 U.S. companies may be locked out of existing
sources.

Costs. While no firm usage data is yet available, it is possible to provide estimates for the cost of
SMR fuel compared with that for large reactors. These suggest that SMR fuel, at least for PWR
designs, will likely be significantly higher per MWh than for standard large reactors. 97 Of course,
other designs (e.g., molten salt) will have significantly cheaper (and more easily acquired) fuel.

The Challenge From China

China and, to a lesser degree, Russia are furthest along in the deployment of SMRs. They are
likely to be highly cost competitive with U.S. designs, and of course will benefit from the vast
range of supports and subsidies that China bestows on industries it deems strategic. In both
cases, national champions or the equivalent have emerged. In China, nuclear power development
was controlled by a state-owned entity, but is now largely run through the China National Nuclear
Corporation (CNNC), which controls most of the nuclear sector including R&D, engineering
design, uranium exploration and mining, enrichment, fuel fabrication, reprocessing, and waste
disposal. It also appears to be the major investor in all nuclear plants in China, which are
managed or controlled by an array of state entities (the China State Power Corporation, State
Nuclear Power Technology Corporation, State Power Investment Corporation, China Power
Investment Corporation, and China General Nuclear Power Group). 98
Much of the relevant performance data for Chinese reactors—including the degree of state
subsidization—is hidden from outside view.
China also has a deep manufacturing base on which to draw, as well as substantial experience
building larger nuclear reactors. Given the current political climate, Chinese reactors are not
likely to be deployed in the United States or Europe. But other countries will not be so picky, so
Chinese companies are likely to slide down the cost curve more rapidly than are U.S. companies,
further extending their advantages.

Box 6: China and Nuclear Power

Although the United States currently has more operating reactors than does China (see figure 9),
China intends to build 150 new nuclear reactors between 2020 and 2035, with 27 currently
under construction and the average construction timeline for each reactor about seven years, far
faster than for most other nations. It has made advanced nuclear power a priority strategic focus
and is actively working to deploy all six types of fourth-generation nuclear reactors identified by
the Generation IV International Forum. 99

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 35

 Figure 9: Nuclear power plants in operation or under construction, May 2024 100

Canada
South Korea
Russia
France
China
United States

0 20 40 60 80 100

Fully operational Under construction

Advanced nuclear reactors are now reaching deployment: the Shidaowan-1 power plant is the
world’s first operating fourth-generation nuclear reactor, with two 250 MW high-temperature
helium gas-cooled reactors; the Linglong One is a 125 MW SMR, using PWR technology
(operational by late 2025).
China is currently also building two prototype floating nuclear reactors (FNNs). The 125 MW and
50 MW designs use PWR technology. Proposed uses include powering military bases,
desalination, heating, and supporting sea oil drilling activities. 101 This has obvious implications
for regional national security, given China’s efforts to project military power in the South
China Sea.
National security is also driving deployment. CNNC has already connected a 600 MW fast
breeder reactor to the grid, plans to launch another by 2026, and is considering a commercial
1,000 MW fast breeder reactor. Calculations based on Indian plant designs suggest that a 500
MW fast breeder reactor can produce up to 140 kg of weapons-grade plutonium annually—
enough for approximately 25–30 warheads. 102

Demand Side
The door is opening for SMRs because utilities need more clean, firm dispatchable power to
meet mandates from regulators, and because large end users such as data centers are also in
principle committed to using clean energy. That is also true for industrial users seeking to
decarbonize, in the chemicals industry, for example. For these end users, the lack of alternatives
makes SMRs more attractive.

This demand is exacerbated by the sudden increase in projected demand for electricity. Electric
vehicles (EVs) and other decarbonizing technologies are powering the switch from fossil fuels to
electricity—a switch that is, of course, useless from a green perspective if that electricity is itself
powered by fossil fuels. Utilities face the need for more capacity, and they are under pressure
from regulators to make it as clean as possible.

However, the deregulation of the power sector in many countries creates further risks. For
example, nuclear is now much more open to impacts (positive and negative) caused by shifts in
the price of competing fuels. Significant increases in gas prices in Europe, for example, have

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 36

made nuclear much more attractive there. Conversely, the fracking boom and subsequently lower
prices in the United States made nuclear less competitive.

The reality is that demand—even new demand—is potentially fickle, especially if it is driven by
regulation or political choices. The sudden emergence of big data as an ideal customer for SMRs
(see New Markets section) is also potentially unstable. Data centers may find alternative sources
of cheaper energy (they are already investing significantly in both gas turbines and solar plus
batteries), especially if popular interest in green energy wanes. The projected demand from data
centers could also quickly peak if AI training becomes much more efficient (as Deepthink r1
seems to show). There are also timing concerns: SMRs will likely take a decade to become a
significant option, so by the time SMRs become fully available, their moment for fueling the AI
revolution may have passed.

Even gas plants can be affected by shifts in competing fuel prices. A number of U.S. power
plants went bankrupt in the early 2000s as gas became more expensive and those plants became
mid-stack suppliers rather than baseline producers. 103
From the demand-side perspective, SMRs are being developed now for markets that don’t yet
exist, and for an environment in which firm clean power will be highly attractive. There are
obviously risks that these assumptions are false.

However, there are also some significant opportunities to mitigate these risks. Notably, long-term
PPAs are contracts between generating companies and end users or utilities, in which users
agree to buy energy for a long period at a fixed price. Typically that price is somewhat higher
than current prices, and represents a reasonable deal for both sides: a secure market for the
seller, and secure access to power at a fixed price for the buyer.
Risks can also be mitigated by government guarantees of various kinds (e.g., CfD), and by
different ways of directly allocating market risks. These are discussed in the policy section
ahead.
Taken together, supply-side and demand-side risks dramatically affect pathways for SMRs
through the minefield of market failure. These risks can be mitigated, but they are formidable.

Will Demand Materialize?

Despite a further increase in electrification, there may not be increased electricity demand. Over
the past four decades, electrification has reached many parts of our lives at scale, yet demand
for electricity has grown only 15 percent since 1980, and is significantly down on a per capita
basis. 104 That’s because our use of electricity has become much more efficient: appliances are
far more energy efficient than their predecessors were; LED bulbs take less energy than
incandescent bulbs. So further electrification may not mean that electricity demand will grow.

Still, demand seems to be picking up across the economy, and data centers are potentially a
substantial source of new demand for electricity. Data centers seem to be the deep-pocketed
patient investors that all start-ups imagine in their dreams.

However, as Michael Barnard has pointed out, there are good reasons to doubt that that demand
will be transformative for the electricity sector as a whole. The recent release of DeepSeek’s r1
model, which appears to use 95 percent less energy than competing models has obvious
implications, and that model is open source, so those algorithms can spread quickly—although

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 37

DeepSeek’s performance could rely on piggybacking off ChatGPT and other leading models.
Further, ITIF background conversations with Amazon, Meta, and Google strongly suggest that
they are planning for massive data center investment that will require very large-scale energy.
But Barnard made three other points as well. 105
1. We have been here before. In the early 2000s, as data centers were deployed for the first
time at scale, there was a substantial concern that data centers would raise demand for
energy. But that didn’t happen

2. In part, that was because optimization (inevitably) followed deployment. Once primary
objectives were met (capacity, throughput, etc.) attention could turn, very successfully, to
optimizing the software. Optimized software uses fewer cycles, and fewer cycles use less
electricity. There was no electricity demand boom in the 2000s.
3. Data centers use a lot of energy to power graphics processing units (GPUs). But that
hardware is quickly getting more energy efficient as well. Nvidia’s new Blackwell chips
will be much more energy efficient: Nvidia claims the Blackwell Grace200 will be 30
times as energy efficient for inference tasks as the Hopper 100.
There are still good reasons for data centers to be looking at nuclear. But the massive boom in
related energy demand should be viewed with some caution. 106

Managing Market Risks

For most supply-side risks, there is little that SMRs companies can do about competing
technologies and companies. Instead, they are focused on the one risk they actually control: that
the production process will not turn out as advertised. SMRs must shift as much of the
production process to the factory as they can. That means both designing for manufacturability—
an established branch of industrial design—and developing plans to bring production into the
factory as soon as possible. At this early stage, it seems likely that smaller reactors will be more
easily manufactured, so interest is growing in microreactors (20 MWe or less).

From a policy perspective, recent supply-side efforts have focused on reshoring the nuclear
supply chain, or at least making sure that U.S. reactors are not dependent on Russian uranium.
The Prohibited Uranium Imports Act and subsequent Biden executive orders have effectively
shut out Russian uranium; the question, though, is whether sufficient new sources will come
online soon enough, especially if SMRs get market traction and hence start to impact overall
demand. Recent agreements with allies also aim to build a supply chain that excludes Russia. 107
DOE has started to address the problem of enrichment; this requires additional U.S. capacity,
and DOE has provided an initial contract to Centrus. There is still uncertainty about whether
enrichment can scale up effectively at a pace that matches SMR deployment, but that issue is
still some years away. An alternative pathway would open if molten-salt breeder reactors (TS-
MSBR) are deployed. TS-MBR technology creates more fissile material than it uses, and can use
thorium, a widely available and much cheaper alternative to enriched uranium. 108 Its low
pressure also makes safety concerns less of an issue and less expensive to address.

There are also workforce concerns. Constructing reactors is expensive, in part because the
concrete, steel, and welds needed are all required to meet much higher standards than those for
commercial or residential construction. Those higher standards require a skilled workforce, but
the sporadic pace of nuclear deployment in the United States means that each workforce has to

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 38

be trained from scratch. Any major success in reducing costs will almost certainly require that a
trained specialized workforce remains fully employed on nuclear projects. Operations also require
trained workers, but this is less difficult to achieve because that workforce does not dissolve once
construction is completed; operations are needed for the life of a plant.
Finding customers with deep pockets and long-term needs is the gold standard for addressing
demand risk, and SMR companies are clearly having some success there. They are working with
utilities, network operators, and large end users to develop offtake agreements that will address
the risk that demand won’t be there when power eventually starts to flow. The Tennessee Valley
Authority, for example, is buying a GE-BWRX 300 MW reactor (it’s also supporting the Kairos
Hermes reactor at Oak Ridge). Google has an agreement in principle to buy six reactors from
Kairos, while Amazon has partnered with Energy Northwest for a series of SMRs (starting with X-
Energy reactors) that could eventually provide 960 MW. Amazon is also partnering with Dominion
Energy in Virgina on a 300 MW SMR project.

Political Risks
Large reactors can take 10 years or more to build. That period covers at least three U.S.
administrations, five national elections, and at least 10 annual budgets plus any number of other
financial and administrative crises. There is, in short, ample time for political apple carts to be
upset. And that’s just at the national level—attitudes toward nuclear have flipped often in U.S.
states, as New York’s sudden new interest in nuclear demonstrates.
For any industry, this is difficult. For nuclear, it is potentially existential, as the pathway to
sustainability is powered by government funding. Developing an effective nuclear power
development program requires a stable flow of funds against well-defined milestones.
Those concerns are perhaps more relevant for large reactors than SMRs. Not only are SMRs
faster to deploy, shortening the period of political risk, but also they have some hope of
eventually reaching financial sustainability, at which point ongoing government funding will
become less necessary. And the amounts of funding should also be lower. That said, until SMRs
reach scale, they will understandably depend to a considerable extent on government funding.

Nuclear accidents drive a second set of risks. Fukushima occurred in Japan, but the global
backlash to nuclear power that it created helped destroy the German nuclear industry (and set
the Japanese nuclear industry back a decade). Three Mile Island had similar effects in the
United States. Every accident can trigger a turn away from nuclear, and usually tightens the
regulatory screw.

Finally, there are political risks related to climate politics. While climate concerns have helped
drive the recent nuclear boomlet, the backlash is already here. Nuclear is today a lot more
expensive than natural gas in the United States, and it is more expensive than coal in the
developing world. If climate-driven policy is rejected, SMRs could find themselves in a very
wintry environment.
These political risks can be mitigated mainly by developing a cross-party consensus in support of
nuclear policy that is sufficiently robust to withstand a change in administration. That will be
challenging, although some countries where national energy security concerns play a big role
appear to be developing at least the basis for that consensus (e.g., Poland, and perhaps the

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 39

United Kingdom). In the long run, SMRs themselves may help to reduce these risks by becoming
sufficiently competitive to avoid dependence on long-term subsidies. That, however, is some
way off.
Clearly, the broad political environment has clearly become much less predictable over the past
decade. Not even its supporters expected Brexit, and perhaps even fewer that Donald Trump
would be on the verge of a second term. The turn against incumbents across the West, and a
parallel rejection of experts and their expertise, has simply added to the risks. But more than
other carbon-free technologies, nuclear itself has fans across the political spectrum. While the
incoming secretary of Energy owns a fracking company and is a strong supporter of fossil fuels
(and is a climate skeptic), he is also a board member and investor with Oklo, an SMR company.
That said, political risks are hard to mitigate. Nuclear is expensive, and an easy target for
political grandstanding. The best solution is clearly to get beyond government funding as quickly
as possible.

Regulatory Risks
All nuclear plants are tightly regulated, and that process can be time consuming, expensive, and
opaque. It has been very difficult to get new designs approved, it’s difficult to get site approvals,
alignment between different national regulatory regimes is poor (so designs need to get
separately approved), and the balance between safety and progress is, fair to say, heavily tilted
toward safety.
All this is challenging, and the advent of SMRs makes it worse.
Regulatory authorities are not yet prepared for a world dominated by SMRs. The regulators
understand this: their operating model is of an extremely safety-first culture in which any
proposed design changes are examined minutely and in exhaustive detail on the premise that
such changes will happen once a decade or so (if that). As noted earlier, SMRs will need to
iterate, and it’s not clear how that will be regulated. It’s also apparent that NRC does not have
the funding or the personnel needed to handle the flood of regulatory activity required if SMRs
arrive at scale.

