Impacts on Subsistence Harvesting and Land Use

What are the impacts on hunting, fishing and subsistence harvesting? What have people said?

Executive Summary

The proposed Deep Geological Repository (DGR) at the Revell Site presents significant risks to hunting, fishing, and subsistence harvesting through both physical land exclusion and the psychological stigma of radiological contamination. The project footprint and associated security zones will permanently remove hundreds of hectares of Crown land from active use, impacting established traplines, bait harvest areas, and bear management units. [Analysis: 15.8 Non-Indigenous Land and Resource Use]

Community members and Indigenous Nations have expressed profound concern that even if technical containment is maintained, the perception of risk will lead to a "chilling effect," where harvesters avoid traditional grounds due to fears of bioaccumulation in moose, fish, and medicinal plants. [Comment Ref: 485, 517] Technical deficiencies in the proponent's baseline data, which relies on decade-old regional studies rather than site-specific tissue sampling, further exacerbate these anxieties. [Analysis: 15.4 Traditional Foods and Medicines]

Detailed Analysis

Physical Displacement and Habitat Fragmentation

The project will occupy approximately 342 hectares of provincial Crown land, which is currently utilized for both Indigenous and non-Indigenous harvesting. This area overlaps directly with Trapline DR024, Bait Harvest Area DR0046, and Bear Management Area IG-09A-040. [Analysis: 15.8 Non-Indigenous Land and Resource Use] The construction of high-security fencing and restricted access "Protected Areas" will create a permanent barrier to traditional movement and resource extraction. [Analysis: 10. ACTIVITIES, INFRASTRUCTURE, STRUCTURES, AND PHYSICAL WORKS]

Beyond the immediate footprint, the industrialization of the Revell Site—including blasting, heavy haul traffic on Highway 17, and the operation of a rail spur—will likely displace wildlife from the immediate vicinity. [Analysis: 19.2.3.10 TERRESTRIAL WILDLIFE AND WILDLIFE HABITAT] Noise and vibration from 24/7 operations are expected to disrupt migration patterns and habitat suitability for moose and furbearers, which are central to the local subsistence economy. [Comment Ref: 276, 357]

Contamination Risks to Traditional Foods

Harvesting and gathering plants, including blueberries, wild rice, and medicinal herbs like Labrador tea, are popular activities in the Revell Lake watershed. [Analysis: 15.4 Traditional Foods and Medicines] There is significant concern regarding the deposition of criteria air contaminants and fugitive dust from construction and rock management on these food sources. [Analysis: 19.2.3.1 AIR QUALITY]

Downstream impacts on aquatic ecosystems are a primary worry for those who rely on fishing for walleye and northern pike. [Comment Ref: 276] The proponent acknowledges that treated effluent will be discharged into the local watershed, but site-specific modeling for the bioaccumulation of radionuclides in fish tissue has not yet been completed. [Analysis: 19.2.3.7 FISH AND FISH HABITAT]

The "Stigma Effect" and Behavioral Modification

A critical impact identified by the Manitoba Métis Federation and other groups is the psychological effect of proximity to a nuclear facility. [Comment Ref: 517] Even in the absence of a radiological leak, the mere perception of contamination can lead to behavioral modification where citizens avoid traditional harvesting areas. [Analysis: 25. Overall Conclusions and Path Forward]

This avoidance impacts mental wellness, cultural connection to the land, and food security. [Comment Ref: 517] The proponent's framing of these concerns as mere "perceptions" rather than material impacts has been criticized as a minimization of the legitimate socio-economic risks to those who live off the land. [Analysis: 25. Overall Conclusions and Path Forward]

IAAC Summary of Issues Alignment

The concerns raised by the community regarding harvesting and subsistence are explicitly reflected in the IAAC Summary of Issues (SOI). The Agency identifies "Socio-economic impacts to land use" as a key issue, specifically noting the need for information on how the project affects hunting, fishing, plant harvesting, and trapping. [Analysis: 15.8 Non-Indigenous Land and Resource Use]

