Strengthen the guidelines and no support for Nuclear Waste storage in Northwestern Ontario

I am writing to urge you to strengthen the Draft Tailored Impact Statement Guidelines for the proposed Deep Geological Repository for Canada’s used nuclear fuel.

You must prohibit operation without addressing the long-term management of high-level radioactive waste.

There is clearly a lack of planning and foresight to establish reliable and socially acceptable methods of managing long-lived radioactive wastes, unacceptable!

An endpoint of a national nuclear waste system that includes the generation, handling, transportation, and long-term disposal of radioactive waste across Canada must include an impact assessment that reflects the full scope and scale of this project.  Currently this is not the case.

There is little to no attention to international radiological protection principles, upholding Indigenous rights and the active and meaningful participation of the public and impacted communities. 

The lack of precautionary and preventative planning for this waste means we must mitigate the unique environmental, human health and security risks the production of nuclear energy poses.

All requiring the highest possible standard of review.

There is much agreement that the Impact Assessment Agency of Canada must strengthen the Draft Guidelines to ensure the impact assessment:

1 - Clearly requires the proponent to conduct a cumulative effects assessment of the project, inclusive of activities at the nuclear sites where the waste is presently housed and along the transportation corridor, taking into account radiological risk from accidents and malfunctions;

2 - Respects and upholds Indigenous rights by aligning the IA process with the principles of UNDRIP, including the requirement of free, prior, and informed consent;

3 - Directs an assessment of alternatives that delivers the best options in the overall lasting public interest, with attention to cumulative, socio-economic, health and environmental effects and their interactions; and

4 - Applies an environmental justice lens, taking into account intergenerational impacts and the meaningful involvement of those impacted by environmental racism, in order to advance transparency and credibility in the IA process.

This is a critical opportunity to close a 50-year gap in accountability and ensure decisions are made in a way that protects people, communities, and the environment—now and for generations to come.

Thank you,

Cathy.