Project # 88774; the Impact Assessment Agency Canada’s initial review of project APM-REP-05000-0211-R0000

Kitchissippi-Ottawa Valley Chapter of the Council of Canadians
January 25, 2026

To All Whom it May Concern:

Our chapter of the Council of Canadians is located in Renfrew County, also the home to Canadian Nuclear Laboratories (CNL) research facilities at Chalk River. The Chalk River campus of CNL is considered the “Centre of Excellence” by Canada’s nuclear industries and is prominent in the economic realm of our region. As such, our group – which is very concerned about environmental issues – has taken a close interest in the management of the nuclear industry’s radioactive waste and have spent considerable time informing ourselves on related matters.

We specifically request that the Impact Assessment Agency override the request of the proponent to omit transportation from your review of NWMO’s proposed Deep Geological Repository (DGR), intended for northwestern Ontario. We assert your review of NWMO’s plans must include all matters pertaining to transportation from temporary storage sites to the proposed location.

Shipping exceedingly high-level materials to the proposed DGR, on public and heavily used roadways, is a core aspect of the proposed project. At the same time, the transportation of the highest-level nuclear waste, also known as “used fuel,” is clearly the most contentious issue concerning this DGR project.

We have massive concerns that the Nuclear Waste Management Organization (NWMO) has asked your agency to review its proposal while specifically stating that they do not want an Impact Assessment of their plans to transport the waste to that proposed facility. The elimination of review of transportation of waste to the proposed DGR site is foolhardy and serves the industry in only a very limited way, as we explore herein.

There are potentially significant impacts to the public and environment through the increased movement of radioactive waste. Should an accident occur during the transportation period, the proponent and/or shipper face the likelihood of complex clean-up and a concurrent claim for damage to the environment and/or to the health of any persons who were in or travelling through the vicinity of the accident. In the event of an accident, that risk of liability could only be mitigated by a fully effective clean-up process but high-level radioactive material loose in the natural world is not easy to clean up.

The risks include increased traffic due to the site preparation and construction phases of the project. In addition, security implications for moving high level radioactive waste must be taken into consideration. A lapse in security could have very serious consequences and liaibility risks.

In general, our concerns relate to the distance the nuclear material must be transported for the proposed project, because:

• each kilometre of travel statistically increases the potential for accidents, and there are some exceptionally long distances from the legacy sites as well as various intended generating stations to the proposed DGR storage facility location;

• there are well-acknowledged safety issues on the northern section of this route, with that section of the TransCanada being known for high rates of accidents, especially in winter;

• any accident involving this material risks contamination of the surrounding natural environment and nearby waterways as well as human settlements, possibly even humans travelling past the accident site;

• due to the remote distances involved:

  • there will be increased need for security monitors and protection;

  • transportation aspects of this proposed project will generate very considerably more greenhouse gas emissions than if longterm storage of the waste was located on or close to the generation facilities, as is widely recommended;

  • rescue of material and the vehicle after an accident will require seconding highly trained personnel with appropriate equipment from wherever they are located, where they may or may not be ready for immediate deployment – thus increasing the potential for all the contamination mentioned above and more.

It is obvious from the issues identified above that the proponent or their partner risks liability from NOT having the benefit of a full and proper Impact Assessment review of the transportation between the temporary storage sites sprinkled across Ontario and currently in Manitoba, Quebec and New Brunswick. (We note that materials from Quebec and Manitoba are or are scheduled to be moved to Chalk River for a second round of temporary storage, before being moved again to the proposed DGR site.)

We used the word “currently” above because news media have reported that various industry development proponents might hope to use this proposed DGR facility for “permanent” storage of the high-level radioactive waste “Small Modular [Nuclear] Reactors” are expected to produce. Already there is discussion of SMRs being located even further away than the current high level (or “fuel”) temporary locations.

Pulling on international experience, it is known to be preferable to build the repository for higher activity wastes as close to the site of most of the waste because it is recognised that transportation is one of the highest risk activities (on-site, public roadways, or railways). In conformity, at the present time, Canadian high-level nuclear waste (fuel) is currently moved but almost always on-site / a very short distance to temporary storage. 

Including the 80-year backlog of legacy “CANDU” and temporarily-stored waste, NWMO estimates shipping approximately 120,000 used fuel bundles to the proposed DGR per annum. It is currently projected that 10 used fuel containers will be processed and placed in the repository each day. The proponents estimate they will have these hazardous shipments on our roadways approximately 270 days per year, for several decades! This adds up to a huge mess if mistakes are made because important matters were not addressed in the Impact Assessment review.

Given the advances in similar repository designs internationally, where many engineering issues have already been identified for corrective action, transportation is arguably the highest risk activity during the operational phase of this proposed DGR.  It poses the greatest potential hazardous impacts to the public and environment, and also the highest security risks. All these are multiplied by the long distances the material must travel. There is great potentiality for problems causing liability, should something go wrong that was foreseeable and preventable.

The proponent made an unwise and dangerous decision to request that your agency, the federal Impact Assessment Agency, omit consideration of the matter of transportation from and to locations of temporary storage. Your agency potentially risks the same exposure to liability if you fail to correct the proponent’s lapse in judgement. Relying on the Canadian Nuclear Safety Commission to have the environmental and human impact expertise to manage this is not sufficient. They simply don’t have the capacity nor the mandate of your agency, and need to be guided by your review of all these transportation issues.

It is misleading for the proponent to say their project proposal is fulfilling all the requirements outlined in the IAAC Impact Assessment 101 definitions or the Regulations laid out in SOR2019-2023. There are numerous items we believe have not been properly addressed. It is important for the Impact Assessment Agency to take these particulars into account regarding review of NWMO’s proposed DGR development. For the Agency’s convenience, these are referenced in Appendix A: Specific Comments related to Apparent Shortcomings of APM-REP-05000-0211-R0000 (KOV - January 23, 2026),  attached below. 

