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Peace River Nuclear Power Project

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Attachment Requirement to Reinstate the Pause on Phase 1 of the IAA 2019 Process – Peace River Nuclear Power Project

Peace River Nuclear Power Project
Author: Administrator on behalf of Woodland Cree First Nation
Reference Number: 616
Submitted: 2026-04-15 - 11:13 AM
Project Phase: N/A
Participation Notice: N/A
See the attached submission / Veuillez consulter la pièce jointe
Attachment Included
April 14, 2026 Peace River Nuclear Power Project Impact Assessment Agency of Canada 160 Elgin Street, 22nd Floor Ottawa, Ontario K1A 0H3 Telephone: 613-699-6778 Re: Requirement to Reinstate the Pause on Phase 1 of the IAA 2019 Process – Peace River Nuclear Power Project To Whom It May Concern, The Woodland Cree First Nation is formally advising the Impact Assessment Agency of Canada that the Nation does not support the resuming of Phase 1 of the federal impact assessment process for the proposed Peace River Nuclear Power Project, date March 2, 2026. The pause must remain in place. The proponent has not met the minimum requirements necessary to justify moving forward, and advancing the process now would undermine the integrity of the assessment and the Nation’s ability to participate meaningfully. The Project was Paused on August 20, 2025, and since that time Energy Alberta has taken no meaningful steps to address the issues that led to ...

Attachment Peace River First Nations Initial Comments on PRPP Siting Matters

Peace River Nuclear Power Project
Author: Administrator on behalf of Peace River First Nations
Reference Number: 608
Submitted: 2026-04-10 - 11:30 AM
Updated: 2026-04-13 - 3:45 PM
Rationale: Comment updated for administrative purposes
Project Phase: Planning
Participation Notice: N/A
Good morning Justin and Claudette, Further to our initial information meeting on siting matters related to the Peace River Nuclear Power Project, the Peace River First Nations wished to provide the attached document to you and your colleagues at the Canadian Nuclear Safety Commission and the Impact Assessment Agency of Canada. As you will have gathered from the tenor of our discussions last week, and from the matters raised in the attached document, the Peace River Nations have serious concerns with the approach and methodology adopted by the proponent in relation to siting. While the approach may be considered by your agencies to sufficiently meet existing guidance on siting matters, the Nations remain concerned that this process contains significant gaps and deficiencies. In particular, it fails to adequately consider, evaluate, avoid, and address adverse impacts on the Nations’ rights, culture, and way of life that will certainty flow from ...
Attachment Included
1 Peace River First Nations Initial Comments in Respect to Energy Alberta’s Siting Criteria and Methodology For the Peace River Nuclear Power Project Date: April 8, 2026 (REVISED and REISSUED) Prepared for: Energy Alberta in Relation to the proposed Peace River Nuclear Power Project (“Project”) Prepared by: Peace River First Nations (“PRFNs” or “Nations”) which, for purposes of this initial submission, is inclusive of:  Tallcree Tribal Government  Little Red River Cree Nation  Beaver First Nation  Dene Tha’ First Nation  Duncan’s First Nation Copied to: Casey Horseman: Horse Lake First Nation Subject: Initial Comments on the Approach and Methodology for Siting the Peace River Nuclear Power Project 2 1.0 Purpose and Context • These initial comments are provided by the PRFNs in respect of Energy Alberta’s current approach to siting the proposed Project. • The PRFNs understand Energy Alberta has identified two prospective ...

Attachment Peace River Nuclear: 15th Show stopper: New Research ignore / CNSC health protection framework invalidated

Peace River Nuclear Power Project
Author: Administrator on behalf of Chris
Reference Number: 596
Submitted: 2026-03-19
Project Phase: Planning
Participation Notice: N/A
See the attached submission / Veuillez consulter la pièce jointe
Attachment Included
IAAC COMPLAINT Energy Alberta Peace River Nuclear Power Project SS 15 CNSC Conveniently Ignores the Latest Research Source: INWORKS 2023–2025; Harvard Environmental Health 2025; Harvard Nature Communications 2026; IJMS March 2025; Current Environmental Health Reports Meta-Analysis 2024; European Journal of Epidemiology November 2024 The Argument The Canadian Nuclear Safety Commission’s radiation health protection framework rests on three claims in that:  The CNSCs’ risk coefficient of five percent per Gray adequately captures the cancer mortality risk from chronic low-dose radiation;  The linear no-threshold model is conservative at low doses;  Compliance with dose limits derived from these two claims constitutes adequate provision for the protection of health under the Nuclear Safety and Control Act. The original INWORKS cohort study in August 2023 challenged the CNSC’s radiation health protection framework. The CNSC’s response, posted on ...

