Melgund Recreation, Arts and Culture
Public Comments Archive

23.ESTIMATE OF GREENHOUSE GAS EMISSIONS

Detailed Technical Assessment Report • Ref: REC-SBPJ-F5DY

Section Synopsis

Pages: 64

The NWMO document frames the Deep Geological Repository (DGR) as a vital component of Canada's low-carbon energy strategy and net-zero goals. It acknowledges that the project will generate greenhouse gas (GHG) emissions during construction and operation, primarily from a heating plant, mobile fleets, and land clearing. The NWMO estimates peak annual emissions at 14,480 tonnes of CO2e during construction and 10,834 tonnes during operations, promising to utilize 'best available technologies' to mitigate these impacts in accordance with federal strategic assessments.

Community Assessment Narrative

The NWMO uses typical corporate framing to position a massive industrial project as an environmental necessity. By leading with the 'clean, reliable' nature of nuclear power, they attempt to shield the Revell site's local carbon footprint behind national climate goals. For those of us in Melgund Township, the phrase 'responsible management' feels like marketing fluff designed to make us accept a major industrial heating plant and a fleet of heavy machinery less than 10km from our front doors. The document glosses over the reality that 14,480 tonnes of CO2e per year represents a significant shift from our current quiet, forested baseline to an active industrial zone. The mention of 'land clearing' is particularly sterile; it refers to the destruction of the very carbon sinks that define our region.

Impacts on Local Recreation: The proposed land clearing and the operation of a massive heating plant pose direct threats to the lifestyle of Dyment and Borups Corners residents. The 'mobile fleets' and 'blasting' mentioned will inevitably degrade the acoustic environment, potentially driving game away from traditional hunting grounds and ruining the peace of local trapping lines. Increased industrial traffic on Highway 17 will make transporting ATVs and snowmobiles more hazardous. Furthermore, the visual impact of a large-scale heating plant and the potential for localized air quality issues could diminish the appeal of the Dyment Recreation Hall as a community hub, turning a pristine wilderness area into a visible industrial corridor. The NWMO fails to explain how 'best available technologies' will prevent the hum of generators and the smell of exhaust from permeating our favorite fishing spots and trails.

Corrective Measures & Recommendations

The NWMO must provide a localized air quality and noise impact study specifically for Melgund Township and the Dyment area. It is not enough to cite national GHG totals; we need to know the concentration of particulates and emissions at the 10km radius. They should also commit to a 'Local Recreation Protection Fund' to compensate for the loss of land access and to enhance the Dyment Recreation Hall, ensuring community assets are improved as a direct offset to the industrialization of our backyard.

Furthermore, the proponent must define 'best available technologies' with concrete examples. If they intend to use electric mobile fleets or carbon-neutral heating sources, these should be mandated requirements rather than vague promises. We also demand a transparent plan for how 'land clearing' will be offset within the immediate Revell site vicinity, rather than through distant carbon credits that do nothing for our local ecosystem.

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)

Based on a cross-reference of Melgund Township’s assessment of the NWMO’s Initial Project Description against the IAAC’s February 16, 2026, Summary of Issues (SOI), the following alignments, supporting details, and gaps have been identified:

Alignments on Land Use and Transportation
Melgund Township’s concerns regarding the ambiguity of "land clearing" and the destruction of local habitat align directly with the IAAC SOI section on Terrestrial, riparian and wetland environments. Specifically, the IAAC flagged "Construction effects" including "site clearing" as a key issue, which validates the community's demand for a detailed map of clearing zones. Furthermore, the community’s request for a traffic study of the Highway 17 corridor near Dyment is strongly supported by the IAAC’s Transportation section, which explicitly notes "concerns surrounding traffic... and increased infrastructure demands" and "Transportation service and infrastructure preparedness."

Community Validation of Health and Air Quality Issues
The Township’s technical observation identifying the heating plant as a major source of unquantified pollutants (NOx, SOx) provides necessary technical detail to the broader issue raised in the IAAC’s Health, social and economic conditions section. Where the IAAC broadly lists "changes in air... [and] noise" under "Health effects," Melgund’s analysis supports this by pinpointing the specific machinery (heating plant and mobile fleets) causing these changes. Additionally, the community's recommendation for a "Local Recreation Protection Fund" offers a concrete mitigation strategy for the issue identified by the IAAC under Socio-economic impacts to land use, which calls for information on how the project affects "recreation... and existing roads."

Identified Gap: Greenhouse Gas Emissions
A significant discrepancy exists regarding Greenhouse Gas (GHG) emissions. Melgund Township explicitly quantified peak annual emissions (14,480 tonnes CO2e) and raised concerns regarding the project's contribution to climate change via the heating plant and construction activities. However, the IAAC SOI does not list direct GHG emissions or the project's contribution to climate change as a specific "Key Issue." The IAAC mentions "Climate change effects on transportation" (how climate affects the project), but fails to capture the community's concern regarding how the project affects the climate. This represents a gap where the community’s assessment is more comprehensive than the Agency’s summary.

