Wednesday, April 22, 2026

U.S. Imperialism Enters a New Stage



 April 21, 2026

Image by Edgar Serrano.

Donald Trump’s rhetoric and actions against Iran, Venezuela and Cuba over the last year have few parallels in modern history. They have to be seen as marking a new stage. As such they call for a reevaluation of analysis and strategy on the part of the Left.

Trump’s repeated threat to bomb Iran “back to the Stone Ages where they belong” is unmatched by the rhetoric of even the most notorious and brutal heads of state over the recent past. Decapitating the entire leadership of a country to compel total submission, as Washington and Tel Aviv have done in Iran, is also a novelty in war strategy. The kidnapping of Venezuela’s president and First Lady as a first step in attempting to establish a colonial relationship by taking complete control of the country’s principal source of revenue, namely petroleum, represents a throwback to practices associated with centuries-old imperial rule

These are examples of “hyper-imperialism,” a concept theorized by Samir Amin to describe the United States “as the sole capitalist superpower.” More recently, the Tricontinental: Institute for Social Research has observed that U.S. hyper-imperialism persists despite a marked erosion of its economic and, though to a lesser extent, financial power. Its military supremacy is not only unrivaled, but is complemented by hybrid warfare, most notably “hyper-sanctions” and the use of lawfare.

What needs to be added to the concept of hyper-imperialism, particularly Trump’s version of it, is its sui generis nature. To find a parallel for the kind of hegemony the United States now exercises – highlighted by the continuous indiscriminate use of force and the threat of it – one would have to look back to the Roman empire or even earlier. One of Trump’s innovations is his deployment of the military to reinforce the system of economic sanctions, examples being the interdiction of oil tankers, the quarantine of Cuban oil, and full-scale war against Iran.

Trump II’s foreign policy hardly represents a complete break from the past. The groundwork was laid by past Democratic and Republican administrations. However, his actions force the Left not only to reformulate strategies, but to reconsider past evaluations and analyses of nations of the Global South subjected to extreme forms of imperialist aggression. The resistance to U.S. aggression must be given greater weight when evaluating governments. In addition, the popular desperation and exhaustion that erode revolutionary fervor and distance people from those same governments should be understood in light of the daily trauma people endure as a direct result of imperialist actions.

What Trump’s hyper-imperialism tells us

The starting point is to recognize that since Trump’s return to the White House, Iran, Venezuela and Cuba have been in a de facto state of war, which is an escalation of the multiple forms of hostility and aggression of past years. This is key to how all three nations should be judged. While the Left’s commitment to democracy needs to remain unquestionable and unwavering, in these cases primary responsibility for democracy’s somewhat uncertain prospects lies with the siege imposed by imperialist powers. No one other than James Madison said “Of all the enemies to public liberty, war is perhaps the most to be dreaded.”

The encirclement imposed by hyper-imperialism on Iran, Cuba, and Venezuela illuminates salient features of imperialism going back in time: first, Washington has honed the sanctions regime into a powerful tool, sometimes inflicting damage comparable to armed intervention; second, imperialism is the principal driver of the pressing economic problems facing the three nations; third, the justification for the actions taken against the three nations does not hold up under scrutiny; and fourth the brutality of the sanctions system underscores the need for its complete elimination. The discussion below looks at these points.

Tehran’s response to Operation Epic Fury underscores the crushing impact of sanctions. The nation’s leaders have made clear that the lifting of sanctions – as well as “international guarantees of U.S. non-interference” in the nation’s internal affairs – is a non-negotiable condition for ending the current conflict. That is to say, the Iranian leaders place the destruction caused by the sanctions on a similar footing as the bombs.

In the case of Venezuela, the events leading up to the abduction of Nicolás Maduro and Cilia Flores on January 3, 2026 reveal the far-reaching and highly coordinated machinery underpinning the sanctions regime. The second Trump administration’s tracking of the “ghost fleet” carrying Venezuela’s sanctioned oil—and its interdiction of several of those vessels— underscores how far Washington has gone in perfecting sanctions enforcement since the early years of the Cuban Revolution.

