Reviewing Section 19.2.3.10: Terrestrial Wildlife and Wildlife Habitat
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 potential impacts of the Deep Geological Repository (DGR) on terrestrial wildlife. The assessment identifies several species present or potentially present in the project vicinity, including moose, various carnivores, and notably, five bat species designated as provincially endangered. The proponent acknowledges that project activities—such as site clearing, blasting, and construction—have the potential to cause moderate to high adverse effects on these populations if left unmanaged.
However, the proposal claims that by implementing standard environmental design features, buffer zones, and adhering to regulatory requirements like the Species at Risk Act (SARA), the residual risks will be reduced to “negligible.” The NWMO asserts that these mitigation strategies are well-established and sufficient to protect wildlife habitat availability and survival.
Underlying Assumptions
Our review of the technical submission identified several key assumptions that support the proponent’s conclusion of “low risk”:
- Sufficiency of General Mitigation: The assessment assumes that general industry “best management practices” are sufficient to protect specific endangered species without detailing site-specific interventions.
- Low Density Equates to Low Impact: It is assumed that because wide-ranging carnivores (like wolverine and cougar) currently have low population densities or are distant, the project will not significantly impact their regional connectivity or habitat fragmentation.
- ALARA Applicability: The proponent assumes that the ALARA (As Low As Reasonably Achievable) principle, typically used for radiation, is an adequate metric for managing sensory disturbances like noise and light for wildlife.
- Predictability of Residual Effects: There is an assumption that the transition from a potential “high adverse effect” to a “negligible residual effect” is guaranteed solely through regulatory compliance.
Community Assessment
Through our engagement with the ECO-STAR North community and technical review, we have identified concerns regarding the gap between the identified risks and the proposed solutions. A primary concern is the lack of species-specific mitigation for the five endangered bat species identified on-site. While the proponent suggests buffer zones, the unique roosting and foraging requirements of these species require detailed, proactive management plans rather than generic avoidance strategies.
Furthermore, the community notes that the dismissal of impacts on wide-ranging carnivores ignores the broader ecological context. Even if current numbers are low, the DGR site could serve as a critical future corridor; fragmenting this habitat could have long-term regional consequences. Finally, the technical review highlights that the claim of “negligible” residual effects is not currently supported by quantitative modeling or case studies from similar projects. Without specific thresholds for noise and light disturbance, it is difficult for the community to verify whether mitigation measures are actually working.
Path Forward
To address these findings, we recommend the following corrective measures be integrated into the planning process:
- Comprehensive SAR Management Plan: The proponent must develop a detailed plan for Species at Risk, specifically for bats, including quantified habitat offset ratios and the installation of maternity roosting structures.
- Defined Quantitative Thresholds: To improve transparency, the proponent should define specific metrics for what constitutes “negligible,” “low,” and “moderate” effects, rather than relying on qualitative descriptors.
- Independent Monitoring: A long-term, peer-reviewed monitoring program should be established. This program must utilize baseline data to trigger pre-defined adaptive management actions if wildlife population indicators deviate from predictions.
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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