Section Synopsis
Pages: 137-139The Nuclear Waste Management Organization (NWMO) is conducting baseline environmental studies to identify Species at Risk (SAR) and their habitats for the proposed Deep Geological Repository (DGR). The assessment utilizes desktop research, terrestrial mapping, eDNA metabarcoding, and acoustic monitoring. Findings to date have identified several SAR, including two bat species, eleven bird species, and the Snapping Turtle. While some species like woodland caribou and wolverine were excluded based on distance from regulated ranges, others like the American eel were detected via eDNA but remain unconfirmed. The proponent asserts that current data is sufficient for a risk-informed assessment, though further field studies are planned to verify species presence and define Significant Wildlife Habitat (SWH).
Community Assessment Narrative
The provided text presents a structured but preliminary overview of the biological baseline for the DGR project. A significant concern is the proponent's reliance on 'opportunistic identification' for Significant Wildlife Habitat (SWH) and the dismissal of certain high-profile species, such as woodland caribou and wolverine, based solely on current regulatory boundaries (61 km and 80 km respectively). This approach fails to account for potential migratory corridors, climate-induced range shifts, or the cumulative effects of infrastructure development that may extend beyond static map lines. Furthermore, there is a notable tension between the claim that studies are 'sufficiently advanced' for risk assessment and the admission that critical data—such as the verification of American eel presence and the characterization of upland breeding birds—is still missing. The uncertainty regarding eDNA results for the American eel is treated with skepticism because it falls 'outside the typical range,' which may indicate a bias toward expected results rather than an objective acceptance of emerging data. The reliance on desktop studies for several provincial SAR bats and invertebrates suggests a gap in active field verification that could lead to an underestimation of the project's ecological footprint. Transparency regarding the 'uncertainty' of eDNA methods is appreciated, but it must be met with rigorous, traditional sampling to ensure the precautionary principle is upheld in this sensitive nuclear waste context.
Corrective Measures & Recommendations
The proponent should transition from 'opportunistic' identification of Significant Wildlife Habitat to a systematic, grid-based survey methodology. This is essential to ensure that candidate habitats for maternity colonies, hibernacula, and nesting sites are not overlooked due to the timing or location of general terrestrial mapping. Systematic surveys provide a statistically defensible baseline that is required for a project of this magnitude and long-term impact. Additionally, the proponent must conduct a connectivity analysis for wide-ranging species like woodland caribou and wolverine. Relying on static distance buffers from known ranges is insufficient for an impact assessment; the study should evaluate whether the project site serves as a movement corridor or if secondary impacts, such as increased noise or traffic, could affect these species' regional recovery. Finally, the uncertainty surrounding the American eel detection must be resolved through immediate, targeted traditional netting or electrofishing surveys. If the eDNA detection is valid, the presence of a critically endangered species would fundamentally alter the project's mitigation requirements and regulatory triggers. The proponent should also expand the scope of terrestrial invertebrate surveys beyond 'potential' presence to include active sampling for the Yellow-banded Bumble Bee and Monarch butterfly, given their federal status and the likelihood of habitat disruption during construction.
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 Melgund Township community assessment findings demonstrate a high degree of alignment with the "Species at risk and their habitat" and "Terrestrial Wildlife and their Habitat" themes identified in the IAAC Summary of Issues (SOI) published on February 16, 2026. Specifically, the IAAC SOI flags a "concern regarding insufficient information on species at risk and their habitats," which is directly validated by the community’s observation that the proponent’s reliance on "opportunistic" identification for Significant Wildlife Habitat (SWH) is technically inadequate. The community’s finding that the proponent has prematurely concluded that data is "sufficiently advanced" for a risk-informed assessment provides a concrete example of the "missing baseline data" concern listed under the IAAC’s "Uncertainty related to project effects" section.
