Melgund Recreation, Arts and Culture
Public Comments Archive

14.10 Terrestrial Wildlife and Wildlife Habitat

Detailed Technical Assessment Report • Ref: REC-K6Z7-J9U0

Section Synopsis

Pages: 134-137

The provided text outlines the baseline terrestrial wildlife and habitat data collected by the Nuclear Waste Management Organization (NWMO) for a proposed Deep Geological Repository. The characterization includes ungulates, carnivores, small and semi-aquatic mammals, bats, herpetofauna, and invertebrates, utilizing desktop reviews, eDNA analysis, and field surveys. While identifying several Species at Risk (SAR) and Significant Wildlife Habitats (SWH), the report notes that data collection is ongoing. It highlights a low calf-to-cow ratio in local moose populations and acknowledges gaps in reptile and invertebrate data, yet asserts that current information is sufficient for a risk-informed assessment of potential impacts.

Community Assessment Narrative

The submission presents a structured but preliminary overview of the biological landscape, relying heavily on first-year data and desktop studies. A significant tension exists between the proponent's claim that current data is 'sufficient to support a risk-informed assessment' and the repeated admissions of data gaps, such as unoptimized eDNA for reptiles and reliance on invertebrate records from the 1980s. This creates a potential transparency issue, as it may downplay the necessity of comprehensive baseline data before drawing conclusions about project significance. The focus on moose due to their importance to Indigenous communities is appropriate, yet the report notes a low calf:cow ratio without a clear commitment to investigating how project-related stressors might exacerbate this existing vulnerability. Furthermore, the dismissal of project-related impacts on tick distribution appears premature given the lack of a detailed ecological pathway analysis for how land clearing or habitat fragmentation might alter host-parasite dynamics. The tone is professional, but the reliance on 'candidate' habitats and 'potential' occurrences suggests that the ecological risks are not yet fully characterized, making the 'early conclusions' regarding impact significance appear potentially biased toward project advancement.

Corrective Measures & Recommendations

The proponent should prioritize a multi-year population health study for moose to determine the drivers of the low calf:cow ratio and assess how project-related noise, dust, and habitat fragmentation might impact this sensitive demographic. This study must integrate Indigenous Knowledge with western science to ensure that 'community importance' translates into robust, culturally relevant mitigation strategies. Additionally, the proponent must optimize and re-run eDNA and field surveys for reptiles and invertebrates, as the current reliance on unoptimized methods and 40-year-old data is insufficient for a modern impact assessment. A formal justification or pathway analysis should also be provided to support the claim that project activities will not influence tick abundance or distribution, particularly regarding how changes in forest edge habitat might affect host species like white-tailed deer.

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 strong alignment with several key themes in the IAAC Summary of Issues (SOI), particularly regarding the adequacy of baseline data and the potential for adverse effects on terrestrial wildlife. The IAAC’s section on "Species at Risk and their habitat" explicitly notes concerns regarding "insufficient information" and the need for better data on "direct and indirect pathways of effects." This aligns directly with Melgund’s observation that the proponent’s eDNA methods for reptiles were not optimized and that invertebrate data is nearly four decades old. By identifying these specific technical gaps, the community assessment provides the evidentiary support needed to validate the IAAC’s broader concern that the current baseline is insufficient for a modern, risk-informed impact assessment.

Furthermore, the community’s focus on the low calf-to-cow ratio in local moose populations provides a critical localized context to the IAAC’s "Current use of lands and resources" and "Terrestrial Wildlife and their Habitat" sections. While the IAAC flags general concerns about "disturbance, displacement, or harm" to wildlife, Melgund Township identifies a specific demographic vulnerability—low productivity—that could make the local population less resilient to project-related stressors like noise and habitat fragmentation. This finding supports the IAAC’s identified need to understand how project effects might impact Indigenous harvesting and hunting rights, as a declining moose population would directly interfere with the "Current use of lands and resources" for traditional purposes.

A notable gap exists regarding the social and health implications of tick expansion. While the IAAC SOI includes a broad category for "Human Health and Well-Being," it does not explicitly mention vector-borne diseases or how project-induced habitat changes (such as increased forest edge) might affect public health. Melgund Township’s analysis identifies that the proponent has dismissed community concerns regarding ticks by treating them only as an ungulate stressor. This community finding suggests that the IAAC’s "Human Health" and "Socio-Economic Impacts to Land Use" sections should be expanded to include pathway analyses for how land-use changes might influence host-pest dynamics and, consequently, community health.

Finally, there is a clear alignment regarding the "Consideration of Indigenous Knowledge" and "Physical and cultural heritage." The IAAC SOI highlights concerns about how Indigenous culture and practices are reflected in project planning. Melgund’s observation that the proponent lacks a transparent process for screening species of "cultural value" beyond moose validates the IAAC’s concern. The community’s finding suggests that the proponent’s current prioritization is too narrow and may overlook species that are regionally significant to Indigenous groups, thereby failing to meet the IAAC’s expectation for meaningful incorporation of Indigenous Knowledge.

