Section Synopsis
Pages: 1216-1217This document outlines the Nuclear Waste Management Organization's (NWMO) commitments to additional baseline data collection for the Deep Geological Repository (DGR) project. It details planned activities across thirteen environmental and socio-economic categories, including geological characterization, biodiversity surveys, and radiological monitoring. The commitments are intended to supplement existing field data to support future regulatory submissions, impact assessments, and the initial license application, with a specific focus on updating socio-economic baselines using 2026 Census data and Indigenous community engagement.
Community Assessment Narrative
The provided text presents a comprehensive list of future data collection activities, yet it exhibits a subtle but persistent bias toward pre-determined outcomes. For instance, the commitment to 'confirm the non-acid generating and non-toxic nature' of repository rock suggests a conclusion has been reached before the testing program is complete. This phrasing undermines the perceived objectivity of the scientific process. While the document claims previous work was 'technically rigorous,' the extensive list of necessary 'additional' studies across almost every environmental parameter suggests that the current baseline may have significant gaps that require mitigation before a robust impact assessment can be conducted.
Furthermore, the document's approach to social and cultural data is somewhat reactive. By stating that studies will be updated 'as required by regulatory processes,' the proponent risks appearing to meet minimum compliance rather than proactively seeking deep integration of community values. The mention of 'participatory tissue sampling' and 'engagement' with First Nations and Métis communities is positive, but the text lacks specific details on how Indigenous Knowledge will be weighted or integrated into the technical design of the DGR. The use of vague qualifiers such as 'as warranted' or 'appropriate survey methods' provides the proponent with significant discretion, which may lead to transparency issues during the public review phase if the criteria for these decisions are not clearly defined.
Corrective Measures & Recommendations
The proponent should revise the language in the geochemistry and environmental sections to reflect a truly exploratory and objective scientific approach. Instead of committing to 'confirm' specific positive attributes (e.g., non-toxicity), the commitment should be framed as 'characterizing' or 'evaluating' these attributes to avoid the appearance of confirmation bias. Additionally, the proponent must provide clear, predefined criteria for what constitutes 'as warranted' regarding terrestrial wildlife and invertebrate studies. Establishing these thresholds in advance will increase transparency and allow regulators and community stakeholders to understand the triggers for more intensive sampling.
To improve the socio-economic and cultural baseline commitments, the NWMO should explicitly outline the methodology for integrating Indigenous Knowledge (IK) into the environmental media and biodiversity studies. This should go beyond 'engagement' to include a formal framework for how IK will influence baseline interpretations and subsequent impact predictions. Furthermore, the proponent should clarify the contingency plan if the 2026 Census data or specific community-led studies are delayed, ensuring that the impact assessment timeline does not compromise the depth or accuracy of the socio-economic baseline.
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 issues identified in the IAAC Summary of Issues (SOI) published on February 16, 2026, particularly regarding the technical rigor of baseline data and the integration of local and Indigenous knowledge. Melgund’s observation regarding the proponent’s use of "confirmation" language in geochemical studies directly supports the IAAC’s concern under the theme of Physical and Biological Environment: Geochemical behaviour of rock material. While the IAAC flags the potential for acid rock drainage and metal leaching, Melgund’s analysis identifies a specific methodological flaw—the assumption of a positive outcome before testing—which validates the Agency’s need for a more detailed and objective understanding of the rock formation.
Furthermore, Melgund’s concerns regarding the vague triggers for wildlife and bird surveys ("as warranted") align closely with the IAAC sections on Terrestrial Wildlife and their Habitat and Birds (Including Migratory Birds) and Their Habitat. The IAAC notes a general need for more information on levels of disturbance and displacement; Melgund’s finding identifies the specific lack of protocols and decision-making criteria as the root cause of this information gap. This suggests that the proponent’s current commitments may be insufficient to meet the IAAC’s requirement for a comprehensive understanding of direct and indirect pathways of effects on species at risk.
