Replacement comment: Deep Geologic Repository Comments - Transportation must be included

My apologies, I first sent a draft version of our group's comments. Please delete those and consider these comments (below and attached)

Ontario Climate Emergency Campaign’s submission re the DGR Initial Project Description

Deadline: Feb 4

Submitted by the Ontario Climate Emergency Campaign

Phase: Planning

Public Notice: - Comments invited on the summary of the Initial Project Description and funding available

Attachment(s): N/A

Date Submitted: 2026-01-_____  

Full assessment including transportation needed!

Deep Geological Repository (DGR) for Canada’s Used Nuclear Fuel Project 

Thank you for the opportunity to respond. The Initial Project Description (IPD) does not consider transportation risks. The NWMO’s plan involves 2 to 3 shipments per day for more than 50 years, with each truck hauling 35 tonnes of radioactive waste per trip. There is no comparable or near-comparable international experience to this massive, long-term, high-volume transportation program and the additional climate impacts of the program and the risks more generally, have not been justified. In fact, if the purpose is to isolate the wastes from the environment, that purpose could be met through alternatives to the project and alternative means of carrying out the project which have not been described in the IPD. In addition, there is no level of exposure to ionizing radiation that does not pose an associated risk to human health. The IPD lacks one of the essential elements of project planning and monitoring--a detailed budget and especially a specified cost to the taxpayer.  In sum, the profound shortcomings of the IPD are most productively taken as a warning to abandon nuclear power generation in favour of more affordable, more readily available, and much safer renewable power generation.

In addition, please consider the following:

1) Unbiassed experts on DGRs agree the risks of radiation leaks during the lifetime of radioactive waste storage is extremely high. This will create massive yet unnecessary long-term threats to all living organisms and ecosystems - 

2) Promoting the nuclear industry promotes the absolute most expensive form of energy, more expensive than clean safe renewable energy and even more than methane gas

3) The nuclear industry directs profits and power out of Canada, especially to the United States WRT reactor and waste storage technology and uranium mining, undermining Canadian sovereignty and our domestic economy and jobs

4) Nuclear energy is not only too expensive but also too slow to develop to keep up with Canada’s energy needs

5) Without adequate Indigenous support, how is UNDRIP and free prior informed consent being respected?

6) Why is the federal government overlooking the cheapest, safest and most rapid evidence-based energy options, namely energy conservation, green renewables including wind, solar, hydro, geothermal and modern battery technology to invest in nuclear energy which is so costly it leaves insufficient funding to develop the clearly superior options.