Section Synopsis
Pages: 232-234The document outlines the potential impacts of the Deep Geological Repository project on vegetation, riparian, and wetland environments across all project phases. It identifies various pathways of change, including physical clearing, air emissions, and hydrological alterations. While acknowledging that residual adverse effects are certain due to site clearing, the proponent classifies the overall risk as low. This conclusion is based on the implementation of standard mitigation measures, the regional abundance of similar ecosystems, and the commitment to avoid sensitive species like black ash and wild rice where practicable.
Community Assessment Narrative
The proponent's assessment exhibits a significant internal tension between the acknowledged certainty of environmental destruction and the characterization of that destruction as negligible. By stating that the likelihood of residual effects is high because vegetation removal is certain, yet labeling the degree of effect as negligible, the text potentially minimizes the localized ecological impact. The reliance on the argument that Northern Ontario has not reached critical levels of wetland loss serves as a regional justification for local degradation, which may overlook the specific ecological functions of the site-specific wetlands. Furthermore, the commitment to avoid species of conservation concern and culturally significant plants like wild rice and balsam fir is qualified by the phrase 'to the extent practicable.' This creates an analytical ambiguity, as it provides no clear criteria for when avoidance would be deemed impracticable, leaving a gap in the protection framework for Indigenous cultural resources. The use of ALARA (As Low As Reasonably Achievable), typically a radiological protection principle, to describe air and water quality mitigation suggests a technical rigor that is not fully supported by the qualitative descriptions provided.
Corrective Measures & Recommendations
The proponent should provide a detailed, quantitative breakdown of the total area of each vegetation community and wetland type to be permanently lost or altered, rather than relying on regional abundance to justify local impacts. This should include a specific 'No Net Loss' plan for wetlands that outlines compensatory mitigation strategies where avoidance is not possible. Additionally, the proponent must define the specific technical and economic criteria that determine the 'extent practicable' for avoiding species of conservation concern and culturally significant vegetation. To address socio-economic and cultural concerns, the proponent should engage in site-specific co-mapping with Indigenous communities to identify and protect traditional medicine gathering areas. This engagement should result in a formal agreement on how balsam fir, balsam poplar, and wild rice will be managed, including potential relocation or restoration efforts led by traditional knowledge holders to ensure that the 'low risk' designation aligns with community values and ecological reality.
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 "Physical and Biological Environment" and "Indigenous Peoples" sections of the IAAC Summary of Issues (SOI). Specifically, the community’s concern regarding the permanent loss of habitat patches and the proponent’s reliance on "regional abundance" to justify local impacts directly supports the IAAC’s identified issue under Terrestrial, riparian and wetland environments, which flags potential adverse effects from site clearing and altered drainage. The community’s observation of a contradiction between the "high likelihood" of clearing and a "negligible" rating for the degree of effect provides a technical validation of the IAAC’s broader concern in the Project description section regarding how the proponent characterizes risk and the effectiveness of proposed mitigation measures.
Furthermore, the community’s focus on the loss of balsam fir, balsam poplar, and wild rice aligns closely with several themes in the IAAC SOI under the Indigenous Peoples heading. The community’s identification of these species as traditional medicines and the lack of specific mitigation beyond "avoidance" supports the IAAC’s concerns regarding Current use of lands and resources (specifically gathering and harvesting) and Physical and cultural heritage. The community’s critique of the phrase "avoided to the extent practicable" highlights a significant gap in accountability that mirrors the IAAC’s call for more information on how Indigenous Knowledge and cultural practices are incorporated into project planning.
A notable discrepancy exists where the community assessment provides a more granular critique of the proponent’s methodology than the SOI. While the IAAC identifies general concerns about wetland impacts, Melgund Township specifically identifies the misuse of regional ecological data to downplay site-specific functional loss. This suggests that the community’s analysis has identified a methodological flaw—the "regional abundance" justification—that the IAAC has categorized more broadly. The community’s findings serve to validate the IAAC’s inclusion of these issues while providing the specific evidence needed to challenge the proponent’s "low risk" designations.
Recommendations
The working group recommendations emphasize the necessity of moving beyond vague commitments toward a data-driven and collaborative mitigation framework. By requiring a detailed, quantitative breakdown of vegetation loss and a formal "No Net Loss" plan for wetlands, the community provides a clear pathway to address the IAAC’s concerns regarding Construction effects to terrestrial, riparian and wetland environments. These recommendations ensure that "low risk" designations are not merely assertions but are backed by compensatory strategies and technical criteria that define the limits of what is "practicable" for the proponent.
Additionally, the recommendation for site-specific co-mapping and formal management agreements with Indigenous communities directly addresses the IAAC’s requirement for meaningful engagement and the Consideration of Indigenous Knowledge. By involving traditional knowledge holders in the relocation and restoration of medicinal plants, the community’s proposed approach transforms a passive "avoidance" strategy into an active protection plan. This aligns with the IAAC’s focus on Rights of Indigenous Peoples, ensuring that the project does not interfere with the exercise of treaty rights or the intergenerational transmission of cultural practices related to the land.
Key Claims
Underlying Assumptions
Critical Observations & Gaps
Analysis Table| Issue Identified | Implication | Information Required |
|---|---|---|
| The claim that wetland loss is not 'critical' in Northern Ontario is used to downplay site-specific impacts. | Using regional abundance to justify local loss may lead to the degradation of specific local ecological niches that are not easily replaced. | A site-specific ecological function assessment for the wetlands being removed. |
| The phrase 'avoided to the extent practicable' regarding wild rice and balsam fir lacks accountability. | Vague commitments to avoid culturally significant plants may lead to their destruction if project engineering takes precedence. | Clear definitions of 'practicable' and a formal consultation record with Indigenous groups regarding these species. |
| Contradiction between 'high likelihood' of clearing and 'negligible' degree of effect. | If the 'negligible' rating is based on a flawed comparison between local loss and regional abundance, the risk assessment is skewed. | A revised risk matrix that accounts for the permanent loss of specific habitat patches. |
| Balsam fir and balsam poplar are identified as traditional medicines but no specific mitigation for their loss is provided beyond 'avoidance'. | Loss of traditional medicine plants can have long-term impacts on the health and cultural practices of Indigenous communities. | A plan for the sustainable harvest or relocation of medicinal plants prior to clearing. |
Working Group Recommendations
Require the Proponent to define the technical and economic criteria for 'practicability' regarding the avoidance of traditional medicinal plants (Balsam fir/poplar) and wild rice.
Challenge the characterization of residual effects on wetlands as 'negligible' and demand a site-specific 'No Net Loss' plan for the 17% of the site identified as swamp and fen.
Demand the Proponent demonstrate 100% self-sufficiency for fire and medical response during the site clearing and blasting phases identified in the pathways of change.
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.