Melgund Recreation, Arts and Culture
Public Comments Archive

iii. Wabigoon Lake Ojibway Nation Story

Detailed Technical Assessment Report • Ref: REC-9B5B-AX59

Section Synopsis

Pages: 6

This section of the Initial Project Description (IPD) outlines the 12-year engagement journey of the Wabigoon Lake Ojibway Nation (WLON) regarding the proposed Deep Geological Repository (DGR). It details a transition from involuntary involvement in 2010 to a community-led learning process rooted in Anishinaabe values and Ceremony. The narrative highlights a 2024 referendum where 87.4% of participating members voted to proceed into regulatory phases, contingent on proven safety and environmental respect. Furthermore, it introduces the Regulatory Assessment and Approval Process (RAAP), a jurisdictional framework through which WLON intends to exercise its authority and oversight over the project.

Community Assessment Narrative

The text presents a narrative of transformation, moving from a position of involuntary inclusion to one of asserted sovereignty and jurisdictional oversight. A significant portion of the text focuses on the social and cultural 'byproducts' of the engagement process, such as identity reclamation and the reconnection of Sixties Scoop survivors. While these are positive social outcomes, their inclusion in a project description for a nuclear waste repository serves to frame the project as a catalyst for community healing, which may inadvertently downplay the inherent risks and long-term burdens associated with high-level radioactive waste. The tone is aspirational and emphasizes community unity, yet it lacks transparency regarding the internal diversity of opinion that typically accompanies such high-stakes projects.

There is a notable tension between the 'technical studies' mentioned and the lack of specific criteria for what constitutes 'proven safe.' The document relies heavily on qualitative descriptions of 'Ceremony' and 'learning' without providing a summary of the technical findings that led to the 87.4% approval rating. Furthermore, the description of the Regulatory Assessment and Approval Process (RAAP) is vague regarding its legal standing and how it will interface with federal and provincial regulatory bodies. This creates a potential for future jurisdictional conflict or public confusion if the RAAP's findings diverge from the Impact Assessment Agency of Canada's (IAAC) conclusions. The narrative successfully establishes the Nation's intent to lead, but leaves significant gaps regarding the evidentiary basis of their current 'willingness' to proceed.

Corrective Measures & Recommendations

The proponent should provide a detailed technical annex summarizing the 'technical studies' conducted by WLON over the past 12 years. This should include the specific safety parameters, environmental indicators, and Anishinaabe cultural criteria used to evaluate the DGR proposal. By clarifying the 'proven safe' threshold, the proponent can demonstrate a more rigorous and transparent link between community learning and the referendum outcome, ensuring that 'informed support' is backed by accessible data.

Additionally, the proponent must clarify the operational and legal relationship between the WLON RAAP and the federal Impact Assessment process. It is essential to outline how discrepancies in findings or conditions between these two regulatory paths will be resolved. Providing a clear roadmap for how WLON’s conditions, monitoring, and enforcement mechanisms will be integrated into the project's lifecycle will mitigate risks of regulatory uncertainty and ensure that the Nation's sovereignty is practically rather than just rhetorically recognized.

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’s findings regarding the Wabigoon Lake Ojibway Nation (WLON) engagement process show strong alignment with the IAAC Summary of Issues (SOI), particularly under the theme of Rights of Indigenous Peoples. The community’s concern regarding the lack of clarity between the WLON Regulatory Assessment and Approval Process (RAAP) and the federal IAAC process directly supports the IAAC’s identified issue of "Respect for Indigenous authority and jurisdiction." The IAAC SOI explicitly notes concerns regarding the recognition of Indigenous governance and decision-making; Melgund Township’s analysis validates this by pointing out the absence of a framework or Memorandum of Understanding (MOU) to resolve potential discrepancies between these two regulatory paths.

There is also significant alignment regarding the technical thresholds for safety. The community’s observation that the term "proven safe" remains undefined mirrors the IAAC’s concerns under Radiological Conditions and Accidents and Malfunctions, where the Agency flags "high uncertainty" and the need for a "detailed understanding" of containment. The community’s recommendation for a technical annex summarizing 12 years of WLON studies provides a concrete mechanism for the proponent to address the IAAC’s requirement in Annex A (Public Engagement and Communication) for "clear, accessible, plain-language... communications, particularly regarding safety."

A notable gap exists where the community has identified a specific transparency issue that the IAAC SOI touches upon only broadly. While the IAAC mentions "Social cohesion and community wellbeing" and "Adequacy of Indigenous engagement," Melgund Township specifically flags the lack of disclosure regarding referendum voter turnout and eligibility. The community’s finding suggests that without this granular data, the "informed support" cited by the proponent cannot be fully validated. This serves as a critical local refinement of the IAAC’s broader concern about whether engagement activities are "meaningful, ongoing, and sufficient."

