Melgund Recreation, Arts and Culture
Public Comments Archive

C. LOCATION INFORMATION AND CONTEXT

Detailed Technical Assessment Report • Ref: REC-G9UU-AFF3

Section Synopsis

Pages: 95-96

The proposed project is located on Crown land within the Canadian Shield in northwestern Ontario, specifically within the territory of the Wabigoon Lake Ojibway Nation (WLON) and Treaty #3. The site, situated approximately 43 km northwest of Ignace and 21 km from WLON reserve lands, was selected based on technical suitability, safety, and community willingness. The Nuclear Waste Management Organization (NWMO) currently operates under a provincial land withdrawal order (W-K-98/13) covering 17,600 hectares, with plans to transfer ownership from the Ontario Ministry of Natural Resources (MNR) prior to licensing. The site overlaps with existing forest management units, a mining claim, and private land parcels, and is situated near several small communities and infrastructure corridors.

Community Assessment Narrative

The text provides a clinical geographic and legal overview of the project site but leaves several critical areas open to interpretation. While it lists 'community willingness' as a primary factor for site selection, it does not define the metrics or the specific outcomes of the consultation process that led to this conclusion. This is particularly relevant given the project's location within Treaty #3 territory and its proximity to multiple First Nations. The mention of 'social and cultural perspectives' as a selection criterion is vague, lacking a description of how these perspectives were weighted against technical requirements. There is a potential for perceived bias in the presentation of land status; the text frames the transfer of Crown land as a planned arrangement, which may downplay the complexity of provincial-Indigenous-proponent negotiations.

Furthermore, the proximity data reveals a potential gap in community engagement focus. While the Township of Ignace is frequently cited as a primary hub, the communities of Borups Corners and Dyment are significantly closer to the project centroid (10 km and 13 km respectively). The narrative does not address whether these smaller, non-incorporated entities have been afforded the same level of 'willingness' assessment as the larger municipalities. Additionally, the overlap with the Wabigoon and Dryden Forest Management Units suggests a potential conflict with existing economic activities and ecological management plans that is not explored. The reliance on straight-line distance measurements for proximity may also be seen as an oversimplification of environmental and social impact zones, which often follow transport routes or watersheds rather than radial lines.

Corrective Measures & Recommendations

The proponent should provide a detailed 'Willingness and Consultation Report' that explicitly defines the criteria used to determine community support. This report must differentiate between the consent of Indigenous nations (WLON and Treaty #3 signatories) and the 'willingness' of municipal bodies like Ignace. It is essential to clarify how the project will address the concerns of the residents in Borups Corners and Dyment, who are the closest to the site, ensuring they are not marginalized in favor of larger population centers. This should include specific socio-economic impact assessments for these immediate neighbors, focusing on noise, traffic, and potential changes to land value.

Additionally, the proponent must elaborate on the land transfer process and the resolution of existing encumbrances. Specifically, a mitigation plan is required for the private landholders and mining claim holders whose interests overlap with the withdrawal area. The proponent should also engage with the managers of the Wabigoon and Dryden Forest Management Units to produce a 'Forestry and Biodiversity Integration Plan.' This plan should justify the removal of land from active timber production and outline how the project will maintain ecological connectivity within the Canadian Shield ecosystem, moving beyond simple geographic coordinates to address functional environmental impacts.

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 assessment findings from Melgund Township demonstrate a high degree of alignment with the issues identified in the IAAC Summary of Issues (SOI) published on February 16, 2026. Specifically, the community’s concern regarding the proximity of the project to small, non-municipal settlements like Borups Corners and Dyment (10–13 km) directly supports the IAAC’s theme of Socio-Economic Conditions, which highlights concerns that "project-related economic benefits may not be equitably shared among all affected regional communities, including those outside hosting agreement areas." While the IAAC document speaks broadly to "nearby residents," Melgund’s analysis provides the necessary geographic specificity to validate the Agency’s concern regarding the distribution of impacts and benefits beyond the primary municipal partner, Ignace.

Furthermore, the community’s observation regarding the project’s overlap with the Wabigoon and Dryden Forest Management Units (FMUs) and a specific mining claim (#868881) aligns closely with the IAAC’s section on Socio-economic impacts to land use. The IAAC explicitly identifies the need for information on how the project may affect "forestry" and "existing roads used by these land users." Melgund’s findings go a step further by identifying the specific legal encumbrances and the potential removal of land from active timber production, providing a concrete basis for the IAAC’s broader concern regarding "cumulative environmental effects" and "regional land disturbance."

A significant alignment is also found in the realm of Indigenous Peoples and Project Description. Melgund Township flagged the "vague reference to cultural perspectives" in the site selection process, which mirrors the IAAC’s requirement for the proponent to address "how Indigenous Knowledge, culture, practices, and protocols are considered, incorporated, and reflected in project planning." Additionally, the community’s concern over "tentative coordinates" for facilities validates the IAAC’s call for greater clarity in the Project Description, specifically regarding the "adequacy, clarity, and transparency" of how the project footprint will impact the local environment.