The first Trump administration pioneered in promoting “overcompliance” in which Washington’s well-publicized monitoring was designed to assure that companies and financial institutions world-wide would shun all transactions with Venezuela, even ones not specifically targeted by the sanctions. The aim was to impose a veritable blockade. Mike Pompeyo and Elliot Abrams spearheaded a campaign – drawing on the FBI, the Treasury, U.S. embassies, and the intelligence community – to scrutinize the dealings of companies worldwide with Venezuela, in what amounted to a warning shot to companies throughout the world. Even firms that engaged in oil-for-food swaps, which were not proscribed by the sanction regime, were warned that they ran risks. Companies under investigation were likewise told that penalties could be suspended if they halted all dealings with Venezuela.

A retrospective look at the first Trump administration’s sweeping enforcement measures and their devastating impact reinforces the argument that the sanctions have been so harmful that they need to be dismantled unconditionally and entirely. This position contrasts with that of liberals such as the Washington Office on Latin America (WOLA), which criticized the sanctions against Venezuela yet called for using “negotiations to flexibilize financial and oil sanctions” as leverage to secure concessions. Indeed, power brokers in Washington also favored sanctions relief as a bargaining tool to push the Maduro government to enact market-oriented reforms to the benefit of U.S. capital.

A full grasp of the scale and severity of Washington’s “war” on Venezuela undercuts the notion upheld by some on the left who argue that the sanctions were no more to blame for the nation’s pressing problems than government mismanagement. An even harsher position on the left affirms that the sanctions “do not explain the root causes of the societal collapse we have lived through.”

Likewise, the forcible removal of Maduro and Flores demonstrates that Washington was intent on dismantling a government whose example and policies ran counter to U.S. interests. Prior to the January 3 kidnapping, some on the left in Venezuela and elsewhere denied that Washington sought to remove Maduro from power because they were convinced that he had effectively sold out. But they were wrong insofar as Washington clearly wanted Maduro out. Pedro Eusse, a leading member of the Communist Party of Venezuela (PCV), which broke with the Maduro government in 2020, wrote in July 2025, “Everything indicates that the true intention of the US and its allies’ policy of aggression toward the Venezuelan government has not been its overthrow, but its subordination.”

In the case of Cuba, the extreme measures of the Trump II administration against the nation also shine light on the cruelty and effectiveness of the system of sanctions per se. Trump’s navy-enforced quarantine on oil shipments is a first for the nation since the October 1962 missile crisis. The result has been recurring 16-hour blackouts that have disrupted water delivery, hospital operations, food production, and garbage collection.

The quarantine spotlights Cuba’s near total dependence on oil, in contrast to nearby Jamaica and the Dominican Republic, which generate a significant share of their electricity from coal and natural gas. The dependence stems precisely from the sanctions, which impeded imports and pushed Cuba into relying almost entirely on Venezuelan oil—only for Trump to cut off that supply too.

Indeed, the quarantine underscores Cuba’s reliance on Venezuelan oil and the reciprocal solidarity that saw fuel exchanged for Cuban medical personnel. That’s a plus for Maduro. The program undercuts the claim of some on the left that Maduro’s foreign policy, in the words of the PCV, never moved beyond an “anti-imperialist rhetoric” without substance.

The Washington-crafted narrative on Cuba and the reaction to it by the mainstream media and the Left are curious. In contrast to the demonization directed at Venezuela and Iran, Washington’s condemnation of Cuba has been relatively hollow and has gained little traction in mainstream outlets or left-leaning circles. The anti-Cuba vilification—driven by hardline anti-Communism—remains largely confined to the far right, epicentered in Miami. The official rhetoric is a departure from the wording in 1982 when the State Department designated Cuba as a State Sponsor of Terrorism due to “its long history of providing advice, safe haven, communications, training, and financial support to guerrilla groups and individual terrorists.” Now the Trump administration’s justification for the same designation is that the Cuban government grants “safe harbor to terrorists” and refuses to extradite them.

