Section Synopsis
Pages: 1233The NWMO outlines its commitment to Canada's climate goals by providing estimated Scope 1 and 2 greenhouse gas emissions for the project's construction and operation phases. It identifies the heating plant as the primary emission source and commits to a Greenhouse Gas Management Plan (GHGMP) focused on best available technologies and minimizing offsets.
Community Assessment Narrative
The text presents a professional but narrow view of climate impact. By focusing exclusively on Scope 1 and 2 emissions and labeling them 'negligible' relative to national totals, the proponent may be downplaying the localized or cumulative impact of the project. The claim that the project's role in facilitating nuclear power is 'considerable' introduces a pro-project bias without providing a comparative lifecycle analysis to support such a weight. Furthermore, the commitment to develop a Greenhouse Gas Management Plan (GHGMP) 'prior to operation' leaves a significant gap during the construction phase, which actually has higher estimated annual emissions (14,480 tonnes) than the operations phase. The reliance on 'best available technologies' is a vague placeholder without specific examples of how the heating plant—the source of approximately 90% of emissions—will be decarbonized or transitioned to renewable energy sources.
Corrective Measures & Recommendations
The proponent should expand the emission reporting to include Scope 3 emissions, specifically those related to the transportation of nuclear waste and the carbon footprint of construction materials like concrete and steel. This would provide a more transparent and comprehensive understanding of the project's total climate impact, ensuring that 'negligible' claims are based on the full lifecycle rather than a subset of data.
The Greenhouse Gas Management Plan should be moved forward to the pre-construction phase rather than the pre-operation phase. Since construction emissions are higher and the heating plant is identified as the primary contributor, the proponent must demonstrate specific, actionable strategies for utilizing low-carbon heating technologies, such as geothermal or electric heat pumps, during the initial build to align with the stated goal of prioritizing best available technologies.
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), particularly regarding technical transparency and the timing of environmental oversight. Melgund’s specific focus on the heating plant as a primary emission driver directly supports the IAAC’s concern under the "Alternative means" section, which notes a lack of options considered for project components. By identifying the heating plant as the "overwhelming driver of emissions," the Township provides a technical justification for the IAAC’s requirement that the proponent explore alternative technologies and low-carbon fuel sources.
Furthermore, Melgund’s identification of the omission of Scope 3 emissions aligns with the IAAC’s broader concerns regarding "Cumulative environmental effects" and "Transportation." While the IAAC SOI highlights the "length of the transportation corridor" and "cumulative regional land disturbance," Melgund’s analysis points out a critical data gap: the carbon footprint of waste transportation and construction materials like concrete and steel. This validates the IAAC’s focus on the "Cumulative Transportation Effects" by arguing that a "negligible" impact claim cannot be verified without the full lifecycle data the community is demanding.
A significant alignment is also found regarding the temporal scope of environmental management. Melgund Township flagged that the Greenhouse Gas Management Plan (GHGMP) is currently only required "prior to operation," leaving the high-emission construction phase without formal oversight. This finding directly supports the IAAC’s inclusion of "Monitoring of effects during construction and operation" in Annex A. Both the community and the Agency have identified that the proponent’s current timeline creates a regulatory gap during the most carbon-intensive phase of the project’s early lifecycle.
Finally, Melgund’s concern regarding the ambiguity of Indigenous consultation in climate planning aligns with the IAAC’s section on "Consideration of Indigenous Knowledge." The Township’s observation that Indigenous communities are listed as "recipients" rather than "partners" in the GHGMP development echoes the IAAC’s requirement for the proponent to demonstrate how Indigenous knowledge and authority are incorporated into project planning and decision-making.
Recommendations
The working group recommendations focus on closing the gap between the proponent’s high-level climate commitments and the technical realities of the project’s execution. It is recommended that the proponent be required to expand emission reporting to include Scope 3 lifecycle data. This recommendation directly addresses the IAAC’s concerns regarding "Cumulative environmental effects" by ensuring that the total carbon cost of the project—including the massive amounts of concrete required for the DGR and the fuel for long-distance waste transport—is transparently accounted for before "negligible" impact determinations are finalized.
Additionally, the working group recommends that the Greenhouse Gas Management Plan (GHGMP) be moved to the pre-construction phase. This shift is essential to address the IAAC’s identified issue regarding "Monitoring of effects during construction." By requiring the proponent to demonstrate actionable strategies for low-carbon heating technologies (such as geothermal or electric heat pumps) during the initial build, the community ensures that the project adheres to the "best available technologies" standard from day one. These recommendations provide a clear pathway for the proponent to resolve the uncertainties flagged in the IAAC Summary of Issues while ensuring the local environment and climate goals of Melgund Township are protected.
Key Claims
Underlying Assumptions
Critical Observations & Gaps
Analysis Table| Issue Identified | Implication | Information Required |
|---|---|---|
| Lack of detail on the heating plant technology or fuel source. | The heating plant is the overwhelming driver of emissions, meaning the project's climate success depends almost entirely on one system. | A technical breakdown of the heating plant and an analysis of low-carbon alternatives. |
| Omission of Scope 3 emissions. | Excluding Scope 3 emissions (supply chain and transport) likely results in a significant underestimation of the project's total carbon footprint. | A comprehensive lifecycle greenhouse gas assessment. |
| The GHGMP is only required 'prior to operation'. | The highest emission phase (construction) may proceed without the formal oversight of the Greenhouse Gas Management Plan. | Requirement for a GHGMP or mitigation strategy specifically for the construction phase. |
| Ambiguity regarding the depth of Indigenous consultation in climate planning. | Indigenous communities are listed as recipients of the plan but their role in its development or approval is unclear. | Clarification on how Indigenous traditional knowledge will inform the GHGMP. |
Working Group Recommendations
Demand a detailed technical evaluation of low-carbon alternatives for the proposed heating plant, such as geothermal or industrial-scale electric heat pumps, to replace high-emission fuel sources.
Require the development and implementation of the Greenhouse Gas Management Plan (GHGMP) prior to the start of site preparation and construction, rather than 'prior to operation'.
Challenge the Proponent to demonstrate 100% self-sufficiency in fire suppression and emergency response capacity for the proposed heating plant and associated industrial infrastructure.
Request a comprehensive lifecycle greenhouse gas (GHG) assessment that includes Scope 3 emissions, specifically focusing on the transportation of nuclear waste and the carbon footprint of construction materials.
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.