Northwatch Review of the NWMO’s Consolidated Information on the Transportation of Used Fuel - Plain Language Summary

On January 6, 2025 the Impact Assessment Agency invited comments (https://iaac-aeic.gc.ca/050/evaluations/document/164641) from the public and Indigenous people on the summary (https://iaac-aeic.gc.ca/050/evaluations/document/164740) of an Initial Project Description (https://iaac-aeic.gc.ca/050/evaluations/document/164492) prepared and submitted by the Nuclear Waste Management Organization (NWMO) with respect to their proposed Deep Geological Repository (DGR) for Canada’s Used Nuclear Fuel Project (https://iaac-aeic.gc.ca/050/evaluations/proj/88774?culture=en-CA).

Northwatch was one of more that 600 individuals and organizations who provided comments (https://iaac-aeic.gc.ca/050/evaluations/proj/88774/contributions) on that Initial Project Description, with more than 95% of those intervenors being critical of or opposed to the NWMO’s project and the NWMO’s presentation of the project in the Initial Project Description.

On February 16^th the Impact Assessment Agency of Canada (IAAC or “the Agency”) posted their Summary of Issues (https://iaac-aeic.gc.ca/050/evaluations/document/165449) which included instructions to the NWMO to respond to that summary, but made clear the expectation that the proponent review all submissions on the Canadian Impact Assessment Registry Internet site (the Registry) for the project (Reference Number #88774) and requested that the proponent consider issues that may not have been captured by the IAAC SOI.

The NWMO posted their 767-page Response to the Summary of Issues (https://iaac-aeic.gc.ca/050/evaluations/document/165422) on March 12, 2026. That initial response was comprised of a one-page executive summary, a two-page introduction, and 48 pages described as “Response to Summary of Issues Tables”. More than 600 pages of the NWMO “response to the Summary of Issues” submission was comprised of a subset of transportation-related documents the NMWO has produced during its two decades of operation. The criteria for presentation of this subset of transportation-related reports versus other transportation-related reports was not provided.

The NWMO states in their response to the summary of issues that “This present document contains complete responses to the SOI issued by IAAC, including to concerns raised about transportation of used fuel.”

We disagree. By our assessment the NWMO response to the SOI does not respond to the issues and concerns set out in the submissions on the IPD made by the public, Indigenous people, local governments and federal departments and agencies. Rather, it restates or summarizes claims and generalizations made in the IPD and for which the IPD was soundly criticized.

In the same paragraph in their response to the summary of issues, the NWMO went on to state that “The NWMO recognizes the high level of interest regarding transportation and will be submitting an additional document to consolidate the information on the transportation of used fuel in a single location before the end of the 30-day period allocated for the proponent's response.”

On March 17 the NWMO posted that “additional document”, which was a supplementary report with the title “Consolidated Information on the Transportation of Used Fuel - Plain Language Summary (https://iaac-aeic.gc.ca/050/documents/p88774/165474E.pdf)” (Registry Document #713).

The purpose of this communication is to provide Northwatch’s comments on the NWMO’s supplementary response to the SOI, aka the “Consolidated Information on the Transportation of Used Fuel - Plain Language Summary”.

This commentary on NWMO’s supplementary response to the IAAC Summary of issues is in four parts: 1) the introduction (above), 2) Northwatch’s review of the NWMO’s Consolidated Information on the Transportation of Used Fuel - Plain Language Summary and 3) Northwatch’s assessment of the NWMO’s response to the transportation-related issues raised in Northwatch’s comments on the IPD. Brief concluding remarks are found in Section 4.

Our commentary is attached.

Further to our review of the NWMO’s Response to the IAAC’s Summary of Issues and their supplementary filing of the Consolidated Information on the Transportation of Used Fuel - Plain Language Summary our earlier analysis and conclusions have been affirmed and deepened: the transportation aspects of the NWMO’s project to transport, process, bury and abandon all of Canada’s high-level nuclear fuel waste at the Revell site in the heart of Treaty 3 territory in northwestern Ontario must be included in the impact assessment process.

It falls to the Impact Assessment Agency to ensure that these and other issues raised during the comment period on the Initial Project Description are included in the draft Integrated Tailored Impact Statement Guidelines which we understand will be released for public review and comment in the near future.