Challenge the Proponent's assertion that 2021-2022 baseline results based on 'desktop... mapping' and 'eDNA sampling' are 'sufficiently comprehensive,' specifically citing the admission in the text that eDNA interpretation is 'difficult due to limited data.'
Strategic Rationale
"The Proponent's submission relies heavily on modelling and novel techniques (eDNA) rather than traditional field observation for the initial assessment. While the text admits that future work (point counts, acoustic surveys) is needed, it attempts to validate 'early conclusions' based on incomplete desktop data. For the Melgund area, establishing a robust, field-verified baseline is essential to accurately monitor future impacts. Accepting conclusions based on desktop data creates a risk of unmeasured baseline conditions, making it impossible to prove project-induced changes later. The Board must demand that the 'Planned Work' (field surveys) be completed to validate the models before the baseline is accepted."
Source Context
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.