Peace River First Nations Initial Comments on PRPP Siting Matters

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 siting decisions made at this early, critical, and strategic phase of the Project’s development. The Nations have made the case that more can and should be done through a collaborative approach to address these issues while there is still time, space, and opportunity to do so.

We appreciate the opportunity to have met with you to better understand your agencies’ approach to siting matters and to obtain initial information. As noted by your colleagues, siting is a complex matter, and the assessment of siting options, analysis, and decisions can ultimately play a determinative role in where the Project is located and in the range of effects and impacts that flow from that decision.

We look forward to ongoing engagement with your agencies and remain hopeful that the Nations will be able to establish reasonable and substantive engagement and capacity work plans. This support will be necessary if the Nations are to keep pace with this complex and demanding regulatory process and to meaningfully understand and respond to the significant volume of technical and policy information being generated by the proponent and your agencies.

This is an unprecedented 'greenfield' nuclear project. It is the first new 'greenfield' nuclear project proposed in modern Canadian history, and the first of its kind to be proposed in northwestern Alberta within a boreal forest landscape that was, and is actively used and relied upon by the Peace River Nations for the exercise of their rights, the practice of their culture, and the maintenance of their traditional way of life. This major project is being proposed in a landscape of vital importance to all of these Nations: the Peace River valley, the Peace River corridor, and the Peace River itself.

With thanks,

Matt General
Technical Representative to Duncan’s First Nation
Supporting Coordinator to the Peace River First Nations (via JFK Law)