Attachment Peace River Nuclear: 16th Show stopper: Harm

Peace River Nuclear Power Project
Author: Administrator on behalf of Chris
Reference Number: 597
Submitted: 2026-03-19
Project Phase: Planning
Participation Notice: N/A
See the attached submission / Veuillez consulter la pièce jointe
Attachment Included
IAAC COMPLAINT ADDITIONS Energy Alberta Peace River Nuclear Power Project — Registry #89430 SHOW STOPPER 16 The Rights Hierarchy and the Regulatory Vacancy The CNSC has no standard for harm, no instrument to measure it, and no constitutional permission to price the right to life This Show Stopper makes a three-part argument, each part independently sufficient to require the Panel to find that the CNSC’s submission does not answer the question the Impact Assessment Act requires to be answered. Part 1 establishes that the CNSC has never defined a standard for unacceptable harm and that its framework — ALARA and dose compliance thresholds — is structurally incapable of producing a determination of unacceptability. Part 2 establishes that the CNSC’s monitoring framework cannot detect harm to the host community even if it occurs. Part 3 establishes that the constitutional and human rights framework independently prohibits the result the CNSC’s ...

Attachment Peace River Show Stopper 30

Peace River Nuclear Power Project
Author: Administrator on behalf of Chris
Reference Number: 601
Submitted: 2026-03-19
Project Phase: Planning
Participation Notice: N/A
See the attached submission / Veuillez consulter la pièce jointe
Attachment Included
| Page 1 IAAC COMPLAINT ADDITIONS Energy Alberta Peace River Nuclear Power Project — Registry #89430 A Formal Submission to the Impact Assessment Agency of Canada Registry #89430 — Energy Alberta Peace River Nuclear Power Project March 2026 SHOW STOPPER 30 A PROCESS REDUCED TO A MOCKERY How Energy Alberta treated the Statutory consultation process with disdain, how the CNSC participated and enabled this disdain and how the IAAC allowed it to happen The Impact Assessment Act does not contemplate a proponent that treats the statutory process as a commercial convenience. It does not contemplate a national nuclear regulator that provides technical evidence to a quasi- judicial panel for determinations it knows its own institutional posture precludes it from supporting. And it does not contemplate an assessment agency that watches both of those things happen while continuing the assessment as though nothing has gone wrong. The Act is built on ...

Attachment Show Stopper 34 - Public Subsidy Needed!!

Peace River Nuclear Power Project
Author: Administrator on behalf of Chris
Reference Number: 605
Submitted: 2026-03-18 - 12:49 PM
Project Phase: Planning
Participation Notice: N/A
See the attached submission / Veuillez consulter la pièce jointe
Attachment Included
Energy Alberta Peace River Nuclear Power Project — IAAC Registry #89430 | SHOW STOPPER 34 — Commercial Unviability | March 2026 1 | P a g e ENERGY ALBERTA PEACE RIVER NUCLEAR POWER PROJECT IAAC Registry File No. 89430 March 2026 SHOW STOPPER 34 PERMANENT PUBLIC SUBSIDY NEEDED THE PEACE RIVER NUCLEAR POWER PROJECT CANNOT COMPETE IN ALBERTA'S DEREGULATED ELECTRICITY MARKET WITHOUT A PERMANENT PUBLIC SUBSIDY. NO GOVERNMENT HAS BEEN COMMITTED BY ANY SUCH GOVERNMENT SUBSIDY. HE GAP BETWEEN WHAT NUCLEAR COSTS AND WHAT ALBERTA'S MARKET WILL PAY IS APPROXIMATELY $76 TO $156 PER MEGAWATT-HOUR — LARGER THAN ALBERTA'S ENTIRE 2025 AVERAGE POOL PRICE. THE TISG DOES NOT REQUIRE THE PROPONENT TO DISCLOSE A REVENUE MODEL, QUANTIFY THE SUBSIDY REQUIRED, OR DEMONSTRATE THAT THE PROJECT CAN ATTRACT PRIVATE FINANCE WITHOUT A COMMITTED GOVERNMENT REVENUE GUARANTEE. THESE OMISSIONS IN THE TISG ARE FATAL TO THE PUBLIC INTEREST ...