Regulation and SMRs

Both Congress and NRC are working to fix the problems with nuclear regulation. Since the mid-
2010s, NRC has followed a twin-track strategy to accelerate certification for nuclear reactors,
including both design and operations. It has—following direction from Congress—developed a
new pathway for certification, known as Part 53. This is now working through the rulemaking
process. It has also followed the lead of industry groups and developed new models that work via
exemptions from the existing Part 50 and Part 52 processes. Traditional plants using established
technology can also use those existing pathways without needed exemptions.
These developments reflect the history of nuclear power regulation in the United States. From
1945 to 1954, nuclear technology in the United States primarily focused on plutonium
production reactors for military use at sites such as Hanford and Oak Ridge. As interest in
commercial nuclear power grew, the need for safety regulations emerged. The initial regulatory
approach (defined in the 1954 Atomic Energy Act) was largely ad hoc, relying on expert panels
convened by the new Atomic Energy Commission to evaluate designs and require implementation

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 40

using conservative operating margins. Construction and operating licenses were separate,
borrowing from the 1934 Telecommunications Act covering radio station licensing.

By the end of the 1970s, flexible expert reviews had evolved into much more prescriptive
regulations increasingly specific to light-water reactors (LWRs), which had become the dominant
design because industry needed more predictability in the face of inconsistent decisions, and
sometimes failed projects as reactors were denied operating permits late in the process.
Safety analysis methods also evolved. Initially, DuPont used worst case accident (WCA) analysis
in the 1940s—which assumed catastrophic failure. That shifted to maximum credible accident
(MCA) analysis, which included the probability of failure in safety calculations. As plants grew
larger and more complex, this evolved into the design basis accidents (DBA) approach—a set of
regulatory assumptions that were believed to provide a consistent safety envelope for plant
operation.
That changed in the 1970s, as the Reactor Safety Study (RSS/WASH 1400) introduced
systematic, systems-level safety analysis. This study showed that smaller but more frequent
accidents could pose higher risks. Three Mile Island was a turning point. It had become a basic
assumption of safety regulation that if the largest potential problems were addressed, smaller
ones would be addressed as well. Three Mile Island exploded those assumptions, as a small
failure quickly cascaded and led to meltdown. Subsequently, considerable efforts were expended
looking at how to evaluate and address risks that were more systematic: not the failure of a single
large component, but the impact of multiple smaller failures, for example. The existing checklist
approach clearly needed to be supplemented, or possibly replaced.
Regulation evolved further in the 1980s and 1990s. Risk-informed approaches allowed for more
intelligent safety assessment, and potentially reduced excessive conservatism in design
requirements, eventually leading to technology-inclusive, risk-informed, and performance-based
regulation (TIRPB) in the 1990s and early 2000s.
Still, by the mid-late 2010s, more flexibility was clearly needed, especially for new designs. In
2019, Congress passed the Nuclear Energy Innovation and Modernization Act (NEIMA), which
directed the Nuclear Regulatory Commission to develop a comprehensive regulatory framework
applicable to all reactor technologies, sizes, and operational methods; establish predictable fee
structures; and addressed uranium processing regulations. The 2024 ADVANCE Act called on
NRC to add staff and reduce licensing application fees (it also introduced prize competitions).

The NEIMA mandate was reflected in the new Part 53 rulemaking now under way. The comment
period has now closed, and Part 53 is expected to become operational in 2027. The new
framework aims to accommodate emerging technologies such as SMRs and microreactors while
maintaining safety standards. 109 Key aspects of the new Part 53 rulemaking include the
following:
▪ A technology-inclusive, risk-informed approach using probabilistic risk assessment. This
replaces the highly prescriptive model used to date, and includes a new concept of
“defense in depth” using certain design characteristics (e.g., underground location,
passive safety designs where failure leads to automated shutdown by design).

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 41

 ▪ Eight distinct license application types, including early site permits, construction
permits, and operating licenses (see box 8). This is designed to split the process into
more standardized and transparent milestones, which should improve the bankability of
projects.
▪ Support for efficient licensing of multiple plants using “similar” designs.
▪ Modified technical requirements addressing fitness for duty, physical protection, and risk
metrics, including an alternative to existing requirements.
▪ Comprehensive waste management requirements (although there is still no national lone-
duration repository)
The final draft rule is expected in 2025, with final rule approval anticipated by the end of 2027.
This would be a new standard pathway for regulatory approval.
But since NEIMA passed, NRC has demonstrated that Part 50/52 regulation may still be viable,
as the existing regulatory exemption process may be flexible enough to work for SMR vendors.
The exemption process has been used successfully to license new reactor technologies such as
Kairos Power’s reactors and TerraPower’s Natrium reactor, which uses liquid sodium along with
molten salt as an energy storage medium.
That is partly because the exemption process has itself been somewhat standardized. In the
2010s, an industry group led by the Southern Company sought to build a new toolkit for
assessing nuclear safety, aiming to develop a pathway that satisfied NRC and at the same time
worked for different technologies and different-sized reactors. 110 This approach seems to have
been remarkably successful: the LMP model has now been formally approved by NRC (although
it is not yet itself a formal alternative pathway). Companies can point to the LMP model in their
regulatory filings, and NRC will accept that reference.

Box 7: New NRC Mission Statement

In 2025, the NRC issued a new mission statement:
The NRC protects public health and safety and advances the nation’s common defense and
security by enabling the safe and secure use and deployment of civilian nuclear energy
technologies and radioactive materials through efficient and reliable licensing, oversight, and
regulation for the benefit of society and the environment.
The new statement adds a focus on enabling the use of civilian nuclear power, a new mission
element.

So developers of new nuclear technologies can now either pursue licensing under Part 50/52
using the exemption process, or wait to use the new Part 53 framework, which offers broader
applicability but comes with uncertainties. The NRC’s somewhat surprising flexibility seems to
be working for developers, and they may be reluctant to wait for a new process that will start only
in 2027 (or later), may be subject to legal challenges, and where the handling of innovative
technologies is in practice simply unknown. If the exemption route proves capable of managing
innovative designs quickly and efficiently, it may yet become the preferred pathway even if Part
53 rulemaking concludes on schedule.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 42

 Box 8: License Types Under the Proposed Part 53 Framework
There are eight types:
 Early Site Permit: Allows approval of a site before seeking construction or combined license.
This is the initial stage of licensing.
 Limited Work Authorization (LWA): Can be requested alongside an early site permit for
performing specific construction activities.
 Standard Design Approval (SDA): Provides approval for a final standard reactor design that can
be referenced in future applications for construction permits, operating licenses, combined
licenses, or manufacturing licenses.
 Standard Design Certification (SDC): Similar to SDA but goes through a rulemaking process for
approving a standard nuclear facility design, and has more finality, as it is a rulemaking and
commission approval. 111 More clarity will be needed: for example, when is an SDC required
or used as opposed to an SDA?
 Construction Permit: Authorizes actual construction of the nuclear plant. Must be obtained
before an operating license.
 Operating License: Permits operation of the completed facility after construction.
 Combined License: Merges construction permit and operating license into a single license. [
 Manufacturing License (ML): Authorizes the manufacture of nuclear reactors. NRC is
specifically seeking input on provisions for manufacturing and deploying manufactured
reactors, including whether Part 53 should allow combined license or operating license
holders to reference a manufacturing license.

Remaining Regulatory Problems

The various reform efforts under NEIMA and the ADVANCE Act, and through NRC’s own
activities, are clearly moving in the right direction. They should make NRC certification more
predictable and often shorter, while expanding coverage to a much wider array of technologies.

However, there are still significant problems:

▪ Design certification takes a lot of time and money—tens of millions of dollars, even
though it remains an optional step. Costs also vary widely, and therefore are difficult to
predict for small companies with limited resources.
▪ Design certainty comes at a price: An SDC or SDA certification locks in a design, which
may cause problems later when adjustments are needed. Companies face trade-offs
between faster approval and design lock-in.
▪ There seems to be very little attention paid in the sector to the need for iteration. Nuclear
deployment has been so slow, and expert analysis has led to a strong focus on the need
for design replicability at the cost of design innovation, such that iteration has largely
been ignored. 112 Iteration will be crucial for SMRs, and regulation will need to address a
range of design changes. A process for identifying and quickly approving noncritical
design changes will be needed.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 43

 ▪ Fee structures need to better reflect the realities of start-ups; the current 100 percent
private sector contribution dates to a period when large reactors were being built by large
companies. A range of fees would be an improvement, and this would require
congressional action.
▪ Interconnection will be a problem for SMRs, as it is for other energy technologies. Recent
improvements won’t be enough to solve the enormous backlog of projects seeking
interconnection approval from FERC. It is possible that the long lead times for SMRs will
mean that the backlog is not as much of a problem.
Can Regulators Smooth the Path for SMRs?
SMRs face four levels of regulation in the United States (most other countries are broadly
similar). First, the design itself must be approved by NRC. This is time consuming (seven years
on average), and requires working closely with regulators who are safety-first inclined.
Technologies that are genuinely new attract more scrutiny (for understandable reasons: these
reactors have not yet been built anywhere!). And most countries require in-country certification,
so companies must complete multiple regulatory paths to generate even the capacity for global
scale.
Second, the proposed site for a reactor must be approved for both safety and compliance with
NEPA. The latter is especially time-consuming in the United States, where nuclear opponents
(and concerned locals) have weaponized NEPA to bring countless and long-drawn-out lawsuits.
Sites must also, of course, get approval from local authorities (usually counties and\or states in
the United States).
Third, NRC must approve an operational and safety plan—which would include both actual
safety and operations and evacuation plans and other wider safety measures (e.g., operator
training, fuel transportation, and waste management).
Fourth, the new reactor must be approved for interconnection to the grid. Perhaps because
reactors take so long to build, the five-year queue waiting for FERC interconnection approval has
not been as visible a problem as other regulatory issues, but if SMRs gain traction and dozens of
SMR projects seek approval, that will change quickly. And interconnection denial can kill a
project, as Amazon’s rejected effort to use energy form the Susquehanna nuclear plant shows.
For SMRs to gain traction at scale, a lot of existing regulatory processes will have to be shortened
dramatically, and overlaps eliminated.

International Standardization of Licensing and Certification

While the broad pathway for nuclear certification is similar in every country, specific regulatory
pathways are defined in national law and are significantly different. These differences present
major barriers to scale-up, as SMRs will need to go through certification in every country where
they plan to sell products. Not even the EU has a unified certification scheme.
International standardization of licensing as well as harmonization of regulatory requirements has
been a goal of several programs, including those of CORDEL (Cooperation in Reactor Design
Evaluation and Licensing NEA working group), MDEP (Multinational Design Evaluation
Programme), and ERDA (European Reactor Design Approval). CORDEL has looked at
international aviation licensing as a model from which good practices can be drawn. IAEA has

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 44

developed an SMR Regulators’ Forum, a working group for member states and stakeholders to
discuss their knowledge and experience, but no regulatory legislation or template specifically for
SMRs has yet emerged. 113
The point is that unlike large reactors, which have been largely country specific, SMRs could
evolve into a global market. The need for scale also implies that companies that can meet the
regulatory requirements of multiple countries and regions will have a significant advantage. In
the United States, either DOE or NRC needs to be fully aware of and participating in the
development of international standards and certification regimes.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 45

DERISKING SMRS
In general, there are strategies available to share and mitigate the risks related to SMR
development and deployment, but so far, no well-defined set of best practices has emerged.

A lot of nuclear policy is about handling and mitigating risks. For example, the Price-Anderson
Act established what is essentially a nuclear insurance fund: all nuclear operators are required to
participate and to pay up to $137.6 million per reactor in the event of an accident. They must
also carry $450 million in direct insurance per reactor. The fund has paid out about $200
million since its inception in 1957, including $71 million for Three Mile Island.

But insurance is far from the only way to mitigate the range of risks related to nuclear power.
In the end, risks are shared between government and end users. The latter are usually rate payers
for a utility, but they can be large end users participating directly. No one else can pay for
nuclear—operators are, in general, not big enough to assume all the risks involved, and in any
event, they will simply pass costs on to ratepayers and end users.

Ideally, as SMRs are successfully deployed, and as their costs fall and deployment timelines
become more predictable, risks simply decline. And as that happens, the need for government
intervention declines in parallel. We can imagine a future in which government funding shifts to
much earlier in the product development curve, focusing on basic and early applied research that
is quickly adopted by a flourishing SMR industry. Eventually, even early stage research can be
funded by industry, as it mostly is for semiconductors and pharmaceuticals.

But until then, financial risks need to be addressed. Several options focused on different stages
of development and deployment have emerged. In general, the earlier in the product
development cycle, the higher the justification for government funding.
From a financing perspective, SMRs have two huge advantages over large nuclear reactors: they
require much less up-front capital per reactor (because they are smaller), especially once the
initial investment in factory manufacturing is completed, and the promise is that they will be
completed and delivered in a much shorter period of time, perhaps 2–4 years or less, instead of
7–10 or even more. Lower capital costs and shorter timeframes reduce risk.

These advantages, along with the promise of larger markets—and eventual cost reductions from
scaling up—have led to an influx of private sector funding from both investors and end users,
such as the large data companies. Despite this, financing remains an enormous challenge for
SMRs: they are essentially a new technology that will take at least a decade to reach markets at
scale and probably more than that to break even in a context where many energy markets are still
regulated and where existing competitors have deep pockets and strong roots. P3 is a long
way off.
Market financing is driven by the balance of risk and reward. So left to markets alone, SMRs are
not attractive to investors; a lot of government policy in the United States and elsewhere has
focused on trying to change that balance at both ends.

Eleven options have emerged for financing nuclear plants, aiming to reallocate costs and hence
financial risks:

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 46

 1. Government loans. In the United States, the LPO is a primary financial resource for large
energy projects, providing loans and guarantees at below-market rates (using government
borrowing power) to help fund construction for projects wherein either private investors
will not take the risk or market financing is too expensive. These loans are focused on
construction.