As false as the narco-terrorism case against Maduro is, it nonetheless offered a rationale that undoubtedly resonated with at least a slice of public opinion. Compare that to Marco Rubio’s line on Cuba which flatly denies the catastrophic effects of the oil quarantine. Rubio claims “we’ve done nothing punitive against the Cuban regime” and adds, the blackouts “have nothing to do with us.” Instead Rubio faults the Cuban leadership on grounds that “they want to control everything.” A classic case of victim-blaming, but with few buying into it. A YouGov survey in March found that only 28 percent of U.S. adults support the U.S.’s blocking of oil shipments to Cuba, as opposed to 46 percent opposed.

In addition, Rubio’s assertion that the only novelty is that Cuba is “not getting free Venezuelan oil anymore” is blatantly fallacious. Rubio is well aware of Venezuela’s swap with Cuba involving the latter’s International Medical Brigades, which maintain a sizeable presence in Venezuela and elsewhere. This is precisely why Rubio has vigorously attempted to sabotage the program throughout the region, unfortunately with a degree of success.

If the oil quarantine demonstrates anything it’s that the hardships facing the Cuban people are rooted in Washington’s war on Cuba, now going on 65 years. Criticism of Cuban government policies, or of socialism itself, comes in a distant second place.

The Trump II disaster should be an eye-opener

Trump’s bullying offensive abroad has fueled mounting opposition to interventionism and has even fostered anti-imperialist sentiment in the United States. Just one week into the 2026 Iranian bombings, 53 percent of the U.S. population opposed the strikes, in sharp contrast to U.S. military involvement in Vietnam, the Gulf War, Afghanistan, and Iraq, which enjoyed large majority support at the outset. That the former editor of The New Republic called the U.S. war on Iran imperialistic is telling. In a New York Times op-ed, Peter Beinart wrote “Donald Trump’s foreign policy vision is imperialism.”

One lesson of recent events is particularly relevant for the Left: the demonization of heads of state is a sine qua non for military intervention. In the case of Iran and Venezuela, the discrediting combines some fact with a large dosage of fake news. In the case of Maduro, the demonization which dates back to shortly after he assumed office in 2013, was taken to higher levels as a result of the controversial presidential election of July 28, 2024, which the opposition claimed was fraudulent. Subsequently the corporate media consistently tagged the word “autocrat” and “dictator” onto Maduro’s name. Six months later, Trump was in office and the vilification escalated to a new pitch. Indeed, the branding of Maduro as a narco-terrorist was an indispensable prelude to the bombing of boats in the Caribbean and the subsequent kidnappings – notwithstanding the doubts raised by some media outlets regarding the veracity of the claim.

The takeaway is that the Left needs to distinguish between criticism and demonization and take cognizance of the possible dire consequences of the latter.

The demonization of Supreme Leader Ali Khamenei and his inner circle also set the stage for imperialist actions, but, of course, his government could not be placed in the same category as those of Cuba and Venezuela. The Iranian government is theocratic, not leftist, and it actively defends patriarchal values. Furthermore, the level of lethal repression unleashed during the Woman, Life, Freedom protests in 2022—and in the demonstrations that erupted beginning late last year—has no parallel in Venezuela or Cuba.

Nevertheless, the U.S.-imposed stranglehold on Iran makes a peaceful path to democratization highly unlikely. Furthermore, as in Venezuela and Cuba, harsh sanctions have been conducive to shadow economies, clientelistic networks, and fraudulent dealings, patterns well documented in numerous studies on sanctions throughout the world.

Eskandar Sadeghi-Boroujerdi, a prolific scholar on Iran who is highly critical of the government, told Jacobin “While the Islamic Republic is paranoid, it is also very much under siege from all sides.” He also notes the intrinsic relationship between the sanctions and the nation’s pressing problems: “Sanctions and structural weaknesses of the Iranian economy feed off one another — there’s a symbiotic relationship between them.”

