The Oregon Conservancy Foundation (OCF) calls out the proposed "Radiation Protection Framework" rule changes for what they are: more of the familiar public relations playbook followed for decades by the nuclear industry and our government.  This deceptive and misleading playbook highlights alleged “benefits” of more nuclear power while minimizing and suppressing the serious harms to workers and the public by increasing radiation pollution exposure. The theme is “a reckless denial of reality” as illustrated by physicist Dr. Rudi Nussbaum of Physicians for Social Responsibilty who wrote in 2011 in the aftermath of Fukushima: “In agencies that are mandated to protect public health a mindset that denies reality is intolerable.”  We believe that the mindset reflected in these proposed rule changes is a continuation of the betrayal of workers, the public, and generations to come: reckless and intolerable.

Comments on revisions to 10 CFR 20 and 10 CFR 50 proposed by the Nuclear Regulatory Commission (NRC) on July 15, 2026, Docket ID NRC–2025–11402

Committee to Bridge the Gap's comments focus on describing the ways that NRC's current radiation protection standards are already too weak and should not be weakened further by the new rule, and explaining the Linear No Threshold (LNT) model.

These comments address NRC proposed rule NRC-2025-1140 and its potential impact on public health and future generations. They discuss the scientific basis for radiation standards, the greater vulnerability of women, pregnant people, infants, and children, and concerns about weakening ALARA, increasing allowable exposures, and permitting greater radioactive releases. The comments also challenge reliance on “Reference Man” as the basis for population-wide protection. They conclude by urging the NRC to reject the proposed rule, retain ALARA and existing public protections, and base future regulations on independent science that prioritizes vulnerable populations.

Urges the NRC to withdraw proposed rule NRC-2025-1140, citing weakening radiation protections by reducing ALARA requirements, increasing allowable exposures and radioactive releases, and shifting risks onto workers, communities, and future generations. The letter emphasizes the greater vulnerability of women, pregnant people, infants, and children and calls for radiation standards based on independent, peer-reviewed science. Specifically asks the NRC to retain ALARA, existing public dose limits, and other essential protections, and to reject any changes that do not demonstrate improved public health and safety.

Beyond Nuclear comments (including three Annex submissions) on [NRC-2025-1140] Reforming and Modernizing the NRC's Radiation Protection Framework, as requested by Executive Order 14300 Ordering the Reform of the Nuclear Regulatory Commission

As a Coalition, and as individual organizations comprising the Coalition, we are compelled to place on the record our fundamental opposition to the Nuclear Regulatory Commission’s (NRC) proposed rulemaking.