Department of Energy Funding Update

The U.S. Department of Energy (DOE) on March 24, 2025, reissued its $900 million solicitation for small modular nuclear reactors (Generation III+ Small Modular Reactor Pathway to Deployment, DE-FOA-0003485) using funds from the Infrastructure Investment and Jobs Act (IIJA). The original solicitation was issued in October 2024, and applications were due three months later in January 2025. Why this is being reissued, what has changed and what we can learn from it are set forth below, as this funding opportunity provides a unique opportunity for a before-and-after comparison.

First and foremost, it is critical to note that DOE explicitly states that applications previously submitted in response to the prior version will not be reviewed. Interested parties will need to resubmit proposals consistent with the amended solicitation. Further, DOE notes that new applicants and applications are allowed. However, the one month provided to complete a full proposal may be challenging for some new applicants, particularly those needing to register with the System for Award Management (SAM) and obtain a Unique Entity Identifier (UEI), as compared with the three months that were originally allotted.

Why Is This Being Reissued? It is not unusual for a new administration to reissue funding opportunities to ensure that they align with the new policy priorities and objectives beyond what is established in statute. In this case, per the solicitation, "[It] has been modified from previous released versions to align the Gen III+ SMR program with the policies of the Trump administration. All requirements for Community Benefits Plans and any related elements, have been removed."

What Has Changed? Though the Executive Summary has been updated to reflect the new administration's priorities and remove the previous administration's goals, the program purpose and structure primarily remain the same. Interested parties, particularly those resubmitting proposals, should be aware of content and procedural changes beyond simply removal of the Community Benefits Plan (CBP) requirement, including:

Content

• Project Narrative (Tiers 1 and 2). Changes to the project site discussion: For Tier 1, this now includes a discussion of "how the proposed site meets the nation's strategic need for nuclear power due to the national energy emergency." For Tier 2, discussion of community engagement and support has been removed.
• Licensing and Construction Strategy (Tier 1). Removed discussion of workforce development plan. Though this still appears in a list of attributes for ranking projects under the $800 million Tier 1 topic, the development of a plan is provided as a potential project milestone.
• Past Performance (Tiers 1 and 2). Added a new discussion, which appears to be part of the Management Team and Project Partners five-page document, but the application requirements tables also point to a stand-alone document that is not separately described elsewhere.
• Review Criteria (Tiers 1, 2.1 and 2.2). The CBP Criterion has been removed and the scoring spread equally to the four remaining criteria. Additional changes specific to Tier 1 include: under the first criterion and Project Achievability, added "the team's ability to navigate project execution risks"; under the third criterion and Achievability of Construction Strategy, added "obtaining the necessary skilled workforce for the project"; under the fourth criterion, added a new element related to past performance of the Applicant and proposed team members (this was already part of Tier 2 in the prior version).
• Other Selection Factors (Tiers 2.1 and 2.2). Removed items related to inclusion of Minority Serving Institutions, partnerships with underrepresented businesses, and spurring economic development and job creation in distressed communities.
• Reporting Requirements (Tiers 1 and 2). Removed explicit mention and listing of potential reporting requirements tied to IIJA.

Process

• New Submission Process. Submission is now through FedConnect.net and not the Office of Clean Energy's OCED‑Exchange website. The presence of a Control Number in filename conventions is a holdover from the Exchange system. Applicants are now asked to assign their own tracking number alongside implementing a modified format for document headers. Maximum file sizes have been cut in half, and a cap on total application size has been added.
• Marking Confidential Information. Instructions for inline marking of confidential information now specify the use of double brackets, where previously highlighting was also allowed.
• Contact Information. Designated email address was changed from Gen3PlusSMR@hq.doe.gov to Gen3PlusSMR@id.doe.gov.

Holland & Knight Insights

This before-and-after snapshot provides some insight on a number of dimensions, including:

• The Trump Administration's Support for Funding Sectors Such as Nuclear. Reissuance of this solicitation so early in a new administration offers encouragement on a number of fronts. First, it signals that funding will still be moving forward where it aligns with administration priorities. Second, it signals that DOE may be working through its transition and may be prepared to engage on advancing key technologies and demonstrations once again.
• Shift to Office of Nuclear Energy and FedConnect.net. The amendment deliberately places DOE's Office of Nuclear Energy ahead of OCED, inverting these from the prior version. Concurrently, OCED Exchange appears to have removed its table listing funding opportunities and replaced it with a message that the office is reviewing all of its current notices. The resulting shift to FedConnect.net for submission is noteworthy and may be unfamiliar to many applicants who are used to the Exchange or Grants.gov portals.
• Removal of CBP and Related Materials. This has been expected for DOE solicitations generally, but prospective applicants have been left wondering about implementation. We now see that while the CBP has been removed along with its merit scoring and other selection considerations, some elements related to workforce development are still present. Notably, treatment of workforce development appears inconsistent under Tier 1, where it appears to have been removed from the discussion under Licensing and Construction Strategy on the one hand, while scoring was added to the merit criteria on the other. Applicants will still want to address this topic given the merit scoring.
• Reporting Potential Impacts on Indian Tribes and Related Documentation Still a Requirement. This remains part of the application package despite removal of the CBP and related materials, which some may have been questioning.
• Word Choice Matters. Applicants to federal programs should choose their words carefully. DOE not only removed the CBP requirement – the word "community" was systematically found and removed or replaced in all other contexts, to be replaced by phrases such as "residents and organizations."