Head of Government Affairs · Final round case study

New nuclear
in Illinois

A government affairs plan to build Blue Energy plants: the legislature, the ICC, and everyone in between.

Brynn Hammond The legislature ICC · IRP docket Stakeholder campaign
Prepared for
01Before we start

Where AI helped, and where it did not

Research

Copilot, on BIPA background

I was unfamiliar with BIPA, so I asked Copilot why the bill came about. I like to know the impetus behind any proposal.

Presentation

Claude, on this site

Built this presentation from my talking points: layout, figures, and styling. It also gathered public sources for the Illinois context slide.

Mine

The thinking

The strategy, the recommendations, and every example from my own work. Ask me about any of it.

02Today

How I will walk through this

My general approach first. Then the specific legislative and regulatory questions, with real examples from my own work along the way.

Interrupt me any time. Questions in real time are welcome.

EthosHow I approach government affairs
The legislaturePower Act, BIPA, CEJA
The ICCIllinois's first integrated resource plan
The failsafeIf none of these work
The campaignHow I organize stakeholders, with proof
03The board

Illinois, in one slide

Three sites, one strategic investor, and four policy fronts moving at once.

SecuredSite 1Gas-to-nuclear capable
Close to securedSite 2A separate county
In discussionSite 3Brownfield, with the IPP owner
Moratorium
Lifted. Repeal signed January 2026. Governor's goal: at least 2 GW of new nuclear.
Constellation
Owns all 11 Illinois reactors and is a strategic investor in Blue Energy. Plans uprates; new units only at existing stations.
ICC
First-ever IRP. Year-long docket opens in November. Chair aligned with the Governor.
Power Act
Bring Your Own New Clean Capacity and Energy for data centers, plus water use rules.
BIPA
Biometric liability that keeps hyperscalers cautious about Illinois.
CEJA
Gas phaseout by 2045. Amendments could surface in the fall veto session.

Sources in appendix. Site details from the case prompt.

04Ethos

How I approach this work

Keep these three in mind as we get specific.

Stakeholder engagement

Not just lawmakers and commissioners

Landowners, community members, and non-energy groups need to have our backs.

Fly-by-night development sours people. That is what leads to NIMBYism.

Early engagement

Never ask a stranger

We should never be asking someone for something if we have not previously met.

Coalitions and partnerships

Partner whenever possible

Utilities carry real weight in states. Constellation already has a stake in Blue Energy and in new nuclear. No need to reinvent the wheel if their GA effort can help carry us.

05Coalitions of the unusual

I like to have a partner whenever possible. The weirder the better.

FirefightersThey train for water rescues on our cooling pond in Michigan.
First SolarA solar company lobbying alongside a gas portfolio.
Quantum and jet fuelComing up on BIPA.
06The legislature

Three outcomes. Three different fights.

Outcome, in priority orderWho is fightingMy approach
a  Power Act counts advanced nuclearThe bill's clean energy advocates built its supply plans around new renewables and storageDefine clean without being technology prescriptive. Credit accredited capacity.
b  BIPA rollbackTrial lawyers against data centers, labor, and generatorsReform, not repeal. Lead a new coalition through an emerging-industries lens.
c  CEJA gas phaseout extensionThe environmental lobby against generators, labor, and supply realistsOfframps for reliability and affordability, not a fight over the deadline.

And if all three fail, there is still a path. That comes after the ICC.

07Proof · Michigan

I have run this play before

My portfolio includes the largest cogeneration site in the United States, once the largest in the world. It sells power and steam.

2023. The first Democratic trifecta in 40 years proposes 100% renewable by 2035. That would have forced our early retirement.

The groundwork was already there. Lawmakers had toured the site. Locals were proud to have us.

We worked it together. Legislators, offtakers like Dow and Corteva, the firefighters, and our commercial team in the room.

Two paths, both won
Path 1 · Statewide

From renewable to clean

We changed the definition and helped write it without being technology prescriptive.

Path 2 · Our plant

A specific carve-out

The most flexibility of any generator in the state, with offramps for reliability and affordability. It made our power the most valuable to utilities, so they signed PPAs with us.

I can advocate for policy all day long. If it is not technically feasible, it is not good policy.

08Priority a · Power Act

Get nuclear inside the definition

The Power Act is the Michigan fight in a new form. The question is what counts as clean.

As introduced
Data centers must bring new clean capacity and energy, framed around renewables and battery storage.
The carrot
Faster interconnection and firm service for data centers that do.
Our ask
Advanced nuclear is eligible clean capacityRecognized for delivering large volumes of clean energy reliably.
Credit for accredited capacityHigh accredited capacity value is what helps the state's resource adequacy.
What carries over from Michigan
  • Lawmakers see the site and the scale before we ask for anything.
  • Commercial is in the room, so every ask is technically feasible.
  • Write the definition around outcomes, not technologies.
  • A clean, firm supply makes us the obvious partner for a data center that has to bring its own.
09Priority b · BIPA

Reform, not repeal

If we went for rollback

Start with Rep. Ugaste and Sen. Cunningham, who backed the 2024 amendment. Chambers of Commerce help. No organized group exists for rollback, so we would have to lead one.

Why I would not

  • There is a clear opening for targeted reform. The law dates to 2008 and was amended in 2024.
  • Think about the worst-case read. BIPA was written to build consumer confidence in a new technology. Nuclear has its own confidence campaign ahead. Blue Energy should not look like it is dismantling a consumer protection.