Finally, the community’s concern regarding the Hosting Agreement and potential economic dependency aligns with the IAAC’s socio-economic theme, specifically "Distribution of economic benefits for all regional communities." While the IAAC focuses on the equitable sharing of benefits, the community’s analysis goes further by suggesting that the lack of transparency regarding the scale of these incentives could compromise objective safety assessments. This supports the IAAC’s call for "community-led baseline data" and more information on how the project affects social cohesion and "acceptable risk" across generations.

Key Claims

WLON was involuntarily brought into the DGR conversation in 2010.
A 12-year community-led learning process included technical studies, Ceremony, and knowledge sharing.
87.4% of participating WLON members voted in favor of proceeding to regulatory phases on November 16, 2024.
WLON has established its own Regulatory Assessment and Approval Process (RAAP) based on Anishinaabe law.
The DGR project has facilitated cultural healing and the return of off-reserve members to the community.

Underlying Assumptions

The 87.4% vote among 'participating members' is representative of the entire Nation's long-term will.
Technical safety can be definitively 'proven' to a level that satisfies both spiritual and scientific requirements.
The social benefits of the engagement process (e.g., family tree tracing) are inextricably linked to the DGR project's continuation.
The RAAP will be recognized as a valid regulatory authority by federal and provincial governments.

Critical Observations & Gaps

Analysis Table
Issue Identified Implication Information Required
The referendum results mention 'participating members' but do not disclose the total voter turnout or eligibility criteria. Without knowing the turnout, the 87.4% figure may not accurately reflect the sentiment of the entire community, potentially leading to future internal conflict. Disclosure of total eligible voters versus actual participants to assess the mandate's breadth.
The term 'proven safe' is used as a condition for hosting but is not defined by specific technical or radiological standards. Subjective definitions of safety can lead to regulatory delays or community withdrawal of support if expectations are not met. A definition of the safety criteria and thresholds established by WLON during their 12-year study period.
The RAAP is described as a jurisdictional authority, but its integration with the IAAC process is not explained. Unclear regulatory hierarchies can lead to legal challenges and project instability. A framework or memorandum of understanding (MOU) describing how the RAAP and federal processes will coexist.
The text mentions a 'Hosting Agreement' and 'benefits' but provides no details on the nature or scale of these incentives. The promise of benefits may create economic dependency that complicates objective safety assessments in the future. Summary details of the Hosting Agreement to evaluate potential economic pressures on the decision-making process.

Working Group Recommendations

Environment

Request the immediate disclosure of the specific 'technical studies' regarding land, air, and water referenced as part of the WLON learning journey.

The Proponent's submission cites over a decade of 'technical studies' that informed the community's decision regarding responsibilities to 'land, air, water.' As Melgund shares the immediate watershed and airshed with the proposed project site, this pre-existing data is vital for establishing a comprehensive regional baseline. Accessing these studies allows the Environment Working Group to validate whether the 'proven safe' conclusion accounts for the specific geological and hydrological conditions relevant to Dyment and Borups Corners, rather than relying solely on the Proponent's summary assertions.
ENV-095
Human Environment (People)

Request a quantitative projection of the 'returning home' population mentioned in the submission and analyze the cumulative impact on regional emergency service hubs (Ignace/Dryden).

The Proponent's submission explicitly states that off-reserve members are expressing a desire to 'return home' to raise families on the land. Melgund Township (Dyment/Borups Corners) is an unorganized territory with zero local emergency capacity (no fire, ambulance, or police), relying entirely on regional hubs in Ignace and Dryden. An unquantified influx of population into the region will strain these shared services, potentially increasing response times for Melgund residents during emergencies. It is critical to challenge the Proponent to demonstrate how this demographic shift will be managed without degrading the already fragile safety net for the unorganized communities.
HEP-110
Human Environment (People)

Clarify the definition of 'Safety' within the Regulatory Assessment and Approval Process (RAAP) and how it integrates with the safety requirements of non-Indigenous neighbors.

The text introduces the RAAP as a jurisdictional process where determinations hinge on 'safety' and 'Anishinaabe Values.' While respecting WLON's sovereignty, Melgund residents need assurance that this parallel regulatory framework does not supersede or conflict with federal safety standards required to protect unorganized territories. Specifically, the Working Group must determine if the RAAP's safety criteria include the physical safety and emergency response realities of Dyment and Borups Corners, or if the Proponent is operating under two distinct safety standards.
HEP-109

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.