Require the development and implementation of the Greenhouse Gas Management Plan (GHGMP) prior to the start of site preparation and construction, rather than 'prior to operation'.
Strategic Rationale
The Proponent's submission indicates that annual emissions during the construction phase (14,480 tonnes CO2e) are actually higher than during the operations phase (10,834 tonnes CO2e). Despite this, the filing suggests delaying the formal GHGMP until operations. For Melgund, the construction phase represents the most intense period of local environmental disruption. Moving the GHGMP forward ensures that mitigation strategies for the heating plant and heavy machinery are in place when emissions are at their peak. This proactive approach allows the community to monitor environmental performance from day one, ensuring that the highest-impact phase of the project is not left without a formal management framework.
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.