Endangered Bat Species at Revell DGR Site

I was reading about the bats. We didn't know there were lots of bat species in the area. Are any of them endangered? What is being done/said to protect the bats?

Executive Summary

The proposed Revell Site Deep Geological Repository (DGR) is located in an area that supports at least six distinct bat species. Technical analyses confirm that several of these species are classified as endangered at both the federal and provincial levels. The Little Brown Myotis and Northern Myotis are specifically identified as federally endangered species present within the project vicinity [Analysis: 14.11 Species at Risk and Their Habitat].

Current protection strategies proposed by the Nuclear Waste Management Organization (NWMO) rely on standard mitigation hierarchies, including the avoidance of known nesting or hibernating sites where practicable. However, internal technical reviews and public comments highlight significant gaps in the baseline data, particularly regarding the identification of maternity roosts and the reliance on preliminary acoustic studies that have not yet been fully ground-truthed [Analysis: 14.10 Terrestrial Wildlife and Wildlife Habitat].

Detailed Analysis of Bat Species and Status

The biophysical environment surrounding the Revell site, located along the Trans-Canada Highway (Highway 17) in the unorganized territory of Melgund Township, is home to a diverse bat population. The species identified include the Big Brown Bat, Silver-Haired Bat, Eastern Red Bat, Hoary Bat, Little Brown Myotis, and Northern Myotis. Of these six, five are designated as species of conservation concern [Analysis: 14.10 Terrestrial Wildlife and Wildlife Habitat].

The Little Brown Myotis and Northern Myotis are listed as Endangered under Schedule 1 of the federal Species at Risk Act (SARA). Additionally, the Silver-Haired Bat, Eastern Red Bat, and Hoary Bat have recently been provincially uplisted as Species at Risk (SAR) in Ontario. These designations reflect the high vulnerability of these populations to habitat loss and sensory disturbances caused by large-scale industrial developments [Analysis: 14.11 Species at Risk and Their Habitat].

Habitat and Sensory Vulnerabilities

Technical studies have identified candidate Significant Wildlife Habitat (SWH) for both Bat Maternity Colonies and Bat Hibernacula within and surrounding the project site. These areas are critical for the survival and reproduction of the species. Bats are particularly sensitive to the noise, vibration, and light emissions that will be generated during the multi-decade construction and operation phases of the DGR [Analysis: 19.2.3.10 TERRESTRIAL WILDLIFE AND WILDLIFE HABITAT].

The project involves intensive activities such as blasting for underground facilities and heavy equipment use on access roads. These stressors can lead to habitat abandonment or reduced reproductive success if not managed with extreme precision. The proponent's current assessment classifies these sensory disturbances as "negligible," a conclusion that is contested due to the lack of site-specific acoustic modeling [Analysis: 19.2.3.10 TERRESTRIAL WILDLIFE AND WILDLIFE HABITAT].

IAAC Summary of Issues Alignment

The Impact Assessment Agency of Canada (IAAC) has explicitly identified "Species at risk and their habitat" as a key issue for the Revell DGR project. The Agency notes a specific concern regarding insufficient information on species at risk in the area surrounding the project, including the need for more detail on direct and indirect pathways of effects [IAAC Summary of Issues: Species at risk and their habitat].

This alignment is further supported by our technical analysis, which highlights that the proponent's current risk characterization for terrestrial wildlife is premature. The Agency's focus on the need for more information on levels of disturbance and displacement mirrors the community's demand for more rigorous baseline studies before project advancement [Analysis: 19.2.3.10 TERRESTRIAL WILDLIFE AND WILDLIFE HABITAT].

Evidence from Public Registry

Community members and environmental experts have raised pointed concerns regarding the project's impact on biodiversity. One commenter, a senior ecologist, highlighted the potential for irreparable damage to environmental quality and biodiversity resulting from the project's industrial footprint [Comment Ref: 285].

Specific concerns have been raised about the adequacy of the inventories for local flora and fauna. Stakeholders have called for more detailed inventories of Species at Risk, specifically naming bats and moose as high-priority receptors that require more than just preliminary desktop studies [Comment Ref: 117].

General opposition to the project often cites the disturbance of wildlife as a primary reason for concern. Commenters argue that the long-term presence of hazardous materials and the associated industrial activity will lead to the permanent displacement of sensitive species from the Revell area [Comment Ref: 641].

Technical Deficiencies & Gaps

A major technical deficiency is the proponent's reliance on preliminary acoustic studies that failed to detect certain species that were later identified through other desktop sources. Furthermore, environmental DNA (eDNA) sampling conducted by the NWMO did not detect any bat species, highlighting the limitations of current sampling methods for these nocturnal mammals [Analysis: 14.10 Terrestrial Wildlife and Wildlife Habitat].

The proponent has committed to further studies only "as warranted," which provides too much discretion and lacks transparent triggers for when more intensive monitoring must occur. There is currently no site-specific modeling for how light pollution and blasting vibrations will carry through the unique topography of the Revell batholith to affect known bat habitats [Analysis: 14.11 Species at Risk and Their Habitat].

Recommendations & Mandates

We strongly recommend that the proponent implement a rigorous, multi-year acoustic monitoring program that covers all four seasons. This is necessary to establish a statistically valid baseline of bat activity and to identify specific foraging corridors that may be disrupted by the project's surface infrastructure and lighting [Analysis: 14.10 Terrestrial Wildlife and Wildlife Habitat].

It is strongly recommended that the NWMO conduct comprehensive maternity roost identification surveys within a 10-kilometer radius of the project centroid before any site clearing or grubbing begins. These surveys must be performed by qualified professionals and the results must be used to establish mandatory, non-negotiable buffer zones around confirmed roosting trees [Analysis: 4. Mitigation, Protection and Enhancement Measure Commitments].

We strongly recommend the establishment of "stop-work" thresholds for noise and vibration. If real-time monitoring detects significant behavioral shifts or habitat abandonment by endangered bat species during the construction phase, the proponent must have pre-defined protocols to suspend activities and implement additional dampening measures [Analysis: 19.2.3.10 TERRESTRIAL WILDLIFE AND WILDLIFE HABITAT].

Conclusion

The presence of multiple endangered and at-risk bat species at the Revell site introduces a high level of ecological sensitivity to the DGR project. While the proponent has acknowledged these species, the current mitigation framework is overly reliant on qualitative assurances and standard industry practices that may not be sufficient for the unique, long-term risks of this facility. The path forward requires a transition from preliminary desktop assessments to rigorous, field-verified data and legally binding habitat protections to ensure the survival of these vulnerable populations in Melgund Township.