Section Synopsis
Pages: 128-130The provided text outlines the baseline data and planned studies for fish and fish habitat regarding a proposed Deep Geological Repository. It details findings from 2021-2022 field studies and desktop reviews, identifying 55 fish species in the regional area and 26 via eDNA. While the proponent identifies various spawning and nursery habitats in the regional investigation area, it notes a lack of documented 'important' fish habitat within the immediate project site. The document concludes that while more data is required for regulatory authorizations, the current information is sufficient for preliminary risk assessments, with future work focusing on community surveys, benthic studies, and food web characterization.
Community Assessment Narrative
The submission exhibits a notable tension between its admission of data gaps and its assertion of readiness for impact assessment. The proponent acknowledges that 'important' fish habitat has not yet been documented within the project site, yet simultaneously claims the current baseline is 'sufficiently comprehensive' to support early conclusions on impact significance. This creates a potential transparency issue, as the absence of evidence (due to limited local field data) appears to be framed as evidence of absence regarding critical habitats. The reliance on eDNA metabarcoding for species detection without completed ground-truthing introduces technical uncertainty, as eDNA can indicate presence but not necessarily habitat use or population health. Furthermore, the text focuses heavily on desktop data and 'citizen science,' which may not capture the granular, site-specific nuances required for a project of this magnitude. There is also a conspicuous absence of Indigenous Knowledge or local harvester perspectives in this section, which are vital for identifying seasonal migration patterns or historical spawning grounds that desktop databases often overlook. The tone is professional but leans toward a 'low-risk' bias by emphasizing regional biodiversity while downplaying the lack of specific data for the local investigation area.
Corrective Measures & Recommendations
The proponent must prioritize the 'ground-truthing' of eDNA results with traditional netting or electrofishing surveys to confirm species presence and abundance within the local investigation area. This is critical because eDNA can yield false positives or detect DNA transported from outside the immediate area, leading to an inaccurate characterization of the project site's ecological value. Additionally, the proponent should conduct targeted multi-season field studies, specifically focusing on overwintering and spring-spawning activities in the unnamed watercourses and wetlands proximal to the site, as these are currently identified as data gaps. To address the lack of socio-cultural integration, the proponent should formally incorporate Indigenous Traditional Ecological Knowledge (TEK) regarding fish movements and historical habitat use. This would provide a more robust baseline than desktop databases alone and ensure that the assessment accounts for species of cultural and subsistence importance to local communities. Finally, the proponent should revise the 'early conclusions' on impact significance once these local, field-verified data points are integrated, ensuring the Impact Statement is based on empirical evidence rather than preliminary assumptions.
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 technical findings and public comments 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 concerns regarding the proponent’s reliance on eDNA without field verification and the absence of overwintering habitat data directly support the IAAC’s identified issue under the Species at Risk and Their Habitat and Fish and Fish Habitat themes. The IAAC document notes a broad concern regarding "insufficient information on species at risk" and "potential effects of the project on fish and fish habitat." Melgund Township’s analysis provides the necessary technical specificity to these broad concerns by identifying that 26 species detected via eDNA lack ground-truthing, which could lead to an inaccurate characterization of the project site’s ecological value.
Furthermore, Melgund Township’s observation regarding the lack of Indigenous engagement and Traditional Ecological Knowledge (TEK) in identifying fish habitat aligns perfectly with the IAAC’s section on Indigenous Peoples, specifically the sub-themes of Consideration of Indigenous Knowledge and Uncertainty related to project effects. The IAAC highlights concerns regarding "limited, inaccurate, or missing baseline data" and the need for Indigenous Knowledge to be "incorporated and reflected in project planning." The community’s finding that the proponent has excluded local and Indigenous knowledge in its fish habitat assessment validates the IAAC’s concern that the current baseline may be inadequate for predicting impacts on harvesting and cultural practices.
A significant alignment is also found in the community’s critique of the proponent’s "early conclusions" on risk significance. This mirrors the IAAC’s theme of Uncertainty related to project effects, where the Agency notes concerns about "missing baseline data available to accurately predict effects." Melgund Township’s assessment identifies a specific gap: the proponent claims data is sufficient for risk assessment despite acknowledging that overwintering and rearing habitats have not been identified. This supports the IAAC’s broader mandate for the proponent to provide a response that sets out how it intends to address "high levels of uncertainty" before moving toward an Impact Statement.
Recommendations
The working group recommendations focus on the immediate necessity for the proponent to transition from desktop-heavy modeling to empirical, field-verified data collection. By prioritizing the "ground-truthing" of eDNA results through traditional netting and electrofishing, the proponent can directly address the IAAC’s concerns regarding "insufficient information" on species at risk. These recommendations emphasize that multi-season field studies—particularly during the winter and spring freshet—are not optional but are required to fill the data gaps identified in the IAAC’s Summary of Issues regarding fish habitat and watercourse functionality.
Furthermore, the recommendations advocate for the formal integration of Indigenous Traditional Ecological Knowledge (TEK) to supplement technical surveys. This approach directly relates to addressing the IAAC-identified issues of "Indigenous authority and jurisdiction" and the "current use of lands and resources." By revising early conclusions on impact significance only after this local and cultural data is integrated, the proponent will ensure the Impact Statement aligns with the IAAC’s requirement for a "risk-informed" assessment based on a robust and inclusive baseline. These actions are essential to resolving the uncertainties flagged by both the community and the Agency, ensuring that the assessment of the DGR project is grounded in the actual ecological and social realities of the Melgund Township region.
Key Claims
Underlying Assumptions
Critical Observations & Gaps
Analysis Table| Issue Identified | Implication | Information Required |
|---|---|---|
| 26 species detected via eDNA require future confirmation. | Reliance on eDNA without ground-truthing may lead to incorrect species lists or missed habitat identifications. | Field verification data (netting/visual) to validate eDNA findings. |
| No overwintering or rearing habitat identified in local watercourses or wetlands to date. | Missing overwintering and rearing data in the local area could lead to the destruction of critical habitat during construction. | Multi-season field surveys, particularly during winter and spring freshet. |
| Claiming data is sufficient for risk assessment despite acknowledged gaps. | Premature conclusions on impact significance may undermine the credibility of the Impact Statement. | A clear justification of how 'risk-informed' assessments are valid without local habitat confirmation. |
| No mention of Indigenous engagement or Traditional Ecological Knowledge in identifying fish habitat. | Excluding local and Indigenous knowledge may result in overlooking habitats of high cultural or subsistence value. | Integration of TEK and community consultation records regarding local fisheries. |
Working Group Recommendations
Require a dynamic impact assessment that models fish passage scenarios assuming the natural failure or removal of the identified 'beaver dam' barriers.
Challenge the Proponent's conclusion that 'no potentially important fish habitat' exists within the Project site, specifically requesting winter field surveys to validate the claim of 'no overwintering habitat' in local watercourses.
Request immediate physical ground-truthing (netting or electrofishing) for the 26 species detected solely via eDNA metabarcoding in the Regional and Local Investigation Areas.
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.