Furthermore, the SOI aligns with community fears regarding "Radiological effects to wildlife," including bioaccumulation and migration. [Analysis: 15.4 Traditional Foods and Medicines] The Agency also highlights the "Interference with the exercise of Indigenous rights" related to harvesting and stewardship, mirroring the profound spiritual and practical issues raised by Grand Council Treaty #3. [Comment Ref: 660]

Evidence from Public Registry

Sylvia Davis, an Indigenous harvester, stated that her activities such as hunting, fishing, and gathering are central to her way of life and that any environmental degradation is a direct threat to her health and livelihood. [Comment Ref: 276] She noted that rock naturally contains moving water, which could serve as a pathway for radioactive material to reach traditional food sources. [Comment Ref: 276]

The Nishnawbe Aski Nation (NAN) argued that the perceived risk of transporting radioactive materials through their territory will have a "chilling effect" on the ability of member First Nations to exercise their treaty rights. [Comment Ref: 485] Similarly, the Manitoba Métis Federation highlighted that the safety of harvested wildlife and plants is a central concern, noting that caribou and moose are already in decline due to existing development. [Comment Ref: 517]

Local residents in Melgund Township have also voiced concerns about the loss of Crown land access for subsistence harvesting and the potential for property devaluation to economically isolate those who rely on the land. [Comment Ref: 391] They emphasize that for many in this remote area, hunting and fishing are not just recreational but are essential for food security. [Comment Ref: 391]

Technical Deficiencies & Gaps

Our analysis identifies a significant reliance on outdated regional data. The proponent cites the "First Nations Food, Nutrition and Environment Study" from 2014 and a 2016 study, which may not reflect current ecological or contaminant conditions in the Revell Site area. [Analysis: 15.4 Traditional Foods and Medicines]

There is a critical lack of site-specific baseline data regarding the health and social conditions of Treaty #3 First Nations. [Comment Ref: 660] The proponent's "participatory tissue sampling program" relies on voluntary donations from community members, which lacks the statistical rigor of a systematic, proponent-funded scientific sampling program. [Analysis: 15.4 Traditional Foods and Medicines]

Furthermore, the proponent dismisses the project's impact on existing contaminants like mercury. [Analysis: 15.4 Traditional Foods and Medicines] This fails to address how physical land disturbance or hydrological changes might mobilize existing environmental stressors in the sediment, potentially increasing the toxic load in harvested fish. [Analysis: 15.4 Traditional Foods and Medicines]

Recommendations & Mandates

We strongly recommend that the proponent conduct a contemporary, site-specific baseline study of traditional foods and medicines. This study must include systematic sampling of soil, water, and biota within the immediate project footprint and downstream areas to ensure a statistically robust baseline. [Analysis: 15.4 Traditional Foods and Medicines]

The proponent should be mandated to develop a "No Net Loss" policy for harvesting access. If specific Crown lands are closed for security, the proponent strongly recommend providing land-for-land replacement or funding for the enhancement of adjacent harvesting grounds to ensure the local recreational and subsistence footprint is not diminished. [Analysis: 15.8 Non-Indigenous Land and Resource Use]

We strongly recommend the establishment of an independent, community-led environmental monitoring program. This program should empower local and Indigenous harvesters to conduct their own sampling and analysis, with results made public in real-time to combat the "stigma effect" and rebuild trust in the safety of local food sources. [Analysis: 24. Environmental Management System]

Conclusion

The impacts on hunting, fishing, and subsistence harvesting at the Revell Site are not merely technical but are deeply rooted in the cultural and economic survival of the region's inhabitants. The current proposal fails to adequately mitigate the risk of land-use avoidance driven by the perception of radiological contamination. Moving forward, the project must transition from a proponent-led "engagement" model to a co-management framework that prioritizes the protection of traditional food systems and ensures that the immediate neighbors in Melgund and Treaty #3 territory are not forced to bear the uncompensated burdens of Canada's nuclear legacy.