The Pre-Application Pathway
Early, structured engagement with the regulator establishes the licensing basis before a formal application, reducing late-stage design risk.
Engage early
The program favors pre-application engagement: structured discussion with the regulator well before a formal license application. For a machine type the regulator has not licensed before, this establishes shared understanding of the hazards, the framework, and the evidence the application will need to contain.
What pre-application settles
- Which regulatory framework applies, a byproduct-material basis for this device
- What the safety case must demonstrate for tritium, neutrons, and activation
- What analyses and test evidence the eventual application will rely on
- How the gate program's measurements support the licensing basis
Why it reduces risk
The costliest licensing outcome is discovering late that the regulator expects a different basis or additional evidence, forcing redesign after construction has advanced. Pre-application surfaces those expectations while the design is still adjustable, aligning the build with the licensing basis rather than reconciling them at the end.
Relationship to the build
Pre-application runs in parallel with detailed design and the start of construction in Q2 2027. The physics gates produce evidence that feeds the licensing basis: neutron and tritium accountancy from G3, in particular, are directly relevant to a byproduct-material safety case.
Status
This is engagement, not authorization. Formal submissions are governed by counsel review, and the pathway described here is the program's intended route for a machine not yet licensed.