Section Synopsis
Pages: 235-238This section of the Initial Project Description (IPD) for the Deep Geological Repository (DGR) outlines the baseline conditions and potential impacts on migratory and Species at Risk (SAR) birds. The proponent identifies 64 upland breeding bird species (including 8 SAR), 3 shorebird species, 10 waterbird species, and 7 raptor species within the project area. The document acknowledges that project activities such as site clearing, blasting, and effluent discharge could cause moderate to high adverse effects without mitigation. However, the proponent claims that through the application of standard mitigation measures—such as timing windows for vegetation clearing, buffer zones, and dust suppression—the residual effects will be negligible in degree and the overall risk to bird populations will be low. The assessment relies on the effectiveness of established industry practices and regulatory compliance with the Migratory Birds Convention Act (MBCA) and the Species at Risk Act (SARA).
Community Assessment Narrative
The proponent’s assessment of migratory and SAR birds presents a comprehensive list of species but relies heavily on the assumed efficacy of standard mitigation measures to justify a 'negligible' residual impact rating. While the identification of 64 upland species and multiple SAR (e.g., Eastern Whip-poor-will, Canada Warbler) indicates a high level of biodiversity, the text lacks quantitative data regarding the specific acreage of habitat loss or the carrying capacity of adjacent lands to which displaced birds are expected to move. There is a notable tension between the admission that project activities could cause 'moderate to high' adverse effects and the subsequent conclusion that residual effects will be 'negligible.' This leap in logic assumes that mitigation measures, such as timing windows, are 100% effective at preventing long-term population declines, which may not account for the cumulative stress of sensory disturbances like noise and light over the project's multi-decade lifespan.
Furthermore, the tone of the document is occasionally over-confident, using phrases like 'high level of certainty' and 'well-established' without providing site-specific evidence or case studies involving the specific SAR identified. The use of the ALARA (As Low As Reasonably Achievable) principle—traditionally a radiological protection standard—to describe the mitigation of noise and air quality impacts on birds is somewhat unconventional and requires clearer definition in an ecological context. Additionally, while the text mentions pathways of change affecting Indigenous land use, it fails to integrate Indigenous Traditional Knowledge (ITK) regarding bird migration patterns or the cultural significance of specific species, representing a gap in the holistic assessment of the project's impact.
Corrective Measures & Recommendations
The proponent should provide a quantitative habitat loss assessment that specifies the total area of each habitat type (e.g., wetlands, upland forest) to be removed or altered. This should be accompanied by a species-specific displacement analysis for the identified SAR, evaluating whether suitable adjacent habitat is available and capable of supporting displaced individuals without increasing competition or mortality. This data is essential for validating the claim that residual effects will be 'negligible' at a population level.
It is also recommended that the proponent formally incorporate Indigenous Traditional Knowledge (ITK) into the bird monitoring and mitigation plans. This should involve consultation with local Indigenous communities to identify culturally significant bird species and to refine sensory disturbance buffers based on traditional observations of bird behavior. Furthermore, the proponent should establish a transparent, long-term monitoring framework with specific 'trigger' thresholds that, if exceeded, would mandate immediate adaptive management actions beyond the standard best practices currently cited.
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 analysis of the proponent’s Initial Project Description (IPD) regarding migratory birds and Species at Risk (SAR) shows a high degree of alignment with the "Summary of Issues" (SOI) published by the IAAC on February 16, 2026. Specifically, Melgund Township’s concern regarding the lack of quantitative data on habitat loss directly supports the IAAC’s identified issue under the theme "Species at risk and their habitat," which notes a general concern regarding "insufficient information on species at risk and their habitats" and the need for more detail on "direct and indirect pathways of effects." While the proponent claims residual effects will be "negligible," the community’s finding that this rating lacks a scientific baseline due to missing acreage data validates the IAAC’s call for more information on the "levels of disturbance, displacement, or harm" listed under "Terrestrial Wildlife and their Habitat."
