Analysis of Section 19.2.3.9: Ecological Impacts on Avian Populations
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 the Initial Project Description, the Nuclear Waste Management Organization (NWMO) outlines the baseline conditions for bird populations within the project area. Their surveys identified a diverse range of avian life, including 64 upland breeding species, shorebirds, waterbirds, and raptors. Notably, eight Species at Risk (SAR) were observed, including the Barn Swallow, Canada Warbler, and Eastern Whip-poor-will.
The proponent acknowledges that project activities—such as site clearing, blasting, and the construction of infrastructure—have the potential to cause moderate to high adverse effects on these populations. However, the proposal claims that by implementing standard environmental design features and mitigation measures (such as timing vegetation clearing to avoid nesting periods and establishing buffer zones), the residual adverse effects will be reduced to a "negligible" level. The assessment concludes that the risk to self-sustaining bird populations is low.
Underlying Assumptions
Our review of the technical submission has identified several key assumptions that support the proponent’s conclusion of "low risk." These include:
- Universality of Mitigation: The assumption that standard industry best practices are equally effective for all species, including highly sensitive Species at Risk like the Eastern Whip-poor-will.
- Habitat Availability: The implicit assumption that displaced birds will successfully relocate to adjacent habitats without causing overcrowding or increased mortality rates.
- Regulatory Sufficiency: The assumption that compliance with the Migratory Birds Convention Act and Species at Risk Act automatically equates to the preservation of local ecological integrity.
- ALARA Application: The assumption that the "As Low As Reasonably Achievable" (ALARA) principle, typically used for radiation safety, is an appropriate metric for managing ecological stressors like noise and light pollution.
Community Assessment
Through our engagement with the ECO-STAR North project and community consultation, we have identified specific gaps in the current assessment that require attention. The primary concern is the lack of quantitative data regarding habitat loss. While the proponent lists the species present, the document does not specify the exact acreage or hectares of specific habitat types (e.g., wetlands vs. upland forest) that will be permanently removed or altered. Without this baseline data, it is scientifically difficult to validate the claim that the impact is "negligible."
Furthermore, the assessment relies heavily on general industry experience rather than species-specific evidence. For Species at Risk, generic buffer zones may not be sufficient to prevent population decline. There is also a noted gap in the integration of Indigenous Traditional Knowledge (ITK). The current documentation does not clearly demonstrate how local Indigenous knowledge regarding bird migration patterns and culturally significant species has been utilized to inform the baseline or the proposed mitigation strategies.
Path Forward
To ensure the protection of our local avian biodiversity, we recommend the following corrective measures be addressed in future phases of the impact assessment:
- Quantitative Habitat Assessment: The proponent must provide a detailed breakdown of habitat loss by type and area (hectares) to allow for a transparent review of the scale of impact.
- Species-Specific Analysis: A displacement analysis should be conducted for identified Species at Risk to evaluate whether surrounding habitats can truly support displaced individuals.
- Integration of ITK: Formal consultation with local Indigenous communities is necessary to identify culturally significant bird species and refine mitigation plans based on traditional ecological knowledge.
- Defined Trigger Thresholds: The monitoring program requires specific, measurable thresholds that, if exceeded, trigger immediate adaptive management actions beyond standard best practices.
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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