Recommendations

The working group recommends that the proponent initiate a multi-year, comprehensive population health study for moose to identify the underlying drivers of the current low calf-to-cow ratio. This study must be designed to assess the cumulative impacts of project-related noise, dust, and habitat fragmentation on this vulnerable demographic. To ensure the study meets the standards of both the IAAC and the community, it must integrate Indigenous Knowledge with western science. This approach will ensure that "community importance" is not just a label, but a foundation for robust, culturally relevant mitigation strategies that protect traditional harvesting rights.

Additionally, it is recommended that the proponent modernize its environmental baseline by re-running eDNA and field surveys for reptiles and invertebrates using optimized, contemporary methods. The reliance on 40-year-old data is a significant technical deficiency that prevents an accurate assessment of biodiversity loss. The proponent should also be required to provide a formal pathway analysis regarding tick abundance. This analysis must move beyond ungulate health to address community concerns about human health, specifically examining how changes in forest edge habitat and white-tailed deer distribution—driven by project activities—might influence the prevalence of ticks in the region. These steps are essential to addressing the uncertainties and data gaps identified in the IAAC Summary of Issues.

Key Claims

Moose densities within 30 km of the site are moderate at 25.7/km2, but calf:cow ratios are low.
Current baseline data is sufficient to support a risk-informed assessment of potential effects.
No species of conservation concern were detected via eDNA for carnivores or small mammals.
Project-related effect pathways do not link the project to tick distribution or abundance.
Woodland caribou range is approximately 61 km north and unlikely to be directly impacted.

Underlying Assumptions

A 30 km radius is an adequate spatial extent for assessing impacts on highly mobile ungulates like moose.
The absence of detection via eDNA (specifically for reptiles) is a result of unoptimized methodology rather than true absence.
Desktop data from the 1980s remains a valid proxy for current terrestrial invertebrate populations.
First-year 'select field aspects' are representative of multi-seasonal ecological variations.

Critical Observations & Gaps

Analysis Table
Issue Identified Implication Information Required
The cause of low moose productivity is unknown and could be exacerbated by construction. A low calf:cow ratio indicates a population that may be less resilient to new stressors introduced by the project. Long-term demographic monitoring and stressor analysis for the local moose population.
eDNA for reptiles was not optimized and invertebrate data is decades old. Incomplete baseline data for reptiles and invertebrates prevents an accurate assessment of biodiversity loss. Updated field surveys and optimized eDNA metabarcoding for all herpetofauna and invertebrates.
The proponent treats ticks only as an ungulate stressor, ignoring potential project-induced habitat changes that favor tick expansion. Community concerns regarding ticks and human health are dismissed without a technical pathway analysis. A conceptual model showing how land use changes will or will not affect tick-host dynamics.
The prioritization of species is based on 'community importance' but lacks detail on how other species were screened for cultural value. Focusing primarily on moose may overlook other species of cultural significance to Indigenous groups. Documentation of the consultation process used to determine which species are 'regionally important'.

Working Group Recommendations

Environment

Reject the use of 1980s desktop data (GBIF) for terrestrial invertebrates and the 'unoptimized' eDNA results for reptiles; mandate a new, comprehensive field program to establish a valid modern baseline for these groups.

The Proponent's submission relies on terrestrial invertebrate data from the 1980s and admits that 2021 eDNA analyses for reptiles 'may not have been fully optimized,' resulting in zero detections despite high potential for species like snapping turtles. In an unorganized territory like Melgund, the natural environment is the primary asset. Relying on 40-year-old data or failed experimental methodologies creates a significant data gap. The Working Group must require robust, current field data to ensure that 'Species at Risk' and 'Significant Wildlife Habitats' are accurately identified and protected prior to any site disturbance.
ENV-013
Human Environment (People)

Require the Proponent to provide a detailed evidence-based justification for the claim that there is 'no potential link' between the Project and tick distribution/abundance, specifically analyzing the impact of creating edge habitats on deer (host) density and human interaction.

The Proponent acknowledges community concerns regarding wood ticks and human health but dismisses them by stating no effect pathway exists. However, large-scale infrastructure projects often create 'edge habitats' that increase populations of white-tailed deer, the primary host for ticks. Given that Melgund Township is an unorganized territory with zero local medical services (no doctors, no hospitals), any increase in vector-borne diseases like Lyme disease places a disproportionate burden on residents who must travel to distant hubs (Dryden/Ignace) for treatment. The Working Group must demand a technical defense of the 'no link' assertion rather than accepting a summary dismissal.
HEP-010
Environment

Challenge the sufficiency of the Proponent's moose population baseline, specifically the 'low calf:cow ratio' where the cause is currently undetermined, and require a specific investigation into whether current predation or habitat factors are driving this decline before Project stressors are added.

The Proponent's submission identifies a 'low calf:cow ratio' in the local moose population but admits the cause 'cannot be determined from current evidence.' Despite this, the Proponent asserts that studies are sufficient for a risk-informed assessment. For the Melgund area, where moose are a critical subsistence and cultural resource, proceeding without understanding why the population is already struggling presents an unacceptable risk. If the herd is already at a tipping point due to predation or disease, the additional stress of Project construction (noise, traffic, habitat fragmentation) could lead to local extirpation. The Working Group must demand a causal analysis of this demographic decline to ensure mitigation measures are actually effective.
ENV-014

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.