SMR pre-application engagement realism
The pre-application engagement timeline most SMR developers carry into the first NRC meeting is optimistic. We sketch what we now use as a planning baseline.
The optimism takes a consistent form: developer assumes that one or two pre-application meetings will produce sufficient agency feedback to lock the design's licensing strategy and that the application can then be filed within twelve to eighteen months. The reality across the past several SMR cohorts is that pre-application engagement has typically run two to four years before the application is submitted, with multiple topical reports and several rounds of agency feedback before the application package is in shape.
The drivers of the longer timeline are not opaque. The agency's review staff has limited bandwidth for any single design, and SMR review competes against operating-fleet license amendments, advanced-reactor work for other developers, and decommissioning oversight. The agency rightly wants the application to be in good shape before it accepts it for formal review. A weak application creates work for the agency that consumes the staff bandwidth needed for the next applicant.
Our planning baseline starts at three years of pre-application engagement, with a minimum of four substantive meetings, two to four topical reports submitted and accepted, and a documented set of design-specific licensing positions on the issues the agency has flagged. Programs that aim to compress this benefit from being honest about why they need to compress it; sometimes the compression is achievable with clear program priorities, and sometimes it is not.
The other planning consideration is on the topical-report strategy. Topical reports are the agency's mechanism for resolving generic technical positions that apply across multiple applications; getting a key topical report accepted before the application is submitted shifts a substantial chunk of review work off the application's critical path. Programs that file topical reports in parallel with their application package, rather than ahead of it, end up paying for the same review work in the application phase.