Comments on Initial Project Description – NWMO Deep Geological Repository Project

The Town of Latchford submits the following comments in response to the Nuclear Waste Management Organization’s (NWMO) Initial Project Description (IPD).

The Town of Latchford is a municipality in northeastern Ontario that would be potentially affected by the long-term transportation of high-level radioactive nuclear waste proposed under this project.

Exclusion of Transportation from the IPD

The IPD is deficient because it excludes the long-distance transportation of high-level radioactive waste. Transportation is integral to the project and cannot be separated from the proposed deep geological repository. Without transportation, the project cannot proceed.

Under the Impact Assessment Act, activities that are integral or incidental to a project must be included in the assessment. Excluding transportation improperly removes the ability of potentially affected municipalities to have impacts on their communities assessed.

All Risk, No Benefit

The Town of Latchford would bear risk without benefit. The NWMO estimates 2–3 shipments per day for more than 50 years. These shipments would pass through or near communities that are not host communities and have not consented to the project. Risks include routine radiation exposure, accident potential, emergency-response impacts, and long-term public concern.

Transportation Cannot Be Deferred or Avoided by Marine Shipping

The Town notes that marine shipping is not a viable or acceptable alternative to land transportation and does not negate the need to assess transportation impacts:

• Canada’s nuclear waste inventory originates largely inland, requiring road and rail transport regardless of marine use.

• Marine transport would introduce risks to the Great Lakes–St. Lawrence system, drinking-water sources, ports, and coastal communities.

• Shipping would involve international waters and treaty obligations, adding jurisdictional and regulatory complexity.

• Port handling, transfers between modes, and navigation risks would create additional points of failure and emergency exposure.

As a result, land-based transportation through Ontario communities is unavoidable and must be assessed.

Request

The Town of Latchford requests that the Impact Assessment Agency of Canada require the NWMO to include transportation of high-level radioactive waste within the scope of the federal impact assessment and ensure that impacts on non-host municipalities are fully evaluated.