Garter Snakes and Herpetofauna at Revell Site

What about garter snakes?

Executive Summary

The presence of garter snakes and other herpetofauna at the Revell Site remains a significant point of ecological uncertainty. While the proponent has identified candidate Significant Wildlife Habitat (SWH) for snake hibernacula within a 2 km radius of the project centroid, no specific reptile species have been detected during initial field surveys [Analysis: 14.10 Terrestrial Wildlife and Wildlife Habitat].

Community members have expressed deep concern regarding the potential for habitat destruction and the toxicity of spent fuel on "animal nations" [Ref: 133, 568]. The lack of site-specific data is attributed to unoptimized sampling methods, which the Impact Assessment Agency of Canada (IAAC) has flagged as a key issue requiring further information on disturbance and harm [SOI: Wildlife].

Detailed Analysis

The Revell Site is situated within the Canadian Shield, an environment that typically supports various herpetofauna, including the common garter snake. The proponent's baseline data collection for reptiles is currently considered deficient, as it relies on unoptimized environmental DNA (eDNA) metabarcoding and desktop analyses that have failed to confirm species presence [Analysis: 14.10 Terrestrial Wildlife and Wildlife Habitat].

This is particularly concerning given that the site is located in an unorganized territory directly along the Trans-Canada Highway (Highway 17), where industrial activity is already present. The unorganized nature of Melgund Township means that local oversight of these sensitive habitats is limited, placing a higher burden of responsibility on the proponent to ensure rigorous baseline characterization.

Despite the lack of direct detection, the proponent acknowledges that candidate SWH for snake hibernacula exists within the project area [Analysis: 14.10 Terrestrial Wildlife and Wildlife Habitat]. Hibernacula are critical for the over-winter survival of garter snakes, and their destruction during site clearing or blasting would result in localized population collapses. The proponent has not yet provided a plan to verify these candidate sites through physical field inspections.

Sensory disturbances, including noise and vibration from "controlled drill and blast" techniques, pose a direct threat to herpetofauna [Analysis: 9.5 Construction]. Snakes are highly sensitive to ground-borne vibrations, which can disrupt thermoregulation and denning behaviors. The proponent's reliance on the ALARA principle for sensory stressors lacks specific quantitative thresholds for reptiles, which is a significant oversight in the current project description [Analysis: 19.2.3.10 TERRESTRIAL WILDLIFE AND WILDLIFE HABITAT].

The industrialization of the Revell site will involve significant topographical changes that could permanently alter the thermal properties of the rock, which is essential for snake survival. The proponent has not yet completed the necessary modeling to determine how the thermal pulse from the repository might affect subsurface temperatures in the vicinity of potential hibernacula [Analysis: 19.2.3.10 TERRESTRIAL WILDLIFE AND WILDLIFE HABITAT]. This represents a major gap in the long-term safety case for local biodiversity.

IAAC Summary of Issues Alignment

The concerns regarding garter snakes and herpetofauna are explicitly aligned with the IAAC Summary of Issues. The Agency has identified "Wildlife" as a key issue, specifically noting the need for more information on the levels of disturbance, displacement, or harm to reptiles [SOI: Wildlife]. This alignment is further documented in our technical review of the proponent's environmental baseline [Analysis: 14.10 Terrestrial Wildlife and Wildlife Habitat].

Furthermore, the SOI highlights concerns regarding the radiological effects on wildlife, including bioaccumulation and migration [SOI: Radiological effects to wildlife]. This aligns with community fears that radionuclides could enter the food chain through small vertebrates like snakes [Ref: 223]. Our internal analysis confirms that the proponent has not yet completed the necessary modeling to address these pathways, particularly for species that utilize both terrestrial and aquatic habitats [Analysis: 19.2.3.10 TERRESTRIAL WILDLIFE AND WILDLIFE HABITAT].