In short, any serious reading of Iran must foreground the role of sanctions—an approach that inevitably tempers the tendency to cast its leadership in purely demonizing terms.

The lessons of July 28, 2024

The issue of the accurateness of the July 28, 2024 election tallies in Venezuela needs to be reframed. Those elections could not have been democratic, regardless of the announced results, because Venezuelan voters had a gun pointed at their heads: reelect Maduro and the sanctions continue; elect an opposition candidate and the sanctions will be lifted.

The overwhelming majority of Venezuelans knew full well what was at stake. Luis Vicente León – the nation’s leading pollster, himself a member of the opposition – reported that 92 percent of the population believed that the sanctions negatively impacted the economy, and most characterized the effect as “very negative.” (The poll puts the lie to the State Department’s repeated claim that the sanctions only harm government officials.)

A similar scenario played out in the Nicaraguan presidential elections of 1990 when opposition candidate Violeta Chamorro upset the Sandinistas in the midst of a devastating, U.S.-promoted civil war. But there was a fundamental difference. Far from demonizing the Sandinistas, Chamorro accepted a power-sharing transition agreement with them. In contrast, for over a decade prior to the July 28 elections the opposition’s main leader, María Corina Machado, had ruled out negotiations with those who had allegedly violated human rights. She never tired of voicing the slogans “no immunity,” ”no to amnesty,” “no agreements with criminals,” often with specific reference to the Chavistas and to Maduro himself. Maduro and his followers had every reason to fear the type of repression that the opposition initiated during the two-day abortive coup it staged in April 2002 against the Chavista government. Even opposition pollster León admitted that the fear was well-founded.

Marta Harnecker, the renowned leftist theoretician, wrote that the Sandinistas erred in holding the 1990 elections amid U.S.-promoted violence and sabotage. Harnecker labeled the decision to organize elections “on terrain shaped by the counterrevolution” a “strategic error.”

A reevaluation and reinterpretation of the July 28 elections is instructive. The hard-core Chavistas accept the official results which showed Maduro winning with nearly 52 percent of the vote. The opposition refutes that claim. A third position is defended by supporters of Maduro who nevertheless express skepticism and point out that because of a massive hacking attack from outside the country, it may be impossible to ever know the true count.

The debate about the accuracy of the official results of July 28 sidesteps the overriding issue of whether the elections should have been held in the first place. Indeed, the idea of conditioning elections on the lifting of sanctions was not far-fetched. A year before the elections, Maduro, in a reference to the United States, declared: “If they want free elections, we want elections free of sanctions.” Subsequently, Elvis Amoroso, the Chavista head of the nation’s electoral council, tied the participation of European Union electoral observers to its lifting of sanctions. At the same time, the Biden administration indicated its willingness to bargain with the Venezuelan government along those lines.

Carlos Ron, a former vice-minister and currently an analyst for Tricontinental, told me that the Chavista leadership ruled out delaying the elections in order to demonstrate its democratic credentials in the face of the international smear campaign. Ron said “At that moment, greater importance was placed on the need to defend the democratic character of the Bolivarian political process and its continuity, and abide by the Constitution, in the face of imperialist pressures.”

Maduro’s intentions may have been commendable. But the decision overlooked one compelling reason to suspend the electoral process. Tying the holding of elections to the removal of the sanctions would have placed the entire blame for setbacks to democracy where it belonged: U.S. intervention in Venezuela’s internal affairs.

In defense of democracy

As a rule, the Left has always championed the defense of democracy. In this sense, the Left’s vision compares favorably with U.S.-style “liberal democracy,” shaped by the influence of big money and other inherently undemocratic practices such as gerrymandering, the Electoral College and voter suppression.

Historically, however, the Left has faced formidable obstacles on this front. For instance, it has come to power in countries like Russia, China and Cuba that were lacking in democratic tradition. That, however, was the least of the problem. Its main problem has been, and continues to be, imperialist hostility which limits options.

