Critical Review: Fish Habitat and Water Quality
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 19.2.3.7 of the Initial Project Description, the Nuclear Waste Management Organization (NWMO) outlines potential impacts on fish and fish habitat resulting from site clearing, blasting, construction, and water withdrawal. The proponent acknowledges that without intervention, these activities could lead to moderate or high adverse effects. However, the proposal claims that by implementing standard environmental design features—such as adhering to Fisheries and Oceans Canada (DFO) timing windows and using fish-friendly intake designs—the residual effects will be reduced to a “negligible” degree and a “low” overall risk.
Underlying Assumptions
Our analysis of the text identifies several key assumptions relied upon by the proponent to reach their conclusion of low risk:
- Assumption of Mitigation Efficacy: The text assumes that standard industry mitigation strategies are inherently sufficient to reduce impacts to negligible levels, despite the specific complexities of the local ecosystem.
- Geochemical Safety: The assessment assumes that because the excavated rock is “non-acid generating,” groundwater seepage poses no risk to fish health, potentially overlooking other contaminants like heavy metals or blasting residues.
- Qualitative Sufficiency: The document assumes that subjective terms like “negligible” are adequate for describing environmental loss without providing specific biological metrics or thresholds.
Community Assessment
Through our review, we have identified significant gaps in the current assessment that require attention. A primary concern is the use of the term “negligible” to describe residual effects without a clear, quantitative definition. Without measurable thresholds for habitat loss or water quality changes, it is difficult for the community to verify the “low risk” designation objectively.
Furthermore, we observed a contradiction in the proponent’s narrative. While they assert a “high level of certainty” in the effectiveness of their mitigation measures, they simultaneously assign a “moderate likelihood” to residual effects occurring. This suggests that the mitigation measures may not be as foolproof as implied.
Finally, while the text links fish habitat to Indigenous health and traditional land use, there is a lack of evidence showing how Indigenous Knowledge informed the risk screening. Different communities may have different thresholds for what constitutes a “negligible” impact on a traditional food source.
Path Forward
To address these concerns, we recommend the following corrective measures be integrated into the planning process:
- Define Impact Metrics: The proponent must provide clear, quantitative definitions for “negligible,” “low,” and “moderate” impact degrees based on measurable biological indicators.
- Expanded Testing: Comprehensive leachate testing must be conducted for a broader range of potential contaminants beyond just acid-generating potential to ensure groundwater safety.
- Community-Led Monitoring: The NWMO should develop a formal Community-Led Environmental Monitoring Program that integrates Indigenous Knowledge alongside Western science, ensuring local communities are directly involved in verifying fish health and water quality.
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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