Key Claims

The DGR is a critical component for Canada to achieve net-zero emissions.
Maximum annual construction emissions will be 14,480 tonnes of CO2e.
The heating plant is the largest single source of project emissions.
NWMO will prioritize 'best available technologies' to reduce direct emissions.

Underlying Assumptions

National climate benefits outweigh the localized environmental degradation in Melgund Township.
GHG estimates provided are exhaustive and account for all secondary industrial activities.
Federal 'Strategic Assessment of Climate Change' requirements are sufficient to protect local air quality.
The 'clean' label of nuclear energy justifies the carbon-intensive construction of its waste facilities.

Critical Observations & Gaps

Analysis Table
Issue Identified Implication Information Required
Vague mention of 'land clearing' without quantifying the acreage or the loss of sequestration capacity. Land clearing reduces local carbon sinks and destroys habitat, which is not fully captured by simple CO2e emission estimates. A detailed map of clearing zones and a plan for local reforestation.
The heating plant is identified as the largest emitter but its fuel source and technology are not specified. The heating plant could be a major source of local air pollution (NOx, SOx) beyond just CO2. Technical specifications for the heating plant and projected local air quality dispersion models.
Transport emissions are mentioned but the frequency and route of these 'mobile fleets' are omitted. Increased heavy vehicle traffic for 'used nuclear fuel transport' and 'mobile fleets' impacts road safety and noise levels for Melgund residents. A comprehensive traffic and noise study for the Highway 17 corridor near Dyment.

Working Group Recommendations

Environment

Request technical specifications for the proposed heating plant, including fuel source and emission control technologies, alongside a localized air quality dispersion model for the Revell site.

The Proponent's submission identifies the heating plant as the largest single source of greenhouse gas emissions during the operations phase. However, the filing lacks detail on secondary pollutants such as nitrogen oxides (NOx) and sulfur dioxide (SO2) that directly impact local air quality. For the residents of Melgund Township, who currently enjoy a pristine wilderness baseline, this industrial emission source represents a significant environmental shift. By demanding specific technical data on the 'best available technologies' mentioned in the filing, the community can ensure that national net-zero goals do not come at the expense of local air purity. This recommendation forces a higher standard of transparency and allows for the verification of mitigation claims.
PENDING
Human Environment (People)

Challenge the Proponent to demonstrate 100% self-sufficiency in emergency response and fire suppression for industrial risks identified in the filing, specifically blasting and heavy mobile fleet operations.

The Initial Project Description explicitly lists blasting, land clearing, and the operation of mobile fleets as core activities. These industrial processes carry inherent risks of fire and accidents. Melgund Township is an unorganized territory with zero local fire, police, or ambulance services. The community has no local capacity to respond to industrial emergencies, and reliance on distant regional services in Ignace or Dryden creates an unacceptable risk due to response times. The Proponent must be held to a mandate of total self-sufficiency, providing 100% of the emergency capacity on-site. This ensures that project-related accidents do not overwhelm distant regional resources or leave Melgund residents unprotected during a crisis.
PENDING
Environment

Require a quantitative assessment of the total acreage of 'land clearing' and the resulting loss of carbon sequestration capacity, paired with a localized reforestation strategy.

The Proponent's submission acknowledges that land clearing will contribute to greenhouse gas emissions but fails to quantify the loss of the existing carbon sink provided by the local forest. In Melgund, the forest is a primary ecological and carbon-capturing asset. Simply reporting CO2e emissions from machinery is insufficient; the permanent removal of sequestration capacity must be baselined. This recommendation seeks to ensure that 'net-zero' claims are not met through distant carbon credits, but through tangible, local ecological restoration. This provides an opportunity for the Proponent to improve the project's environmental standing by committing to local reforestation that benefits the immediate ecosystem of the Revell site.
PENDING
Human Environment (People)

Request a comprehensive traffic safety and infrastructure impact study for the Highway 17 corridor, specifically addressing the frequency and weight of 'mobile fleets' and 'used nuclear fuel transport'.

The filing notes that transport activities are a source of emissions but does not address the socio-economic impact of increased heavy vehicle traffic on local residents. Highway 17 is the primary artery for Melgund residents for daily travel and recreation. The introduction of industrial fleets and nuclear fuel transport increases the risk of collisions and road degradation. Given the lack of local emergency services to respond to highway accidents, understanding the exact volume of project-related traffic is a critical safety requirement. This study will provide the necessary data to demand infrastructure upgrades or dedicated safety lanes, improving the project's integration with the existing community transport patterns.
PENDING

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.