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Richard Zierer

Texas Doesn’t Need a Nuclear Moonshot. It Needs Comanche Peak 3 and 4.

By Richard Zierer · Structured Finance Attorney, Dentons · Member, American Nuclear Society, Texas Nuclear Alliance Views are my own and do not represent Dentons or its clients. The fastest large-scale nuclear expansion in Texas is hiding in plain sight. Texas has a growth-power problem. Not because the state is

The Paperwork Reactor: Why Nuclear Licensing's Documentation Burden Is a Structural Finance Problem

In 2022, Southern Nuclear Operating Company filed its Revision 11 update to the Updated Final Safety Analysis Report for Vogtle Units 3 and 4. The filing ran to 6,462 pages. That was just the UFSAR. Accompanying it were another 567 pages of Tier 1 design documentation, 60 pages of

The Shot Clock Problem: Why Nuclear Energy Needs Real Deadlines, Not Administrative Aspirations

When two companies file a Hart-Scott-Rodino (“HSR”) notification for a large merger, a clock starts. The antitrust agencies have thirty days to issue a Second Request. If they don't act within that window, the parties can close the transaction. The agencies retain authority to challenge the

The Boeing 737 Problem: Why Nuclear Energy Needs FAA-Style Type Certification

When the FAA certifies a new aircraft design, it certifies the design — once. Every subsequent aircraft built to that design rolls off the production line with the full benefit of that upfront regulatory work. An airline buying its fifteenth 737 MAX does not ask Boeing to re-engineer the wing.

Build What Works: Why America Should Deploy the AP1000—Now

America has a nuclear problem, but it’s not the one most people think. The issue isn’t whether nuclear power can be safe, clean, or affordable. The issue is that the United States has lost the habit of building large, complex infrastructure at scale—especially nuclear plants. If we