LPO was instituted in 2010 but has been massively upsized in the past few years. In just
October and November 2024, it provided direct loans or loan guarantees for $15 billion
to Pacific Gas and Electric Company, $6 billion to Rivian for EV manufacturing,
approximately $5 billion for the Grain Belt Express, a high-voltage direct-current
transmission project, $500 million for a semiconductor plant for EVs, and $445 million
for an EV materials project. By the end of 2024 it had provided $69 billion in
outstanding loans and $41 billion in loan guarantees, with $11.5 billion going to Vogtle
and $1.5 billion for restarting the Palisades plant in Michigan. 114
Given the enormous capital needs for SMR deployment at scale, and the long-term risk
profile, market-only financing may be very difficult, and expensive, as investor risks must
be compensated. Significant nuclear deployment in the United States without LPO
support or the equivalent will therefore be challenging.

2. Tax credits. U.S. tax policy has been used to reduce operating expenses as well. The IRA
offers either ITCs—credits against construction costs for clean energy projects—or PTCs.
PTCs offer a subsidy of up to $33/MWh for new clean energy projects, covering the first
10 years of operation. 115 Energy providers can use either, but not both.

3. Operating subsidies don’t address construction risks, but they do address longer-term risks
that the market for energy will not evolve in ways that make proposed projects
sustainable. While this model may offer more certain payment flows than CfDs , these
subsidies are paid regardless of market conditions, and could—if construction is cheaper
than expected—lead to significant overpayments for developers. Alternatively, PTCs could
be insufficient to ensure that a project is sustainable if market prices for energy fall to
below even the subsidized price of a new build. That may well happen with hydrogen in
the United States. Further, the 10-year subsidy cutoff in the IRA is quite arbitrary;
supporters may just hope that political currents 10 years hence will allow for their
extension. After all, it’s not as though the cost of an existing project will suddenly fall by
$33/MWh 10 years into its operating lifetime. And tax credits are only effective when
there is a positive income against which to count them. Failing projects may have no net
income. This kind of operating subsidy is somewhat unusual; CfDs appear to be used
more widely, and it’s possible that the rate-asset-based model will also be adopted more
widely.

4. Risk tranching. In financial markets, tranching is a well understood strategy for risk
management. For example, while a single mortgage carries a unitary risk (the mortgage
will either be paid or it won’t), a bundle of mortgages looks quite different: there is an
extremely high likelihood that sufficient mortgages will be paid to cover, for example, 30
percent of the total payments due. It is likely, but not so certain, that the next 50 percent
will be paid. The final 20 percent is riskier. Interest rates and prices are tuned
accordingly.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 47

 For SMRs, the EFI Foundation has suggested a Cost Stabilization Facility using a
tranching model to manage construction costs and possible overruns; the idea is to
develop an order book for multiple SMR reactors that use a single reactor design. That
order book would be collectively owned by a single holding company, which in turn would
be owned by project sponsors, and other stakeholders. Construction risks would then be
sliced into three tiers: budgeted costs, which would be paid by the project sponsors; costs
within a set contingency (e.g., 15 percent over budget), which would be shared between
owners and other stakeholders, including vendors, on a negotiated basis; and unexpected
costs beyond contingency planning, which would be paid by tapping a government
guarantee (in the United States, perhaps through an LPO guarantee). 116
Tranching could remove tail-end risks, encouraging investors to accelerate SMR
development. The downside of course is that government is on the hook should things go
badly wrong. And the EFI model adds considerable complexity: projects have to be
aggregated into order books, a special holding company has to be agreed on, and shares
negotiated between participants and then tiers of financial risk need to be assigned.

5. Contracts for difference. The CfD model asks potential energy developers to bid for
operating subsidies, with the winner being the company that seeks the lowest subsidy.
Essentially, the developer pays the entire cost of construction, while government offers to
pay the difference when market prices for energy from a project are lower than the
agreed-upon level (the “strike price”). In the United Kingdom, this process is run through
auctions in which the government also imposes a maximum amount of subsidy that it is
prepared to pay. This has—for example, in the case of a recent auction of wind energy
subsidies—led to cases where there are no developers prepared to bid at the level the
government is prepared to offer.

Developers may prefer the CfD structure, which provides more direct contractual certainty
and offers a long-term shift of operational risk from the contractor onto the state and
hence taxpayers. CfDs have become quite widely used in Europe, and there are multiple
subgenres with different ways of determining a strike price and different sources of
funding. KEPCO has apparently been somewhat reluctant to bid on Sizewell C because it
prefers CfD financing. However, the CfD model has nothing to say about construction and
regulatory risks: it is all about operational funding.

6. End-user funding via PPAs. PPAs are usually an integral part of the financing package for
any large energy project in the United States or Europe. Utilities or sometimes large end
users sign agreements that take power (usually for a long time period) from the new
energy source. This provides a reliable source of bankable revenue that can be used to
help raise financing for the construction—as, for example, Google’s 20-year PPA funded
development of the Story County II wind farm in Iowa. 117

7. Ratepayer pays. In the United States, ratepayers of Georgia Power and a couple of smaller
utilities are on the hook for much of the vastly expanded cost of the Vogtle power station
in Georgia. 118 Essentially, in this model, the utility contracts for the reactor and then
recoups the costs through charges to ratepayers (although, for Vogtle, the federal
government also contributed $3.7 billion through DOE in 1981 and $8.33 billion in LPO
loan guarantees in 2010).

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 48

 An alternative version of ratepayer pays is the rate-asset-based model being deployed in
the United Kingdom for the Sizewell C reactor (now estimated to cost £40 billion). It
adds a small surcharge to ratepayer bills (approved by an independent regulator—in this
case, Ofgen) so that funds are incoming during the construction process itself—the
proposed surcharge for Sizewell C should be approximately £1-2/month for each
ratepayer during the construction phase. 119 This should reduce the cost of capital by
generating revenues earlier, and also places the credit of the regulator (and hence the
government) behind a big project without adding any liabilities onto the government’s
balance sheet. 120
The rate asset base approach shares risks between a developer and a ratepayer, but it
also changes the incentives for developers. If that funding is available without constraint,
it can lead developers to overspend, and has been called an “open checkbook” by
critics. 121
This model also means that a regulator must estimate construction costs in advance
(including supply chains, construction length, interest rates, and a host of other
variables) to calculate an appropriate charge for ratepayers. After all, the increased
revenue certainty for investors and developers is generated by early costs imposed on
ratepayers.

8. Vendor financing. The Paks II project in Hungary is 80 percent financed by Rosatom, the
Russian national nuclear contractor. Given that the two countries most likely to provide
vendor funding are Russia and China, and that this kind of financing would be extended
primarily to allies, this seems to be a fairly limited model. It appears likely that reactors
in China are benefitting from complex financing flows between the buyers, vendors, and
state entities.

9. Cooperative financing (Mankala model). Olkiluoto 3 in Finland is based on the Mankala

model whereby several parties join resources to acquire and co-own an asset. Financing
lies on the balance sheet of the Mankala company, which does not generate profit or
distribute dividends. Instead, shareholders can purchase electricity at cost and cover
expenses in proportion to their ownership share. The electricity can in turn be used for
self-consumption or sold by the shareholder. More than half of Finland’s electricity is
generated through Mankala arrangements. The Mankala model stresses the financial
contribution of end users; they are also on the hook for construction and operating risks.

10. Vendor owned and operated. SMRs are small enough that they potentially offer a wider
array of financing arrangements. For example, Last Energy is preparing to deploy its
SMRs using a model wherein it takes on all the risk. It owns and operates the reactor,
and simply sells the resulting electricity to the utility (or another end user). The company
is confident that it can deliver at a competitive price, and that there won’t be cost
overruns or delays that would affect the price it must charge.

11. Government equity. With, for example, the U.K. government now effectively owning a
majority share of the Hinkley plant and the Swedish government exploring such options in
Swedish nuclear plants, governments around the globe are taking various stakes in
nuclear plants.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 49

A recent report from OECD looks in detail at financing for new build reactors across the world,
illustrating the wide range of construction financing strategies (see table 2). In some (e.g.,
Hungary and the Czech Republic) most of the financing is debt, and it is directly funded by a
government (the Russian government in the case of Hungary). The Vogtle plant in Georgia was
entirely funded by equity, primarily by the utilities that expected to buy the electricity (plus
significant federal loan guarantees). And while the Barakah plant in the UAE was 80 percent
debt funded, the terms were different than those at other plants; it was apparently a fixed price
contract with KEPCO. Debt comes from different sources as well—sometimes government
agencies, but often commercial banks (at least ostensibly).
Table 2: Financing arrangements for eight recent nuclear plants 122

Debt-to-Equity Equity Provider(s) Debt Provider(s)

Olkiluoto 3 75:25 ▪ Consortium of electro- ▪ Commercial banks

intensive companies

Vogtle 3 and 4 0:100 ▪ Georgia Power ▪ N/A

▪ OPG
▪ MEAG Power
▪ Dalton Utilities

Barakah 80:20 ▪ ENAC ▪ UAE government

▪ KEPCO ▪ Korean EXIM
▪ U.S. EXIM
▪ Commercial banks

Akkuyu N/A ▪ Rosatom ▪ Commercial banks

HPC 0:100 ▪ EDF Energy ▪ N/A

▪ CGN

Sizewell C TBD ▪ EDF Energy ▪ TBD

▪ U.K. government
▪ Additional, TBD

Paks II 80:20 ▪ Hungarian government ▪ Russian government

Dukovany 5 98:2 ▪ CEZ ▪ Czech government

It’s reasonable to conclude that no standard financing structure for risk sharing has emerged.
SMRs pose additional challenges because initial funding will include not just construction costs
for first-of-a-kind reactors, but also for building the factories that are eventually expected to bring
unit costs down substantially.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 50

NUCLEAR R&D IN THE UNITED STATES
Over the past few years, DOE’s support of nuclear, which traditionally focused on large reactors,
has transitioned toward an approach that is more welcoming and supportive of SMRs. Civilian
nuclear R&D is run through the Office of Nuclear Energy (ONE), although nuclear projects close
to the market are also funded by OCED and LPO. From the perspective of SMRs, which are still
at the developmental stage, DOE offers a range of supports across the development cycle. There
are programs for short-, medium-, and long-range development, as well as government-owned
infrastructure primarily located at INL and ANL that can be accessed through public-private
partnerships. The U.S. Nuclear Reactor Innovation Center (NRIC) at INL provides technical
support from proof of concept through commercial demonstration, and access to test reactors
and safe environments for reactors using designs that are going critical for the first time. ONE is
also working on the nuclear supply chain, supporting the development of domestic capabilities
for manufacturing HALEU.
INL, the nation’s top laboratory for nuclear research, development, and demonstration (RD&D),
works with nuclear researchers to develop, demonstrate, test, and validate next-generation
nuclear reactors. 123
This support is usually provided through Strategic Partnership Projects (SPPs) and Cooperative
Research and Development Agreements (CRADAs). SPPs offer partner institutions (including
non-DOE federal agencies, universities, and private firms) access to INL’s advanced technology
equipment, facilities, and research personnel, sometimes on a no-charge basis, otherwise at
cost. 124 For example, INL researchers will review the design of NANO Nuclear Energy’s new
microreactor and provide feedback from an expert panel. 125 CRADAs are cost-sharing
partnerships designed to partner the INL with non-federal entities. Under a CRADA, INL and the
partner institution work collaboratively, with INL providing personnel, services, and property to
the project, but no direct funds. 126
INL can also serve as a location for new demonstration reactors. 127 BWXT Advanced
Technologies, an advanced manufacturing company in Virginia, has partnered with the
Department of Defense (DOD) to develop an advanced, transportable reactor that will be piloted
at INL. 128
INL also offers modeling and simulation programs, which are traditionally difficult to produce but
essential for nuclear engineering. The Multiphysics Object Oriented Simulation Environment
(MOOSE) provides open source and licensed access to 13 simulations describing phenomena in
nuclear engineering. Access to this shared resource helps firms reduce the cost of developing
models and speeds up reactor development.
DOE has provided substantial support to three SMR projects dating back to the early 2010s (see
table 3). However, modest levels of investment were supercharged by funding made available
through the Infrastructure Investment and Jobs Act (IIJA), which is the basis for $4.6 billion in
awards all focused on building first-of-a-kind reactors in the United States, as a recent GAO
report shows.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 51

Table 3: DOE funding for selected SMRs 129

Amount
Awardee Period Competition Purpose
($M)

NuScale design development and $226

2014–18 Competitive
certification

Site permitting and licensing of the $8

2015–21 Noncompetitive
NuScale SMR

Phase 1. NuScale Nuclear $48

2018 Competitive
Demonstration Readiness Project
NuScale/Carbon
Free Power Phase 2. NuScale Nuclear $43
2018–19 Competitive
Project Demonstration Readiness Project

NuScale Nuclear Demonstration $263

2020–24 Noncompetitive
Readiness Project completion

Commercialization and deployment $1,355

of the first NuScale SMR in the
2020–30 Noncompetitive
United States: The Carbon Free
Power Project

TOTAL $1,943

Advanced Fuel Qualification $0.5

2020–22 Competitive Methodology Report for Traveling
TerraPower Wave Reactor

2021–28 Competitive NatriumTM Demonstration Project $1,979.0

TOTAL $1,979.5

Xe-100 Pebble Bed: solving critical $40

challenges to enable the Xe-100
2016–22 Competitive
Pebble Bed Advance Reactor
Concept

Design and license application $19

development for high assay low-
2018–22 Competitive
X-energy enriched uranium fuel fabrication
facility

Xe-100 conceptual design and risk- $3

2020–22 Competitive
informed licensing

X-energy to deploy first commercial- $1,232

2021–27 Competitive
scale advanced reactor by 2027

TOTAL $1,294

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 52

Supports are being provided by the ARDP, which was funded through $500 million via annual
appropriations and then $2.48 billion in the 2021 IIJA. That was designed to fund ARDP
through 2025, and to be further supported through subsequent annual appropriations. While
ARDP does not support all U.S. reactor designs, it is supporting 10 of them at various stages of
development.