Furthermore, the community’s focus on the American eel and the need for traditional sampling (netting/electrofishing) to verify eDNA detections supports the IAAC’s "Fish and Fish Habitat" category. While the IAAC SOI identifies general concerns regarding effects on fish and water quality, the Melgund Township analysis identifies a specific regulatory and technical gap: the potential dismissal of a critically endangered species based on unverified eDNA results. This alignment suggests that the IAAC’s broad concern about "direct and indirect pathways of effects" must include the rigorous verification of high-priority species that could trigger federal protection mandates.
A significant alignment also exists regarding wide-ranging species like the woodland caribou and wolverine. The IAAC SOI notes concerns regarding "radiological effects to wildlife," including impacts related to "migration." The community assessment expands on this by criticizing the proponent’s use of arbitrary 61-80km distance buffers to exclude these species. By identifying the need for "connectivity and movement corridor analysis," the community provides the necessary technical depth to the IAAC’s general requirement for more information on "levels of disturbance, displacement, or harm" to local wildlife.
Recommendations
The working group recommendations focus on transitioning the proponent’s environmental study program from a passive, opportunistic model to a rigorous, systematic framework. By implementing grid-based survey methodologies for Significant Wildlife Habitat and targeted sampling for SAR invertebrates like the Yellow-banded Bumble Bee, the proponent can directly address the "insufficient information" gap identified in the IAAC Summary of Issues. These systematic approaches are necessary to provide the statistically defensible baseline data that the IAAC and the community require to accurately predict project impacts and establish meaningful mitigation measures.
Additionally, it is recommended that the proponent resolve the uncertainty surrounding the American eel and wide-ranging mammals through active field verification and connectivity modeling. These actions relate directly to addressing the IAAC-identified issues of "uncertainty related to project effects" and "indirect pathways of effects." Resolving these data gaps before finalizing the risk assessment is essential to ensure the Integrated Tailored Impact Statement Guidelines are based on a complete ecological profile of the Revell Site, rather than on "potential" presence or arbitrary exclusion zones.
Key Claims
Underlying Assumptions
Critical Observations & Gaps
Analysis Table| Issue Identified | Implication | Information Required |
|---|---|---|
| Use of opportunistic identification for Significant Wildlife Habitat (SWH). | Relying on 'opportunistic' data for SWH may lead to the destruction of critical habitats that were simply not noticed during general mapping. | A systematic and dedicated SWH survey protocol. |
| Exclusion of wide-ranging species based on 61-80km distance buffers. | Excluding caribou and wolverine based on arbitrary distance ignores ecological connectivity and potential indirect impacts. | Connectivity and movement corridor analysis for these species. |
| Uncertainty and potential dismissal of American eel eDNA detections. | The American eel is a high-priority SAR; dismissing eDNA results without immediate verification risks non-compliance with federal protections. | Verification through traditional sampling (netting/electrofishing) and barcode gap analysis. |
| Premature conclusion that data is 'sufficiently advanced' for risk-informed assessment. | Claiming data is sufficient for risk assessment while admitting to missing field data undermines the rigor of the IA process. | Completion of planned field studies before finalizing the risk assessment. |
| Lack of confirmed field data for terrestrial invertebrates like the Yellow-banded Bumble Bee. | Invertebrates are often indicators of ecosystem health; 'potential' presence is not a substitute for baseline data. | Targeted field surveys for SAR invertebrates during appropriate seasonal windows. |
Working Group Recommendations
Contest the exclusion of Woodland Caribou and Wolverine from the environmental baseline studies based solely on static distance buffers (61 km and 80 km, respectively) and request a connectivity/corridor analysis.
Challenge the Proponent's methodology regarding the 'opportunistic identification of candidate Significant Wildlife Habitat (SWH)' alongside terrestrial ecosystem mapping, requesting a transition to systematic, dedicated SWH surveys.
Formally object to the Proponent's statement that studies are 'sufficiently advanced to support a risk-informed assessment' while simultaneously admitting that 'further field studies are needed to verify the presence and distribution of SAR'.
Request immediate, traditional field verification (netting/electrofishing) for the American Eel, following the positive eDNA metabarcoding detection which the Proponent currently characterizes as 'uncertain' and 'outside the typical range'.
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.