Nuclear Underpants Gnomes

Not long ago, my friend Nils Gilman introduced me to the underpants gnome meme. The meme derives from an episode of South Park, in which Kyle and the boys stay up all night in their friend Tweek Tweak's bedroom to see the underpants gnomes, who Tweek Tweak claims show up in the middle of the night to steal his underpants. When they finally meet the underpants gnomes, they learn that the gnomes are businessmen. They explain to the boys their three-part business plan:

1. Collect underpants
2. ?
3. Profit

The underpants gnomes has become a meme for ill-conceived business ideas. But it also pretty well describes a lot of nuclear advocacy over the years, particularly online advocacy, on X, Substack, and podcasts. The nuclear version of the underpants gnome business plan is even simpler: “just do x,” where x represents some obvious silver bullet. So “just build large light water reactors.” Or “just abolish the Nuclear Regulatory Commission.” Or “just stop building wind and solar” (or, alternately, “just stop fracking”). In each formulation, the slogan is magically achieved. Decarbonization or energy abundance or some other desired outcome then ensues.

It is easy to confuse this kind of advocacy with garden variety activist sloganeering. But these remedies are not simply pro-nuclear equivalents of “keep it in the ground” or “split wood, not atoms.” They are actually making quite specific, even wonky, policy and technical claims. And the slogans are not directed at the environmental or anti-nuclear movements or even undecided, on the fence, policy-makers or constituencies. Rather, they are almost always directed at other nuclear advocates, generally those of us who have actually developed detailed proposals and strategies to get nuclear built.

And so “just build large light water reactors” is not actually directed at any policymaker or business in a position to make such a decision but groups like Breakthrough that have spent a lot of time over the last decade advocating for policies that might make it feasible to license and commercialize small advanced reactors. And “just abolish the NRC” is directed at those of us who have spent the last decade working to reform the NRC and reduce the regulatory obstacles to nuclear technology innovation. And “just stop building wind and solar” is directed at groups that resist the technology tribalism that constructs energy technology policy as a series of zero sum conflicts between renewables and nuclear or clean energy and fossil fuels.

In all of these cases, the problem, according to the underpants gnome school of nuclear advocacy, is not that rebooting the US nuclear sector for the 21st century is a hard problem in the face of an ossified industry, an overbearing and underprepared regulator, liberalized electricity markets that are ill-suited to investing in large public works projects, and competition from both cheap gas and a mature, subsidized renewables industry. Rather, the problem is that other nuclear advocates are collecting the wrong kind of underpants.

Two recent examples will illustrate the dynamic.

Large Light Water Reactor Gnomes

A few months ago, I went on Chris Keefer’s Decouple podcast, which has a significant following among nuclear advocates, to debate Chris and James Krellenstein. Chris has recently started describing himself as a “reformed nuclear bro,” to denote his latter day conviction that small and non-light water reactors are little more than a fantasy and that large light water reactors are the only path forward (as a side note, this is actually the most nuclear bros take ever). Over the last several years, he has devoted countless episodes of his podcast to debunking the notion that anything other than a large light water reactor might ever get deployed at any meaningful scale, frequently featuring James as the house expert to validate his view.

What ensued, though, was not a knock down, drag out debate but a respectful conversation in which there was a surprising amount of agreement, at least between me and James. The reasons for this were twofold.

First, as opposed to debating a caricature of an SMR advocate, they had to debate me. And I have never suggested that SMR or advanced technologies were the only way forward or that they were a slam dunk, obvious technological fix. Commercializing economically competitive small and advanced reactors will require significant regulatory reform, to allow rapid iteration and innovation. It will require sufficient policy support for a select group of firms with good technology, significant capital, and smart business plans to build order books large enough to weather the inevitable challenges that come with working out the bugs in new technology, building supply chains, and developing manufacturing efficiencies. It will simultaneously require not prematurely down-selecting technology before we have a clear sense of which firms and technologies have a real shot at success.

And even then, success is by no means guaranteed. This is one potential path to a nuclear future which is in turn one potential path to a low carbon future, or at least one in which the world becomes a lot less dependent on fossil fuels. I believe that it is promising and worth pursuing and have done a lot of work to make it a reality over the last decade. But it is one path and we’ll see if it succeeds.