Evidence from Public Registry

Public sentiment reflects a strong desire to protect the "animal nations" inhabiting the Northwestern Ontario wilderness [Ref: 133]. Commenters have characterized the project as a threat to the spiritual and physical well-being of all life forms, urging the adoption of non-lethal wildlife management strategies [Ref: 389, 568]. There is a pervasive fear that the project will turn the region into a wasteland, impacting the life that sustains human existence [Ref: 532, 595].

Specific concerns have been raised about the "Highway of Fears" (Highway 17), where increased heavy industrial traffic is expected to lead to higher rates of wildlife-vehicle collisions [Ref: 258]. Residents of the Melgund unorganized territory are particularly concerned that the industrialization of the Revell site will drive wildlife into residential areas, creating new conflicts [Analysis: 14.10 Terrestrial Wildlife and Wildlife Habitat]. The lack of a "say" or consent from non-human entities is also a recurring ethical theme in the public registry [Ref: 275].

Technical Deficiencies & Gaps

The primary technical deficiency is the proponent's reliance on "unoptimized" eDNA metabarcoding for reptile detection [Analysis: 14.10 Terrestrial Wildlife and Wildlife Habitat]. This methodology is insufficient for a project of this magnitude, as it can result in false negatives for cryptic species like garter snakes. The proponent admits that more species will likely be identified as the program progresses, rendering current "low risk" conclusions premature and unsupported by empirical data.

There is also a significant gap in the assessment of cumulative effects. The proponent has not modeled how the combination of habitat fragmentation, blasting vibrations, and potential radiological seepage will interact to affect herpetofauna over the 160-year project lifecycle [Analysis: 19.2.3.10 TERRESTRIAL WILDLIFE AND WILDLIFE HABITAT]. The reliance on "industry-standard" mitigation measures fails to account for the unique physiological sensitivities of reptiles in a cratonic environment, where they are already at the northern limit of their range.

Recommendations & Mandates

We strongly recommend that the proponent conduct systematic, multi-year field surveys specifically targeting snake hibernacula and maternity dens within the 342-hectare project footprint. These surveys must utilize traditional search methods, such as cover boards and visual encounter surveys, to supplement eDNA data and provide a verifiable baseline of species presence and abundance. This work should be completed prior to any site preparation activities to ensure that critical habitats are identified and protected.

It is strongly recommended that the proponent develop a "No-Kill Wildlife Coexistence Strategy" that explicitly includes herpetofauna. This strategy should mandate the use of non-lethal exclusion fencing around active construction zones and the relocation of any snakes found within the blast radius by qualified biologists [Ref: 133, 568]. The proponent should also provide training for all site personnel on the identification and humane handling of local reptile species to minimize accidental mortality.

We strongly recommend the establishment of real-time vibration monitoring at the coordinates of all identified candidate hibernacula. The proponent must define specific "stop-work" triggers for blasting activities to ensure that ground-borne energy does not exceed levels known to cause physiological stress or structural collapse of over-wintering sites [Analysis: 19.2.3.3 NOISE, VIBRATION AND LIGHT]. These thresholds should be based on peer-reviewed literature regarding reptile sensitivity to seismic energy.

Finally, we strongly recommend that the proponent conduct a detailed thermal modeling study to assess the impact of the repository's heat output on subsurface habitats. This study should evaluate whether the thermal pulse could prematurely wake snakes from hibernation or alter the suitability of traditional denning sites. The results of this study must be shared with the Local Services Board of Melgund and regional Indigenous partners to ensure transparency and informed decision-making.

Conclusion

The current assessment of garter snakes and herpetofauna at the Revell Site is technically immature and relies on the absence of evidence rather than evidence of absence. The identification of candidate hibernacula in an unorganized territory directly adjacent to Highway 17 necessitates a much higher standard of empirical verification. Without rigorous field studies and binding non-lethal management protocols, the project poses an unmitigated risk to the ecological integrity of the regional herpetofauna populations. The proponent must move beyond conceptual assurances and provide concrete data to protect these "animal nations" for future generations.