Attachment Peace River: Show Stopper 33

Peace River Nuclear Power Project
Author: Administrator on behalf of Chris
Reference Number: 604
Submitted: 2026-03-18 - 12:28 PM
Project Phase: Planning
Participation Notice: N/A
See the attached submission / Veuillez consulter la pièce jointe
Attachment Included
Energy Alberta Peace River Nuclear Power Project — IAAC Registry #89430 | SHOW STOPPER 33 — No Demonstrated Need | March 2026 1 | P a g e ENERGY ALBERTA PEACE RIVER NUCLEAR POWER PROJECT IAAC Registry File No. 89430 March 2026 SHOW STOPPER 33 THERE IS NO SUCH ELECTRICITY NEED ENERGY ALBERTA'S CLAIM THAT IT WILL SUPPLY 25 PER CENT OF ALBERTA'S ELECTRICITY IS ARITHMETICALLY INVALID: IT IMPLIES A BASELINE THAT DOES NOT EXIST. THIS FOUNDATIONAL ERROR CORRUPTS THE ENTIRE NEED JUSTIFICATION. THE CAPACITY GAP ENERGY ALBERTA ALLEGES AND PROPOSES TO FILL DOES NOT EXIST ON AESO'S OWN DATA. THE ONLY IDENTIFIABLE FUTURE GAP BEFORE AND AFTER 2038 — A 3,078 MW COAL-TO- GAS RETIREMENT RISK IN 2038 — ARRIVES BEFORE ENERGY ALBERTA CAN PRODUCE ELECTRICITY AND PROVISION FOR THIS IS ALREADY MADE BY THE PROJECTS ALREADY IN THE PIPELINE. THE IAAC TISG FALLS SHORT BECAUSE IT DOES NOT REQUIRE ENERGY ALBERTA TO CONDUCT A VERIFIED ...

Attachment Peace River: Show Stopper 32

Peace River Nuclear Power Project
Author: Administrator on behalf of Chris
Reference Number: 602
Submitted: 2026-03-18 - 11:53 AM
Project Phase: Planning
Participation Notice: N/A
See the attached submission / Veuillez consulter la pièce jointe
Attachment Included
Energy Alberta Peace River Nuclear Power Project — IAAC Registry #89430 | SHOW STOPPER 32 — Temporal Overreach & Methodology Defect | March 2026 1 | P a g e ENERGY ALBERTA PEACE RIVER NUCLEAR POWER PROJECT IAAC Registry File No. 89430 March 2026 SHOW STOPPER 32 TEMPORAL OVERREACH THREE TECHNOLOGIES THAT SOLVE THE PROBLEMS CREATED BY SOLAR, WIND, AND NUCLEAR WILL BE COMMERCIALLY MATURE BEFORE THE PEACE RIVER PROJECT OPENS IN THE 2040s. IAAC'S TISG DOES NOT REQUIRE THE PROPONENT TO COMPARE THE PEACE RIVER PROJECT AGAINST ANY OF THESE ALTERNATIVE TECHNOLOGIES. THE REGDOC §2.2.1 COMPARISON METHODOLOGY IS ALSO STRUCTURALLY DEFECTIVE: IT DOES NOT WEIGHT FOR THE DURATION, MAGNITUDE, OR IRREVERSIBILITY OF NUCLEAR RISK. 32.1 The Starting Point: Two Problems That Need Solving To understand why Show Stopper 32 matters, a reader needs to understand two technology problems that currently shape Alberta's electricity options. ...

Attachment TISG Amendment: Third Request (Impact Statement)

Peace River Nuclear Power Project
Author: Chris Nel
Reference Number: 592
Submitted: 2026-03-13 - 6:10 PM
Project Phase: Planning
Participation Notice: N/A
The current IAAC TISG document in draft is entire deficient
Attachment Included
Page 1 of 9 IAAC CURRENT DRAFT TISG THE DOCUMENT IS DEFICIENT AS A REGULATORY INSTRUMENT AN IMPACT STATEMENT PRODUCED UNDER IT CANNOT SUPPORT A LAWFUL PUBLIC INTEREST DETERMINATION UNDER IAA SECTION 63 March 2026 SHOW STOPPER STATEMENT The draft Integrated Tailored Impact Statement Guidelines for the Peace River Nuclear Power Project are deficient as a regulatory instrument in twenty-seven identified respects. An Impact Statement produced under the draft TISG as written cannot provide the Review Panel with the evidentiary foundation required to discharge its independent functions under IAA section 46, cannot demonstrate compliance with mandatory CNSC regulatory requirements for an initial licence application, and cannot support a lawful public interest determination by the Minister under IAA section 63. IAAC cannot approve this project on the basis of an Impact Statement produced under deficient guidelines. Approval would constitute an ...

