Section Synopsis
Pages: 48-52This section outlines the multi-jurisdictional regulatory framework governing the proposed DGR project, including the Wabigoon Lake Ojibway Nation’s (WLON) Regulatory Assessment and Approvals Process (RAAP), federal oversight by the Impact Assessment Agency of Canada (IAAC) and the Canadian Nuclear Safety Commission (CNSC), and various provincial permits. It lists numerous acts and regulatory documents (REGDOCs) concerning safety, environmental protection, and transportation that the NWMO must comply with to secure licenses for site preparation, construction, and operation.
Community Assessment Narrative
The NWMO’s summary of regulatory approvals is a masterclass in 'corporate-speak' designed to overwhelm the reader with a blizzard of acronyms and legal citations while saying very little about the actual disruption to Melgund Township. By framing the project as a series of checkboxes—IAA, CNSC, SARA, etc.—the document attempts to create an aura of inevitability and rigorous oversight. However, for those of us in Dyment and Borups Corners, these lists of 'Potential Permits' feel like a roadmap for the industrialization of our backyard. The text glosses over the reality that 'compliance' with a noise or air emission permit doesn't mean the noise or dust won't be there; it just means it will be within a limit set by a bureaucrat in Ottawa or Toronto who doesn't have to sleep 10km away from a 24/7 construction site.
There is a glaring lack of mention regarding the local voice of Melgund residents. While the document rightfully acknowledges the WLON RAAP process, it leaves the non-Indigenous residents of the immediate vicinity in a regulatory vacuum. We are told the project is 'Canada’s plan,' but the 'Plain Language Summary' hides the technical risks behind a wall of REGDOC numbers. The assumption that federal and provincial standards are sufficient to protect our specific way of life is a significant leap of faith that many in the community are not prepared to take, especially when the document admits that 'discussions about the applicability of Ontario provincial laws... have not yet occurred.'
Impacts on Local Recreation: The mention of the Fisheries Act, the Explosives Act, and 'water takings' signals a massive threat to our local recreation. The Revell site is not a dead zone; it is where we hunt, fish, and ride. The 'Authorization for Harmful Alteration' of fish habitat is a polite way of saying some of our local fishing spots might be ruined or restricted. Furthermore, the storage of explosives and the construction of 'tall structures' with aeronautical lighting will permanently scar the acoustic and visual environment that makes the Dyment Recreation Hall a community hub. If trails are cut off for 'security' or 'safety' zones, the snowmobiling and ATV networks that sustain our local social life will be severed. The NWMO mentions 'merchantable timber' and 'aggregates,' which suggests large-scale clearing that will displace the wildlife we rely on for hunting, effectively turning our recreational backyard into a restricted industrial zone.
Corrective Measures & Recommendations
The NWMO must move beyond listing federal and provincial statutes and provide a 'Local Impact Mitigation Plan' specifically for Melgund Township. This plan should include legally binding commitments to maintain access to existing hunting and fishing grounds, or provide equivalent land offsets. Furthermore, the proponent must fund an independent, community-led monitoring station at the Dyment Recreation Hall to track noise, light pollution, and air quality, with the power to trigger a 'stop-work' order if levels exceed baseline community comfort, not just federal minimums.
To address the loss of local character, the NWMO should provide direct financial support for the enhancement of the Dyment Recreation Hall and local trails as a form of 'recreational compensation.' They must also clarify the 'exclusion zones' associated with the Explosives Act and nuclear security requirements, providing a map that shows exactly which ATV and snowmobile trails will be closed or rerouted. Transparency is not just listing REGDOCs; it is showing us exactly where we will no longer be allowed to walk.
