Section Synopsis
Pages: 170-173The provided text outlines the baseline data for non-Indigenous land and resource use regarding the Nuclear Waste Management Organization's (NWMO) proposed Deep Geological Repository (DGR) site in northwestern Ontario. The 342-hectare site is located on provincial Crown land previously disturbed by forestry. While the NWMO identifies overlaps with specific traplines, bait harvest areas, and bear management zones, it characterizes the site as having 'minimal' land use activity. The document notes the importance of tourism, outfitting, and recreational activities like snowmobiling to the local economy and lifestyle. The NWMO concludes that current desktop-based archaeological assessments and existing engagement data are sufficient, stating no further non-Indigenous land-use baseline data collection is planned.
Community Assessment Narrative
The proponent's description of land and resource use exhibits a potential bias toward minimizing the perceived impact of the project. By labeling the site as having 'minimal important features' and 'minimal land and resource use activity,' the NWMO risks pre-empting the findings of a formal impact assessment. This characterization is particularly concerning given that the site overlaps with active traplines, bait harvest areas, and unofficial recreational trail systems that are acknowledged as vital to the local 'sense of place' and economy. The reliance on a 'Stage 1' desktop archaeological assessment to conclude that no further data collection is required for non-Indigenous land use is a significant transparency and methodology gap. Desktop studies only identify 'known' sites; they do not account for undiscovered physical evidence that a field-based Stage 2 assessment would uncover.
Furthermore, there is a lack of clarity regarding how 'unofficial' land uses, such as the forestry roads used by ATVs and snowmobiles, will be mitigated or compensated if access is restricted. The text acknowledges that hunting and fishing are both a 'lifestyle and source of food' for residents, yet it simultaneously dismisses the need for further study. This creates an internal inconsistency: if the land is central to the community's quality of life and economy, a decision to cease data collection before the formal regulatory process fully matures appears premature. The tone, while professional, leans toward a foregone conclusion that the project's footprint is negligible, which may undermine community trust during the consultation phase.
Corrective Measures & Recommendations
The proponent should reconsider its decision to forgo additional non-Indigenous land-use baseline data collection. Specifically, a Stage 2 archaeological assessment involving physical field surveys should be conducted across the 342-hectare site. Relying solely on the Ontario Archaeological Sites Database is insufficient for a project of this magnitude, as many historical and cultural sites in remote regions remain unrecorded. Physical verification is essential to substantiate the claim that no cultural or historical resources will be impacted, thereby ensuring regulatory compliance and community confidence.
Additionally, the NWMO should perform a quantitative socio-economic impact study on the 'unofficial' trail systems and the specific traplines (DR024, IG033) and bait harvest areas (DR0046) affected. Rather than qualitatively labeling use as 'minimal,' the proponent should provide data on the frequency of use and the potential economic loss to outfitters and trappers. A clear mitigation plan or 'Access Management Plan' should be developed in consultation with local recreational clubs and commercial land users to address the displacement of activities from the project site to the surrounding broader area.
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 demonstrate a high degree of alignment with the "Summary of Issues" (SOI) published by the Impact Assessment Agency of Canada (IAAC) on February 16, 2026. Specifically, the community’s concern regarding the NWMO’s reliance on desktop-based archaeological data directly supports the IAAC’s identified issue under the Physical and Cultural Heritage theme, which flags potential adverse effects on physical sites, structures, or artifacts of historical importance. Melgund Township’s technical observation—that Stage 1 assessments are insufficient for remote regions where many sites remain unrecorded—provides a specific, evidence-based justification for the IAAC’s broader concern regarding the protection of cultural heritage.