Precisely for that reason, the Left needs to tread cautiously in the way it frames the issue of democracy in nations that are in the crosshairs of imperialism. In the three countries discussed in this article, the Left can’t deny that democracy has been infringed upon. The Maduro government, for instance, stripped the PCV – the country’s oldest political party, forged in a history of militant struggle including two periods of clandestine resistance and armed struggle in the 1950s and 1960s – of its legal status, transferring recognition to a marginal breakaway faction that appropriated its name and symbols.

Nor can it deny that discontent is currently widespread in the three nations, which became most evident in the Iranian “Woman, Life, Freedom” protests and those of the first days of this year. In Cuba and Venezuela, protests reflect widespread disillusionment, even while the mobilizations have been manipulated and financed from abroad.

One troubling sign in Venezuela is that the disturbances have spread out from upper-middle class neighborhoods where they were confined during the 4-month protests (the “guarimba”) of 2014 and, albeit less so, during those of 2017. The two days following the July 28, 2024 elections, for instance, protests were registered in Caracas barrios such as Petare, the city’s largest. Reflecting on the protests, long-standing Caracas resident and international commentator Phil Gunson reported “Petare is a traditionally Chavista zone, but ever since a few years ago, people have been distancing themselves from the government.”

The Left can’t turn its back on this reality. But nor can it join mainstream voices that channel dissatisfaction into blanket vilification of governments under imperial siege. Rather its line has to be basically: “What do you expect!” In the face of hyper-imperialist aggression these countries are at war, figuratively and in some cases literally speaking. Criticism needs to be framed within this context.

Lenin’s concept of democratic centralism – the principle designed to guide the internal workings of his political party – is instructive. In his writing throughout his political career, party democracy remained a constant, but the degree of centralism depended on the political climate in the nation. Along similar lines, the Left’s adherence to democracy can never be minimized. However, valid criticism of undemocratic practices in countries like Venezuela and Cuba in which the Left is in power needs to be viewed as overreactions to imperialist aggression.

In this era of intensified hyper-imperialism, the Left is compelled to stand behind nations like Cuba and Venezuela, and recognize that the real blame for backsliding including violation of democratic norms lies with imperialism. The barbaric actions of Trump II are making this imperative clearer than ever.

Steve Ellner is a retired professor of the Universidad de Oriente in Venezuela where he lived for over 40 years and is currently Associate Managing Editor of Latin American Perspectives. He is the author and editor of over a dozen books on Latin American politics and history. In 2018 he spoke in over twenty cities in the U.S. and Canada as part of a Venezuelan solidarity tour.









  1. Karl Kautsky: Ultra-imperialism (1914) - Marxists Internet Archive

    Nov 9, 2023 · One particular form of this tendency is imperialism. Another form preceded it: free trade. Half a century ago, free trade was seen as the last word of capitalism, just as imperialism is today. …

U$A

A Guide to Commenting on Rules Removing Public Oversight of Nuclear Reactor Safety


April 22, 2026

Public comments on two new NRC rules are due soon — May 4 and May 18, 2026. This is a quick guide on what these rules do and how to submit comments that carry legal weight, even if you have never done it before.

The Nuclear Regulatory Commission (NRC) is undergoing a radical restructuring that is happening so fast it’s hard for the public to keep up — but public participation has never been more important. Two rules published in April 2026 would permanently remove the public from the safety review process for new commercial nuclear reactors.

On April 2 the NRC published a proposed rule that would allow companies seeking commercial nuclear reactor licenses to substitute a secret Department of Energy (DOE) or Department of War (DOW) internal safety authorization for the NRC’s own independent safety review. Those DOE safety reviews are not just secret — they have been secretly rewritten.

Here is what that means in practice. A startup company with no commercial nuclear track record tests a small experimental nuclear reactor under a secret DOE safety review that the public never sees. It then walks into the NRC and uses that secret authorization to satisfy the commercial nuclear reactor safety requirement. Because the public had no access to the underlying safety study, it has no basis to challenge the license in court.

