A cross-disciplinary team from the University of Illinois Urbana-Champaign has submitted a public comment to the U.S. Nuclear Regulatory Commission (NRC) on the agency’s proposed Part 57 rule, a landmark regulatory initiative that would establish a dedicated licensing framework for microreactors and other advanced reactors with comparable risk profiles.
Developed pursuant to Section 208 of the ADVANCE Act, the proposed rule represents a significant step in the evolution of advanced reactor regulation in the United States and could help shape the future licensing pathway for emerging nuclear technologies.
The full public comment is available through the NRC’s public rulemaking docket.
The effort was led jointly by NPRE Professor Zahra Mohaghegh and Professor Arden Rowell of the University of Illinois College of Law. The research team also included George Joslin, a Ph.D. student in the Department of Nuclear, Plasma and Radiological Engineering (NPRE) and a graduate research assistant in Mohaghegh’s Socio-Technical Risk Analysis (SoTeRiA) Research Laboratory.
The Illinois team’s submission evaluates the technical and legal foundations of the NRC’s proposed licensing framework and examines whether the rule adequately satisfies the requirements of the Atomic Energy Act, the ADVANCE Act, and the Administrative Procedure Act.
The comment presents a comprehensive techno-legal analysis that integrates engineering, risk assessment, economics, and administrative law. The submission focuses on two principal questions:
- Whether the proposed safety framework provides an adequate technical and legal basis for demonstrating compliance with the NRC’s statutory obligations, including adequate protection, risk-informed and performance-based regulation, efficient licensing, and reasoned decision-making.
- Whether the NRC’s supporting regulatory analysis provides a balanced, evidence-based assessment of the rule’s costs, benefits, and alternatives and adequately supports the agency’s conclusions regarding regulatory efficiency.
The comment recommends that the NRC retain and continue developing cost-benefit analysis as an important tool for implementing the ADVANCE Act’s efficiency mandate while strengthening the evidentiary basis for both its safety determinations and regulatory analysis. Among other recommendations, the submission calls for additional technical and legal justification of the proposed safety criteria and accident-analysis methodologies, clarification of how cumulative impacts will be evaluated for multi-reactor deployment, and a revised regulatory analysis that more fully accounts for costs, benefits, alternatives, and uncertainty.
“Advanced reactor regulation is evolving during a period of significant technical, legal, and policy change,” said the research team. “Our work demonstrates how interdisciplinary research can help address uncertainty associated with these concurrent changes while supporting the development of more durable, efficient, and technically defensible regulatory frameworks.”
The submission builds on an ongoing collaboration between the SoTeRiA Research Laboratory in the NPRE Department and the University of Illinois College of Law examining how advances in reactor technology, risk assessment, and administrative law can transform the practice of nuclear regulation. The effort is part of a broader NRC-funded research program investigating risk-informed and performance-based approaches to advanced reactor licensing.
The comment was submitted to the NRC on June 15, 2026, and is now part of the public administrative record that the Commission will consider as it evaluates public feedback and develops the final Part 57 rule. The submission reflects the University of Illinois’ ongoing contributions to advancing interdisciplinary research at the intersection of engineering and law and to informing the future of advanced reactor regulation.
Disclosure: The views expressed in the public comment represent the professional judgment of the research team and do not necessarily reflect the views of the University of Illinois Urbana-Champaign or the U.S. Nuclear Regulatory Commission (NRC).