Section Synopsis
Pages: 115-117This section of the Initial Project Description outlines the baseline data and planned studies for the atmospheric, acoustic, and visual environments at the proposed Deep Geological Repository site. It identifies existing regional industrial influences on air quality but notes a lack of local monitoring data, necessitating a new collection program initiated in 2023. The proponent also details plans for seasonal noise monitoring and summer-based light pollution assessments, while asserting that the visual environment baseline is already sufficiently characterized based on existing landscape descriptions.
Community Assessment Narrative
The submission reveals a significant historical data vacuum regarding the local environment, particularly concerning air quality. Relying on monitoring stations in Thunder Bay and Winnipeg—located 240 km and 350 km away, respectively—is scientifically inadequate for establishing a site-specific baseline in a complex northern airshed. While the proponent has initiated a local monitoring program, the delay in establishing this baseline until 2023 suggests that early project planning may have lacked site-specific atmospheric context. Furthermore, the description of the visual environment is notably thin. Characterizing the visual baseline as 'sufficiently complete' based on a general description of tree species and a single photograph is a reductive approach that fails to account for professional viewshed modeling or the cultural significance of the landscape to Indigenous communities.
There are also methodological concerns regarding the proposed noise and light studies. The noise monitoring plan utilizes only two-week snapshots, which may fail to capture the full range of seasonal variability or specific atmospheric conditions that affect sound propagation in northern climates. Similarly, the light monitoring plan is restricted to summer months. This ignores the significant impact of 'sky glow' during winter months when snow cover significantly increases ground albedo, potentially magnifying the impact of artificial light. The tone of the document is professional, yet it exhibits a degree of overconfidence regarding the sufficiency of existing visual data, which could be perceived as dismissive of stakeholder concerns regarding landscape alteration.
Corrective Measures & Recommendations
The proponent should expand the scope of the light and noise monitoring programs to ensure they are representative of the full annual cycle. Specifically, light monitoring must include winter assessments to account for snow-covered ground albedo, which significantly alters how artificial light impacts 'intrinsically dark' environments. Noise monitoring should also be extended or synchronized with key biological windows for local wildlife to ensure that baseline acoustic data reflects sensitive periods for fauna, rather than just arbitrary two-week seasonal windows.
Additionally, the proponent must revisit the 'sufficiently complete' status of the visual environment baseline. A formal Viewshed Analysis should be conducted, utilizing digital elevation modeling to identify specific points of visibility from surrounding transportation corridors, water bodies, and areas of Indigenous land use. This study should be supplemented by qualitative consultations with the Wabigoon Lake Ojibway Nation and the Ignace community to identify and protect culturally or aesthetically significant landmarks that may not be captured by a standard biological classification of the forest.
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 "Summary of Issues" (SOI) published by the Impact Assessment Agency of Canada (IAAC) on February 16, 2026. Specifically, the community’s concerns regarding the inadequacy of baseline data for the atmospheric, acoustic, and visual environments directly support the IAAC’s identified need for "community-led baseline data collection" under the Socio-Economic Conditions section. The Township’s observation that the proponent is relying on air quality data from stations hundreds of kilometers away (Thunder Bay and Winnipeg) validates the IAAC’s inclusion of "Monitoring of effects during construction and operation" in Annex A, which specifically requests monitoring of effects on air and soil for communities in close proximity to the site.
There is a significant alignment between the community’s critique of the light and noise monitoring programs and the IAAC’s focus on "Health, social and economic conditions" under the Indigenous Peoples section. The IAAC identifies "changes in air, water, food quality, noise, light, stress, or perceived health risks" as key concerns. Melgund Township’s analysis provides the technical justification for these concerns by highlighting a critical gap: the omission of winter light monitoring. By pointing out that snow-covered ground albedo significantly alters light pollution impacts, the community assessment identifies a technical deficiency that, if unaddressed, would lead to the "limited, inaccurate, or missing baseline data" cautioned against in the IAAC’s section on "Uncertainty related to project effects."
Furthermore, the community’s call for a formal Viewshed Analysis aligns with the IAAC’s theme of "Physical and cultural heritage," which notes concerns that the project may adversely affect "landscapes, structures, or artifacts of cultural, spiritual, or historical importance." While the proponent has deemed the visual baseline "sufficiently characterized" based on general habitat descriptions, Melgund Township’s findings suggest this is a gap in the proponent’s submission. This supports the IAAC’s requirement for the proponent to consider "impacts to culturally and historically significant sites" and "socio-economic impacts to land use," including tourism and recreation, which are inherently tied to the visual integrity of the landscape.
Recommendations
The working group recommendations focus on expanding the temporal and technical scope of environmental monitoring to ensure the baseline is truly representative of the local environment. It is recommended that the proponent extend light monitoring into the winter months and synchronize noise monitoring with specific biological windows for local fauna. These recommendations are designed to address the "Terrestrial Wildlife and their Habitat" issues identified in the IAAC SOI, ensuring that "levels of disturbance, displacement, or harm" are measured against a baseline that accounts for the most sensitive periods for local species and the unique reflective conditions of the Northern Ontario winter.
Additionally, it is recommended that the proponent move beyond general forest classifications and conduct a digital Viewshed Analysis. This recommendation directly addresses the IAAC’s concerns regarding "Physical and cultural heritage" and "Socio-economic impacts to land use." By utilizing digital elevation modeling and engaging in qualitative consultations with the Wabigoon Lake Ojibway Nation and the Ignace community, the proponent can identify specific, culturally significant viewpoints. This approach ensures that the "sufficiently complete" status of the visual baseline is validated through community and Indigenous expertise, rather than remaining a point of discrepancy between the proponent’s submission and the IAAC’s Summary of Issues.
Key Claims
Underlying Assumptions
Critical Observations & Gaps
Analysis Table| Issue Identified | Implication | Information Required |
|---|---|---|
| Extreme distance of existing monitoring stations (Thunder Bay and Winnipeg). | Using air quality data from hundreds of kilometers away may lead to inaccurate modeling of project-related emissions impacts. | Validation of how regional data will be integrated with the new 2023 site-specific data. |
| Light monitoring is planned only for summer months. | Light pollution impacts are often most severe in winter due to snow reflection; omitting this data underestimates potential impacts. | Inclusion of winter baseline light data collection. |
| Visual environment assessment is deemed complete based on general habitat descriptions. | A 'sufficient' visual baseline without Indigenous input ignores the cultural value of the landscape. | A formal viewshed analysis and consultation on culturally significant viewpoints. |
| Noise monitoring is limited to two-week snapshots. | Short monitoring windows may miss intermittent noise events or specific atmospheric conditions that enhance sound travel. | Justification for why two weeks is considered representative of a full season. |
Working Group Recommendations
Request the expansion of the baseline light data collection program to include winter monitoring periods.
Request justification for the limited two-week duration of the seasonal noise monitoring program and assess the need for longer-term continuous monitoring.
Formally dispute the Proponent's conclusion that the visual environment baseline is 'sufficiently complete' and demand a technical Viewshed Analysis.
Challenge the applicability of using air quality data from Thunder Bay and Winnipeg (240-350 km away) and request detailed validation against the new local 2023 dataset.
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.