Reviewing Section 19.2.3.11: Non-Indigenous Health Conditions
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 assessment of Non-Indigenous Health Conditions, the Nuclear Waste Management Organization (NWMO) proposes a distinction between direct and indirect health effects. The proponent asserts that direct human health effects (such as radiation exposure) will be managed exclusively through the Nuclear Safety and Control Act (NSCA) licensing process, rather than the Impact Assessment Act (IAA). Consequently, they do not anticipate deep evaluation of these direct effects within the current IAA framework.
However, the proposal acknowledges that the project could indirectly impact health through environmental changes (air quality, noise) and social conditions. Specifically, the Initial Project Description notes that the influx of a temporary workforce and increased disposable income could exacerbate social determinants of health, including substance abuse and domestic violence. Despite these potential moderate-to-high adverse effects, the proponent concludes that with the implementation of a corporate Code of Conduct and employee assistance programs, the residual risk to the community will be "negligible."
Underlying Assumptions
Our analysis identified several key assumptions within the proponent’s text regarding health and safety:
- Regulatory Separation: It is assumed that excluding direct health effects from the IAA in favor of the NSCA process will not hinder the public’s holistic understanding of project risks.
- Internal Controls vs. Public Safety: The text assumes that internal corporate policies (such as a Code of Conduct) are sufficient mechanisms to prevent social issues like gender-based violence or substance abuse from spilling over into the broader community.
- Service Capacity: There is an assumption that existing local services can handle potential strains, or that internal employee programs will sufficiently mitigate the need for external community support.
- Economic Trade-offs: The proponent assumes that while short-term income spikes may lead to poor health decisions, long-term employment will ultimately improve health outcomes.
Community Assessment
Our review highlights a significant gap in the assessment of community well-being. By deferring direct health effects to the NSCA, the process risks fragmenting the assessment, making it difficult for the community to see the full picture of health impacts. Of particular concern is the reliance on internal mitigation measures to address broader social risks.
The proponent acknowledges that local addiction and mental health services are already limited. However, the current plan relies heavily on internal employee assistance programs rather than proposing concrete investments to bolster public resources. Furthermore, relying on a corporate Code of Conduct to manage the behavior of a large, transient workforce is viewed as an inadequate safeguard for vulnerable populations in the region. Without specific data or binding agreements, the claim that risks to social determinants of health are "negligible" appears unsubstantiated.
Path Forward
To address these deficiencies, we recommend the following corrective measures:
- Integrated Health Assessment: The proponent should bridge the gap between the NSCA and IAA to provide a single, comprehensive health impact assessment for public review.
- Capacity Building: Instead of relying solely on internal programs, the NWMO must commit to formal funding or augmentation of local mental health, addiction, and social services to address the acknowledged service gaps.
- Concrete Safety Agreements: The project requires specific, measurable agreements with local law enforcement and social service providers to monitor and respond to potential increases in gender-based violence and substance abuse, rather than relying on internal administrative policies.
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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