Reviewing Section 15.8: Non-Indigenous Land and Resource Use
This article is part of a series exploring the views and perspectives of youth, artists and community members working with the Melgund Integrated Nuclear Impact Assessment Project. This initiative is a climate entrepreneurship and arts-based community recreation program, developed through community consultation, engagement participation in the integrated impact assessment process for the NWMO’s proposed Deep Geological Repository for nuclear waste fuel.
What is Proposed
The Nuclear Waste Management Organization (NWMO) has outlined the baseline data for non-Indigenous land and resource use within the proposed 342-hectare Project site in northwestern Ontario. The site is located on provincial Crown land that has been previously disturbed by forestry activities. According to the Initial Project Description, the NWMO characterizes the current land use activity as "minimal." While the proponent acknowledges overlaps with specific traplines, bait harvest areas, and bear management zones, they conclude that the project generally does not interfere with community use. Furthermore, the NWMO states that a desktop-based Stage 1 archaeological assessment has been completed with no sites found, and explicitly notes that no further non-Indigenous land-use baseline data collection is planned.
Underlying Assumptions
Our review of the provided text identifies several critical assumptions guiding the proponent’s current approach:
- Sufficiency of Desktop Data: The assessment assumes that a desktop review (Stage 1) of the Ontario Archaeological Sites Database is sufficient to rule out the presence of cultural or historical sites, without the need for physical field verification.
- Qualitative Characterization: The proponent assumes that labeling land use as "minimal" is an adequate baseline description without requiring quantitative data on the frequency of use or economic value.
- Static Data Needs: There is an assumption that the current baseline data is complete, justifying the decision to cease further non-Indigenous land-use data collection.
- Informal Access: The assessment assumes that "unofficial" trail systems (forestry roads used for snowmobiling and ATVs) do not require a formal management or mitigation plan at this stage.
Community Assessment
Through our engagement process, we have identified specific concerns regarding the methodology and conclusions presented in Section 15.8. A primary observation is the absence of field-based (Stage 2) archaeological assessments. Relying solely on database records for a remote region is a significant risk; unrecorded historical sites could be accidentally destroyed during construction if not physically verified. This matters deeply to the community’s stewardship of local history.
Furthermore, the characterization of land use as "minimal" is subjective. Without quantitative data on trapline yields, bait harvest economic metrics, or trail usage frequency, this language risks alienating local stakeholders who rely on these lands for their livelihood and lifestyle. The lack of a formal plan for the "unofficial" forestry road trail system is also a social concern, as the disruption of these routes affects community cohesion and the quality of life for residents who use them to connect between communities like Ignace and Dryden.
Path Forward
To ensure a robust and respectful impact assessment, the following corrective measures are recommended:
- Mandate Field Surveys: The proponent should reconsider its decision to forgo additional data collection and conduct a Stage 2 archaeological assessment involving physical field surveys across the 342-hectare site.
- Quantitative Study: A quantitative socio-economic impact study should be performed regarding the specific traplines (DR024, IG033) and bait harvest areas affected, rather than relying on qualitative descriptions.
- Access Management Plan: A formal Access Management Plan should be developed in consultation with local snowmobile and ATV clubs to address the displacement of activities and ensure continued connectivity.
About the Integrated Assessment Process
The federal Impact Assessment Agency of Canada (IAAC) has formally launched the integrated impact assessment process for the proposed Deep Geological Repository (DGR) for Canada’s Used Nuclear Fuel Project, a major national infrastructure initiative led by the Nuclear Waste Management Organization (NWMO).
The proposed underground repository is designed to permanently contain and isolate used nuclear fuel in a secure geological formation. Wabigoon Lake Ojibway Nation and the Township of Ignace have been selected as host communities for the project. The site is located approximately 21 kilometres southeast of Wabigoon Lake Ojibway Nation and 43 kilometres northwest of Ignace, Ontario, near Highway 17.
According to project materials, the repository would provide permanent storage for approximately 5.9 million bundles of used nuclear fuel. The full lifecycle of the project is expected to span roughly 160 years, including site preparation, construction, operations, closure, and long-term monitoring.
Integrated Federal Review
Major nuclear projects in Canada are subject to an integrated assessment process jointly led by the Impact Assessment Agency of Canada and the Canadian Nuclear Safety Commission (CNSC). This “one project, one review” approach is intended to streamline regulatory oversight while ensuring rigorous evaluation of environmental, health, social, economic, and Indigenous rights impacts.
Under this framework, IAAC oversees the impact assessment requirements under the Impact Assessment Act, while the CNSC regulates nuclear safety under the Nuclear Safety and Control Act. The CNSC will issue the initial site preparation licence and manage all subsequent nuclear licensing for the project’s duration.
The integrated assessment also includes a focus on potential impacts on Indigenous Peoples, including rights, land use, cultural practices, health, and socio-economic conditions. Where potential adverse effects are identified, the process is intended to identify mitigation measures to reduce or avoid harm.
Public Comment Period Now Open
The first public comment period for the project is currently open and will run until February 4, 2026. During this phase, the public is invited to provide feedback on the Summary of the Initial Project Description submitted by the NWMO. Submissions received during this period will inform IAAC’s summary of issues, which will guide the next stages of the impact assessment. All comments submitted become part of the public project record and are posted to the federal Impact Assessment Registry.
This plain-language summary is provided by ECO-STAR North and Art Borups Corners to support public engagement.
Disclaimer: The views and perspectives expressed in this article are solely those of the independent arts program led by ECO-STAR North and Art Borups Corners. They do not reflect the official positions of the Nuclear Waste Management Organization (NWMO) or the Government of Canada.
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