Section Synopsis
Pages: 255The passage provides a preliminary estimate of Greenhouse Gas (GHG) emissions for the proposed used nuclear fuel repository. It identifies Scope 1 and 2 emissions for construction and operations, estimating maximum annual totals of 14,480 and 10,834 tonnes of CO2 equivalent, respectively. The document highlights that heating plants using propane and natural gas are the primary emission sources. It also asserts the project's role in supporting Canada's net-zero goals by providing a long-term waste management solution.
Community Assessment Narrative
The provided text presents a preliminary GHG assessment that is technically structured but contains notable gaps in scope and a degree of rhetorical bias. The opening section frames the project as an environmental imperative for Canada's net-zero goals, which shifts the tone from a neutral technical description to a justificatory narrative. While the identification of Scope 1 and 2 emissions is clear, the omission of Scope 3 emissions—specifically the embodied carbon in construction materials like concrete and steel—is a significant transparency concern for a project of this magnitude. Furthermore, there is a clear internal tension between the project's stated support for a low-carbon economy and its heavy reliance on fossil fuels (propane and natural gas) for heating, which accounts for nearly all of its projected emissions. The commitment to 'best available technologies' remains vague without a specific explanation as to why lower-carbon heating alternatives were not integrated into the initial project design or estimates.
Corrective Measures & Recommendations
The proponent should expand the GHG assessment to include a preliminary analysis of Scope 3 emissions, focusing on the lifecycle impacts of carbon-intensive materials such as cement and steel required for the repository's construction. This would provide a more comprehensive and transparent understanding of the project's total carbon footprint and its actual alignment with federal net-zero targets. Additionally, the proponent should provide a detailed justification for the selection of fossil-fuel-based heating systems. Given that heating represents 88 to 95 percent of the project's direct emissions, the proponent should evaluate and present alternative low-carbon heating technologies, such as industrial heat pumps or geothermal systems, to mitigate the project's primary source of GHG emissions and demonstrate a genuine commitment to best environmental practices.
On 16 February, 2026 the Impact Assessment Agency of Canada (IAAC), with input from the Canadian Nuclear Safety Commission (CNSC), published a Summary of Issues (SOI) for the proposed Deep Geological Repository (DGR) for Canada’s Used Nuclear Fuel Project, put forward by the Nuclear Waste Management Organization (NWMO). The SOI identifies the key issues that IAAC considers relevant to the federal integrated impact assessment process for the project. NWMO’s response to the SOI will assist IAAC in determining whether an impact assessment is required under section 16 of the Impact Assessment Act. If an impact assessment is required, the issues outlined in the SOI—together with NWMO’s response—will help shape the scope of the assessment and inform the continued development and finalization of the Integrated Tailored Impact Statement Guidelines and associated plans.
Alignments to IAAC Summary (SOI)
The community findings from Melgund Township regarding Greenhouse Gas (GHG) emissions and project framing show both strong alignments with the IAAC Summary of Issues (SOI) and identify a significant technical gap in the Agency’s current documentation. Specifically, the community’s concern regarding the high reliance on fossil fuels for heating aligns directly with the IAAC’s identified issue under "Other Key Issues Related to the Federal Undertaking," specifically the section on "Alternative means." The IAAC notes a lack of options considered for project activities; Melgund Township’s analysis provides a concrete example of this by highlighting the proponent’s failure to evaluate low-carbon heating technologies like geothermal or industrial heat pumps in favor of carbon-intensive propane and natural gas.
Furthermore, the community’s observation regarding the "promotional tone" of the proponent’s submission validates concerns raised in Annex A of the IAAC SOI. The Agency has flagged the need for better "adequacy, clarity, and transparency" in the Project Description, particularly regarding how uncertainty and risk are characterized. The community’s finding that the proponent uses policy justification rather than neutral technical specifics suggests a lack of objectivity that mirrors the IAAC’s call for more transparent and inclusive communications.
However, a notable gap exists regarding the technical depth of GHG accounting. While the IAAC SOI mentions climate change primarily in the context of its effects on transportation infrastructure, it does not explicitly list the project’s total carbon footprint or Scope 3 emissions as a standalone key issue. Melgund Township’s assessment identifies the omission of embodied carbon in materials like cement and steel as a major oversight. This community finding suggests that the IAAC’s current SOI may be underestimating the project’s total environmental impact by not explicitly requiring a full lifecycle carbon analysis, which is essential for determining alignment with federal net-zero mandates.
Recommendations
The working group recommendations focus on ensuring the proponent moves beyond high-level policy justifications to provide rigorous, transparent technical data. It is recommended that the proponent be required to expand the GHG assessment to include a comprehensive Scope 3 analysis. This must specifically detail the lifecycle impacts of carbon-intensive construction materials. By addressing this gap, the proponent will fulfill the IAAC’s requirement for a more transparent project description and provide the "community-led baseline data" requested in the Socio-Economic Conditions section of the SOI.
Additionally, the working group recommends that the proponent provide a formal feasibility study of low-carbon heating alternatives. This recommendation directly addresses the IAAC’s concern regarding "Alternative means" for project components. Moving away from a 95 percent reliance on fossil fuel heating is not only a technical necessity for emissions reduction but also a vital step in demonstrating the "best practices" the IAAC expects from a federal undertaking. Implementing these recommendations will ensure that the project’s environmental claims are substantiated by data rather than promotional framing, thereby addressing the transparency and objectivity concerns shared by both the community and the Agency.
Key Claims
Underlying Assumptions
Critical Observations & Gaps
Analysis Table| Issue Identified | Implication | Information Required |
|---|---|---|
| Omission of Scope 3 emissions. | Underestimates the total carbon footprint of the project by ignoring upstream and downstream impacts. | Preliminary data on embodied carbon of materials and full lifecycle transport. |
| High reliance on fossil fuels for heating. | Contradicts the project's stated goal of supporting a low-carbon future by relying on fossil fuel combustion. | Analysis of alternative low-carbon heating technologies. |
| Promotional tone in the introductory paragraph. | May signal a lack of objectivity in the assessment by framing the project as a moral or policy necessity. | More neutral language focusing on project specifics rather than policy justification. |
Working Group Recommendations
Request a detailed feasibility study and comparative analysis of low-carbon heating alternatives (such as industrial heat pumps or geothermal systems) to replace the proposed propane and natural gas heating plants.
Demand the Proponent demonstrate 100% self-sufficiency for fire and emergency response capacity specifically for the high-volume propane and natural gas storage and combustion infrastructure identified in the filing.
Request the Proponent expand the scope of transportation safety and emission assessments to include the Highway 17 corridor through Melgund, rather than only the access roads 'after turn off from Highway 17'.
Understanding the Impacts of Nuclear Waste on our Community
This digital archive houses the public comments submitted to the Impact Assessment Agency of Canada regarding Project 88774: The Nuclear Waste Management Organization Deep Geological Repository (DGR) for Canada's Used Nuclear Fuel Project. The impact assessment is led jointly by the Impact Assessment Agency of Canada and the Canadian Nuclear Safety Commission. This archive preserves community perspectives, concerns, and observations shared during the assessment process, particularly in relation to Melgund Township, Northwestern Ontario and the communities of Dyment and Borups Corners who are the closest and most impacted of all in the process.