Valar Atomics is one such startup. Founded in 2023 and backed by defense AI giant Palantir, it was one of eleven companies selected by the DOE to race toward nuclear reactor criticality by July 4 under a program that bypasses NRC licensing entirely. Its nuclear reactor — a 100 kilowatt device the size of a shipping container — will be tested under a secret DOE safety review with no independent observer and no public verification of whether the test succeeds or fails. The July 4 deadline is a White House political target, not a safety milestone. Valar has already stated publicly what the April 2 rule means for its plans to expand from a test nuclear reactor to full commercial scale deployment: “We cannot achieve this necessary scale if every subsequent commercial application is forced to re-litigate foundational safety demonstrations that have already been validated by the Department of Energy or the Department of War.” Industry lawyers are already advising clients to use this kind of pilot nuclear reactor data to seek NRC approval for “10 to 20 units on a commercial AI campus.” The NRC would be directed to accept a secret safety review conducted on a nuclear reactor the size of a shipping container as the foundation for licensing nuclear reactors potentially 100 times larger, operating for 40 to 80 years, next to civilian communities.

On April 17 the NRC published companion Interim Staff Guidance (ISG) — a procedural document telling NRC staff how to implement the April 2 rule — which amounts to instructions to defer to the DOE and DOW with no independent judgment required. This is consistent with what recent investigations by ProPublica and E&E News have found: that the NRC no longer functions as an independent regulatory agency, with its draft rules now subject to White House review and the DOE directing major agency decisions. Over 400 NRC staff have departed since Trump took office. Under executive orders with a hard November 2026 deadline, the agency is being systematically redirected to serve the administration’s nuclear energy agenda.

Why Your Comment Matters — and How It Works

The NRC nuclear reactor licensing process normally has two separate parts — a safety review and an environmental review governed by the National Environmental Policy Act (NEPA). Both are required by law and the public — which includes individuals, community groups, environmental organizations, and indigenous nations — gets to comment on both. Those comments create the legal record necessary to challenge agency decisions in court. Without them there is no basis for a legal challenge. For an example of how the same pattern of secrecy is playing out in the environmental review process, see my recent article on the Paducah Laser Enrichment Facility.

NRC comment periods are typically 30 days or less — barely enough time for most people to learn a rule exists, let alone analyze it. But you do not have to be an expert to submit a comment. You can reference the technical arguments of others in your submission, which incorporates those arguments into the administrative record under your name and strengthens the legal foundation for any future court challenge. You can also copy and paste any part of this article, including the bullet lists below, directly into your comment.

By searching the NRC docket online I found detailed, fully cited technical comments submitted by Fred Schofer, a former NRC Regulatory Analysis Team Lead and Rulemaking Project Manager who spent 16 years at the agency before retiring in April 2024. His analysis is the most rigorous I have encountered in years of covering nuclear regulatory policy. He submitted detailed comments on the April 2 rule and followed with a 19-point formal comment on the ISG on April 19. At the time of publishing his ISG comment had not yet posted — search his name at the ISG docket and it will come up. Here are the highlights of both.

April 2 Rule — Docket NRC-2025-1503

+DOE and DOW are not regulatory agencies. The NRC was created in 1974 specifically to separate nuclear promotion from nuclear regulation because the Atomic Energy Commission had tried to do both and the conflict of interest proved irreconcilable. Neither DOE nor DOW has safety standards equivalent to the NRC’s independent framework.

+No objective acceptance criteria. Companies self-certify that a prior secret authorization satisfies NRC safety requirements with no defined standard for when it does.

+The safety basis cannot be scaled. The NRC’s own regulations define a prototype plant as one similar to a commercial design “in all features and size.” A nuclear reactor tested at small scale under a secret DOE authorization fails that definition for any commercial application and the April 2 rule never acknowledges this conflict. As Fred writes: “every application that references a materially differently-sized prior authorization contains an unresolved regulatory deficiency that an intervenor can contest at the licensing stage, and a petitioner can challenge directly in the courts of appeals within 60 days of final rule publication.”