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 show a high degree of alignment with the IAAC Summary of Issues (SOI), particularly regarding environmental protections and socio-economic equity. Melgund’s concern regarding "significant local water table disruption" and the need for site-specific hydrogeological studies directly supports the IAAC’s themes under Groundwater and Surface Water, specifically the "Water usage" and "Potential and cumulative effects on water" categories. The IAAC’s inclusion of concerns regarding "local drinking water sources" and "aquifers" validates the Township’s observation that large-scale water takings and sewage works could jeopardize the local aquifers used by residents in the Melgund/Dyment area.
There is also strong alignment regarding land use and the distribution of project benefits. Melgund’s recommendation for legally binding commitments to maintain access to hunting and fishing grounds is mirrored in the IAAC’s Socio-Economic Conditions section, under "Socio-economic impacts to land use," which explicitly lists hunting, fishing, and recreation. Crucially, Melgund’s concern about being excluded from the "Hosting Agreement" framework is validated by the IAAC’s identified issue: "Distribution of economic benefits for all regional communities," which highlights concerns that benefits may not be equitably shared with communities outside formal hosting areas. This suggests that the Agency recognizes the potential for "information asymmetry" and economic marginalization that Melgund has flagged.
A significant gap exists, however, regarding the specific regulatory authority and physical security footprint of the project. While the IAAC mentions "Security Risks and Safeguards" in a general sense (terrorism and proliferation), Melgund’s analysis identifies a more localized technical concern: the lack of detailed maps showing the physical footprint of "exclusion zones" associated with a Class 1B facility. The community’s focus on how these zones will specifically reroute ATV and snowmobile trails is a granular land-use issue that the IAAC’s broader summary touches upon but does not detail with the same level of urgency.
Finally, Melgund’s recommendation for an independent, community-led monitoring station at the Dyment Recreation Hall with "stop-work" authority goes beyond the IAAC’s general call for "Monitoring of effects during construction and operation" found in Annex A. While the IAAC acknowledges the need for monitoring air, water, and noise, Melgund’s demand for local enforcement power represents a specific governance gap. The community is asking for a formal regulatory role that the IAAC SOI notes as a concern ("Social cohesion and community wellbeing") but does not yet provide a framework to resolve. This suggests that while the IAAC has captured the symptoms of community concern, Melgund’s findings provide the specific mechanisms (like the Local Impact Mitigation Plan) required to address them.
Key Claims
Underlying Assumptions
Critical Observations & Gaps
Analysis Table| Issue Identified | Implication | Information Required |
|---|---|---|
| Lack of a formal local community regulatory role. | Melgund residents are excluded from the formal 'Hosting Agreement' framework mentioned for WLON, leaving them without a clear regulatory voice. | A defined framework for Melgund Township to participate in the RAAP or a parallel local oversight process. |
| Potential for significant local water table disruption. | Water takings over 50,000 L/d and sewage works could impact local aquifers and the water table used by residents. | Specific hydrogeological impact studies for the Melgund/Dyment area. |
| Ambiguity regarding the size and impact of security/exclusion zones. | The classification as a Class 1B facility brings intense security and exclusion requirements that are not detailed in the summary. | Detailed maps showing the physical footprint of all restricted areas. |
| Information asymmetry between the proponent and the community. | The 'Plain Language' label is misleading as it points to complex REGDOCs that are not easily accessible or understandable to the public. | Summaries of each REGDOC's specific implications for the Revell site in truly plain language. |
Working Group Recommendations
Challenge the Proponent to demonstrate 100% self-sufficiency for emergency response and nuclear emergency preparedness as referenced in REGDOC-2.10.1 and the Explosives Act.
Request comprehensive hydrogeological baseline studies for the Melgund and Dyment area to address the potential impacts of water takings exceeding 50,000 L/d and large-scale sewage works.
Demand a specific Transportation Safety and Emergency Response Plan for the movement of used nuclear fuel and explosives through the Melgund corridor, as governed by the Transportation of Dangerous Goods Act.
Require the establishment of local air quality and noise baseline monitoring stations at community-sensitive locations, such as the Dyment Recreation Hall, to validate future compliance with provincial standards.
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.