Mr. Richard Goorevich
Senior Policy Advisor
Office of Nonproliferation and International Security, NA 24
National Nuclear Security Administration
U.S. Department of Energy
1000 Independence Avenue, S.W.
Washington, D.C. 20585
Re: Proposed Rule on Assistance to Foreign Atomic Energy Activities, (RIN 1994-AA02)
Dear Mr. Goorevich:
As the Department of Energy (DOE) proceeds to update 10 C.F.R. Part 810, governing the export of commercial nuclear technology, we hope that the DOE will fully account for the fundamental global economic, political and technological changes, and enable U.S. suppliers to be competitive in a global market estimated by the Department of Commerce to be between $500 and $740 billion over the next decade.
The U.S. Chamber of Commerce, the world's largest business federation representing the interests of more than three million businesses and organizations of every size, sector, and region, as well as state and local chambers and industry associations, and dedicated to promoting, protecting, and defending America’s free enterprise system, strongly believes that the proposed Part 810 rule fails to correct the shortcomings of the current regulation and introduces new elements that have wide-ranging adverse consequences for the U.S. nuclear industry. If the proposed rule were to come into force, billions in U.S. exports and thousands of U.S. jobs would be put in jeopardy.
We fully endorse the detailed industry comment letter submitted by the Nuclear Energy Institute to the DOE on November 27, 2013, including the letter’s recommendations for amending the proposed rule.
The global revival of nuclear power offers the United States an opportunity to enhance its influence on global nuclear nonproliferation and safety norms while increasing U.S. exports, jobs, technology leadership, and energy security. We strongly urge DOE to amend the proposed rule to avoid unintended consequences for U.S. strategic and economic interests.
Sincerely,
R. Bruce Josten