Editors' Summary: In the 1982 Term, the Supreme Court decided three cases involving the nuclear power industry. In the first and third cases, the Court continued its pattern of deference to the Nuclear Regulatory Commission (NRC) and nuclear energy. But to the surprise of many observers, in the second case, Pacific Gas & Electric Co. v. State Energy Conservation and Development Commission, the Court unanimously held that the Atomic Energy Act (AEA) does not preempt a California statute imposing a moratorium on new nuclear plant construction until the federal government approves a technology for disposing of nuclear wastes. Although approving the ultimate ruling, Professor Tarlock criticizes the Court for its failure to provide useful guidance on the law of preemption. The Court found that the state law was founded on economic and not safety concerns and was therefore not preempted by the AEA, which vests exclusive control over nuclear safety with the NRC. Because of the Court's distinction, Professor Tarlock points out, the question of preemption turns on fictitious legislative drafting leaving open the possibility that other states' statutes may not fare so well. However, he concludes that the Court was justified in defining the conflict between federal and state regulation narrowly and refusing to continue to defer blindly to the agency.