The ARDP itself supports projects that are expected to result in a fully functional advanced nuclear
reactor within seven years of the award. The first awards in 2020 went to TerraPower for its
Natrium MSR and to X-energy’s HGTR. Both included funding for fuel facilities.
Risk Reduction for Future Demonstration Projects (RRFDP), part of ARDP, focuses on projects that are
10–14 years away from full-scale deployment. The following five U.S.-based-teams’ projects have
received RRFDP funding (DOE’s share ranges from approximately 32–80 percent):
▪ Hermes Reduced-Scale Test Reactor:—Kairos’s Hermes reduced-scale test reactor, a major
is a step toward a commercial-scale Fluoride Salt-Cooled High Temperature Reactor. This
is an innovative design that involves TRISO (Tri-structural Isotropic) fuel in pebble form
combined with a low-pressure fluoride salt coolant. Funding is $629 million (DOE share
is $303 million).
▪ eVinci Microreactor: This Westinghouse heat pipe-cooled microreactor is aimed at
producing a nuclear demonstration unit by 2024. Total award value over seven years will
be $9.3 million (DOE share is $7.4 million).
▪ BWXT Advanced Nuclear Reactor: This is a commercially viable transportable microreactor
using TRISO fuel particles and an improved core design using a silicon carbide matrix.
Funding is $106.6 million (DOE share is $85.3 million).
▪ Holtec SMR-160 Reactor: This is an early-stage design for a light water-cooled SMR-160,
with $147.5 million (DOE share is $116 million) in funding.
▪ Molten Chloride Reactor Experiment: Developed by Southern Company, this is the world’s
first critical fast-spectrum salt reactor. Funding is $113 million (DOE share is $90.4
million).
Advanced Reactor Concepts-20 (ARC-20) projects (part of ARDP) support advanced reactor designs at
the earliest phases (15 years out or more). 130 The following three projects have been selected, with
total DOE funding of $57.2 million:

▪ Advanced Reactor Concepts: This is a conceptual design of a seismically isolated advanced

sodium-cooled reactor facility that builds upon the initial pre-conceptual design of a 100
MWe reactor facility. Funding is $34.4 million (DOE share is $27.5 million).
▪ General Atomics (San Diego, CA): This MWe fast modular reactor conceptual design has
verifications of key metrics in fuel, safety, and operational performance. Funding is
$31.1 million (DOE share is $24.8 million).
▪ Boston Atomics: This is the development of the Modular Integrated Gas-Cooled High
Temperature Reactor (MIGHTR) concept from a preconceptual stage to a conceptual
stage. Funding is $4.9 million (DOE share is $3.9 million)
Supply chain improvements:

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 53

 ▪ DOE’s recent Nuclear Supply Chain Deep Dive Assessment concludes that the United
States needs to develop a robust domestic nuclear fuel supply chain. 131 Between 1980
and 2019, U.S. uranium production fell from 47 million to 0.17 million pounds. And the
last U.S. plant for conversion of uranium into fuel closed in 2017, although it has since
restarted. While all existing LWR plants use low-enriched uranium (for which there are
three U.S.-based suppliers), advanced reactors will almost all use HALEU.
▪ DOE is deploying a $188 million program for U.S.-based HALEU production. This will be
partly focused on down-blending existing government-owned stocks of uranium, but
mainly on the ramping up of the American Centrifuge Plant’s (Piketon, Ohio) enrichment
capabilities, where Centrus has completed a HALEU production demonstration project
that enriches uranium up to 19.75 percent, the first such project in United States for 70
years. Centrus claims that annual production can reach approximately 900 kg. Other
efforts are underway beyond the Centrus agreements. 132
NRIC at INL. 133

▪ NRIC’s mission is to work with industry and national laboratories to bridge the gap
between concept, demonstration, and commercialization of advanced nuclear technology
(see table 4). It builds or enhances DOE infrastructure to support testing of components
and systems. NRIC will have established four new experimental facilities and two large
reactor test beds for integrated technology demonstrations and experimentation by 2028,
and plans to complete two advanced nuclear technology tests by 2030.
Table 4: 11 NRIC capabilities 134

Proof of Concept Proof of Performance Proof of Operations

R&D for feasibility Established performance of Demonstration platform to

nuclear technologies address economic/operational
feasibility

Materials and fuels Validation data Sites for demonstration

Predictive modelling and Irradiation and transient testing Licensing support

simulation

Experimental capabilities Irradiated materials Integrated energy systems

characterization support

Key programs and featured resources relevant to SMRs in particular include the following:
▪ Demonstration of Microreactor Experiments (DOME), which hosts advanced experimental
reactors up to 20 megawatt thermal (MWth) using HALEU, providing a safe environment
for reactors going critical for the first time
▪ Laboratory for Operation and Testing in the United States (LOTUS), which is a testbed for
microreactor experimental reactors up to 500 KWth using HALEU. It too provides a safe
environment for reactors going critical for the first time

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 54

 ▪ The He-CTF testbed, which allows industry to test and qualify reactor components for
gas-cooled reactor designs
▪ The METL (intermediate-scale facility at Argonne National Laboratory), which provides R-
grade sodium to experimental vessels for testing advanced reactor components
DOE also launched the U.S. Industry Opportunities for Advanced Nuclear Technology
Development program in 2018, offering funding for applied research at private companies
seeking to develop advanced reactors, including SMRs. 135 These projects focus not on building
reactors, but rather on ancillary technologies that support reactor deployment, including some
help with regulatory preparation. 136
It’s fair to conclude that DOE is providing considerable support for R&D across the nuclear
reactor development cycle. ARDP’s distinction between short-, medium-, and long-term projects
is sensible, and if ongoing funding is provided, should develop into an effective pathway from
very early-stage research to commercialization of nuclear reactors. NRIC’s efforts are also
significant, offering a range of very practical supports (including technical help with licensing,
and facilities that support the first test of reactor criticality). However, there are risks that this
pathway will become a dead end; all this work is subject to annual appropriations. It is also
unclear whether DOE has the interest or the funding to both move beyond the existing 10
projects operating within the ARDP and add companies to the short-term list as they mature,
which would require raising the level of support to help reach first-of-a-kind commercial
deployment.
Advanced Research Projects Agency–Energy (ARPA-E) runs its own nuclear power research
program, typically offering grants of $2 million to $5 million in support of nuclear-related
technologies. Currently, there are 61 nuclear projects in its portfolio, of which about one-third
involve private companies. ARPA-E aims to fund research that will support the deployment of
advanced nuclear reactors, including SMRs. 137
Note: Outside the programs discussed in this section, DOE also operates its Small Business
Innovation Research (SBIR) program, which provides funding to innovative small businesses.
DOE SBIR funding continues to be siloed based on the source of funding (despite National
Academies recommendations to the contrary), and it is also not clear that this funding is seen as
important or even relevant by ONE, which typically works with larger organizations at a much
larger scale.

CONCLUSIONS: DEFENDING AND EXPANDING THE INNOVATION AGENDA

FOR SMRS
SMRs open a potential pathway for development that large reactors cannot follow. While SMRs
and large reactors both offer low emissions, high energy density, relatively small footprints, and a
high capacity factor (and we should also expect SMRs to be reliable), only SMRs offer the
possibility that they will experience the rapid decline in costs associated with factory production,
and that they could eventually become a cost-competitive source of clean energy, with potentially
significant implications for other industries as well. There is a possible path to P3.

At a global level, getting to P3 with competing energy sources is mandatory: we know that for the
foreseeable future, market-driven economies will not adopt SMRs at scale unless they reach P3.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 55

We also know that developing countries don’t have the resources to pay a significant premium for
clean energy, so they won’t buy SMRs at scale either.

Innovation
While scale-up is necessary—we won’t get P3 SMRs without it—it is not sufficient. We need
substantial innovation on many fronts:
▪ A discovery phase, during which many designs and technologies are explored. This is difficult
for nuclear technologies, but necessary. Much of the ARDP is aimed at this phase.
▪ A testing, evaluation, and pilot phase, during which promising designs are tried out. We are
entering this phase now.
▪ Commercial deployment and then coalescence of the industry around a winning design. While
there may be multiple winning firms, and it’s possible that radically different designs will
be needed for microreactors, SMRs, and large SMRs at 300 MW and above, we need to
find the ICE equivalent, and it may well not be PWR. Critically, winning designs must
show a path to P3.
▪ Deployment of winning designs at growing scale. This may well include the licensing of key
technologies outside the leading-edge firms, as some of these firms may not have the
capability to get to scale: building lots of reactors is a great deal more difficult than
building a lot of PV solar.
Discovery phase. This covers basic and applied R&D. DOE offers grants for basic science
(primarily through universities, as well as SBIR funding for private companies). Research
partnerships between private companies and National Labs are possible through CRADAs, and
outside researchers have access to experts and technology at the Labs as well. Regulatory
flexibility will also be needed. Recent reforms at NRC are a good start, but there are still plenty
of challenges, including in particular ways for NRC to facilitate iteration, which is a key element
of the discovery phase.

Testing, evaluation, and pilot phase. This phase is supported both by funding and by access to
Labs’ expertise and technology, notably but not limited to simulation and design software. The
focus here is still primarily on the technology; markets are not really part of the equation.
Development of multiple regulatory pathways for certification and approval at NRC is promising,
but timelines for action are still long. NuScale, X-energy, and TerraPower are all at the point of
exiting this phase.

Deployment and coalescence. SMRs have not quite reached this stage, although we may get there
in the next two to three years. Commercial deployment is a critical step, and OCED is explicitly
designed to support this difficult phase. INL helps here with testing facilities and other supports,
some via NRIC. This phase is tightly connected to regulation, from both NRC and EPA (which
becomes important for siting and transportation).
There is no office within DOE or the federal government explicitly charged with assessing the P3
potential of technologies. This absence leaves a gaping hole in the foundations of federal
strategic plans for clean energy, which has in recent years been filled with an “all of the above
approach,” funding via construction grants and generous operations subsidies via tax credits all
projects that promise significant emissions reduction.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 56

Scale-up. This is the endgame for SMRs; they must get from first-of-a-kind deployment to NOAK
scale. Ideally, markets will determine winners and losers, but the high risks and heavy costs
involved at this point in the development cycle mean that government support will be necessary.
Currently, that mainly involves support from LPO, but that support is at the moment quite badly
designed; under Biden, it was more focused on simply helping to fund clean energy projects than
to drive projects toward P3. The Vogtle nuclear plant in Georgia is one example among many in
that it is not a demonstration of anything specific, and there is no path or plan for Vogtle
technology to reach a scale where its technology reaches P3.

Clean energy has also benefited from PTCs and ITCs that subsidize the production of energy with
low or zero emissions. As we can now see, this is a dangerously unstable basis on which to build
a clean energy sector. While the credits were designed to run for 10–12 years (and advocates
expected they would be extended), they are now on the chopping block.
LPO also rushed to push through new clean energy projects before January 20, 2024,
announcing a whole slew of projects ranging from funds to Rivian for EV production to $2.5
billion to WEPCO (a Wisconsin unity) essentially to help reduce electricity costs for its 1.1
million customers. 138
This undignified scramble reflects a fundamental misunderstanding of the role of LPO. It should
be focused entirely on supporting technologies that are ready to scale, on the supply side of the
energy sector, and on a path to P3. Demand-side funding is hugely expensive and not sufficiently
targeted at P3, although there can be cases in which a short period of targeted subsidy makes
sense to help technologies get over the hump and reach scale.
Further, current funding for scale-up fits into either of two relatively narrow boxes: tax credits or
loans. Evidence from outside the United States shows that there are other ways to support scale-
up and re-risk projects.

Risk and Derisking

Nuclear innovation is a hard nut to crack in large part because it is both very risky (given
construction cost disasters and all the other risks previously noted), and it is also highly capital
intensive. Smaller reactors help with the latter, but there is still a lot of money on the table at
high risk for very long periods of time (full payback can take decades).
Much of the focus to date has unsurprisingly been on getting first-of-a-kind reactors built. They
are especially expensive and especially risky. And while various private sector partners have
invested heavily (including Bill Gates), the risk/reward ratio for being first makes fully private
solutions unlikely.
Government policy should therefore be focused on improving the risk/reward balance, both by
reducing financial and nonfinancial risks and by increasing rewards within the context of
markets.

Nonfinancial risk mitigation centers around improving the regulatory pathway and reducing
technological risk partly through the development and provision of shared capabilities by the
government, largely via the National Labs. It seems quite possible that AI applications will
enhance these capabilities, perhaps substantially, particularly in modeling and simulation. The
expansion of shared test facilities at INL is another important and positive development.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 57

Some companies (e.g., Kairos) have also developed sensible multistage rollout programs,
validating technology before moving to scale. This has been difficult in the nuclear sector given
the enormous investments required, but SMRs are better placed to implement such a strategy,
given lower up-front costs.
A hidden technological risk is that the urgent need to reach commercial revenue will lead
companies to lock in on current technology before the sector’s discovery phase has been
completed. Even though PWR SMRs will likely be cheaper and quicker to build initially, but they
may not have a sufficient pathway for cost improvement to reach P3. That, however, is
speculative at this point.
The reality of political risk is now looming. The appointment of generally pro-nuclear leaders to
several key DOE positions suggests that nuclear will remain a favored technology, but the
demand for cuts in all government spending—and the likely rollback of tax credits—means that
the existing pathway for deployment in the United States is at least under challenge. It will be
especially hard (and important) to defend LPO given the recent obviously political funding rush.

Financial risk. On the supply side, the biggest risk for SMRs is that sufficient projected cost
savings from factory production will not manifest. Today, we simply do not know how big a risk
this is. And these are, to be clear, normal risks for any emerging technology. Sometimes the
technology simply does not reach P3; in other cases—such as the U.S. auto industry—getting to
P3 requires the bankruptcy or acquisition of perhaps the majority of manufacturers. That’s the
necessary creative destruction required to build a new industry. While de-risking is laudable, and
sharing the risk, particularly for building the first few iterations, is both necessary and
reasonable, the fact is that every SMR company is engaged in a highly risky project. That is
unavoidable.
Financial risk mitigation comes in many flavors, and the United States uses only a few of them.
The U.S. model has centered on grants for first-of-a-kind development, loans for construction,
and tax credits for either construction or production. However, it is a mistake to focus solely on
U.S. government policy, as other countries have found different ways to mitigate supply-side and
demand-side financial risks.
Supply side. Much recent risk analysis focuses on the problem of construction costs and how to
share the risks involved. EFI has developed a tiered risk model, which suggests that buyers and
vendors should share most cost overruns and that government should be the insurer of last resort,
providing a financial backstop against catastrophic overruns. This has the advantage of reducing
the private sector’s long-tail risk, especially for first-of-a-kind projects, while leaving the
government (and taxpayers) on the hook only for the most catastrophic overruns.