There is also strong alignment regarding the integration of Indigenous Traditional Knowledge (ITK). The community’s observation that ITK is insufficiently integrated into bird population assessments mirrors the IAAC’s broader requirement under "Indigenous Peoples - Consideration of Indigenous Knowledge," which flags concerns about how such knowledge is reflected in project planning and assessment. Melgund Township’s analysis goes a step further by identifying a specific technical gap: the proponent’s reliance on general industry experience rather than species-specific mitigation success rates. This supports the IAAC’s observation in Annex A (Project Description) regarding concerns over how the "effectiveness of proposed mitigation measures are characterized."
A notable discrepancy or "gap" identified by the community assessment is the proponent’s ambiguous use of the radiological term "ALARA" (As Low As Reasonably Achievable) to describe noise, vibration, and light mitigation for birds. While the IAAC SOI mentions "noise" and "light" under "Indigenous Peoples - Health effects," it does not explicitly flag the potential for ecological thresholds to be obscured by inappropriate radiological terminology. The community’s finding suggests that the IAAC’s general concern for "sensory disturbance" requires more specific ecological standards to be meaningful, as the current IPD language may prevent a true assessment of impacts on sensitive species like the Eastern Whip-poor-will.
Recommendations
The working group recommendations focus on moving from qualitative assertions to quantitative evidence. It is recommended that the proponent provide a comprehensive habitat loss assessment that details the exact hectares of wetlands and upland forests to be disturbed. This data is necessary to address the IAAC’s concern regarding "insufficient information" and to provide a verifiable baseline for the proponent’s "negligible" impact claims. Furthermore, the recommendation for a species-specific displacement analysis is essential to validate whether adjacent habitats can actually support displaced SAR, addressing the IAAC’s requirement to understand the "levels of displacement or harm" more clearly.
To ensure alignment with the IAAC’s focus on Indigenous rights and knowledge, the working group recommends the formal incorporation of ITK into bird monitoring and mitigation plans. This should specifically include using traditional observations to refine sensory disturbance buffers, rather than relying solely on the "ALARA" principle. Finally, to address the IAAC’s identified concerns regarding "Monitoring and institutional control," the proponent should establish a long-term monitoring framework with transparent "trigger" thresholds. These thresholds would ensure that adaptive management is not just a "best practice" commitment, but a mandatory response to specific ecological changes observed on the ground.
Key Claims
Underlying Assumptions
Critical Observations & Gaps
Analysis Table| Issue Identified | Implication | Information Required |
|---|---|---|
| Lack of quantitative data on habitat loss (acreage/hectares). | Without knowing the exact area of habitat lost, the 'negligible' rating lacks a scientific baseline. | A detailed table showing habitat types and the area of each to be cleared or disturbed. |
| Reliance on general industry experience rather than species-specific mitigation success rates. | The effectiveness of buffers for sensitive species like the Eastern Whip-poor-will is not universally 'well-established.' | Citations or case studies demonstrating the success of these specific measures for the SAR identified. |
| Insufficient integration of Indigenous Traditional Knowledge (ITK) regarding bird populations. | Bird displacement may affect traditional harvesting or cultural practices of Indigenous Peoples. | Documentation of how ITK was used to identify sensitive areas or species of concern. |
| Ambiguous use of 'ALARA' for noise, vibration, and light mitigation. | Using radiological terms for ecological stressors may obscure the actual thresholds being used for noise and air quality. | Clarification of the specific ecological thresholds and standards being applied to sensory disturbances. |
Working Group Recommendations
Request a quantitative inventory of habitat loss, specified in hectares, for each of the 64 upland breeding bird species and eight SAR species identified in the Proponent's submission.
Request documentation on how Indigenous Traditional Knowledge (ITK) was integrated into the identification of bird species of concern and the assessment of pathways of change for traditional land use.
Require the Proponent to define specific ecological thresholds for noise, vibration, and light emissions rather than using the radiological 'ALARA' standard cited in the Initial Project Description.
Demand the Proponent demonstrate 100% self-sufficiency in emergency response capacity for accidents related to blasting, site clearing, and construction activities mentioned in the filing.
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.