Melgund Recreation, Arts and Culture
Public Comments Archive

12.1.3.2 PROCESS OF COLLABORATIVE DEVELOPMENT WITH THE CANADIAN PUBLIC AND INDIGENOUS PEOPLES PHASE 1

Detailed Technical Assessment Report • Ref: REC-AJ01-Y4MH

Section Synopsis

Pages: 91-92

The provided text outlines Phase 1 of the Nuclear Waste Management Organization's (NWMO) consultation process, titled 'Conversations About Expectations.' This phase focused on gathering input from the Canadian public and Indigenous Peoples regarding the study's conduct, questions, and management options. Key activities included face-to-face meetings, specialist papers, and a Scenarios Exercise to model future interactions with nuclear fuel over long timeframes. The NWMO claims to have built an information foundation by integrating expert research with Indigenous knowledge and the lived experiences of host communities.

Community Assessment Narrative

The text presents a highly structured and professional overview of the NWMO's initial engagement efforts, yet it exhibits a notable imbalance between the description of activities and the reporting of actual outcomes. While the heading promises a summary of 'activities and outcomes,' the content focuses almost exclusively on the former. The narrative relies on positive, process-oriented language such as 'listening and learning' and 'wisdom and insight,' which, while professional, tends to frame the engagement as inherently successful without providing evidence of the specific feedback received or how that feedback influenced the project's direction. This creates a potential transparency gap regarding the actual influence of public and Indigenous input on the decision-making process.

Furthermore, the reliance on a 'Scenarios Exercise' involving only 26 individuals to project conditions up to 10,000 years raises questions about the representativeness and methodological breadth of such a small group for such a significant task. The text mentions the commissioning of 70 specialist papers, which suggests a robust technical foundation, but it remains unclear how these expert perspectives were reconciled with the 'public values' and 'Indigenous knowledge' mentioned later. The lack of specific data—such as the number of participants, the specific Indigenous nations involved, or the geographic distribution of the 'face-to-face meetings'—makes it difficult to assess the true inclusivity and reach of Phase 1. Without detailing the conflicting views or challenges encountered during these dialogues, the narrative risks appearing as a curated success story rather than a critical assessment of a complex consultation process.

Corrective Measures & Recommendations

To improve the transparency and rigor of the Impact Assessment, the proponent should provide a detailed 'What We Heard' report that explicitly links the feedback gathered in Phase 1 to specific changes or refinements in the project's scope and methodology. This should include a summary of conflicting viewpoints or concerns raised by the public and Indigenous Peoples, rather than only highlighting the 'augmentation' of the information base. Clearly demonstrating how public input altered the study's trajectory would validate the 'listening and learning' claim and provide a more objective basis for evaluating the consultation's effectiveness.

Additionally, the proponent should provide demographic and geographic data regarding participation to ensure that the 'Canadian public' and 'Indigenous Peoples' were represented in a statistically and culturally significant manner. Specifically, the selection criteria for the 26 individuals in the Scenarios Exercise and the 70 specialist paper authors should be disclosed to mitigate concerns regarding expert bias. Providing a more granular breakdown of the 'Indigenous dialogues'—including which communities were consulted and how Traditional Knowledge was ethically handled and integrated—would strengthen the cultural and social validity of the submission.

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 regarding the NWMO’s Phase 1 consultation process show strong alignment with several key themes identified in the IAAC Summary of Issues (SOI) published on February 16, 2026. Specifically, the community’s concern regarding the lack of demographic and quantitative data in the proponent’s reporting directly supports the IAAC’s focus on "Public Engagement and Communication" (Annex A), which emphasizes the need for transparency in historic engagement. By identifying that the proponent’s submission lists "activities" rather than "outcomes," Melgund Township provides a concrete example of the "transparency" and "clarity" issues flagged by the Agency.

Furthermore, the community’s observation regarding the ambiguity of Indigenous involvement aligns closely with the IAAC’s section on "Indigenous engagement." The IAAC highlights concerns regarding the "clarity, accessibility, and transparency of project information" and the "Consideration of Indigenous Knowledge." Melgund’s critique—that vague references to "Indigenous dialogues" do not demonstrate respect for specific treaty rights—validates the IAAC’s requirement for the proponent to describe how Indigenous Knowledge and protocols are ethically incorporated into project planning.

A significant technical alignment exists between the community’s critique of the "Scenarios Exercise" and the IAAC’s concerns regarding "High uncertainty novel project potential for accidents and malfunctions." The community’s finding that a sample size of only 26 participants was used for 10,000-year modeling provides a specific methodological basis for the IAAC’s broader concern about "unanticipated problems" and "limited international case studies." Melgund’s analysis suggests that the proponent’s current information foundation may be too narrow to support the "Long-term sustainability" and "Acceptable Risk" assessments required by the Agency.

Recommendations

The working group recommendations focus on moving the proponent beyond a narrative of "listening and learning" toward a measurable and verifiable framework of "What We Heard." By requiring a report that explicitly links public and Indigenous feedback to specific modifications in the project’s scope, the community is advocating for a standard of transparency that addresses the IAAC’s concerns regarding the "adequacy, clarity, and transparency of the Project Description." These recommendations ensure that the "outcomes" of consultation are not merely listed as activities but are demonstrated as influential factors in the project’s evolution.