One alternative is to focus on building a strong vertically organized financing coalition that
includes the vendor, the construction company, the utility (or energy manager), and eventually
large end users. This Finnish model has been used successfully for many energy projects, and to
fund and manage nuclear projects there.
In the United Kingdom, the proposed rate-asset-based model simply uses the ratepayers to
reduce capital costs by imposing on them some of the construction costs on ratepayers during
construction. By creating an immediate stream of revenue, this both reduces the overall cost of
debt (which is heavily used to fund large reactor projects everywhere). However, charging

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 58

ratepayers a fee before construction and delivery of energy would be a challenge in the United
States.

Government loans also play a significant role, as they lower the cost of borrowing, which reduces
the overall cost of capital substantially. Of course, that implies more government risk, but that
can also be mitigated.

Both utilities and large vendors can play a pivotal role in funding SMRs; Rosatom, for example,
appears to be bringing highly advantageous financing terms and support in its effort to build an
international market for its reactors. The role of the state as a strategic backer of SMRs is likely
to grow, as China and Russia make a concerted effort to grow deployment of their national
champions in other countries.

Demand-side risks. Again, SMRs are inherently less risky from a demand perspective than are
large reactors. They have shorter lead times, so market conditions have less time in which to
change adversely. And they cost less.

Still, it is always difficult to overcome the chicken and egg problem as new technologies seek to
reach competitive scale against incumbent technologies—which, in the case of energy, are also
subsidized. New energy sources are competing not just against other new sources with different
technologies, but also against existing energy sources, some of which will have fully amortized
their construction costs (aside from having other advantages).

Energy projects have traditionally insured against demand risk through PPAs in which a
purchaser guarantees to buy a set amount of energy at a set price for a set period. The recent
agreement between Constellation Energy and Microsoft for the revitalization of reactor #3 at
Three Mile Island is an example. Microsoft will take 100 percent of the energy from the plant for
20 years at a price that is slightly above current market prices for energy but fixed for the life of
the project. Constellation can accept the offer because nuclear operating costs are highly
predictable—it would be risky to do the same deal with gas, whose price could spike. And
without that PPA, it is unlikely that Constellation would have taken the risk to restart Three Mile
Island.
But PPAs are not the only way to mitigate demand risk. Subsidies are another, as they reduce the
price of electricity, hopefully to the point that it is competitive. The $30/MWh in PTCs that
nuclear projects could receive under the IRA would reduce the cost of nuclear energy by perhaps
20–25 percent. These blunt-force subsidies do have a significant downside for government,
though. Because they are paid regardless of the final price, they might be too big (owners would
receive more than the amount needed to make their energy competitive) or they might be too
small (payable but not enough to make the project competitive). The IRA subsidies are also time
limited, and politically exposed.
Alternative forms of support can close the initial gap between the sustainable price of energy
from a project and market prices while retaining more flexibility. CfDs provide companies with
the exact amount of support needed to close that gap, payable as the difference between project
and market prices, for a set period of time. Using an auction approach to CfDs also allows the
funder (government) to set a maximum price for the energy, which limits its exposure.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 59

There are also a range of ownership models for reactors, especially for SMRs and microreactors in
particular. Both Last Energy and Copenhagen Atomics plan to own and permanently operate their
microreactors, selling energy to their customers (presumably through a PPA). Depending on the
capital structure and debt load, that model could be both more risky and more profitable.

Regulation
Despite some recent improvements, U.S. regulation of SMRs must still fit somewhat
uncomfortably into a model designed for a few large reactors using a single basic technology,
rather than a plethora of varied designs deploying across multiple sites. The NRC has adjusted to
some degree, leading to a new rulemaking that should suit SMRs better, reducing the time to
deployment while retaining key safety regulation features—and to an alternative pathway through
NRC exemptions from existing regulation, an approach that has successfully worked for some
SMR manufacturers already (e.g., TerraPower). The new pathway should be operational in 2027,
but the alternative approach has been so functional that the former may become moot.
These improvements still leave plenty to be done. Notably, there is little visibility into the issue
of regulating iteration, a necessity for new designs during the discovery phase. NRC is set up to
validate a finished design; indeed, the new pathway doubles down on that conceptual framing.
That leaves the question of iteration unexplored: how much change in a design should require
review from the NRC, or even recertification? Can the new focus on probabilistic and data-driven
assessment harness new modeling capabilities (and even AI) to support iteration analysis?
There are also still problems with fees, which remain a significant challenge for smaller
companies. Perhaps Congress can create fee scales that reflect both the size of a reactor and its
novelty, with better cost shares for innovative and smaller reactors (larger projects and more
established designs should be better able to pay their share). And issues of capacity will become
much more important if SMRs do reach some scale; despite recent efforts to expand the
workforce, it’s not clear that NRC will have the capacity to manage the necessary throughput of
certifications in a timely manner. This, of course, is a growing concern given the current push to
downsize government.

NEPA review and transportation issues offer further areas for concern. NEPA reform is of course
an issue much wider than the nuclear sector, but recent announcements in the United Kingdom
suggest that nuclear needs may play a role in shaping overall policy. 139 Both time limits for
litigation under NEPA and the assignment of cases to administrative law judges might
significantly shorten average NEPA-related delays.
Finally, interconnection has to be solved. It is not sustainable for the United States to have a
five-year queue of energy projects waiting for interconnection approval. Partly, this is a matter of
bureaucratic procedures, partly it is the result of numerous speculative projects getting in line in
case they get built (especially solar), and partly it is a personnel bottleneck at FERC, where there
are not enough engineers and pay is too low to attract them in an increasingly competitive
environment.

Regulatory review of SMR transportation has not yet really begun, although NRC has released a
white paper on the transportation of fueled reactors. Efforts will ramp up closer to the time when
actual SMRs are being built and require transportation. Where that authority might reside by that
point is not at all obvious.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 60

POLICY RECOMMENDATIONS
Nuclear power could become a strategic industry in the United States if SMRs become a
competitive energy source. To give SMRs the opportunity to become important, government
policy needs to focus on helping SMRs reach P3 compared with competing technologies. That
requires support across the technology development cycle.
In general, DOE must improve its capacity to undertake P3 analysis at each stage of
development. Currently, no single office supports P3 analysis, and DOE is developing no special
capabilities for it. This is an enormous gap, and leads to DOE supporting technologies that have
no substantial likelihood of reaching P3. Failure here also leads to support for incumbent
technologies—such as large reactors using PWR technologies—instead of funding the innovation
needed to reach P3.
The P3 analysis function should be removed from the work of technology- and sector-specific
offices. P3 assessments should not be in the hands of offices that support specific
technologies—the potential conflicts of interest are apparent, and already lead to rosy projections
from interested parties within DOE.

Supporting Further Basic and Applied R&D (TRL 1-3)

Government funding will be critical for early stage R&D, as it is for all technologies. However,
current approaches could be improved in the following ways:

▪ Stabilize or expand budgets for civilian nuclear power. At a minimum, the administration
should stabilize budgets for basic and applied nuclear research both at universities and
start-ups and especially at INL, ORNL, PNNL, and ANL, which offer unique resources
and capabilities. Ideally, the administration would be expanding these activities. The
work done to date on modeling and simulation should be continued and expanded, as
should INL efforts in particular to build shared testing facilities and sites for first-of-a-
kind criticality. This work should in particular focus on alternatives to PWR, notably
molten salt, as these—at a very early stage still—appear to have long-term P3 advantages
over PWR.
▪ Industry input. In general, DOE should encourage nuclear industry input into research
priorities, and should support collaborative precompetitive research. However, DOE
should also insist on the maximum flow of results and technical information to the wider
public, conditional on not revealing critical trade secrets. Transparency should be the
default, rather than—as it is now—the exception.
▪ SBIR for nuclear. This faces some challenges. Because it is impossible to even design a
nuclear reactor with the level of funding SBIR requires, SBIR seems best suited for
focusing on component-level improvement—such as NanoNuclear’s Annular Linear
Induction Pump. Given that ONE controls the topic selection for nuclear SBIR awards, it
should ensure that SBIR remains focused on innovation, not just incremental
improvement to PWR designs.
▪ Addressing the Valley of Death. DOE is trying to fill the current funding gap that exists
toward the end of applied research. This funding—in the $5 million–$25 million range—
can prove critical for prototype development, which helps mark readiness for the testing

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 61

 and evaluation stage. A focus on component development makes sense in the context of
the nuclear sector.
Two final notes: ARPA-E may play a more prominent role in this area now that innovation is
becoming a much more important part of the nuclear landscape, and it has provided grants for
nuclear components in the $5 million range. R&D also matters at other agencies. The U.S. Army
continues to explore ideas for mobile nuclear power that could solve energy problems for bases in
the United States and abroad, and recently issued a call for microreactor proposals and Navy
funds research aimed at improving nuclear powered ships and submarines. The Air Force is also
exploring on-base use of microreactors at several bases. 140 NASA continues to work on nuclear
for use in space.

Supporting Technology Validation, Further Development, and Testing (TRL 3-6)

Historically, government funding has been scarce for the pilot and demonstration phase of
product development, during which designs are constantly being improved, tested, piloted, and
often then further improved (excluding DOD, which has an extensive testing and certification
system).
However, recent policy innovations have made a huge difference here. DOE funding has
supported TerraPower, NuScale, Kairos, and X-energy through this stage of development;
NuScale received about $250 million between 2018 and 2024 in the run-up to its first
commercial-scale deployment, and X-energy received about $60 million (the boundary between
the testing and evaluation phase and commercial deployment is, of course, blurry).
Given that all three companies have transitioned through this stage and are entering the
demonstration and deployment stage, this support must be seen as successful. What is not so
clear is whether DOE has applied a consistent and appropriate P3 lens to these projects. We
don’t know these details because DOE has published very little about funded projects. While
companies of course need to defend their intellectual property, these projects could not exist
without funding from DOE (and hence the taxpayer). It is simply not acceptable that DOE has
published no detailed explanation for this funding. Bland statements—little more than corporate
public relations in DOE dressing—are no substitute.
DOE is currently also supporting the next cohort of SMRs, providing approximately $1 billion to
five companies, mostly for work within the testing and evaluation phase, with Kairos receiving
more than $600 million for its Hermes reactor. Again, while these levels of support are likely
crucial, very little is known publicly about the assessment and evaluation process at DOE.

▪ P3 assessment. DOE needs to ensure that as projects move through TRL levels, P3
evaluation comes increasingly into focus. While design work, modeling, simulation, and
even prototypes will be needed before effective P3 analysis is possible, by the time
substantial funding is provided, DOE must have a clear a understanding of the path to
P3, and must be able to explain that path publicly to all stakeholders (including Congress
and the general public).
▪ Transparency. DOE needs to be much more transparent about its funding decisions.
Simply announcing awards and explaining the objectives of funding are not sufficient. A
detailed techno-economic analysis that includes P3 pathways should be published for

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 62

 every funding decision over a certain amount—and certainly for commitments that rise
into the hundreds of millions or billions of dollars.
▪ TRL 3-6 funding from government is critical. In general, we strongly support funding for TRL
3-6. Private investment will not be sufficient, especially for nuclear, where risks are high
and returns are often a long way off. Building a new industry sector is challenging, and
government funding will be needed. And moving through TRL 5-6 is expensive for first-of-
a-kind reactors.
Demonstration and Deployment (TRL 7-9)
During the demonstration and deployment phase, costs increase tremendously. Deploying a first-
of-a-kind commercial-scale reactor has in the past run to multiple billions of dollars, and even for
SMRs, the total cost is likely to be $1 billion or more for a project the size of TerraPower’s 345
MW Natrium reactor. DOE has now committed more than $5 billion for first-of-a-kind commercial
deployment of the NuScale, TerraPower, and X-energy reactors. This funding has come primarily
from OCED.
At this stage, DOE should have two core objectives: 1) supporting first-of-a-kind deployment to
demonstrate that the technologies work at commercial scale, and that they have reached the
start of a commercial pathway, and 2) ensuring that supported technologies have a feasible path
to P3. Given the huge amounts involved, and the level of technology lock-in necessary to activate
a first-of-a-kind reactor, finding technologies with a path to P3 is critical. Just getting SMRs
operational at commercial scale is not enough, though it is a necessary step.
OCED is an important office; while it has (often at the direction of Congress) supported quixotic
projects such as hydrogen hubs, with little to no regard for P3 concerns, the underlying theory is
correct: companies will invest when the technological and market risks have been reduced to
manageable proportions through demonstration projects. Congress should continue to fund
OCED, which can then support innovative demonstration projects, but it should also require that
OCED ensure that projects have a viable path to P3. Simply funding technologies because they
reduce emissions is not enough, or even necessarily relevant.
On the regulatory side, the NRC has developed more-flexible models for regulating nuclear
reactors, although the proposed new rulemaking is not complete and won’t be implemented until
2027 or later—and the NRC has not addressed the problem posed by the need to iterate new
designs. The NRC also needs to make it a priority to engage with other regulators, working toward
the development of shared certification criteria that would simplify international deployment for
SMRs.
Regulatory reform also has to address interconnection delays, a problem that affects both the
demonstration/deployment stage and scale-up. The current queue should not be tolerated, and
both FERC and Congress should consider innovative ways to address it. These could include
adding engineers and paying them better from the federal budget; creating a priority lane for
companies willing to fund more engineers at FERC (this model has some analogies with
pharmaceuticals and FSA); prioritizing projects based on size to reduce the overall amount of
energy being delayed; and prioritizing based on grid impact so that applications where the grid is
expected to be a rare backup are moved up the queue. The Texas model of simply allowing
interconnection with the option to shut off grid access if necessary is also worth exploring. The

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 63

point here is that drastically shortening the interconnection process should be a national priority,
and thinking outside the existing box will be needed.

