Reviewing Section 14.7: Vegetation, Riparian, and Wetland Environments
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
In Section 14.7 of the Initial Project Description, the Nuclear Waste Management Organization (NWMO) outlines the baseline data collected in 2022 regarding the vegetation, riparian, and wetland environments at the proposed Revell site. Utilizing a combination of desk-based research, Aquatic Habitat Mapping (AHM), and environmental DNA (eDNA) metabarcoding, the proponent has characterized the site as primarily upland conifer forest (77%) with significant wetland coverage (17%). Notably, the preliminary data identified the presence of culturally significant species such as wild rice and medicinal plants. Most significantly, eDNA studies detected the potential presence of the American eel, a species listed as Endangered under the Ontario Endangered Species Act, despite the location being outside its expected range. The proponent suggests that while further study is planned, current data is sufficient to support early risk-informed assessments.
Underlying Assumptions
Our analysis of the proposal identifies several key assumptions that influence the proponent’s conclusions regarding environmental impact:
- Sufficiency of Short-Term Data: The text assumes that a single year of baseline data (2022) is adequate to form early conclusions about the likelihood and significance of potential impacts, despite natural inter-annual variability.
- Regional vs. Local Value: The document implies that because wetlands are abundant in the broader Northern Ontario region, the loss or degradation of wetlands within the specific project site (17% of the land area) is not critical.
- Ambiguity of eDNA Results: There is an assumption that the detection of the American eel via eDNA can be categorized as ‘potential’ or ‘unanticipated’ without necessitating immediate, urgent physical verification protocols in the initial description.
Community Assessment
The community review highlights significant concerns regarding the interpretation of the baseline data. The detection of the American eel is a critical finding; leaving this as a ‘potential’ occurrence without immediate physical verification creates regulatory uncertainty, as the presence of an endangered species would trigger stringent protection requirements that could fundamentally alter project feasibility. Furthermore, the narrative that wetland loss is acceptable due to regional abundance minimizes the local ecological function of the specific wetlands on site—a perspective that risks a ‘death by a thousand cuts’ scenario for local biodiversity. Finally, while wild rice and medicinal plants were identified, the current assessment lacks a detailed understanding of their specific cultural use, potentially infringing on Indigenous rights if these resources are damaged.
Path Forward
To address these gaps, we recommend the following corrective measures be adopted in the detailed impact assessment phase:
- Physical Verification of Endangered Species: The proponent must conduct targeted physical netting or trapping surveys to confirm the presence of the American eel. Relying solely on eDNA is insufficient given the legal and ecological implications of this endangered species.
- Multi-Year Baselines: A commitment to at least three years of field data is necessary to account for seasonal and annual variations in vegetation and aquatic health.
- Collaborative Cultural Mapping: Beyond desk-based identification, a formal Traditional Land and Resource Use (TLRU) study must be co-developed with Indigenous rights holders to map the frequency and cultural value of wild rice and medicinal plants, ensuring specific management plans are in place.
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.
About the Author
