Comments on Draft TISG, PPP, IEPP, Cooperation Plan, and Permitting Plan — Six-Section Analytical Brief"

Re: Comments on the Draft Integrated Tailored Impact Statement Guidelines, Draft Public Participation Plan, Draft Indigenous Engagement and Partnership Plan, Draft Permitting Plan, Draft Cooperation Plan, Generic Requirements for the Preparation of an Impact Statement, Technical Considerations and References, and Protocol among IAAC, CNSC and NWMO

To the Impact Assessment Agency of Canada,

ParadigmForge AI Inc. respectfully submits the attached comment brief on the scoping-stage consultation documents published for the Nuclear Waste Management Organization's proposed Deep Geological Repository (DGR) for Canada's Used Nuclear Fuel. The comment period closes on May 10, 2026.

Scope of analysis

The attached brief addresses six analytical dimensions:

1. Scoping adequacy of the Draft TISG — whether the guidelines compel NWMO to assess every subject required under IAA s.22(1), the CNSC REGDOC framework, and the dual-regulator integrated process.
2. Adequacy of the Crown consultation structure — whether the Draft Public Participation Plan and Draft Indigenous Engagement and Partnership Plan together meet the Crown's duty to consult and accommodate Indigenous Peoples whose rights may be adversely impacted, including rights-bearing communities under Treaty 3 and UNDRIP-aligned frameworks.
3. Integrated assessment structure — whether the Protocol among IAAC, CNSC and NWMO, together with the Draft Cooperation Plan, delivers a genuinely integrated assessment satisfying both the Impact Assessment Act and the Nuclear Safety and Control Act without creating duplicative, contradictory, or sequentially dependent obligations.
4. Long-duration scope — whether the documents adequately address post-closure monitoring, institutional control, and passive-safety phases over the full containment timeframe.
5. Regional context and cumulative effects — whether the TISG and NWMO Initial Project Description Summary adequately scope regional cumulative effects and environmental baseline characterization for the Revell Site near Ignace, Ontario.
6. Permitting plan completeness — whether the Draft Permitting Plan captures the full stack of federal authorizations the project will require across all phases and regulatory regimes.