+Multiple nuclear reactors on one site not addressed. The rule contains no requirement to analyze how multiple nuclear reactors interact through shared infrastructure and combined accident consequences — yet industry lawyers are already advising clients to seek approval for 10 to 20 units on one campus using a single prototype authorization.

+Classified military material could form the safety basis for a commercial license the public cannot examine or challenge in a hearing.

+The regulatory analysis is empty. The NRC admitted it could not quantify costs or benefits, violating its own guidelines.

April 17 ISG — Docket NRC-2026-0760

+All ten appendices instruct NRC staff to defer to DOE or DOW authorization “to the maximum extent practical” with no evidentiary threshold and no methodology for determining when secret information is sufficient.

+Part 53 — the new advanced nuclear reactor licensing framework that took effect April 29, 2026 and is the most likely licensing pathway for the companies this rule was designed for — is completely omitted from the guidance.

+No framework for AI-generated license applications. In March 2026 DOE demonstrated using artificial intelligence to convert a DOE safety document into a 208-page NRC license application in 24 hours. Neither the rule nor the ISG requires disclosure of AI use or any quality assurance for AI-generated content.

+Several pilot program nuclear reactors use high-assay low-enriched uranium TRISO fuel (HALEU TRISO) enriched up to 20% — four times higher than standard commercial nuclear reactor fuel. Fuel qualification data from a prototype-scale nuclear reactor does not automatically transfer to a larger commercial design and the ISG provides no guidance on this.

+One appendix contains a blank section where a required legal analysis should appear with a placeholder reading “discussion to be provided in final ISG.”

Fred’s conclusion: the ISG is “unfit for finalization.”

What To Submit — Copy, Paste, Done

Comments can be submitted online at regulations.gov. You can copy and paste any part of this article — including the bullet lists above — directly into your comment. The sample comments below reference Fred’s docket submissions, which formally incorporates his technical arguments into the administrative record under your name. You can add your own words or submit as written.

For the April 2 rule — deadline May 4, 2026

Submit online at: https://www.regulations.gov/docket/NRC-2025-1503

I oppose the proposed rule “NRC Reviews of Reactor Designs Previously Authorized by U.S. Department of Energy or Department of War,” Docket ID NRC-2025-1503. Independent NRC safety review is a non-delegable mandate under the Atomic Energy Act and cannot lawfully be replaced by secret DOE or DOW internal authorizations that the public cannot access or challenge. I incorporate by reference and adopt as my own the comments submitted to this docket by Fred Schofer, former NRC Regulatory Analysis Team Lead, which identify specific legal deficiencies including the absence of objective acceptance criteria, the unresolved conflict with the NRC’s own prototype definition, the failure to address prototype-to-commercial scaling, and the inadequate regulatory analysis. I request that this proposed rule be withdrawn.

For the April 17 ISG — deadline May 18, 2026

Submit online at: https://www.regulations.gov/docket/NRC-2026-0760

I oppose Interim Staff Guidance DANU-ISG-2026-XX, Docket ID NRC-2026-0760. Independent NRC safety review cannot be reduced to blanket deference to secret DOE or DOW authorizations. I incorporate by reference and adopt as my own the comments submitted to this docket by Fred Schofer, former NRC Regulatory Analysis Team Lead, which identify 19 formal deficiencies including the omission of Part 53, the absence of multi-unit risk assessment requirements, and the lack of any framework for AI-generated license application content. I request that this guidance be withdrawn and reissued after proper public notice-and-comment.

To read Fred Schofer’s comments in full: his April 2 comment is here. His ISG comment will be posted to the second docket shortly — search his name when you get there.

If you are already submitting comments, the Paducah Laser Enrichment Facility draft Environmental Impact Statement also has a public comment deadline of May 11, 2026. I have written about that proceeding and submitted my own comments. You can submit yours at https://www.regulations.gov/docket/NRC-2025-1007.