Section Synopsis
Pages: iThe Nuclear Waste Management Organization (NWMO) outlines its commitment to Indigenous relations regarding the Deep Geological Repository (DGR) project. The document identifies the Wabigoon Lake Ojibway Nation (WLON) as a willing host and acknowledges the project's long-term impacts on traditional lands and resources. The NWMO pledges to seek Free, Prior, and Informed Consent (FPIC), align with Anishinaabe values, and address the National Inquiry into Missing and Murdered Indigenous Women and Girls (MMIWG) Calls for Justice. Crucially, the proponent admits that current data regarding Indigenous populations and on-reserve communities in the Initial Project Description is incomplete.
Community Assessment Narrative
The text presents a highly aspirational and conciliatory tone, framing the project within the context of a 'reconciliation learning journey.' While the acknowledgement of Section 35 rights and the commitment to FPIC are positive indicators of corporate responsibility, there is a notable tension between the claim of having 'willing and informed hosts' and the subsequent admission that the data used to characterize these populations is incomplete. This creates a transparency gap; it is difficult to validate the 'informed' nature of the consent if the proponent simultaneously acknowledges that their own data does not fully represent the Indigenous identity or the characteristics of on-reserve communities. The reliance on WLON as the primary 'proximate' group may also overlook the broader regional impacts on other First Nation and Métis communities who may have unresolved claims or different perceptions of risk.
Furthermore, the document uses emotive language such as 'grateful,' 'honours,' and 'great fortune,' which, while respectful, can serve to obscure the technical and socio-economic burdens the project imposes. The admission that federal acts are being 'imposed' on Indigenous peoples is a significant ethical acknowledgement, yet the text lacks a concrete framework for how Anishinaabe values will be weighted against Western regulatory requirements in the event of a conflict. The mention of MMIWG Call for Justice #13 is a critical inclusion, but without specific actionable items or monitoring programs, it remains a high-level commitment rather than a verifiable mitigation strategy. The overall narrative suggests a project that is socially aware but technically premature in its socio-cultural data integration.
Corrective Measures & Recommendations
The proponent must prioritize the completion of the Indigenous identity and on-reserve community data sets before proceeding to the next phase of the Impact Assessment. This should involve a co-developed data collection protocol that respects data sovereignty and ensures that the 'informed' component of FPIC is based on a comprehensive understanding of the local and regional demographics. Without this baseline, any assessment of socio-economic or cultural impact remains speculative and potentially biased toward the proponent's existing relationships.
Additionally, the NWMO should transition from high-level commitments to a detailed 'Indigenous Rights and Interests Mitigation Framework.' This framework must explicitly define how Anishinaabe values will be integrated into technical decision-making and provide a clear roadmap for actioning MMIWG Call for Justice #13. This should include specific measures such as gender-based analysis plus (GBA+) in workforce planning, community safety protocols for extractive industries, and a transparent mechanism for resolving potential conflicts between traditional governance systems and federal regulatory mandates.
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 proponent’s admission of incomplete data on Indigenous populations directly supports the IAAC’s identification of "Uncertainty related to project effects" under the Indigenous Peoples section. The IAAC notes that limited or missing baseline data hinders the ability to accurately predict effects on land and resource use; Melgund Township’s analysis provides a specific example of this gap by highlighting the lack of representation for on-reserve community characteristics in the Initial Project Description (IPD).
Furthermore, there is a strong alignment between the community’s focus on the National Inquiry into Missing and Murdered Indigenous Women and Girls (MMIWG) Call for Justice #13 and the IAAC’s concerns under Infrastructure and Services. The IAAC SOI explicitly flags "potential increases in gender-based violence" resulting from an influx of temporary workers. Melgund Township’s assessment validates this concern but goes further by identifying a specific policy gap: the proponent has mentioned a commitment to MMIWG calls without providing the actionable, gender-based mitigation plans necessary to address the risks identified by the Agency.
The community’s observation regarding the lack of clarity on integrating Anishinaabe values into technical management aligns with the IAAC’s theme of Consideration of Indigenous Knowledge. While the IAAC asks how such knowledge will be incorporated into project planning, Melgund Township’s findings suggest that without a formal framework, these commitments remain symbolic. Additionally, the community’s concern regarding unresolved land claims supports the IAAC’s section on Rights of Indigenous Peoples, specifically regarding "interference with the ability to exercise Indigenous and Treaty rights" and "respect for Indigenous authority and jurisdiction."
Recommendations
The working group recommendations emphasize that the proponent must not be permitted to move to the next phase of the Impact Assessment until the identified data gaps regarding Indigenous identity and on-reserve demographics are closed. This recommendation directly addresses the IAAC’s concern regarding "Socio-economic effects" and the "need for community-led baseline data collection." By requiring a co-developed data collection protocol that respects data sovereignty, the community ensures that the "informed" part of Free, Prior, and Informed Consent (FPIC) is technically sound, thereby mitigating the risks of speculative impact assessments flagged in the SOI.
To address the social and cultural risks identified in both the community assessment and the IAAC SOI, it is recommended that the NWMO develop a formal "Indigenous Rights and Interests Mitigation Framework." This framework should serve as the operational bridge between high-level proponent pledges and the specific issues raised by the Agency, such as gender-based violence and the integration of Traditional Knowledge. By mandating specific measures like Gender-Based Analysis Plus (GBA+) in workforce planning and a transparent mechanism for resolving conflicts between traditional governance and federal mandates, the community provides a clear pathway to resolve the "Human Health and Well-Being" and "Indigenous engagement" issues outlined by the IAAC.
Key Claims
Underlying Assumptions
Critical Observations & Gaps
Analysis Table| Issue Identified | Implication | Information Required |
|---|---|---|
| Commitment to MMIWG Call for Justice #13 is mentioned without specific actionable measures. | Failure to provide a concrete plan for MMIWG Call for Justice #13 could lead to increased safety risks for Indigenous women and girls during project construction and operation. | A detailed community safety and gender-based mitigation plan. |
| The proponent admits the IPD lacks a full representation of Indigenous identity and on-reserve community characteristics. | Incomplete data on Indigenous populations makes it impossible to accurately assess the project's socio-economic and cultural impacts. | Comprehensive baseline socio-economic and demographic studies co-authored with Indigenous communities. |
| Lack of clarity on how Anishinaabe values will be integrated into the technical and environmental management of the DGR. | Without a defined mechanism, 'aligning with Anishinaabe values' may be relegated to a symbolic gesture rather than a project requirement. | A framework for the integration of Traditional Knowledge and values into project design and monitoring. |
| Acknowledgement of unresolved claims between Indigenous communities and the Crown near the project site. | Unresolved claims could lead to legal challenges or project delays if not addressed early in the IA process. | A status report on how these claims interact with the project footprint and the Crown's duty to consult. |
Working Group Recommendations
Request a detailed map and operational definition of the 'changes in access' to land and water referenced in the Proponent's submission.
Challenge the Proponent to demonstrate a fully self-sufficient security and policing plan to satisfy the commitment to MMIWG Call for Justice #13, without reliance on local resources.
Require the immediate collection and inclusion of socio-demographic data for Melgund Township to rectify the admitted lack of representation for unincorporated communities in the Initial Project Description.
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.