Section Synopsis
Pages: 14-19The provided text outlines the Nuclear Waste Management Organization's (NWMO) long-term engagement strategy with Indigenous Peoples regarding the implementation of Adaptive Phased Management (APM) for Canada's used nuclear fuel. It details the transition from a multi-year site selection process to the regulatory phase, highlighting the selection of Wabigoon Lake Ojibway Nation (WLON) as a host community following a 2024 Hosting Agreement. The document emphasizes the NWMO's 'Reconciliation Journey,' the integration of Indigenous Knowledge through a dedicated Council of Elders and Youth, and the use of 'Learn More Agreements' with regional Indigenous groups. It also notes the statutory framework governing these interactions and the NWMO's commitment to addressing the Calls for Justice from the National Inquiry into Missing and Murdered Indigenous Women and Girls.
Community Assessment Narrative
The text presents a highly structured and polished narrative of corporate responsibility and Indigenous partnership, yet it contains several points of tension that merit critical scrutiny. A primary concern is the reliance on a 'confidential' Hosting Agreement with the Wabigoon Lake Ojibway Nation. While the text asserts that WLON is a 'willing, informed, and supportive host,' the lack of transparency regarding the terms of this agreement complicates the ability of external reviewers and neighboring Indigenous groups to assess the equity and long-term implications of the arrangement. This confidentiality may inadvertently foster distrust among regional stakeholders who are also impacted by the project but are not parties to the specific agreement.
Furthermore, there is a notable temporal gap in the engagement record. Table 3.1 reveals that 'Learn More Agreements' for nearly all regional Indigenous nations—including Eagle Lake, Lac Seul, and the Métis Nation of Ontario—expired in late 2024 or early 2025. Simultaneously, the text notes that letters sent to these nations in July 2025 regarding the Initial Project Description (IPD) have received 'no formal response.' This suggests a potential breakdown in formal engagement or a lack of capacity among regional nations to respond within the proponent's timeline, which contrasts with the NWMO's narrative of 'continuous dialogue.' The use of emotive language such as 'Reconciliation Journey' and 'birthed through ceremony' serves to frame the project in a positive ethical light, but without more granular data on how Indigenous Knowledge has actually altered technical designs or site characterization, these claims remain largely process-oriented rather than outcome-verified.
Corrective Measures & Recommendations
The proponent should provide a non-confidential summary of the Hosting Agreement's key pillars, particularly those related to environmental oversight, community safety, and long-term socio-economic benefits. This would enhance transparency and allow neighboring communities to understand the precedent being set for regional impacts. Transparency is essential to ensure that 'willingness' is viewed as a collective regional consideration rather than an isolated bilateral transaction, especially given the shared nature of water systems and traditional territories.
Additionally, the NWMO must address the status of the expired 'Learn More Agreements' with regional Indigenous groups. The proponent should actively seek to renew these formal frameworks to provide the necessary resources and capacity for these nations to participate meaningfully in the upcoming regulatory and impact assessment phases. Relying on unanswered letters sent shortly before the IPD submission is insufficient for demonstrating robust engagement; a proactive plan to re-establish formal dialogue with regional nations is required to mitigate risks of future litigation or social license challenges.
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 "Indigenous Peoples" and "Socio-Economic Conditions" themes identified in the IAAC Summary of Issues (SOI). Specifically, Melgund’s concern regarding the confidentiality of the Hosting Agreement with Wabigoon Lake Ojibway Nation (WLON) directly supports the IAAC’s identified issue under Indigenous engagement, which flags concerns related to the "transparency of project information." Melgund’s recommendation for a non-confidential summary of environmental and social commitments validates the IAAC’s call in Annex A (Public Engagement and Communication) for "clear, accessible, plain-language, and inclusive communications" regarding project risks and long-term impacts.
There is a strong correlation between Melgund’s observation of unsubstantiated "millions of dollars" in investment and the IAAC’s concern regarding the Distribution of economic benefits for all regional communities. The IAAC specifically notes that project-related benefits may not be equitably shared with communities outside of formal hosting agreement areas. Melgund’s analysis provides a concrete example of this gap, arguing that without a detailed breakdown of these investments, it is impossible to determine if funds are supporting broad regional development or are merely project-specific participation costs. This supports the IAAC’s requirement for the proponent to address how benefits and burdens are distributed across the broader region.
Melgund Township has identified a critical operational gap that the IAAC SOI touches upon but does not specify: the expiration of "Learn More Agreements" in late 2024 and early 2025. While the IAAC identifies Capacity and support for participation as a key issue, Melgund’s findings provide the specific evidence of a "lapse in formal support" during the transition to the regulatory phase. Furthermore, Melgund’s observation regarding the lack of response from four regional nations to the July 2025 letters reinforces the IAAC’s concern under Adequacy of Indigenous engagement regarding whether engagement is "meaningful, ongoing, and sufficient." Melgund’s critique—that relying on unanswered letters sent shortly before an IPD submission is insufficient—serves as a vital validation of the IAAC’s focus on the "timing, clarity, and accessibility" of proponent outreach.
Finally, Melgund’s recommendation that "willingness" must be viewed as a "collective regional consideration" rather than a "bilateral transaction" aligns with the IAAC’s focus on Respect for Indigenous authority and jurisdiction. By highlighting the shared nature of water systems and traditional territories, Melgund’s analysis provides a geographic and environmental justification for the IAAC’s inclusion of "Section 2: Submissions identifying DGR project issues and concerns across the broader region." This reinforces the community’s stance that regional social license is a prerequisite for the project, a sentiment echoed throughout the IAAC’s summary of Indigenous and socio-economic concerns.
Key Claims
Underlying Assumptions
Critical Observations & Gaps
Analysis Table| Issue Identified | Implication | Information Required |
|---|---|---|
| The Hosting Agreement with WLON is confidential at the request of the Nation. | Confidentiality limits the ability of other affected groups to evaluate the fairness of the hosting terms. | A public summary of the agreement's environmental and social commitments. |
| Most 'Learn More Agreements' with regional nations expired in late 2024 or early 2025. | Suggests a potential lapse in formal support for regional nations during a critical transition phase. | Clarification on whether these agreements will be renewed or replaced for the regulatory phase. |
| The claim of 'millions of dollars' in investment is unsubstantiated by specific data. | Without a breakdown, it is unclear if these funds are for project-specific participation or broader community development. | A detailed report on the distribution and impact of these investments. |
| No formal response has been received from four key regional nations regarding the July 2025 IPD letters. | The lack of response may indicate that the engagement timeline is not respecting the internal governance speeds of the Nations. | Evidence of follow-up efforts and an assessment of the barriers to response for these nations. |
Working Group Recommendations
Challenge the confidentiality of the 'Hosting Agreement' specifically regarding provisions for regional emergency response, infrastructure maintenance, and community safety definitions.
Request the quantitative hydrogeological baseline data that underpins the 'Water Statement' and the 'integrative narrative' regarding the 'interconnected systems of water' described in the filing.
Request the specific operational details of the 'social safety' framework and the implementation plan for 'Call for Justice 13' regarding extractive industries, as cited in the Proponent's submission.
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.