In the realm of socio-economic and cultural impacts, Melgund’s assessment identifies a critical gap that reinforces the IAAC’s findings under Socio-Economic Conditions and Indigenous Peoples: Consideration of Indigenous Knowledge. The IAAC SOI explicitly mentions the "need for community-led baseline data collection" and expresses concern over how Indigenous Knowledge is "incorporated and reflected" in project planning. Melgund’s analysis supports this by pointing out that while the proponent mentions "engagement," there is no clear framework for how that engagement or Indigenous Knowledge actually influences the technical baseline. Additionally, Melgund’s critique of the reliance on 2026 Census data provides a concrete example of the "uncertainty due to limited or inadequate baseline data" highlighted in the IAAC’s summary of health and social conditions.
Recommendations
The working group recommendations focus on shifting the proponent’s approach from one of "confirmation" to one of objective "characterization." By revising the language in geochemistry and environmental sections to reflect an exploratory scientific approach, the proponent can directly address the IAAC’s concerns regarding the suitability of the host rock and the potential for environmental effects from excavated material. Establishing predefined, transparent criteria for wildlife and invertebrate studies is also essential. These thresholds will provide the "appropriate survey methods" the IAAC is seeking, ensuring that the baseline data is robust enough to predict impacts on biodiversity and species at risk accurately.
To address the socio-economic and cultural issues identified in the IAAC SOI, it is recommended that the proponent develop a formal framework for the co-application of Indigenous Knowledge and Western science. This framework should move beyond simple engagement to demonstrate how traditional knowledge specifically shapes baseline interpretations. Finally, to mitigate the risks associated with outdated socio-economic data, the proponent must establish contingency plans for the 2026 Census and integrate local municipal data. This ensures that the "community-led baseline data collection" requested by the IAAC is realized, providing a real-time, accurate foundation for assessing the project’s long-term impacts on Melgund Township and surrounding areas.
Key Claims
Underlying Assumptions
Critical Observations & Gaps
Analysis Table| Issue Identified | Implication | Information Required |
|---|---|---|
| The use of 'as warranted' for terrestrial wildlife and 'appropriate survey methods' for birds lacks specific triggers or standards. | Vague language allows for potential under-sampling of certain species if the proponent deems them not 'warranted.' | Specific protocols and decision-making criteria for when additional studies are triggered. |
| Commitment to 'confirm' the non-acid generating and non-toxic nature of rock assumes the outcome before testing. | Suggests a lack of objectivity in the geochemical assessment process. | A commitment to objective geochemical characterization regardless of the outcome. |
| Lack of detail on how traditional food sampling and community engagement will be integrated into the technical baseline. | Engagement is mentioned, but the actual influence of Indigenous Knowledge on the baseline remains unclear. | A defined framework for the co-application of Indigenous Knowledge and Western science in baseline data. |
| Heavy reliance on 2026 Census data which may not capture real-time socio-economic shifts between 2023 and 2027. | The baseline may be outdated or incomplete if it relies solely on the 2026 Census without considering rapid local changes. | Clarification on how interim data or local municipal data will be used to bridge the gap until Census data is available. |
Working Group Recommendations
Request the Proponent provide an objective geochemical characterization protocol for excavated rock that removes the pre-determined language of 'confirming' non-toxicity as stated in Section 14.3 of the Initial Project Description.
Demand the establishment of clear, predefined triggers and thresholds for what constitutes 'as warranted' regarding additional studies for terrestrial wildlife, carnivores, and invertebrates mentioned in Section 14.10 of the filing.
Request a detailed methodology for how the Proponent will bridge the socio-economic data gap between 2023 and the availability of the 2026 Census data mentioned in Section 15 of the Initial Project Description.
Challenge the Proponent to demonstrate 100% emergency response self-sufficiency for the project site and surrounding township, addressing the critical gap in fire, police, and ambulance services identified in the infrastructure planning section of the filing.
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.