Section Synopsis
Pages: 18-19This section of the NWMO summary document outlines the regulatory framework for the proposed Deep Geological Repository (DGR) under the Physical Activities Regulations of the Impact Assessment Act (IAA). It confirms that while the construction and operation of the DGR are designated projects requiring a federal impact assessment, other critical phases—specifically site characterization, decommissioning, and post-closure monitoring—fall outside the IAA's scope and will be managed exclusively by the Canadian Nuclear Safety Commission (CNSC). The NWMO proposes an integrated assessment process to align the IAA requirements with the initial CNSC licensing stages.
Community Assessment Narrative
The NWMO's description of the regulatory process reads like a strategic attempt to minimize federal oversight through a 'regulatory shell game.' By segmenting the project, they claim that site characterization—the very phase that will bring heavy drilling rigs, new access roads, and constant industrial noise to the Melgund area—is not a 'designated activity' under the Impact Assessment Act. For those of us in Dyment and Borups Corners, this is corporate double-speak. They are essentially saying that the years of disruption we will face before a single brick is laid don't count as part of the 'project' for federal assessment purposes. This 'integrated approach' with the CNSC feels less like a rigorous check and more like a way to fast-track the process by burying technical risks in 'conceptual' safety analyses that won't be finalized until we are already living with the waste.
Impacts on Local Recreation: The exclusion of site characterization from the IAA is a direct threat to our way of life in Melgund. The Revell site is not just a 'geological feature'; it is our backyard where we hunt, fish, and run our ATVs and snowmobiles. The NWMO's claim that characterization is merely 'scientific information' ignores the reality of boots on the ground and tires on the trails. Increased truck traffic through Dyment will make hauling trailers to our favorite spots a hazard, and the acoustic environment—the silence we moved here for—will be shattered by drilling. Furthermore, the Dyment Recreation Hall serves as our community's heart; any influx of 'characterization' workers or industrial staging nearby threatens to turn our quiet gathering place into a transit hub for outsiders. If the trails are blocked or the game is driven off by 'characterization' activities that aren't even officially part of the 'Project' assessment, we have no recourse to protect our heritage.
Corrective Measures & Recommendations
The NWMO must voluntarily include the site characterization phase within the scope of the federal Impact Assessment, regardless of the minimum requirements of the Physical Activities Regulations. Melgund residents deserve a formal, legally binding platform to voice concerns about the immediate physical impacts of drilling and road construction. Relying solely on the CNSC's 'graded approach' is insufficient for a community located less than 10km from the site; we need a localized impact management plan that specifically addresses noise and traffic through Dyment.
Furthermore, the proponent must establish a 'Recreation and Access Guarantee' for the Melgund/Revell area. This should include a commitment to maintain all existing ATV and snowmobile trail connectivity during all phases of the project, including characterization. They should also provide direct funding to the Dyment Recreation Hall to upgrade its facilities, ensuring it remains a private sanctuary for local residents rather than being absorbed into the project's industrial footprint. We demand a clear definition of what 'insignificant' impact means to them, as our definition of a 'significant' impact includes any disruption to our seasonal hunting and fishing cycles.
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 findings and recommendations from Melgund Township show a high degree of alignment with the IAAC Summary of Issues (SOI), particularly regarding socio-economic impacts and land use, while also identifying a critical regulatory gap concerning the "site characterization" phase. Melgund’s concern regarding the disruption of seasonal hunting, fishing, and trail connectivity aligns directly with the SOI section on Socio-economic impacts to land use, which explicitly identifies the need for information on how the project affects recreation, hunting, fishing, and existing roads. Furthermore, the community’s demand for a "Recreation and Access Guarantee" for ATV and snowmobile trails supports the SOI’s focus on Social cohesion and community wellbeing, which flags concerns regarding impacts to local lifestyles and the "sanctuary" of community spaces.
There is a strong alignment between Melgund’s observations on industrial traffic through Dyment and the SOI’s section on Transportation service and infrastructure preparedness and demand. The IAAC has acknowledged public concerns regarding the capacity of existing infrastructure and the demands on local roads. Melgund’s analysis provides a specific geographic focus to this issue, arguing that the "characterization" phase will be experienced as a full-scale industrial project. This supports the SOI’s broader inclusion of Socio-economic effects... for all phases of the project, validating the community’s stance that impacts do not begin only once the "designated" construction phase starts.
However, a significant gap exists regarding the regulatory scope of the Impact Assessment. Melgund Township identifies a "segmentation" risk, where site characterization and decommissioning fall outside the IAA’s primary scrutiny, potentially leading to "regulatory capture" by the CNSC. While the SOI mentions Monitoring and institutional control and Reclamation under the Physical and Biological Environment section, it does not explicitly address the community’s specific recommendation that the proponent voluntarily include the site characterization phase within the federal IA scope to ensure a legally binding platform for local concerns. Melgund’s demand for a localized impact management plan for Dyment suggests that the current "integrated" process described in the SOI may not yet be granular enough to satisfy the community’s need for a "clear roadmap" of where local input can stop or alter the project during CNSC-led phases.
Finally, Melgund’s challenge to the definition of "insignificant" impact represents a conceptual gap in the SOI. While the IAAC document discusses Acceptable Risk and Cumulative environmental effects, it does not specifically address the community’s requirement for a definition of significance that accounts for disruptions to seasonal cycles. Melgund’s findings suggest that the proponent’s response to the SOI must go beyond general mitigation and provide the "direct funding" and "access guarantees" requested to protect the Dyment Recreation Hall and local trail networks, which the community views as essential to maintaining their social fabric against the project’s industrial footprint.
Key Claims
Underlying Assumptions
Critical Observations & Gaps
Analysis Table| Issue Identified | Implication | Information Required |
|---|---|---|
| Segmentation of project phases under different regulatory bodies. | Excluding decommissioning from the IAA means the long-term environmental risks of the site's final state may not receive the same level of public scrutiny as the construction phase. | A comprehensive assessment that covers the entire lifecycle from first drill bit to final closure under a single, high-standard framework. |
| Site characterization is dismissed as a non-designated activity. | Melgund residents will experience the 'characterization' phase as a full-scale industrial project, regardless of its legal definition. | Detailed traffic and noise studies for the Dyment area specifically for the characterization phase. |
| Ambiguity regarding the 'integrated' assessment process. | The 'integrated manner' of assessment could lead to 'regulatory capture' where the CNSC and NWMO align before the public has a chance to intervene. | A clear roadmap showing exactly where and how local community input can stop or alter the project during the CNSC-led phases. |
Working Group Recommendations
Challenge the Proponent's reliance on a 'conceptual post-closure safety analysis' within the integrated assessment; demand specific, non-conceptual modelling of long-term groundwater and soil stability prior to IAA approval.
Request the formal inclusion of 'Site Characterization' activities (drilling, traffic, workforce presence) into the Socio-Economic Baseline and Impact Statement, despite the Proponent's claim that it is 'not a designated activity' under the IAA.
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.