▪ OCED should be retained as a critical facilitator for expensive new technologies with great
potential such as SMRs. It fills a critical derisking function, and should be funded on an
ongoing basis.
▪ OCED reform is needed to ensure that its work includes P3 analysis. While pathways to P3
will remain speculative until deployment at scale is reached (and possibly even beyond),
this economic analysis must be a foundation piece for OCED funding.
▪ Cost-share models should be reviewed. It may be that some projects require much less cost
share (perhaps because of other deep pocketed investors) while others require more (e.g.,
stand-alone start-ups). A flexible approach would be helpful. In addition, while in-kind
cost shares are valid, OCED should be cautious about accepting existing investments (and
infrastructure) as cost shares.
▪ NRC and innovation. The NRC will need to find ways to deal with design changes through
the demonstration phase and beyond. Recertification will sometimes be needed, but
insisting on that for all design adjustments would cripple innovation. However, there is no
obvious way to establish which changes impact safety without doing a full-scale safety
assessment.
▪ Interconnection. The administration should insist that FERC reduce interconnection delays
to a maximum of two years, and should provide the resources and political support that
will be needed to make that happen. Interconnection of new energy sources (and big
users) has important implications for existing providers and energy users, so FERC will
need to be smart.; The status quo is not acceptable, and reform is coming too slowly.
Scale-up
As noted earlier, SMRs face a chicken-and-egg problem: they need to scale up in order to
generate economies of scale and lower costs, but they need lower costs in order to attract the
orders that drive scale. The Biden IRA was a clumsy effort to solve this for all clean technologies
(including nuclear): a combination of construction funding through loans (LPO) and tax credits
(ITC) and operational funding through tax credits (PTC). Essentially, this structure was a panic
response to an immediate opportunity. Clean energy supporters knew that this was (for them) a
once-in-a-political-lifetime chance to supercharge clean energy deployment; it didn’t matter
much that many of the resulting policies had no real liftoff capacity or a functional steering
system. The result was massive funding commitments without much regard to long-term
sustainability (P3).

Those mistakes should not blind us to an important reality: new technologies often do need help
to get over the hump of commercial acceptance in order to scale up, and for energy—where
rollout is usually very expensive—that can mean large amounts of funding. However, the scale of
funding needed means that support needs to be smart, not panicked, such as LPO handing out
billions in the last weeks of the Biden administration.

▪ Funding and derisking. LPO is a key tool. Congress and the administration should retain,
reform, and even expand LPO, which plays a critical role in helping companies reach
scale for new energy technologies and is not replaceable within the U.S. innovation

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 64

 ecology. As a revolving loan facility, it should not be a drain on government resources over
the long term.
▪ LPO reform should immediately refocus LPO on helping companies reach P3 through
scale-up. That will require stronger capabilities for both assessing pathways to P3 and
developing clear milestones and metrics along the way. First-of-a-kind deployment is
always hard and risky, but as technologies deploy, risks should recede, and certainty
should replace estimates and guesses. Better analysis and expanded information flows
should improve DOE’s capacity to prioritize between different technologies, and to
determine that some technologies will never reach P3 and should be defunded. This
process will be challenging, and does carry some risks that government will be forced to
pick winners and losers. However, the alternative is failure to prioritize at all.
▪ Transparency. Maximum transparency should be table stakes for acquiring a large DOE
investment. Stakeholders, taxpayers, Congress, and the rest of the industry should all
benefit from maximum flows of technical and financial information from publicly funded
projects at this scale.
▪ Scale-up mechanisms. Congress and the administration should explore alternative
mechanisms for supporting technologies as they get to scale, many of which require
public-private partnerships. This could include risk tiering (as EFI has recommended);
use of more flexible support systems such as CfDs; loans that become due against
specific benchmarks; or perhaps even investments that have some upside for the
government. Flexible use of U.S. government borrowing power will clearly remain
important for reducing capital costs, and loan mechanisms will continue to play a
key role.
▪ Collaboration. Government should also actively encourage development of collaborative
consortia that include vendors, utilities, and end users. The Finnish model shows that
sharing risks across different classes of stakeholders can make nuclear power much more
fundable. Antitrust concerns should be waived, if necessary, to allow vertically organized
collaborations to flourish.
▪ Supply chain. DOE will need to substantially expand is existing positive steps on the
nuclear supply chain. Its HALEU contracts with Centrus are a good first step, but much
more will be needed if SMR deployment accelerates. A robust and flexibly and quickly
expanding fuel supply chain is an absolutely critical component for any sustainable SMR
sector, and there are also international dimensions to consider, especially if SMRs
become a global market.
▪ Transportation and waste. No country has yet grappled with the challenges of
transportation and waste management for SMRs. They will be different in both scale and
type from large reactors. There will be many more SMRs (if all goes well), so many more
containers full of reactor fuel and waste will be crisscrossing the country. It’s possible
that new SMR technologies (e.g., MSRs—see earlier box on Copenhagen Atomics) will
substantially reduce waste, but managing waste at a handful of large reactors is very
different from managing it at perhaps dozens of smaller ones, especially as one advantage
of SMRs is that they could potentially be sited closer to population centers. And again,
transportation and waste have important international dimensions.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 65

 ▪ Procurement. While the federal government has not systematically applied procurement as
a tool for nuclear energy, SMRs may open the door to new options. In the United
Kingdom, Rolls Royce recently signed an $11 billion contract to provide nuclear power to
the Royal Navy, a contract that could fit very well with the company’s efforts on both
SMRs and microreactors. The U.S. Army and Air Force are currently exploring mobile
microreactors, and NASA is looking at nuclear for space. And the General Services
Administration recently announced a 10-year agreement with Constellation Energy that
will (at least in part) rely on added capacity from Constellation’s nuclear fleet to power
government buildings in the Washington DC metro area. 141 Just as DOD was a key funder
of the semiconductor industry during its early years, there may be a role for procurement
in jump-starting SMRs.
▪ Regulation. The NRC will need to accelerate development of regulatory regimes that fit
SMRs. This, in particular, means continuing to support iteration as part of innovation,
which may require moving away from the core regulatory mindset of the “big reactor” era:
that the key step is certifying a standard design that can then be scaled. SMRs will thrive
on innovation, and a single “certified” design is unlikely to emerge, at least for more than
a decade. Lots of work needs to be done on certifying factory environments, dealing with
the possible fueling of reactors within those environments. Changes to the NEPA process
may in the end be as important for SMRs as changes at the NRC.
▪ International. As SMRs gain traction, they will inevitably become part of a globally
competitive industry. U.S. participation in the development of international standards
and certification programs that are at least aligned and perhaps eventually mutually
accepted will therefore be important.
▪ Nuclear Coordinating Office. There are a lot of moving parts to SMRs, including an
important international dimension, different kinds of support across different stages of
development, and the involvement of multiple agencies. Currently, there is effectively no
strategic coordinating body across the nuclear life cycle. ONE largely focuses on R&D;
OCED (which may soon be dismantled) funds demonstration projects at commercial
scale; LPO has the most available funding and is focused downstream of OCED. There is
no obvious coordination structure between these three, or with the DOE Office of Policy,
or across agencies. While offices without budgets tend to be toothless, a coordinating
body (probably located within DOE) would be a good start, and could be strengthened as
SMR deployment gathers pace. Some central coordinating body must be established,
whether at DOE or OSTP or elsewhere.
In the end, SMRs will become important when they reach P3 with competing technologies; they
could become a globally strategic industry within the next two decades. However, SMRs are also
reaching a critical juncture, as they are on the cusp of commercial deployment, after which they
will face the challenge of scale-up. That challenge will be formidable, as this paper
demonstrates, and success will depend on a wide range of positive U.S. government actions,
including some existing programs that need reform and relaunch.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 66

 About the Author
Dr. Robin Gaster is research director at ITIF’s Center for Clean Energy Innovation, president of
Incumetrics Inc., and a visiting scholar at George Washington University. Dr. Gaster’s primary
interests lie in climate, economic innovation policy, metrics, and innovation assessment. He has
worked extensively on climate, innovation and small business, and regional economic
development.

About ITIF
The Information Technology and Innovation Foundation (ITIF) is an independent 501(c)(3)
nonprofit, nonpartisan research and educational institute that has been recognized repeatedly as
the world’s leading think tank for science and technology policy. Its mission is to formulate,
evaluate, and promote policy solutions that accelerate innovation and boost productivity to spur
growth, opportunity, and progress. For more information, visit itif.org/about.

ENDNOTES

1. Robin Gaster, “Mend It, Don’t End It: It’s Time to Reset Clean Energy Policy by Focusing on
Price/Performance Parity (P3)” (ITIF, January 2025), https://itif.org/publications/2025/01/27/time-
reset-clean-energy-policy-focusing-price-performance-parity-p3/; Robin Gaster, Robert D. Atkinson,
and Ed Rightor. “Beyond Force: A Realist Pathway Through the Green Transition” (ITIF, July 2023),
https://itif.org/publications/2023/07/10/beyond-force-a-realist-pathway-through-the-green-transition/.
2. Chris Wright, “A Letter From Our CEO,” introduction to Bettering Human Lives, Liberty Energy,
accessed March 26, 2025, https://libertyenergy.com/esg/bettering-human-lives/.
3. “Advanced Nuclear,” Pathways to Commercial Liftoff, accessed October 26, 2024,
https://liftoff.energy.gov/advanced-nuclear/.
4. “Staff Report on Electricity Markets and Reliability” (CRS, August 2017),
https://www.energy.gov/sites/default/files/2017/08/f36/Staff%20Report%20on%20Electricity%20Ma
rkets%20and%20Reliability_0.pdf.
5. “Georgia Nuclear Rebirth Arrives 7 Years Late, $17B over Cost | AP News,” accessed January 22,
2025, https://apnews.com/article/georgia-nuclear-power-plant-vogtle-rates-costs-
75c7a413cda3935dd551be9115e88a64. There were certainly mitigating factors that suggest that
subsequent plants won’t be such a disaster, but plants in the United Kingdom, Finland, and France
have also been heavily over budget and late.
6. Used with permission. Jessica R. Lovering, Arthur Yip, and Ted Nordhaus, “Historical Construction
Costs of Global Nuclear Power Reactors,” Energy Policy 91 (April 1, 2016): 371–82,
https://doi.org/10.1016/j.enpol.2016.01.011.
7. Deloitte, “Small Modular Reactors: Winning the race in securing access to low-carbon energy,” June
9, 2024, https://www.deloitte.com/fr/fr/our-thinking/explore/climat-developpement-durable/winning-
the-race-in-securing-access-to-low-carbon-energy.html.
8. Used with permission. “Advanced Nuclear Reactor Technology: A Primer” (NIA, November 2024),
https://nuclearinnovationalliance.org/advanced-nuclear-reactor-technology-primer.
9. Prabhat Ranjan Mishra, “Canada Offers Nuclear Reactor with 15-Year Fuel Cycle for Licensing,”
Interesting Engineering, January 25, 2025, https://interestingengineering.com/energy/canada-
nuclear-reactor-to-commercialize-soon.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 67

10. Konsta Värri and Sanna Syri, “The Possible Role of Modular Nuclear Reactors in District Heating:
Case Helsinki Region,” Energies 12, no. 11 (January 2019): 2195,
https://doi.org/10.3390/en12112195; “Korean SMR-Powered Container Ship Design Revealed,”
World Nuclear News, February 13, 2025, https://world-nuclear-news.org/articles/korean-smr-powered-
container-ship-design-revealed.
11. “SMR Feasibility Study” (National Nuclear Laboratory, 2014), https://www.nnl.co.uk/wp-
content/uploads/2019/02/smr-feasibility-study-december-2014.pdf.
12. Grace Symes, “Interview: TerraPower CEO Chris Levesque on Scaling Up New Nuclear,” Energy
Intelligence, December 13, 2024, https://www.energyintel.com/00000193-ad05-de9f-a1d3-
bded8c6b0000.
13. Aman Tripathi, “Deep Fission’s Reactors Buried 1-Mile-Underground to Supply Power,” Interesting
Engineering, January 8, 2025, https://interestingengineering.com/energy/bury-nuclear-reactor-1-mile-
underground.
14. IAEA, Opportunities for Cogeneration with Nuclear Energy, IAEA Nuclear Energy Series No. NP-T-4.1,
v. NP-T-4.1 (Vienna, Austria: International Atomic Energy Agency, 2017).
15. “Texas Partnership Evaluates SMR Use for Water Desalination,” World Nuclear News, accessed
February 23, 2025, https://world-nuclear-news.org/articles/texas-partnership-evaluates-smr-use-for-
water-desalination.
16. See WNA discussion of these technologies at https://world-nuclear.org/information-library/non-power-
nuclear-applications/industry/nuclear-desalination.
17. Theodore Paul Wright, “Factors affecting the cost of airplanes,” Aircraft Operations Sesson, Fourth
Annual Meeting, 1936, https://pdodds.w3.uvm.edu/research/papers/others/1936/wright1936a.pdf.
18. Oliver Schmidt and Iain Staffell, Monetizing Energy Storage: A Toolkit to Assess Future Cost and
Value (Oxford, New York: Oxford University Press, 2023). The analysis here is driven almost entirely
by scaling laws; “SMR Feasibility Study” (National Nuclear Laboratory, 2014),
https://www.nnl.co.uk/wp-content/uploads/2019/02/smr-feasibility-study-december-2014.pdf.
19. Edward S. Rubin et al., “A Review of Learning Rates for Electricity Supply Technologies,” Energy
Policy 86 (November 1, 2015): 198–218, https://doi.org/10.1016/j.enpol.2015.06.011.
20. “Copenhagen Atomics: The Story So Far,” Nuclear Engineering International, July 24 2024,
https://www.neimagazine.com/analysis/copenhagen-atomics-the-story-so-far/.
21. Clara Lloyd, Campbell Middleton, and Tony Roulstone, “The Impact of Modularisation Strategies on
Small Modular Reactor Costs” (ICAPP, Atlanta, GA., 2018),
https://www.researchgate.net/publication/329921662_The_impact_of_modularisation_strategies_on_
Small_Modular_Reactor_Costs.
22. Ibid.
23. “Can building nuclear power become more const effective?” Ernst and Young, 2016,
https://www.researchgate.net/publication/321715136_Small_modular_reactors_Can_building_nuclea
r_power_become_more_cost-effective.
24. Grace Symes, “Interview: TerraPower CEO Chris Levesque on Scaling Up New Nuclear,” Energy
Intelligence, December 13, 2024, https://www.energyintel.com/00000193-ad05-de9f-a1d3-
bded8c6b0000.
25. David Szondy, “Floating Nuclear Power Plants to Be Mass Produced for US Coastline,” New Atlas,
February 21, 2025, https://newatlas.com/energy/core-power-plans-mass-produce-floating-nuclear-
power-plants/.
26. “Overnight costs” are the cost of actual construction, excluding operational costs, interest, site
acquisition etc.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 68