Attachment TISG Amendment: Second Request

Peace River Nuclear Power Project
Author: Chris Nel
Reference Number: 591
Submitted: 2026-03-13 - 5:48 PM
Project Phase: Planning
Participation Notice: N/A
The flexible gas and storage alternatives are mandatory requurements for TISG
Attachment Included
Page 1 of 12 TISG AMENDMENTS – SECOND REQUEST Peace River Nuclear Power Project — IAAC Registry File No. 89430 Submitted to the Impact Assessment Agency of Canada and the Canadian Nuclear Safety Commission MANDATORY COMPARATIVE ASSESSMENT OF FLEXIBLE GAS WITH CCS AND LARGE-SCALE ENERGY STORAGE AS VIABLE COMPETING TECHNOLOGIES March 2026 SCOPE OF THIS SUBMISSION This submission requests two amendments to the final Integrated Tailored Impact Statement Guidelines. Both amendments are mandatory, not discretionary: one arises from a ‘shall’ requirement in CNSC REGDOC-2.5.2 Version 2.1, the other from IAA section 22(1)(f) and (i) in conjunction with the IAAC’s own Summary of Issues. Neither requirement appears in the draft TISG. Amendment 1 (REGDOC-2.5.2 §2.2.1): The proponent must demonstrate by quantitative probabilistic safety assessment that MONARK societal risk is comparable to or less than the risk of generating equivalent electricity by flex gas with ...

Attachment TISG Amendment: First Request

Peace River Nuclear Power Project
Author: Chris Nel
Reference Number: 590
Submitted: 2026-03-13 - 5:34 PM
Project Phase: Planning
Participation Notice: N/A
I ask IAAC please amend their TISG in line with the document attached.
Attachment Included
Page 1 of 16 FORMAL REQUEST TO AMEND THE FINAL INTEGRATED TAILORED IMPACT STATEMENT GUIDELINES Peace River Nuclear Power Project IAAC Registry File No. 89430 March 2026 STRUCTURE OF THIS SUBMISSION This submission is divided into two Parts. Part 1 — The Foundational Error: IAAC has structured the draft TISG on the assumption that CNSC- published science constitutes settled fact. This is a legal and scientific error. Section 46 of the Impact Assessment Act confers Commission powers on the Review Panel independently of CNSC staff. The Review Panel is not bound by CNSC published conclusions and must be capable of forming its own independent scientific judgments. The draft TISG, as written, does not equip the proponent to provide the evidentiary foundation required for the Review Panel to discharge this function. Part 1 identifies this structural deficiency and specifies the mandatory amendments required to correct it. Part 2 — Specific TISG Shortfalls: ...

Attachment Show Stoppers 1 -31

Peace River Nuclear Power Project
Author: Chris Nel
Reference Number: 589
Submitted: 2026-03-13 - 5:14 PM
Project Phase: Planning
Participation Notice: N/A
The entire IAAC process is compromised and cannot be cured, the CNSC is dysfucntional and cannot perform its functions
Attachment Included
Page 1 IAAC COMPLAINT ADDITIONS Energy Alberta Peace River Nuclear Power Project — Registry #89430 A Formal Submission to the Impact Assessment Agency of Canada IAAC Registry #89430 — Energy Alberta Peace River Nuclear Power Project March 2026 SHOW STOPPER 31 THE IAAC PROCESS IS INVALID AND CANNOT BE CURED Seven Independent Grounds of Structural Invalidity, Institutional Failure, and the Case for a Full Process Restart Show Stoppers 1 through 29 establish, across three categories — the evidence, the institution, and the law — that this project cannot be approved. Show Stopper 30 establishes something prior to all of them: that the process through which approval is being sought has been corrupted in ways the IAAC cannot cure by proceeding. This Show Stopper — SS31 — makes the cumulative legal case. It does not repeat the factual analysis of Show Stoppers 1 through 30 in full. It integrates the conclusions of those submissions into a ...

Attachment NB!!!: Show Stopper 31 IAAC process invalid and uncurable

Peace River Nuclear Power Project
Author: Administrator on behalf of Chris
Reference Number: 603
Submitted: 2026-03-13 - 4:25 PM
Project Phase: Planning
Participation Notice: N/A
See the attached submission / Veuillez consulter la pièce jointe
Attachment Included
Page 1 IAAC COMPLAINT ADDITIONS Energy Alberta Peace River Nuclear Power Project — Registry #89430 A Formal Submission to the Impact Assessment Agency of Canada IAAC Registry #89430 — Energy Alberta Peace River Nuclear Power Project March 2026 SHOW STOPPER 31 THE IAAC PROCESS IS INVALID AND CANNOT BE CURED Seven Independent Grounds of Structural Invalidity, Institutional Failure, and the Case for a Full Process Restart Show Stoppers 1 through 29 establish, across three categories — the evidence, the institution, and the law — that this project cannot be approved. Show Stopper 30 establishes something prior to all of them: that the process through which approval is being sought has been corrupted in ways the IAAC cannot cure by proceeding. This Show Stopper — SS31 — makes the cumulative legal case. It does not repeat the factual analysis of Show Stoppers 1 through 30 in full. It integrates the conclusions of those submissions into a ...

