Comment (3) of TerryAnn Towers Saint Amand on FR Doc # 2026-11915, NRC-2026-0265-0005, from TerryAnn Towers Saint Amand

Re: NRC-2026-0265 – Pioneer Units 1 and 2 Phased Construction Permit Application and Environmental Impact Statement Scoping Thank you for the opportunity to comment on the scope of the Environmental Impact Statement for the proposed Pioneer Units 1 and 2 Small Modular Reactor project at the Palisades Energy Center. I encourage the NRC to prepare a comprehensive Environmental Impact Statement that fully evaluates both the direct and cumulative environmental effects of this proposal before any irreversible construction activities proceed. Small Modular Reactors may contribute to future low-carbon electricity generation, but their environmental impacts must be evaluated with the same rigor expected of any major infrastructure project. Public confidence depends upon an environmental review process that is thorough, transparent, science-based, and independent. The EIS should carefully evaluate cumulative impacts associated with the proposed reactors together with the existing and proposed activities at the Palisades site. The combined effects on Lake Michigan, surrounding ecosystems, local communities, transportation systems, emergency planning, and long-term waste management should be assessed rather than considering each project component in isolation. Water resources deserve particular attention. The EIS should evaluate cooling-water withdrawals, thermal discharges, aquatic habitat, fisheries, invasive species pathways, changing lake conditions associated with climate change, and potential cumulative impacts on Lake Michigan over the full operating life of the facility. The analysis should also address climate resilience. Future operating conditions may differ substantially from historical assumptions because of changing precipitation patterns, increasing temperatures, extreme weather events, shoreline erosion, and changing lake levels. Infrastructure should be evaluated for long-term resilience under a range of future climate scenarios. The Environmental Impact Statement should include a robust evaluation of alternatives, including energy efficiency, demand management, transmission improvements, renewable generation, energy storage, and other combinations of resources that may reduce the need for new generating capacity while meeting reliability objectives. I also encourage the NRC to carefully evaluate radioactive waste management, spent fuel storage, transportation risks, decommissioning funding, environmental monitoring, emergency preparedness, and long-term stewardship responsibilities. If limited work authorization is approved before the overall licensing process is complete, the NRC should clearly explain how early construction activities will avoid creating practical or financial pressure that could limit objective consideration of alternatives later in the review process. Environmental review should guide project decisions rather than simply documenting decisions that have effectively already been made. Meaningful public participation should remain an essential part of the licensing process. Local communities, Tribal Nations, independent scientists, emergency responders, and other stakeholders should continue to have opportunities to review information and participate throughout project development. Thank you for considering these comments. TerryAnn Towers Saint Amand