Recommended Amendments to the DTISG and Public Participation Plan

Please find attached, our recommended amendments to the Draft Tailored Impact Statement Guidelines and Public Participation for the Deep Geological Repository (DGR) for Canada's Used Nuclear Fuel Project (Project 88774). 

The key issues identified in our submission emphasize that the protection of water quality and the implementation of rigorous, transparent water testing protocols are of paramount importance to the communities and local peoples living closest to the proposed site. As well, there is an urgent requirement for comprehensive socio-economic health and environmental studies that accurately capture the project's potential impacts on formal and informal recreation, economic impact, food security, local diets, water, transportation and land use.

All possible alternatives to the project as currently proposed must continue to be explored. 

It is critical that the Impact Assessment Agency of Canada (IAAC), Canadian Nuclear Safety Commission (CNSC) and the Proponent ensure these studies are not conducted in isolation, but through the meaningful participation of community members and all local peoples in the design, execution, and oversight of future research. Securing a direct role for locally impacted stakeholders in the ongoing impact assessment and regulatory processes is the only way to ensure that the data reflects the lived reality of the local area and region, and that the community’s fundamental concerns regarding their resources and ways of life are substantively addressed.

While reviewing documents for this submission, our group identified a critical deficiency we feel must be addressed, and one that calls into question the fundamental adequacy of the Proponent's preparatory research. Specifically, our analysis of the "Social Cultural, Economic, and Health Baseline Studies Preliminary Report for Engagement: Wabigoon Lake Ojibway Nation – Ignace Area" (Report APM-REP-06300-0264, 2022) reveals a systemic and unacceptable failure in data collection regarding Melgund Township, its Local Services Board, communities and local peoples living in the immediate project footprint area.

Throughout the document, the statement "Data were not available for the LSB of Melgund" appears no fewer than 58 times, signaling a near total knowledge vacuum across nearly every critical socio-economic and health metric. It is fundamentally flawed for the Nuclear Waste Management Organization (NWMO) to move forward without baseline studies that have so far effectively rendered entire communities and those living closest to the site invisible, especially when these kinds of reports are intended to form the scientific foundation for a project of such immense long-term consequence.

For the amount of time and funding spent on this proposed project to date, this is not a minor oversight; the absence and exclusion of almost 60 key demographic and socio-economic metrics threatens to undermine the integrity of the entire assessment and indicates that the potential impacts on Melgund, its two unorganized communities and local peoples living closest to the site have been procedurally ignored or excluded rather than understood. These profound data gaps must be addressed immediately, with the full and meaningful participation of local peoples and communities, as any assessment built upon such a hollow baseline cannot be considered a credible or meaningful representation of the local realities under the Impact Assessment Act.

To ensure the integrity of the process moving forward, it is essential that all future data collection, particularly the efforts to rectify the current gaps in the Local Study Area baseline, be conducted with full transparency. This must include the timely, public release of raw data and methodologies to impacted local stakeholders, allowing for independent community verification. Meaningful participation is not possible if communities and local peoples are only permitted to review the Proponent’s final conclusions; we must have equitable participation and access to the foundational information to ensure that the unique socio-economic and environmental realities of those closest in proximity to the proposed site and most at risk of impacts are accurately represented and not filtered through a lens of project pre-determination.

We encourage the Proponent and the Regulators to do much better moving forward, because you can.

It is imperative that the Proponent, the IAAC, and the CNSC directly confront the documented risks of psycho-social impact, social disintegration and stigma-induced behavioral change that invariably accompany projects of this magnitude. The intense polarization, proliferation of misinformation, and resulting personal and community divisions have led to a palpable social fracture, threatening the very fabric of social cohesion within many communities. This is well known and has to date been not adequately addressed.

These symptoms of social disintegration are not peripheral concerns; they are core impacts that demand proactive mitigation and a robust institutional response. Multidimensional problems require multidimensional solutions. The lingering psychosocial impacts and the damage resulting from a years-long siting process constitute a significant impact related to the social determinants of health, representing a specific and continuing form of community trauma that requires focused, longitudinal study and comprehensive mitigation strategies.

Despite these profound challenges, the engagement activities of the last few months have proven both productive and rewarding, demonstrating that dedicated, well-funded spaces for constructive dialogue can begin to navigate these deep-seated complexities.

This period of engagement has reinforced the necessity of addressing human-centric impacts with the same technical rigor applied to environmental metrics. Moving forward, the Proponent and regulators must acknowledge that restoring social health, local and regional community cohesion and addressing the determinants of community health and well-being are essential prerequisites for a credible assessment, ensuring that the human cost of the siting process and the future studies to come are neither minimized nor ignored by the Proponent as the formal review proceeds.

From January to May 2026, participation in this process saw our group, along with many others, coming together to discuss the proposed project from all perspectives (for and against) through a comprehensive series of consultations, workshops, and information sessions conducted throughout the last few months. Supported by the IAAC Participant Funding Program, these engagement activities facilitated a rigorous exchange between federal regulators—specifically the Impact Assessment Agency of Canada (IAAC) and the Canadian Nuclear Safety Commission (CNSC)—and industry proponents such as the Nuclear Waste Management Organization (NWMO).

The many information sessions, presentations and events integrated essential local and regional insights from a wide range of local and regional voices, both Indigenous and non-Indigenous, including: The Local Services Board of Melgund and its recreation committee, residents of Borups Corners and Dyment, the communities' non-profit recreation provider, Melgund Recreation, Arts and Culture, arts groups such as The Arts Incubator Winnipeg, and Art Borups Corners, while also incorporating insights and perspectives from the UK’s Nuclear Waste Services. Furthermore, the process ensured the balanced inclusion of critical environmental advocacy through direct participation from organizations such as Northwatch and We The Nuclear Free North, resulting in a multifaceted record of community and stakeholder input for the regulatory record. 

Crucially, these activities brought together voices from across the entire spectrum—inclusive of those both for and against the project—in a spirit of respectful civil dialogue. This level of thoughtful, inclusive and constructive discourse is too often missing from the broader public debate, yet it remains fundamental to a healthy, democratic and transparent assessment process. 

This level of engagement was made possible through the IAAC Participant Funding Program, which serves as an essential pillar for ensuring that local and underrepresented voices have the resources necessary to meaningfully engage with complex technical and social data. It is imperative that programs such as these continue to be offered throughout the upcoming phases of the assessment; without sustained funding and participation, the promise of inclusive and meaningful public involvement of those most impacted cannot be fulfilled.

These collaborative efforts directly embody the spirit and intent of meaningful participation as mandated under the Impact Assessment Act, ensuring that assessment processes are informed by a diverse range of knowledge, perspectives, values, and community interests. In supporting an environment where regulatory authorities, international experts, local and regional stakeholders can engage in transparent dialogue, these activities upheld the Act’s commitment to comprehensive and inclusive public involvement.

We extend our sincere thanks to all individuals and organizations for their participation, contributions, and dedicated engagement, which have been instrumental in shaping a more robust and informed understanding of the project’s potential impacts moving forward.