Recommendations

The working group recommendations focus on the necessity of a "Willingness and Consultation Report" that moves beyond broad generalizations to provide a granular look at community support. This recommendation is designed to address the gaps identified in the IAAC’s Socio-Economic Conditions and Indigenous Peoples sections. By requiring the proponent to differentiate between the legal consent of Treaty #3 signatories and the "willingness" of municipal bodies, the community ensures that the assessment respects the "Indigenous authority and jurisdiction" flagged by the IAAC. This report would serve as a primary tool to mitigate the risk of marginalizing residents in Borups Corners and Dyment, ensuring their specific concerns regarding noise, traffic, and land value are not overshadowed by the larger population centers.

Additionally, the recommendation for a "Forestry and Biodiversity Integration Plan" provides a structured pathway to address the IAAC’s concerns regarding Terrestrial, riparian and wetland environments and Socio-economic impacts to land use. This plan would require the proponent to move from "tentative" geographic data to a functional assessment of ecological connectivity and economic impact on the timber industry. By implementing these recommendations, the proponent can provide the "community-led baseline data" and "mitigation measures" requested in the IAAC Summary of Issues, ensuring that the legal and environmental interests of all local stakeholders—including private landholders and mining claim holders—are formally integrated into the impact assessment process.

Key Claims

The site was selected based on social, cultural, technical, and community willingness factors.
The project is located within the territory of the Wabigoon Lake Ojibway Nation and Treaty #3.
The land is currently Crown-owned and subject to a provincial withdrawal order (W-K-98/13).
A land transfer arrangement with the MNR is planned to occur prior to CNSC licensing.
The withdrawal order takes priority over mining claim #868881 because it was registered earlier.

Underlying Assumptions

Community willingness is a measurable and static condition that has been met.
Straight-line distances are an adequate metric for assessing proximity and potential impact.
The transfer of Crown land from the Province to the NWMO is a procedural certainty.
The withdrawal of land from prospecting and mining is sufficient to mitigate industrial land-use conflicts.
The technical suitability of the Canadian Shield at this location is established.

Critical Observations & Gaps

Analysis Table
Issue Identified Implication Information Required
Proximity to small communities (10-13 km) vs. larger townships (35-43 km). Smaller communities like Borups Corners are closer to the site than the primary municipal partner (Ignace), which could lead to feelings of exclusion or disproportionate impact. Specific engagement strategies and impact assessments for the closest non-municipal residents.
Overlap with private land parcels and mining claim #868881. Existing private land and mining claims within the withdrawal area could lead to legal disputes or compensation requirements. Clarification on the legal status of these parcels and the proponent's strategy for acquisition or compensation.
Location within Wabigoon and Dryden Forest Management Units. The project removes land from active Forest Management Units, potentially affecting local timber economies and habitat management. An assessment of the impact on regional forestry plans and biodiversity management.
Vague reference to cultural perspectives in site selection. The claim that 'social and cultural perspectives' were considered is unsubstantiated without specific examples of how Indigenous knowledge or values influenced the site selection. A detailed account of how Treaty #3 and WLON cultural values were integrated into the selection matrix.
Use of 'tentative' coordinates for major facilities. Tentative coordinates for access roads and facilities suggest the project footprint is still in flux, which complicates the assessment of localized environmental impacts. Finalized facility footprints to accurately assess site-specific environmental disturbances.

Working Group Recommendations

Human Environment (People)

Challenge the Proponent's citation of 'transportation safety' as a selection factor by demanding a gap analysis of emergency response times to the proposed Primary and Secondary Access Roads.

The Proponent's submission lists 'transportation safety' as a justification for the site and provides coordinates for access roads intersecting Highway 17. However, Melgund Township is an unorganized territory with zero local emergency services (no fire, ambulance, or police). Reliance on distant response from Ignace (43 km) or Dryden (40 km) creates an unacceptable risk profile for accidents involving project traffic. The Proponent must be challenged to demonstrate 100% self-sufficiency for emergency response at these access points, rather than burdening a community with no capacity.
HEP-007
Environment

Mandate a baseline noise, vibration, and light pollution study specifically at the coordinates of the nearest residents in Borups Corners and Dyment.

The Proponent's submission provides specific coordinates for the 'ERMA' and access roads, which are only 10-13 km from Melgund communities. To ensure the 'Environment' assessment is valid, the current background levels of silence and darkness—key characteristics of the local rural lifestyle—must be documented at these specific receptor locations before any site preparation or land transfer occurs. This data is essential to hold the Proponent accountable for future nuisances.
ENV-003
Environment

Designate 'Forestry Land Base' as a Valued Component and request a quantitative assessment of the impact of the 17,600 ha withdrawal on the Wabigoon and Dryden Forest Management Units.

The text confirms the project is located within active Forest Management Units and involves a significant withdrawal of Crown land. This removal of land from the inventory directly affects the local environment and economic potential of the area surrounding Melgund. By designating this as a Valued Component, the community ensures that the loss of access to these lands for traditional, recreational, or economic purposes is rigorously assessed and not merely treated as an administrative transfer.
ENV-004
Human Environment (People)

Require the disaggregation of socio-economic baseline data to specifically isolate Borups Corners and Dyment as distinct receptors, separate from the Township of Ignace.

The Initial Project Description explicitly states that Borups Corners (10 km) and Dyment (13 km) are the closest communities to the project, significantly closer than the 'willing' Township of Ignace (43 km). Grouping Melgund residents with distant municipalities in baseline studies will dilute the data regarding potential impacts. Establishing a specific baseline for these immediate neighbors is critical to accurately measuring future impacts on property values, social cohesion, and community well-being that are unique to the unorganized territory.
HEP-006

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.