Additionally, the recommendation to provide granular demographic and geographic data is essential for addressing the IAAC’s identified issues regarding "Social cohesion and community wellbeing" and "Environmental justice." Without the data requested by the community, the IAAC cannot accurately assess whether the project has considered "disproportionate impacts to marginalized and/or racialized communities" or if the consultation was truly representative of the "Canadian public." Implementing these recommendations would provide the IAAC with the objective evidence needed to evaluate the effectiveness of the proponent’s engagement and the validity of their social license to operate.

Key Claims

The NWMO conducted a 'listening and learning' phase to understand public and Indigenous expectations.
A Scenarios Exercise involving 26 individuals modeled future interactions with nuclear fuel for up to 10,000 years.
Approximately 70 specialist papers were commissioned to create an information foundation.
Indigenous knowledge, wisdom, and insight were contributed to and expanded the study's information base.
Citizens from current nuclear fuel storage communities shared their lived experiences to inform the study.

Underlying Assumptions

The 26 individuals involved in the Scenarios Exercise provided a sufficiently diverse and representative range of perspectives for long-term modeling.
The commissioning of specialist papers by the NWMO resulted in an objective and comprehensive information foundation.
The list of activities (meetings, workshops, etc.) equates to a successful and inclusive consultation process.
Indigenous knowledge was successfully integrated into a technical framework without loss of context or meaning.

Critical Observations & Gaps

Analysis Table
Issue Identified Implication Information Required
Lack of demographic and quantitative data regarding participation in the listed initiatives. Without knowing who participated, the assessment cannot determine if the consultation was truly representative of the Canadian public. Participant counts, geographic distribution, and demographic breakdowns for meetings and workshops.
The Scenarios Exercise relies on a small sample size for extremely long-term modeling. A very small group (26 people) making 10,000-year projections may lack the multi-disciplinary breadth required for such a critical safety and social issue. Methodological justification for the group size and the selection criteria for the 26 participants.
Ambiguity regarding which Indigenous communities were involved and how their knowledge was utilized. Vague references to 'Indigenous dialogues' do not demonstrate respect for specific treaty rights or distinct cultural protocols. A list of participating Indigenous nations and a description of the framework used to integrate Traditional Knowledge.
The text promises 'outcomes' in the header but only describes 'activities'. The IAAC cannot evaluate the effectiveness of the consultation if the 'outcomes' (what changed as a result) are not disclosed. A clear summary of the specific findings, public concerns, and subsequent project modifications resulting from Phase 1.

Working Group Recommendations

Human Environment (People)

Require a comparative infrastructure analysis between Melgund Township and the 'communities that currently store used nuclear fuel' cited in the submission.

The Proponent's submission relies on the 'lived experience' of citizens from current storage communities (e.g., Pickering, Bruce) to inform the study. These communities are typically well-resourced municipalities with full-time fire and police departments. Melgund has no such services. Using the comfort level of residents in fully serviced municipalities to predict the social acceptance or safety perception in an unorganized territory is a false equivalence. The Working Group must demand the Proponent demonstrate how this 'experience' is relevant given the critical gap in local protective services.
HEP-085
Human Environment (People)

Challenge the methodology of the 'Scenarios Exercise' which limited 'detailed scenarios' to only 25 years, and request detailed socio-economic modeling that spans the full operational life of the project.

The Proponent's submission states that detailed scenarios were produced for only 25 years, with longer timeframes relegated to 'less detailed' or 'simple what-ifs.' For a community hosting a project with a multi-generational lifespan, a 25-year detailed outlook is insufficient. Melgund needs to understand how the project will impact community well-being, housing, and social cohesion beyond the initial construction phase. Limiting detailed analysis to 25 years obscures potential long-term risks, such as the 'bust' cycle of the economy or the long-term strain on volunteer-based social supports in the region.
HEP-086
Human Environment (People)

Request the specific 'Health and Safety' papers commissioned in Phase 1 to audit them for assumptions regarding local emergency response capacity.

The Proponent's submission notes that 'Health and Safety' papers were commissioned to build an information foundation. However, Melgund Township is an unorganized territory with zero local emergency services (no fire, no ambulance, no police). If these foundational papers assume the existence of standard municipal emergency infrastructure, the baseline safety case is fundamentally flawed. The Working Group must verify that the Proponent has not relied on 'generic' safety models that fail to account for the community's total reliance on distant hubs like Ignace or Dryden, which creates unacceptable risk profiles for local residents.
HEP-087
Environment

Request the index and content of the 'Science and Environment' papers commissioned in Phase 1 to determine if they utilized local site-specific data or generic geological models.

The Proponent's submission claims to have built an 'information foundation' using approximately 70 specialist papers, including those on 'Science and Environment.' It is critical to determine if these early papers were based on the specific granite and muskeg conditions of the Revell site or if they relied on generic environmental assumptions. If the foundation of the environmental assessment is based on generic models rather than local field data, the subsequent predictions regarding water quality and containment safety may be inaccurate. This review is an opportunity to ensure the baseline data reflects the actual local environment.
ENV-058

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.