In closing, we support that the IAAC require a full federal IA of this proposal, which:

1. includes nuclear waste transportation routes and risks within the project scope;

2. upholds all human and environmental justice, including the rights of impacted communities along the proposed routes to be informed and have a say;

3. (corollary to #2) protects Indigenous rights including free, prior and informed consent obligations, internationally recognized in UNDRIP and as required under Canadian law; and,

4. our organization (the Kitchissippi-Ottawa Valley Chapter of the Council of Canadians) asks for formal recognition from your agency to be included in all forthcoming “public consultation” for this proposed DGR project, as you move ahead with review.

Respectfully yours,

Ann Pohl, Co-Chair & Animator
Kitchissippi-Ottawa Valley Chapter of the Council of Canadians


APPENDIX A:
Comments related to: APM-REP-05000-0211-R0000:
Initial Project Description Plain Language Summary – Deep Geological Repository (DGR) for Canada’s Used Nuclear Fuel Project; December 2025

The following concerns are raised regarding specific sections of the document to aid in understanding.

Section 5: Public and Interested Parties Engagement.

Table 5.1: there is no mention of communities along the proposed transportation routes in the communities and interested parties’ table. There are extensive communities along the proposed routes who will be impacted by increased risk to both the public and environment. Waste will be transported from various sites including Quebec and New Brunswick. In addition, communities will be impacted during the site preparation and construction phases. This is covered in more detail in section 10.3 below.

Section 5.3.1: Overarching Themes: Key themes that have been raised to the NWMO by the public include the protection of people and the environment emphasising the need for a project that is safe, secure and environmentally responsible. Looking at this with the lens of transportation, it is not clear if materials required for the construction phase are ging to be locally sourced and, therefore, only affect the routes and communities already mentioned in the report. If this is not the case, it is internationally recognised that increased traffic of large vehicles in remote areas and on small highways is a safety and environmental issue.

Section 7: Strategic Assessment.

An initial estimate of annual greenhouse gas emissions has been provided which includes, amongst other things, the transportation of used nuclear fuel (although this is excluded from this phase of the impact assessment). However, it does not appear to give any consideration to transportation of materials for the site preparation and construction phases.

Section 10.3: Description of activities by phase.

All activities to be completed are included under the respective licenses for site preparation, construction and operation. It is unclear how all activities can be considered without transportation. There are no site preparation and construction without significant movement of material to and from the site. It is not clear if construction materials are being sourced (relatively) locally or if they will travel a long distance. Whilst there are no radiation concerns from this, there is the increased movement of large transportation vehicles on (sometimes) one lane highways.

The last paragraph in this section states:
“Transportation of nuclear and non-nuclear materials within existing highways and railways is independently regulated and ongoing, does not require changes to current infrastructure or regulations and would continue regardless of the Project’s implementation. These activities are governed by existing federal and provincial standards, such as the CNSC’s Packaging and Transport of Nuclear Substances Regulations and the Transportation of Dangerous Goods Regulations and are not considered part of the Project’s designated or incidental activities”.

Figure 1(found at footnote #1 below) illustrates the roles of the CNSC and Transport Canada (TC), as well as Provincial considerations. This shows who is responsible to establish standards and classifications, certify packages, and review security plans. It also indicates who would supply training, reporting requirements, and ensure correct hazard marking is applied.

What this doesn’t show are the CNSC or TC carrying out risk assessments for increased and consistent movement of radioactive materials long distances. They also do not consult with the public over their concerns about these activities. Consideration of security along the whole route during transportation also needs to be considered and plans drawn up.

Regular movement of nuclear material on the scale suggested in this proposed DGR project has not occurred before in Canada. So, whilst regulations and licensing exist for these activities, there are different issues to be considered for frequency of movements, volume of waste and level of radioactivity.

Under the Nuclear Security Regulations (see footnote #2 below), issues such as physical protection, security and contingency planning must be taken into consideration. This has been mentioned in terms of outer fences and inner security areas at the site but security during transportation needs to be addressed. The regulations state that nuclear security plans be prepared, threat assessments conducted, and the implementation of security programs implemented, including transport. Incidents such as attempted theft or sabotage during transport are key areas. There are additional security risks for this project in that the distances from storage site to the GDR are long, there are limited routes available and the plan to take all waste from one storage site at a time increases the risk of the timing of the transport being predicted.

These are activities and risks that need to be considered by the Project and which the public need to be aware of and consulted on as part of this scoping phase as it will inform future planning. This includes communities across the entire route(s).

IAAC Impact Assessment 101 – Planning Phase:

“The IPD includes the location of the Project and identifies the communities and Indigenous Populations that may be affected”.

We don’t think that this IPD includes all the communities that may be affected. The exclusion of transportation means that those communities along the proposed transport routes (nuclear and non-nuclear materials) have not been identified and will, therefore, not be consulted.

Department of Justice Regulations: SOR 2019-283 – Information and Time Management of Time Limits Regulation:

Section 3 - Information Required in Initial Description of Designated Project.

Item 9: Lists of all activities, infrastructure, permanent or temporary structures and physical works to be included in and associated with construction, operation and decommissioning of the Project. Construction, operation and decommissioning activities cannot take place without transportation activities which are excluded from this IPD.

In summary, this Project cannot be planned and assessed in the absence of transportation as it cannot be implemented without transportation. There are risks to the public, environment and greenhouse gas emissions to be considered. There is a considerable security risk in the movement of high-level waste and there is no provision for consulting with the public along the proposed transportation routes.