Attachment Peace River Show Stoppers - 23 to 29

Peace River Nuclear Power Project
Author: Administrator on behalf of Chris
Reference Number: 600
Submitted: 2026-03-13 - 1:45 PM
Project Phase: Planning
Participation Notice: N/A
See the attached submission / Veuillez consulter la pièce jointe
Attachment Included
SUPPLEMENTARY SHOW STOPPERS 23 – 29 A Formal Submission to the Impact Assessment Agency of Canada Registry #89430 — Energy Alberta Peace River Nuclear Power Project Submitted by: Christofeel Gerhardus Nel Peace River Region, Alberta — Treaty 8 Territory | March 2026 SHOW STOPPER 23 Technology Indeterminacy: The Project Description Does Not Identify the Designated Project IAA s. 10 and Physical Activities Regulations r. 7 — uncommitted reactor technology — participation resource depletion The Statutory Requirement Section 10(1) of the Impact Assessment Act requires a proponent to provide the Agency with an initial project description that includes the information prescribed by the Physical Activities Regulations. Regulation 7(c) requires identification of the designated project's physical components, including the type and dimensions of permanent structures. Regulation 7(d) requires identification of the physical activities carried out in ...

Attachment Peace River Show Stoppers - 18 to 22

Peace River Nuclear Power Project
Author: Administrator on behalf of Chris
Reference Number: 599
Submitted: 2026-03-13 - 10:52 AM
Project Phase: Planning
Participation Notice: Public Notice - Public Comments Invited on the Summary of the Initial Project Description
See the attached submission / Veuillez consulter la pièce jointe
Attachment Included
IAAC COMPLAINT ADDITIONS Energy Alberta Peace River Nuclear Power Project March 2026 SHOW STOPPER 18 The Project Without a Reactor The Panel is being asked to assess a project whose defining physical parameter — the reactor technology — has not been decided. An assessment of an undefined project is a legal nullity. 17.1 The Indeterminacy on the Record Energy Alberta filed its Initial Project Description in April 2025 nominating two to four CANDU MONARK reactors. On 21 October 2025 — six months into the IAAC process — it signed a Memorandum of Understanding with Westinghouse to explore deploying AP1000 pressurised water reactors at the same site instead. Its own project website now lists both technologies as “under consideration.” The CNSC’s project page for the Peace River Nuclear Power Project continues to describe the facility as CANDU MONARK. These are not minor design variations. The CANDU MONARK is a pressurised heavy water reactor ...

Attachment Peace Nuclear Plant - 14th Show Stopper

Peace River Nuclear Power Project
Author: Administrator on behalf of Chris
Reference Number: 593
Submitted: 2026-03-12 - 6:46 PM
Project Phase: Planning
Participation Notice: N/A
See the attached submission / Veuillez consulter la pièce jointe
Attachment Included
IAAC COMPLAINT ADDITIONS Energy Alberta Peace River Nuclear Power Project SS 14 The HIA Scope Defect: A Cancer Risk Assessment Labelled as a Health Impact Assessment Source: G4SR6 Paper 1 (Non-Oncological Health Endpoints Excluded from CANDU HIAs) INSERT AFTER SS13 — insert SS14 as the next full show stopper in Part Three: The Law SS14 is a statutory scope argument. It does not require acceptance of any epidemiological finding in SS1–SS13. The Argument Health impact assessments for CANDU nuclear facilities in Canada evaluate cancer risk as the primary, and in practice the sole, quantitative health endpoint. Dose calculations are performed for routine radionuclide releases, incremental cancer risk is computed using the LNT model, and the resulting figure — typically expressed as a fraction of background cancer risk — is used to conclude that routine releases do not pose an unreasonable health hazard. The structure reflects the historical ...

Attachment Peace River Nuclear: 17th Show stopper: Harm Quantum Framework

Peace River Nuclear Power Project
Author: Administrator on behalf of Chris
Reference Number: 598
Submitted: 2026-03-12 - 6:20 PM
Project Phase: Planning
Participation Notice: N/A
See the attached submission / Veuillez consulter la pièce jointe
Attachment Included
March 2026 Page 1 IAAC COMPLAINT ADDITIONS Energy Alberta Peace River Nuclear Power Project — Registry #89430 March 2026 SHOW STOPPER 17 HARM QUANTUM FRAMEWORK SAFETY: GAS POWER GENERATION OVERTOOK NUCLEAR The CNSC has operated for 34 years without the analytical tools its mandate requires. When those tools are built honestly, gas generation with carbon capture overtakes nuclear on every harm metric that matters to the Peace River community. The Panel cannot make a public interest determination without them. INTRODUCTION This submission does not oppose electricity generation. It does not ask the Panel to prefer inaction over development. It asks the Panel to require honest comparison before irreversible commitment. Energy Alberta proposes to site four CANDU MONARK reactors 30 kilometres north of Peace River and to operate them for 60 years. That proposal rests on a comparative proposition — that nuclear is the better option for Alberta's ...