27. Nuclear Energy Institute, “Nuclear Costs in Context,” February 2025,
https://nei.org/CorporateSite/media/filefolder/resources/reports-and-briefs/2024-Costs-in-
Context_final.pdf.
28. “Electric Power Annual,” U.S. Energy Information Administration, accessed December 7, 2024,
https://www.eia.gov/electricity/annual/index.php.
29. Steffen Schlömer (ed.), “Technology-specific Cost and Performance Parameters,” Annex III of
“Climate Change 2014: Mitigation of Climate Change,” Contribution of Working Group III to the Fifth
Assessment Report of the Intergovernmental Panel on Climate Change (2014),
https://www.ipcc.ch/site/assets/uploads/2018/02/ipcc_wg3_ar5_annex-iii.pdf.
30. Capacity factor is the average percentage of the maximum load that is produced, usually measured
annually.
31. DOE, “Nuclear Power is the Most Reliable Energy Source and It’s Not Even Close,” March 24 2021,
https://www.energy.gov/ne/articles/nuclear-power-most-reliable-energy-source-and-its-not-even-close.
32. Robin Gaster, “Why Wind and Solar Need Natural Gas: A Realistic Approach to Variability” (ITIF,
September 30, 2024), https://itif.org/publications/2024/09/30/why-wind-and-solar-need-natural-gas-
realistic-approach-to-variability/.
33. Sean Ong et al., “Land-Use Requirements for Solar Power Plants in the United States,” NREL 2013,
https://research-hub.nrel.gov/en/publications/land-use-requirements-for-solar-power-plants-in-the-
united-states.
34. “Advanced Small Modular Reactors,” Idaho National Laboratory (blog), accessed December 7, 2024,
https://inl.gov/trending-topics/small-modular-reactors/.
35. DOE, “Light Water Reactor Sustainability (LWRS) Program,” accessed March 26, 2025,
https://www.energy.gov/ne/light-water-reactor-sustainability-lwrs-program.
36. “Mid-Life Evaluation of F-Class Combined-Cycle Power Plants—Interim Report: Factors Affecting
Remaining Life of Critical Components” (EPRI), accessed December 9, 2024,
https://www.epri.com/research/products/000000003002016837.
37. Joseph Rand et al., “Queued Up: 2024 Edition, Characteristics of Power Plants Seeking
Transmission Interconnection as of the End of 2023,” Lawrence Berkeley National Laboratory (April
2024), https://emp.lbl.gov/news/grid-connection-backlog-grows-30-2023-dominated-requests-solar-
wind-and-energy-storage; This backlog may be cut by the new interconnection rule finalized by FERC.
See Ted Bloch-Rubin, “What FERC Order 2023 Means for the Interconnection Queue,” POWER
Magazine, April 4, 2024, https://www.powermag.com/what-ferc-order-2023-means-for-the-
interconnection-queue/.
38. Irina Slav, “Brits Pay Billions To Waste Wind Energy,” OilPrice.Com, December 3, 2024,
https://oilprice.com/Alternative-Energy/Wind-Power/Brits-Pay-Billions-To-Waste-Wind-Energy.html.
39. “US Grants $14mln for SMR Project in Romania,” CE Energy News, June 28, 2022,
https://ceenergynews.com/nuclear/us-grants-14mln-for-smr-project-in-romania/.
40. Nuclear Energy Agency, “The Costs of Decarbonisation: System Costs with High Shares of Nuclear
and Renewables” (OECD, 2019), https://doi.org/10.1787/9789264312180-en.
41. Éamonn Fetherston, Michael Kinzler, and Shelie Miller, “How could policies in the early 20th century
have shaped more sustainable transportation systems?” University of Michigan, accessed March 26,
2025, https://www.learngala.com/cases/model-t/.
42. America Hernandez, “France’s EDF to Redraft Small Modular Reactor Design amid Cost, Technology
Concerns,” Reuters, July 1, 2024, sec. Energy, https://www.reuters.com/business/energy/frances-edf-
drops-plans-develop-its-own-small-nuclear-reactor-technology-2024-07-01/.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 69

43. H. A. Tarantous, “Big Improvement in Comfort of 1925 Cars,” The New York Times, January 4,
1925.
44. Government of Japan, Fact Sheet on U.S. Nuclear Powered Warship (NPW) Safety,” accessed March
26, 2025, https://www.mofa.go.jp/region/n-america/us/security/fact0604.pdf.
45. Rod Adams, “ML-1 Mobile Power System: Reactor in a Box,” Atomic Insights, August 2022,
https://atomicinsights.com/ml1-mobile-power-system-reactor-box/.
46. Idaho National Laboratory (INL), “Advanced Small Modular Reactors” (Idaho Falls, ID: INL, n.d.),
https://inl.gov/trending-topics/small-modular-reactors/.
47. Clara A. Lloyd et al., “Transport, Constructability, and Economic Advantages of SMR
Modularization,” Progress in Nuclear Energy, vol. 134 (April 2021),
https://www.sciencedirect.com/science/article/pii/S0149197021000433.
48. Ibid.
49. “VOYGR Power Plants,” NuScale Power, accessed December 18, 2024,
https://www.nuscalepower.com/en/products/voygr-smr-plants.
50. “New Railcar Designed to Transport Spent Nuclear Fuel Cleared for Operation,” Energy.gov, accessed
December 30, 2024, https://www.energy.gov/ne/articles/new-railcar-designed-transport-spent-
nuclear-fuel-cleared-operation.
51. DOE, “Finding Better Ways to Transport HALEU,” accessed March 26, 2025,
https://www.energy.gov/ne/articles/finding-better-way-transport-haleu.
52. DOE, Office of Nuclear Energy, “Benefits of Small Modular Reactors (SMRs)” (Washington, D.C.:
DOE, n.d.), https://www.energy.gov/ne/benefits-small-modular-reactors-smrs.
53. IAEA, “Transporting Radioactive Materials” (IAEA: Vienna, Austria, n.d.),
https://www.iaea.org/topics/transporting-radioactive-materials.
54. U.S. EPA, “Transportation of Radioactive Material” (EPA: Washington, D.C., July 5, 2024),
https://www.epa.gov/radtown/transportation-radioactive-material.
55. Tracey Honney, “SMRs and the Transport Challenge,” Nuclear Engineering International, January 11,
2024, https://www.neimagazine.com/analysis/smrs-and-the-transport-challenge-11427709/.
56. IAEA “Working Group on Design and Safety Analysis: Phase 3 Report” (IAEA: Vienna, Austria,
December 2023), https://www.iaea.org/sites/default/files/24/02/smr_rf_phase_3_report_-
_safety_security_and_safeguards_from_a_regulatory_perspective_an_integrated_approach.pdf.
57. These levels are explicitly defined by NRC.
58. Erik Cothron and Zach Koshgarian, “From Reactors to Repositories: Disposal Pathways for Advanced
Nuclear Reactor Waste” (NIA, December 4, 2024), https://nuclearinnovationalliance.org/reactors-
repositories-disposal-pathways-advanced-nuclear-reactor-waste.
59. Matt Bowen, Maya Lameche, and Marine Gapihan, “Revisiting GTCC and GTCC-Like Nuclear Waste
Disposal in the United States,” July 24, 2024,
https://www.energypolicy.columbia.edu/publications/gtcc-and-gtcc-like-nuclear-waste-in-the-united-
states/.
60. Erik Cothron and Zach Koshgarian, “From Reactors to Repositories: Disposal Pathways for Advanced
Nuclear Reactor Waste” (NIA, December 4, 2024), https://nuclearinnovationalliance.org/reactors-
repositories-disposal-pathways-advanced-nuclear-reactor-waste.
61. “Finland Begins Trial Run of Onkalo Repository,” accessed December 5, 2024,
https://www.ans.org/news/article-6349/finland-begins-trial-run-of-onkalo-repository/; “Nuclear Power
in Finland - World Nuclear Association,” accessed December 5, 2024, https://world-
nuclear.org/information-library/country-profiles/countries-a-f/finland.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 70

62. “Search for a Repository in France: Application for Construction Licence Submitted,” Bundesamt für
die Sicherheit der nuklearen Entsorgung, accessed December 13, 2024,
https://www.base.bund.de/shareddocs/kurzmeldungen/en/2023/0118-repository-search-france.html.
63. “Canada’s Plan,” accessed December 19, 2024, https://www.nwmo.ca/en/canadas-plan.
64. Regeringen och Regeringskansliet, “Final Disposal of Spent Nuclear Fuel,” Text, Regeringskansliet
(Regeringen och Regeringskansliet, January 27, 2022),
https://www.government.se/articles/2022/01/final-disposal-of-spent-nuclear-fuel/.
65. “Radioactive Waste Management And Decommissioning In Hungary,” accessed December 19, 2024,
https://www.oecd-nea.org/rwm/profiles/hungary_report.pdf; U. S. Embassy Sofia, “USTDA Partners
with Bulgaria on Nuclear Safety,” U.S. Embassy in Bulgaria, December 13, 2024,
https://bg.usembassy.gov/ustda-partners-with-bulgaria-on-nuclear-safety/.
66. “IAEA Mission Says Czech Republic Manages Radioactive Waste and Spent Fuel Safely, Encourages
Preparations for Nuclear Power Expansion” (IAEA, November 1, 2023),
https://www.iaea.org/newscenter/pressreleases/iaea-mission-says-czech-republic-manages-radioactive-
waste-and-spent-fuel-safely-encourages-preparations-for-nuclear-power-expansion-0.
67. “Nuclear Phase-Out,” Bundesamt für die Sicherheit der nuklearen Entsorgung, accessed December
13, 2024, https://www.base.bund.de/en/nuclear-safety/nuclear-phase-out/nuclear-phase-
out_content.html; “Nuclear Power in Germany - World Nuclear Association,” accessed November 6,
2024, https://world-nuclear.org/information-library/country-profiles/countries-g-n/germany; “After the
Phase-out: Germany Grapples with Nuclear Legacy as Waste Challenge Remains,” Clean Energy Wire,
September 4, 2015, https://www.cleanenergywire.org/factsheets/what-do-nuclear-waste-storage-
question.
68. “Executive Summary of the Waste Plan,” ONDRAF/NIRAS, accessed December 19, 2024,
https://www.niras.be/sites/default/files/2023-02/A7-E%20Wasteplan-summary_0.pdf; Intern Editor,
“Belgium Approves The Surface Radwaste Storage Facility In Dessel,” ENS, May 18, 2023,
https://www.euronuclear.org/news/belgium-approves-the-surface-radwaste-storage-facility-in-dessel/.
69. “Radioactive Waste,” Nucleair Nederland, accessed December 19, 2024,
https://www.nucleairnederland.nl/en/subject/afval/.
70. “Potential Site Search for High-Level Radioactive Waste Disposal,” Xinhuanet, accessed January 3,
2025, https://english.news.cn/20240119/c6cbf2828f784063bec538f9154a2d77/c.html.
71. “China’s Nuclear Fuel Cycle - World Nuclear Association,” World Nuclear Association, accessed
January 3, 2025, https://world-nuclear.org/information-library/country-profiles/countries-a-f/china-
nuclear-fuel-cycle.
72. “Coping with Growth: China’s Spent Fuel Management Strategy,” Xinhuanet, accessed January 3,
2025, https://www.iaea.org/sites/default/files/publications/magazines/bulletin/bull60-2/6021616.pdf.
73. “Nuclear Accident in New Mexico Ranks among the Costliest in U.S. History,” Los Angeles Times,
August 22, 2016, https://www.latimes.com/nation/la-na-new-mexico-nuclear-dump-20160819-snap-
story.html.
74. Cothron and Koshgarian, “From Reactors to Repositories: Disposal Pathways for Advanced Nuclear
Reactor Waste.”
75. “Department of Energy Moves Forward with Consolidated Interim Storage Facility Project for Spent
Nuclear Fuel,” Energy.gov, accessed December 30, 2024,
https://www.energy.gov/ne/articles/department-energy-moves-forward-consolidated-interim-storage-
facility-project-spent; “Spent Fuel Storage in Pools and Dry Casks Key Points and Questions &
Answers,” NRC Web, accessed December 30, 2024, https://www.nrc.gov/waste/spent-fuel-
storage/faqs.html.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 71