The second reason that we had so much agreement and so little debate was that Chris was not able to simply point out the challenges with small and non-light water reactors while ignoring the many challenges that rebooting the nuclear sector around large light water reactors in the United States and most other advanced developed economies face. The latter are formidable. As I have pointed out many times and did again in my discussion with Chris and James, there has been something of an iron law of successful deployment of large light water reactors that no country in the world has thus far deviated from. In virtually every case, large light water reactors were deployed by monopoly and frequently state-owned, vertically integrated utilities and deployed by national champion, if not state-owned, nuclear vendors. It is relatively easy to settle on a single, standardized, large light water design and build it over and over again in a centrally planned economy with a single, state-owned utility working hand and hand with a single state-owned nuclear vendor. Not so much in a market economy with a balkanized electricity sector, much of which is liberalized, and in which other industries, both fossil and renewable, have substantial interest.

This is the “?” between collecting large light water underpants and “profit” that advocates like Chris have virtually nothing to say about, other than some hand waving about the Tennessee Valley Authority. There is no detailed plan from any large light water advocate for centralized deployment of large reactors. No member of Congress has introduced legislation to nationalize the power sector or the nuclear industry so we can build large reactors at scale. The nuclear industry itself, I’m pretty certain, would oppose such an effort, as would pretty much every other energy interest. Even TVA keeps telling anyone who will listen that it wants to deploy small reactors going forward.

So until large reactor advocates come up with a serious plan to remake the power sector, reregulate power markets, or otherwise create the institutional conditions in which a major standardized deployment of large reactors could actually happen, “just build large light water reactors” will remain a slogan, not a serious political program in the US and much of the West.

Deregulation Gnomes

At the other end of the spectrum are the deregulation gnomes. A few weeks ago, Jack Devanney, a well known nuclear blogger and author penned a post taking Breakthrough and a number of other well-known nuclear advocacy shops to task for failing to be revolutionaries. Jack would like us all to collect more deregulatory underpants. He chides us for failing to understand that nuclear needs to be cheap to make much difference in the energy system and for advocating “token to meaningless changes at the NRC.”

I can’t speak for any of the other organizations that Jack calls out. But this is definitely news to me. The very first nuclear report that Breakthrough ever published, which marked the beginning of efforts by Breakthrough and others to advocate for advanced nuclear and regulatory reform at the federal level, was titled “How to Make Nuclear Cheap.” This title explicitly referenced Breakthrough’s prior and more general advocacy that any success mitigating climate change would require “making clean energy cheap,” a term that we invented and popularized in a 2008 article in the Harvard Law and Policy Review titled “Fast, Clean, & Cheap: Cutting Global Warming’s Gordian Knot,” the subtitle anticipating by about 15 years Jack’s Substack, which he calls “Gordian Knot News.”

Having taken a lot of flack, not least from other nuclear advocates and industry folks, for publicly criticizing the NRC for its slow pace of reform and for publicly opposing the confirmation of not one but two NRC commissioners that we did not believe were sufficiently committed to reform at the agency, I suppose that it is refreshing to be accused of not being sufficiently revolutionary in this regard. But then I read what Jack is arguing for and it’s mostly poorly conceived versions of things we advocated long before him.

Jack would like us all to know that nuclear has the highest energy density. This means that it should be really cheap. Who knew? Jack reminds us that nuclear offers not only a solution to climate change but energy poverty as well. Somebody give this man the Nobel Peace Prize. Jack chides us and others for being progressives who just want to throw subsidies at the problem rather than reform the regulatory system so that we can actually build cheap nuclear. Can’t remember where I’ve seen that criticism before.

Jack’s main beef is with the NRC’s use of a radiological health model called Linear No Threshold (LNT). This is not a novel complaint. It has been a standard point of contention for many nuclear advocates for a long time. LNT implies that no exposure to ionizing radiation, even at infinitesimally small doses, is safe. Many critics of LNT, including Jack, believe instead in hormesis, which posits that because humans, like all other animals, evolved with exposure to low doses of background radiation, low dose exposure to radiation is actually beneficial and aids cellular repair.

The problem with both LNT and hormesis for determining acceptable exposure to low doses of radiation is that both theories are functionally unfalsifiable. The exposures are so low that even if one accepts the LNT hypothesis, the effect is too small to be observable in human populations. The same is true of the benefits that would accrue were the hormesis hypothesis to be true. Defenders of LNT and proponents of hormesis, in other words, are debating entirely theoretical health effects that can’t actually be observed in human populations.

This points to the real problem with the NRC’s approach to radiological health, which is not that the agency uses a radiological health model that has no theoretical threshold below which health consequences stop but that it has failed to establish a reasonable and consistent regulatory threshold below which health consequences that are minimal and unobservable are deemed not a matter of regulatory concern. The problem, in other words, is not that the model has no stopping mechanism but that the regulator has no stopping mechanism.