Attachment Peace Nuclear Plant

Peace River Nuclear Power Project
Author: Administrator on behalf of Chris Nel
Reference Number: 587
Submitted: 2026-03-10 - 4:07 PM
Project Phase: Planning
Participation Notice: N/A
See the attached submission / Veuillez consulter la pièce jointe
Attachment Included
SEVENTEEN YEARS, NO ACTION: THE ODWAC TRITIUM DRINKING WATER RECOMMENDATION, THE CNSC ACKNOWLEDGEMENT, AND THE REGULATORY ACCOUNTABILITY GAP IN CANDU LICENSING Independent Anonymous Researcher 1.. Background In 2009, the Ontario Drinking Water Advisory Committee (ODWAC) — an independent scientific advisory body convened by the Ontario Ministry of the Environment to review the provincial tritium drinking water standard — recommended a 350-fold reduction in the maximum acceptable tritium concentration, from 7,000 Bq/L to 20 Bq/L [1]. The basis for the recommendation was a comprehensive review of tritium health effects evidence, including the differential sensitivity of pregnant women and fetuses, the incorporation of organically bound tritium (OBT) into fetal DNA, and the inadequacy of the existing standard to protect the most sensitive members of the population at concentrations approaching the current limit. The Canadian Nuclear Safety Commission (CNSC) ...
Attachment Included
BUILT ON THE WRONG PEOPLE: FOUR UNVALIDATED EXTRAPOLATION STEPS IN THE LNT DOSE MODEL AS APPLIED TO CHRONIC INTERNAL EMITTER EXPOSURE FROM CANDU REACTORS Independent Anonymous Researcher 1.. Background Every safety determination made by the Canadian Nuclear Safety Commission (CNSC) regarding routine releases from CANDU reactors rests on a risk estimate derived from the Linear No-Threshold (LNT) model as calibrated primarily on the Life Span Study (LSS) of Japanese atomic bomb survivors. The CNSC applies this model to calculate the incremental cancer risk to populations in the vicinity of CANDU facilities from routine tritium and other radionuclide releases, and uses the resulting risk estimates to conclude that routine releases do not pose an unreasonable health risk. This paper does not contest the LNT model as a general framework for radiation protection. It identifies four specific respects in which the population, exposure conditions, and biological ...
Attachment Included
BEYOND CANCER: NON-ONCOLOGICAL HEALTH ENDPOINTS EXCLUDED FROM CANDU ROUTINE RELEASE HEALTH IMPACT ASSESSMENT AND THE STATUTORY MANDATE TO CONSIDER THEM Independent Anonymous Researcher 1.. Background Health impact assessments (HIAs) for CANDU nuclear facilities in Canada are structured to evaluate cancer risk as the primary, and in practice sole, quantitative health endpoint. Dose calculations are performed for routine radionuclide releases, incremental cancer risk is computed using the LNT model, and the resulting figure — typically expressed as a fraction of background cancer risk — is used to conclude that routine releases do not pose an unreasonable health hazard. This structure reflects a cancer-centric model of radiation health effects that has its origins in the postwar period and the prioritisation of stochastic cancer risk in radiological protection frameworks. It does not reflect the current state of the peer-reviewed literature, which documents ...
Attachment Included
REGULATORY ADMISSIONS OF SCIENTIFIC INSUFFICIENCY: WHY THE CNSC FRAMEWORK CANNOT SUPPORT A DEFINITIVE SAFETY DETERMINATION FOR NEW NUCLEAR PROJECTS Independent Anonymous Researcher 1.. Background Nuclear project licensing in Canada requires the Canadian Nuclear Safety Commission (CNSC) to determine that a proposed facility will not pose an unreasonable risk to the health and safety of persons and the environment. This determination relies on dose models, epidemiological studies, and health effect estimates that the CNSC presents to the public, to interveners, and to the Impact Assessment Agency of Canada as conclusions supported by the weight of scientific evidence. This paper does not argue that nuclear power is unsafe. It argues something more precise: that the CNSC's own published documents contain explicit admissions that the scientific foundations of its safety determinations are inadequate for the purpose for which they are used. These admissions ...