76. Michael Barnard, “Nuclear Generation Has Huge and Hidden Security Costs,” The Future Is Electric,
July 13, 2021, https://medium.com/the-future-is-electric/nuclear-generation-has-huge-and-hidden-
security-costs-e0a11264bbac.
77. J. H. Crowley and J. D. Griffith, “US Construction Cost Rise Threatens Nuclear Option,” Nucl. Eng.
Int.; (United Kingdom) 27:328 (June 1, 1982), https://www.osti.gov/etdeweb/biblio/6776328.
78. Dominique Finon and Fabien Roques, “Financing Arrangements and Industrial Organisation for New
Nuclear Build in Electricity Markets” (Energy Policy Research Group, University of Cambridge,
2008), https://www.jstor.org/stable/resrep44783.
79. DOE, “Advanced nuclear commercial liftoff,” accessed March 26, 2025,
https://liftoff.energy.gov/advanced-nuclear-2/.
80. Symes, “Interview.”
81. World Nuclear Association, “Nuclear Power in China,” March 26, 2025. https://world-
nuclear.org/information-library/country-profiles/countries-a-f/china-nuclear-power.
82. Dominique Finon and Fabien Roques, “Financing Arrangements and Industrial Organisation for New
Nuclear Build in Electricity Markets” (Energy Policy Research Group, University of Cambridge,
2008), https://www.jstor.org/stable/resrep44783.
83. W. R. Stewart and K. Shirvan, “Capital Cost Estimation for Advanced Nuclear Power Plants,”
Renewable and Sustainable Energy Reviews 155 (March 1, 2022): 111880,
https://doi.org/10.1016/j.rser.2021.111880.
84. David Kemp and Peter M. VanDoren, “Nuclear Power in the Context of Climate Change: Comparing
the Cost of Nuclear and Fossil Fuel Power Plants with a Carbon Tax,” Cato Working Papers, no. 68
(July 26, 2022), https://doi.org/10.2139/ssrn.4239916.
85. Robbie Lyons and Tony Roulstone, “Production Learning in a Small Modular Reactor Supply Chain”
(The International Congress on Advances in Nuclear Power Plants, Charlotte, North Carolina, 2018).
86. NREL, “Annual Technology Baseline – Solar PV,” accessed March 26, 2025,
https://atb.nrel.gov/electricity/2023/utility-scale_pv.
87. EFI Digital Team, “Making Small Modular Reactors Bankable Investments,” EFI Foundation,
November 8, 2024, https://efifoundation.org/foundation-reports/making-small-modular-reactors-
bankable-investments/.
88. “Effective Frameworks and Strategies for Financing Nuclear New Build” (NEA\OECD, 2024),
https://www.oecd-nea.org/jcms/pl_96124/effective-frameworks-and-strategies-for-financing-nuclear-
new-build?details=true.
89. Ahmed Abdulla, Inês Lima Azevedo, and M. Granger Morgan, “Expert Assessments of the Cost of
Light Water Small Modular Reactors,” Proceedings of the National Academy of Sciences 110, no. 24
(June 11, 2013): 9686–91, https://doi.org/10.1073/pnas.1300195110.
90. “SMR Techno-Economic Assessment Project 1: Comprehensive Analysis and Assessment Techno-
Economic Assessment Final Report Volume 1 For The Department of Energy and Climate Change”
(Atkins, July 21, 2016),
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/665
197/TEA_Project_1_Vol_1_-_Comprehensive_Analysis_and_Assessment_SMRs.pdf.
91. W. R. Stewart and K. Shirvan, “Capital Cost Estimation for Advanced Nuclear Power Plants,”
Renewable and Sustainable Energy Reviews 155 (March 1, 2022): 111880,
https://doi.org/10.1016/j.rser.2021.111880.
92. TerraPower, “TerraPower Announces Strategic Agreement to Commercialize and Purchase HALEU,”
https://www.terrapower.com/terraPower-announces-strategic-agreement.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 72

93 “Centrus brings forward HALEU production date,” World Nuclear News, September 7, 2023.
https://nuclearstreet.com/pro_nuclear_power_blogs/b/world_nuclear_news/archive/2023/09/06/centru
s-brings-forward-haleu-production-date.
94. DOE, “Advanced nuclear commercial liftoff,” accessed March 26, 2025,
https://liftoff.energy.gov/advanced-nuclear-2/.
95. EIA, “Nuclear explained: where our uranium comes from,” accessed March 26, 2025,
https://www.eia.gov/energyexplained/nuclear/where-our-uranium-comes-from.php.
96. “China’s Nuclear Fuel Cycle, ” World Nuclear Association.
97. Christopher P. Pannier and Radek Skoda, “Comparison of Small Modular Reactor and Large Nuclear
Reactor Fuel Cost,” Energy and Power Engineering 2014 (April 30, 2014),
https://doi.org/10.4236/epe.2014.65009.
98. “Nuclear Organisations in China,” World Nuclear Association, http://www.world-
nuclear.org/information-library/country-profiles/countries-a-f/appendices/nuclear-power-in-china-
appendix-1-government-struc.aspx.
99. Stephen Ezell, “How Innovative Is China in Nuclear Power?” (ITIF, June 17, 2024),
https://itif.org/publications/2024/06/17/how-innovative-is-china-in-nuclear-power/; Gas-cooled Fast
Reactor (GFR), Lead-cooled Fast Reactor (LFR), Molten Salt Reactor (MSR), Sodium-cooled Fast
Reactor (SFR), Supercritical Water-cooled Reactor (SCWR), and Very High Temperature Reactor
(VHTR).
100. Stephen Ezell, “How Innovative Is China in Nuclear Power?” (ITIF, June 17, 2024),
https://itif.org/publications/2024/06/17/how-innovative-is-china-in-nuclear-power/.
101. Jonathan Deemer et al., “Uncharted Waters: Assessing China’s Intentions to Deploy Floating Nuclear
Power Plants in the South China Sea” (Center for Global Security Research, LBL, June 2023).
102. Alexander Glaser and M. V. Ramana, “Weapon-Grade Plutonium Production Potential in the Indian
Prototype Fast Breeder Reactor,” Science & Global Security 15, no. 2 (October 23, 2007): 85–105,
https://doi.org/10.1080/08929880701609154.
103. Dominique Finon and Fabien Roques, “Financing Arrangements and Industrial Organisation for New
Nuclear Build in Electricity Markets” (Energy Policy Research Group, University of Cambridge,
2008), https://www.jstor.org/stable/resrep44783.
104. EIA, “U.S. energy production exceeded consumption by record amount in 2023,” June 26, 2024.
https://www.eia.gov/todayinenergy/detail.php?id=62407.
105. Michael Barnard, “AI Electricity Demand Spike Already Drooping Due To Innovation,” CleanTechnica,
January 27, 2025, https://cleantechnica.com/2025/01/27/ai-electricity-demand-spike-already-
drooping-due-to-innovation/.
106. Ibid.
107. DOE, “Biden-Harris Administration Takes Action to Secure Nuclear Fuel Supply Chain, Equip
Revitalized Domestic Nuclear Industry for the Future,” April 19, 2024.
https://www.energy.gov/ne/articles/biden-harris-administration-takes-action-secure-nuclear-fuel-
supply-chain-equip.
108. David Holcomb, “Re-Evaluating the Thermal-Spectrum Molten-Salt Breeder Reactor Fuel Cycle in a
Modern Context” (INL, August 2023), https://inldigitallibrary.inl.gov/sites/STI/STI/Sort_67291.pdf.
109. Federal Register, Vol. 89, No. 211 Nuclear Regulatory Commission Proposed Rule, October 31,
2024, https://www.govinfo.gov/content/pkg/FR-2024-10-31/pdf/2024-23434.pdf.
110. Nuclear regulation has historically differentiated between reactors designed to produce power
commercially and reactors used for research, which were typically much smaller and were regulated

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 73

 more lightly (e.g., very small reactors could simply use steel containment vessels to ensure that no
radiation was released in the event of failure). That is not possible for large reactors.
111. This section benefitted substantially from comments by Nicholas McMurray, NIA.
112. Numerous expert studies have concluded that large reactors will only become significantly cheaper if
they can quickly move to NOAK production, which implies a fixed standard design.
113. International Atomic Energy Agency, “Small Modular Reactor (SMR) Regulators’ Forum” (IAEA:
Vienna, Austria, n.d.), https://www.iaea.org/topics/small-modular-reactors/smr-regulators-forum.
114. LPO, “Portfolio Projects,” accessed March 26, 2025,https://www.energy.gov/lpo/portfolio;
https://www.energy.gov/lpo/portfolio-projects.
115. DOE, “Inflation Reduction Act Tax Credit Opportunities for Hydropower and Marine Energy,”
accessed March 26, 2025, https://www.energy.gov/eere/water/inflation-reduction-act-tax-credit-
opportunities-hydropower-and-marine-energy.
116. Ernest J Moniz et al., “A Cost Stabilization Facility for Kickstarting the Commercialization of Small
Modular Reactors” (EFI Foundation, October 2023), https://efifoundation.org/wp-
content/uploads/sites/3/2023/10/20231011-CSF-FINAL-1.pdf.
117. “Clean Energy Powers American Business” (American Clean Power, 2022),
https://cleanpower.org/wp-content/uploads/2023/01/2022_CorporateBuyersReport.pdf.
118. Kristi E. Swartz, “Plant Vogtle Hits New Delays; Costs Surge near $30B,” E&E News by POLITICO,
February 18, 2022, https://www.eenews.net/articles/plant-vogtle-hits-new-delays-costs-surge-near-
30b/.
119. U.K. Department for Business, Energy & Industrial Strategy, “Future funding for nuclear plants: An
explanation of the Regulated Asset Base (RAB) model option,” October 26, 2021,
https://www.gov.uk/government/news/future-funding-for-nuclear-plants.
120. Michael Crabb, “Financing Nuclear in the UK: The Regulated Asset Base (RAB) Model vs. Contract
for Differences (CfD),” Last Energy, December 2023, https://www.lastenergy.com/blog/financing-
nuclear-in-the-uk-the-regulated-asset-base-rab-model-vs-contract-for-differences-cfd.
121. Ibid.
122. “Effective Frameworks and Strategies for Financing Nuclear New Build” (NEA\OECD, 2024),
https://www.oecd-nea.org/jcms/pl_96124/effective-frameworks-and-strategies-for-financing-nuclear-
new-build.
123. “Nuclear Energy,” Idaho National Laboratory, accessed November 20, 2024, https://inl.gov/nuclear-
energy/.
124. DOE, “Guide to Partnering with DOE National Laboratories” (Washington, D.C.: DOE, n.d.),
https://inl.gov/content/uploads/2023/06/Quick-Reference-to-Partnering-Final.pdf.
125. “Company News,” NANO Nuclear Energy Inc., accessed November 22, 2024,
https://nanonuclearenergy.com/nano-nuclear-energy-signs-strategic-partnership-project-agreement-
with-idaho-national-laboratory-for-an-expert-review-panel-of-its-zeus-micro-reactor-
design/?v=0b3b97fa6688.
126. Idaho National Laboratory (INL), “Cooperative Research and Development Agreement (CRADA)”
(Idaho Falls, ID: INL, n.d.), https://factsheets.inl.gov/FactSheets/CRADA.pdf.
127. “Advanced Nuclear Reactor Siting,” Idaho National Laboratory, accessed November 22, 2024,
https://inl.gov/inl-siting/.
128. Department of Defense, “DoD Breaks Ground on Project Pele: A Mobile Nuclear Reactor for Energy
Resiliency,” news release, September 24, 2024,

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 74

 https://www.defense.gov/News/Releases/Release/Article/3915633/dod-breaks-ground-on-project-pele-
a-mobile-nuclear-reactor-for-energy-resiliency/.
129. “Nuclear Energy Projects: DOE Should Institutionalize Oversight Plans for Demonstrations of New
Reactor Types” (GAO, September 2022), https://www.gao.gov/assets/gao-22-105394.pdf.
130. DOE, “Energy Department’s Advanced Reactor Demonstration Program Awards $20 million for
Advanced Reactor Concepts,” December 22, 2020, https://www.energy.gov/ne/articles/energy-
departments-advanced-reactor-demonstration-program-awards-20-million-advanced.
131. DOE, “Nuclear Energy: Supply Chain Deep Dive Assessment,” February 2022,
https://www.energy.gov/sites/default/files/2024-
12/Nuclear%2520Energy%2520Supply%2520Chain%2520Report%2520-
%2520Final%5B1%5D.pdf.
132. The higher enrichment offered through HALEU supports smaller designs, longer operating cycles, and
increased efficiencies over current technologies. HALEU is used in 9 of the 10 designs supported
under the ADRP.
133. INL, “National Reactor Innovation Center,” accessed March 26, 2025, https://nric.inl.gov/.
134. DOE, “National Reactor Innovation Center Fact Sheet,” accessed March 26, 2025,
https://www.energy.gov/ne/articles/national-reactor-innovation-center-fact-sheet.
135. DOE, Office of Nuclear Energy, “Advanced Small Modular Reactors (SMRs)” (Washington, D.C.: DOE,
n.d.), https://www.energy.gov/ne/advanced-small-modular-reactors-smrs.
136. DOE/ONE “Industry FOA Awardees,” accessed March 26, 2025, https://www.energy.gov/ne/industry-
foa-awardees-7.
137. ARPA-E, “Find a project,” accessed March 26, 2025, https://arpa-e.energy.gov/programs-and-
initiatives/search-all-projects.
138. DOE, “LPO Announces Conditional Commitment to Wisconsin Electric Power Company to Help
Maintain Reliability and Affordability Through Hydropower Rehabilitation and New Utility-Scale
Renewable Generation,” December 13, 2024, https://www.energy.gov/lpo/articles/lpo-announces-
conditional-commitment-wisconsin-electric-power-company-help-maintain.
139. “UK Announces Planning Reforms to Speed up Nuclear Projects,” World Nuclear News, February 6,
2025, https://world-nuclear-news.org/articles/uk-announces-planning-reforms-for-nuclear-projects.
140. Collin Leonard, “Hill Air Force Base Could Get Small Nuclear Reactor as Soon as 2028,” Carbon
Credits, January 21, 2025, https://www.ksl.com/article/51232191/hill-air-force-base-could-get-
small-nuclear-reactor-as-soon-as-2028; https://carboncredits.com/why-the-u-s-military-moves-toward-
nuclear-to-power-its-bases-in-2030s/.
141. Steve Hanley, “US Government Agrees To 10-Year Nuclear Power Plan,” Clean Technica, January 6,
2025, https://cleantechnica.com/2025/01/06/us-government-agrees-to-10-year-nuclear-power-plan/.

INFORMATION TECHNOLOGY & INNOVATION FOUNDATION | APRIL 2025 PAGE 75