A coalition for strategic reform is the better approach.

2008BIPA enacted, as biometric data was first being collected and stored.
2024SB 2979: damages limited to one recovery per person, not per scan. E-signatures count as consent.
NextTargeted reforms, carried by a coalition we lead.
10Priority b · The coalition

Make it about emerging industries

National security and economic development. Two budding industries looking to grow in Illinois.

Powering the quantum state. Quantum companies, universities, and organized labor advocating through an economic development lens. Northrop Grumman's large Illinois campus brings the national security voice.

Clean molecules. SAF producers use SMR steam and hydrogen to cut the carbon intensity of jet fuel, like Dow at my Michigan site. That brings United Airlines' GA team into the mix.

EXPECTED ALLIESData centersLaborPower generatorsChambers of CommerceUNUSUAL ALLIESQuantum + universitiesPOWERING THE QUANTUM STATEDefense + aerospaceNATIONAL SECURITYSAF producersSTEAM + HYDROGEN OFFTAKEUnited AirlinesADDS ITS GA TEAMTargeted BIPA reform
11Priority c · CEJA

Ask for offramps, not a new deadline

My read on the IRP. It will show Illinois does not have enough generation coming online for current demand, let alone large-load and data center scenarios.

Frame it like Michigan. Extension options triggered by reliability or affordability concerns. Never "we can't meet this deadline."

Get creative with partners. GE Vernova makes the BWRX-300 and dual-fuel turbines. Could a hydrogen-capable unit qualify under the phaseout and run past 2045? Or exempt bridge technology that is explicitly bridging to clean power.

ENERGIZENUCLEAR ONLINE2045 · CEJA PHASEOUTBWRX-300 unitsGE Vernova gas turbinesHARD STOP TODAYOFFRAMPRELIABILITY OR AFFORDABILITYOR: DUAL-FUEL H2OR: BRIDGE EXEMPTIONSCHEMATIC · NOT TO SCALE
12The ICC

Sell the need, not the project.

This is Illinois's first IRP. It is the litmus test for every one after it. Shape the process, and our two to three projects fit the answer.

The framing we want in the record

Illinois will have an X MW accredited-capacity deficiency in Northern Illinois beginning in 2030 under plausible data-center load scenarios. That deficiency requires a resource capable of providing Y MW during the highest-risk hours while satisfying Illinois's statutory emissions trajectory.

13The ICC · Before and during

Be top of mind before the docket opens

Now to November · Informal

Shape the inputs

  • Site visits, even if it is just land
  • Stakeholder workshops
  • Scenario-development discussions
  • Data input requests
November onward · Year-long formal docket

Work the record

  • Participate formally in support of state procurement of long-term nuclear supply contracts.
  • No direct contact with Commissioners once the docket opens. The relationships have to exist before November.
  • Many voices for and against nuclear will be in the docket. Ours should already be familiar.
14Proof · Arizona

We met with no ask. A year later, he referred us by name.

The introTwo of our gas plants sit in Rep. Gosar's district. I met with his office to explain our Arizona and national portfolio. No ask.
The contextWe have an MOU with OPG to share knowledge on their Darlington SMR site.
The payoffThe state tax committee asked him for help on an SMR tax regime. He sent them to us, and we presented on the technology.
15If none of these work

There is still a path

Other states have tools Illinois does not. Advocate for them in tandem, or instead if the legislative goals fail.

Money

Grant funding appropriations

Speed

A regulatory environment that streamlines permitting

Markets

Financial incentives like ERCs and other credit mechanisms

What I am building now: a regional trading regime for emission reduction credits under the Clean Air Act, for nonattainment zones. SMRs operating outside nonattainment areas could sell their ERCs into that network.

16The campaign

How I run it

ResourceWhy
In-state lobbyist
Required
Gets meetings where we have no relationship. Worth it, rather than going it alone.
Chamber of Commerce
Nice to have
Useful participation, but not a requirement.
Start granular
Mailers and town hallsFor the properties near each planned site. People want their voices heard.
Face to face, earlyMeet legislators as soon as possible.
A steady drip of winsLike a construction permit application submitted to the NRC.

When we do have an ask, they already know us as a trusted stakeholder.

17Track record

Three times this worked

Michigan

The clean energy plan

A tech-neutral definition and a plant-specific carve-out kept the largest cogen site in the US running.

North Carolina

First Solar and Sen. Tillis

We partnered with First Solar to lobby Sen. Tillis, who became one of the only Republicans to vote against OBBBA.

Arizona

Rep. Gosar and the tax committee

An intro meeting with no ask turned into our panel on how the state should tax SMRs.

Questions

Known before we need them

Early, local, and in unusual company. That is how Blue Energy builds in Illinois, and in the next state after it.

Press A for appendix · ? for controls

19Appendix · The case questions

What Blue Energy asked

1 · The legislature

As a resource-limited startup, how do we participate to secure a favorable path for new nuclear and hyperscaler offtake, protect against impediments, and build or join a winning coalition? What resources are required?

2 · The ICC

How do we position for the IRP before the docket opens and during a year-long formal process, with no direct Commissioner contact once it opens?

3 · Stakeholders

A unified campaign from the Governor to local officials, business, labor, and environmental NGOs, with the adjacent RTOs in view. Internal teams, external partners, and how to measure success.

20Appendix · Sources

Sources for the context slides

Speaker notes

00 Title
offline