Furthermore, there is a direct correlation between the community’s critique of "minimal" land use characterization and the IAAC’s section on Socio-Economic Conditions. The SOI explicitly calls for information on how the project may affect "recreation, tourism, fishing, hunting, forestry, plant harvesting, trapping, bear management area operations, bait harvesters and existing roads." Melgund Township’s analysis identifies specific traplines (DR024, IG033) and bait harvest areas (DR0046) that are at risk, validating the IAAC’s requirement for a deeper understanding of these land users. The community’s finding that the proponent intends to cease further non-Indigenous land-use baseline data collection represents a significant gap that contradicts the IAAC’s noted "need for community-led baseline data collection" and the general requirement for a comprehensive Impact Statement.
Finally, the community’s focus on the "unofficial" forestry road trail system aligns with the IAAC’s concerns regarding Social Cohesion and Community Wellbeing and Socio-economic impacts to land use. While the IAAC SOI mentions "existing roads," Melgund Township identifies a specific risk to the local lifestyle and quality of life that stems from the disruption of informal recreational networks. This suggests that the IAAC’s general concern about "community cohesion" is substantiated by the township’s observation that the loss of these trails, if unmanaged, could alienate local stakeholders and impact the social fabric of the community.
Recommendations
The working group recommendations emphasize that the proponent must reverse its decision to forgo additional non-Indigenous land-use baseline data. To align with the IAAC’s requirements for understanding socio-economic impacts, the proponent should transition from qualitative descriptions to quantitative studies. This includes conducting a formal socio-economic impact study that measures the frequency of use and economic value of the affected traplines, bait harvest areas, and the "unofficial" trail systems. By providing hard data on potential economic losses and usage patterns, the proponent can move toward the "community-led baseline data collection" envisioned in the IAAC Summary of Issues.
Additionally, it is recommended that a Stage 2 archaeological assessment, involving physical field surveys, be mandated for the 342-hectare site. This recommendation directly addresses the IAAC’s concerns regarding the preservation of physical and cultural heritage. To mitigate the social impacts identified in both the community assessment and the SOI, the proponent should develop a formal Access Management Plan in direct consultation with local snowmobile and ATV clubs. This plan should serve as a primary mitigation strategy to address the displacement of recreational activities, ensuring that the project does not disproportionately harm the "lifestyle and wellbeing" of Melgund Township residents as flagged by the IAAC.
Key Claims
Underlying Assumptions
Critical Observations & Gaps
Analysis Table| Issue Identified | Implication | Information Required |
|---|---|---|
| Absence of field-based (Stage 2) archaeological assessments. | Relying on desktop data (Stage 1) for archaeology may lead to the accidental destruction of unrecorded cultural heritage during construction. | Physical archaeological field surveys of the project footprint. |
| Subjective characterization of land use intensity. | Labeling land use as 'minimal' without quantitative data may alienate local stakeholders like trappers and recreational users. | Quantitative data on trapline yields, bait harvest economic value, and trail usage frequency. |
| Explicit statement that no further non-Indigenous land-use baseline data will be collected. | Stopping data collection early may result in an incomplete Impact Statement that fails to meet regulatory requirements. | A commitment to ongoing land-use monitoring and data updates throughout the Impact Assessment phase. |
| Lack of a formal plan for the 'unofficial' forestry road trail system. | Disruption of 'unofficial' trails could impact community cohesion and quality of life if not properly managed. | A formal Access Management Plan developed with local snowmobile and ATV clubs. |
Working Group Recommendations
Request site-specific baseline abundance data for furbearers and black bears within the specific overlapping management units (Trapline DR024, Bear Management Area IG-09A-040) identified in the submission.
Request a Stage 2 Archaeological Assessment (field survey) for the 342-hectare Project site, rejecting the reliance solely on the 'desktop component of a Stage 1 archaeological assessment'.
Require the Proponent to conduct a specific Safety Interface Assessment regarding the interaction between Project industrial traffic and the identified 'unofficial' recreational users (ATV/Snowmobile) on forestry roads.
Challenge the Proponent's statement that 'The NWMO has no planned work to collect additional non-Indigenous land-use baseline data' and request a quantitative usage study of the 'unofficial trail system' and forestry roads identified in the submission.
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.