Attachment Included
SELECTIVE EVIDENCE AND THE UNFOUNDED DECLARATION: HOW THE CNSC’S CHILDHOOD LEUKEMIA ASSESSMENT DIVERGES FROM THE INTERNATIONAL SCIENTIFIC RECORD AND WHY THE KiKK FACT SHEET MUST BE REVISED Independent Anonymous Researcher 1.. Background In 2007–2008, a German government-commissioned case-control study known as the KiKK study reported a statistically significant doubling of leukemia incidence in children under five years of age living within 5 km of German nuclear power plants (NPPs) [1]. The study used the gold-standard case-control methodology, covered all 16 German NPP sites over 23 years, and its primary finding — an odds ratio of 2.19 for leukemia within 5 km — was confirmed by the study’s own follow-up analysis across all 16 sites individually [2]. The KiKK study produced a substantial international scientific response. Regulatory bodies in Germany, the United Kingdom, France, and through the WHO each reviewed the evidence and each reached a position ...
Attachment Included
TRITIUM HEALTH RISK ASSESSMENT IN HEAVY-WATER REACTOR DEPLOYMENT: DOCUMENTED DEFICIENCIES IN THE CNSC REGULATORY FRAMEWORK AND IMPLICATIONS FOR MONARK LICENSING Independent Anonymous Researcher 1.. Background Canada's investment of $304 million in the MONARK next-generation CANDU reactor design, announced March 2025, positions heavy-water reactor technology as a cornerstone of Canada's decarbonisation strategy [1]. The MONARK design retains the Canadian Deuterium Uranium (CANDU) heavy-water moderation system, which is the highest tritium-producing civilian reactor design in commercial operation. Tritium output from CANDU reactors is characteristically one to two orders of magnitude greater than pressurised-water reactors of equivalent thermal output [2]. The Canadian Nuclear Safety Commission (CNSC) regulates tritium releases and sets health- based limits under the authority of the Nuclear Safety and Control Act. As Canada moves toward MONARK deployment, ...
Attachment Included
POPULATION MIXING AS AN UNASSESSED PRE-CONSTRUCTION CANCER RISK: THE KINLEN HYPOTHESIS, CANDU RURAL SITING, AND THE ABSENCE OF A LICENSING REQUIREMENT Independent Anonymous Researcher 1.. Background The most persistent unresolved question in nuclear epidemiology is why childhood leukemia rates are elevated near nuclear power plants (NPPs) at a magnitude that exceeds what current dose models predict from measured radiation releases. Two hypotheses have dominated the literature for four decades: a radiation causation hypothesis, in which the signal reflects unmodelled or underweighted radiation exposure; and the Kinlen population mixing hypothesis, in which the signal reflects an infectious leukemogenic agent triggered by the influx of a large mobile workforce into a small, geographically isolated, immunologically naive resident population. The CNSC’s own KiKK fact sheet identifies population mixing as “the most likely explanation” for the observed childhood ...
Attachment Included
Page 1 of 84 WHY THE IAAC CANNOT APPROVE THIS PROJECT Thirteen Independent Show Stoppers A Formal Submission to the Impact Assessment Agency of Canada Why the IAAC Cannot Approve This Project This submission identifies thirteen independent show stoppers to the approval of the Energy Alberta nuclear facility in the Peace River region. Each show stopper is fatal to the application on its own. The IAAC does not need to find all thirteen persuasive — or even six, or three. Any single one of the thirteen, properly applied to the statutory obligations of the Impact Assessment Act, is sufficient grounds to refuse approval. Together they form a closed logical structure from which there is no exit within the current state of knowledge or the current regulatory architecture. The thirteen show stoppers fall into three categories. The first six concern the evidence — what the science actually shows, why the models fail, and why the studies the CNSC cites as proof ...