Jack, in his various writings, finally gets around to proposing a regulatory threshold. But only after first proposing that we replace LNT with a different and equally unfalsifiable low dose radiological health model called SNT. It’s not at all clear why this is necessary, because Jack then calls for radiological health enforcement to be transferred to the EPA and based upon the EPA’s maximum individual lifetime cancer risk standard, which is based on the LNT model.

To his credit, and in contrast to the large reactor gnomes, Jack finally tells us what to do with the deregulatory underpants. He wants us to urge the Trump administration to transfer regulatory authority via executive order to the EPA. But this is a cure that is worse than the disease. Anyone even a little bit familiar with the EPA would know that the EPA is every bit as capable of overreach as the NRC. The nuclear industry would almost certainly oppose such a move and it is almost inconceivable that the Trump administration, which has set about dismantling much of the EPA’s regulatory authority, would do so.

It is also entirely unnecessary. As Breakthrough’s Adam Stein, with Kyle Danish from Van Ness Feldman, has demonstrated in two whitepapers published over the last year, the EPA approach to assessing ample margin of safety for exposure to ionizing radiation, the very standard that Jack proposes be enforced, is already the law of the land, established under amendments to the Federal Clean Air Act in 1990. So Congress has already established a regulatory threshold that applies to ionizing radiation. There is no need to replace LNT or to transfer regulatory oversight to the EPA. The NRC simply needs to follow the law.

By contrast, replacing one unfalsifiable health metric with a different one won’t much matter. And the fact that Jack proposes shifting the NRC’s regulatory remit to EPA amply demonstrates that if we abolished the NRC tomorrow, we would need to establish it all over again the next day. There is no plausible scenario in which the nation would not regulate the use, handling, and disposal of fissionable material in some fairly substantial fashion.

What does matter is ending, once and for all, the nuclear risk exceptionalism that has allowed the NRC to regulate exposure to ionizing radiation to a far stricter standard than comparable environmental health exposures, including those associated with fossil-based electricity generation. In this regard, principled, consistent advocacy, grounded in good science and law, will be plenty revolutionary enough.

In Defense of Underpants Gnomes

There is, of course, more than a grain of truth to much of what the nuclear underpants gnomes say. If climate change were a real, according to hoyle, existential threat to human societies—an asteroid, not diabetes—nationalizing the power sector and building large proven reactor designs as fast as we can would be both the fastest way to deeply cut emissions and a national imperative in just about every country in the world.

Under those circumstances, there wouldn’t be much point to deploying a lot of wind and solar as well. You’d just overbuild nuclear a bit to account for peak demand and run most of the plants most of the time. The current regulatory regime wouldn’t need that much change either. It’s not so different from China today or France in the 1970s and 80s, which have managed to build and operate large standardized reactor fleets cost-effectively. Regulating large reactor fleets that don’t feature a lot of ongoing design innovation but do have complex safety and operation procedures that require a lot of oversight is what the current regulatory paradigm, despite its many warts, was designed to do.

But that is not the sort of problem climate change is. Despite three decades of escalating rhetoric from advocates, it has not, and will not, motivate the same sort of response as the oil shocks of the 1970s, which motivated much of the global nuclear build out around the world. Moreover, few nations capable of deploying large nuclear at scale are heavily planned economies any longer and once you let the market liberalization genie out of the bottle, it is difficult to put back in.

That is why nuclear regulatory reform has come to the fore, particularly in the United States. Without significant design innovation, there is little reason to think that there is much future for nuclear energy in the liberalized electricity markets that account for over two-thirds of US electricity demand. That doesn’t mean that nuclear regulation can or should be abolished. But it will need to be fundamentally different, decoupled from 1970s era notions of radiological health risk and fears of catastrophic accidents, and simpler and more flexible to accommodate process innovation and manufacturing.

A decade ago, as the pro-nuclear movement was finding its legs, the underpants gnomes were a lot more useful. At a time when far fewer people understood the importance of nuclear energy, every pro-nuclear voice mattered, whether for large reactors, deregulation, or thorium reactors, even if those voices were often half-baked, short on details, or lacking pragmatism.

But today, we’ve won that debate. Both the public and policymakers, across the political spectrum, are with us. Talk, and slogans, particularly online, are cheap. My colleagues and I at the Breakthrough Institute don’t have all the answers. But we show up every day, at the NRC and in Congress to make the case for nuclear. And we work with developers who are trying to get their reactors licensed and built.

What you learn once you’ve been at that for a while is that getting from here to there is hard, not easy. Nobody knows how to build a large conventional reactor in a liberalized electricity market and no one knows how to license and build a small, non-light water reactor in any market. Until we crack one or both of those codes, a future powered by abundant nuclear energy will remain a dream, not a reality.