Challenge the Proponent's conclusion that 'no potentially important fish habitat' exists within the Project site, specifically requesting winter field surveys to validate the claim of 'no overwintering habitat' in local watercourses.
Strategic Rationale
"The Proponent's submission relies heavily on desktop reviews and 'existing databases' to claim an absence of overwintering habitat in the Local Investigation Area. For Melgund Township, 'absence of evidence' in a database is not 'evidence of absence' in the field. If the Proponent designs the site discharge or water crossings assuming no fish are present during winter, they risk causing irreversible harm to undocumented local populations. Requiring multi-season field verification ensures the baseline reflects the actual ecological reality of the unorganized territory's watercourses, rather than just historical data gaps."
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.