Attachment Complaint: Beyond Cancer

Peace River Nuclear Power Project
Author: Administrator on behalf of Chris
Reference Number: 595
Submitted: 2026-03-11 - 3:20 PM
Project Phase: Planning
Participation Notice: N/A
See the attached submission / Veuillez consulter la pièce jointe
Attachment Included
The Clerk Standing Committee on Natural Resources (RNNR) House of Commons Ottawa, Ontario K1A 0A6 rnnr@parl.gc.ca Re: Formal Complaint — Health Impact Assessments for CANDU Nuclear Facilities Assess Cancer and Nothing Else: the Statutory Mandate Requires More, and the Energy Alberta Peace River Project (IAAC File 89430) Is Being Reviewed on an Assessment That Covers One of Seven Documented Health Endpoint Categories I write to bring to the Committee's attention a structural deficiency in the health impact assessment framework applicable to CANDU nuclear facilities in Canada: these assessments evaluate cancer risk as the primary, and in practice sole, quantitative health endpoint. They do not assess cardiovascular disease, neurological and neurodevelopmental effects, immune system dysregulation, ophthalmic effects, adverse reproductive and developmental outcomes, or the synergistic interaction effects of radiation and chemical co-exposures. Each of these six ...

Attachment Peace Nuclear Plant - IAAC cannot approve project

Peace River Nuclear Power Project
Author: Administrator on behalf of Chris
Reference Number: 606
Submitted: 2026-03-11 - 1:06 PM
Project Phase: Planning
Participation Notice: N/A
See the attached submission / Veuillez consulter la pièce jointe
Attachment Included
IAAC COMPLAINT ADDITIONS Energy Alberta Peace River Nuclear Power Project SS 14 The HIA Scope Defect: A Cancer Risk Assessment Labelled as a Health Impact Assessment Source: G4SR6 Paper 1 (Non-Oncological Health Endpoints Excluded from CANDU HIAs) INSERT AFTER SS13 — insert SS14 as the next full show stopper in Part Three: The Law SS14 is a statutory scope argument. It does not require acceptance of any epidemiological finding in SS1–SS13. The Argument Health impact assessments for CANDU nuclear facilities in Canada evaluate cancer risk as the primary, and in practice the sole, quantitative health endpoint. Dose calculations are performed for routine radionuclide releases, incremental cancer risk is computed using the LNT model, and the resulting figure — typically expressed as a fraction of background cancer risk — is used to conclude that routine releases do not pose an unreasonable health hazard. The structure reflects the historical ...

Attachment Reasons Germany Aborted Nuclear

Peace River Nuclear Power Project
Author: Administrator on behalf of Chris
Reference Number: 594
Submitted: 2026-03-11 - 1:03 PM
Project Phase: Planning
Participation Notice: N/A
See the attached submission / Veuillez consulter la pièce jointe
Attachment Included
WHY GERMANY CLOSED ITS NUCLEAR POWER PLANTS A Complete Assessment: Technical, Scientific, Regulatory and Legal Reasons Central thesis: Operators could not discharge the burden of demonstrating that the facilities were safe for the public March 2026 Reading guide: This document proceeds from the central legal thesis (operators could not demonstrate public safety) through the three compound grounds on which that burden failed: waste, health signal, and dose model. Each section documents the technical, scientific, regulatory and legal dimension of that ground. The document concludes with the direct application to the Energy Alberta IAAC proceeding. THE CENTRAL THESIS The operator burden of proof — and why it could not be discharged Germany's nuclear phase-out is frequently mischaracterised as a political decision driven by public anxiety after Fukushima. The technical, scientific, regulatory and legal record establishes something more precise and more ...
Attachment Included
The Clerk Standing Committee on Natural Resources (RNNR) House of Commons Ottawa, Ontario K1A 0A6 rnnr@parl.gc.ca Re: Formal Complaint — The CNSC's Use of the Word "Unfounded" to Prevent the Independent Application of the Precautionary Principle by the Impact Assessment Agency of Canada in Relation to the Energy Alberta Peace River Nuclear Power Project (IAAC File 89430) I write to bring to the Committee's attention what I submit is a matter of constitutional and statutory significance: the Canadian Nuclear Safety Commission (CNSC) has issued a public document characterising the international epidemiological signal of excess childhood leukemia near nuclear power plants as "unfounded." This characterisation, I will demonstrate, is not a scientific conclusion — it is a legal instrument. Its function is to prevent the mandatory precautionary obligation in section 6 of the Impact Assessment Act (IAA) from being independently applied by the Impact Assessment ...

Attachment Guidelines request - Adverse Health Effects

Peace River Nuclear Power Project
Author: Administrator on behalf of Chris
Reference Number: 585
Submitted: 2026-03-10 - 8:50 PM
Project Phase: Planning
Participation Notice: N/A
See the attached submission / Veuillez consulter la pièce jointe
Attachment Included
1 From: Sent: Tuesday, March 10, 2026 8:50 PM To: Peace River Nuclear Power Project (IAAC/AEIC) Cc: info@energyalberta.com Subject: Guidelines request - Adverse Health Effects Hallo Joe Please add to the Guidelines that Energy Alberta must satisfy the Review Panel that the adverse health e ects are in the public interest. This will require them to identify all the adverse health e ects and give each a quantum estimate. Please publish this request. Under IAA s.63, the Minister cannot approve a designated project if the Review Panel is not satisfied that the adverse e ects are in the public interest. The satisfaction standard under s.63 is not "adequate provision" — it is a broader public interest weighing that explicitly includes health e ects, Indigenous rights, and cumulative e ects. Hallo Energy Alberta Please advise whether you accept this obligation and further accept that the cost-qualification cannot discharge this obligation? Regards Chris <email ...

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Date modified:: 2019-03-01

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