Examining Federal Lands and Cross-Border Environmental Impacts
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 20 of the Initial Project Description, the proponent asserts that the project will not affect federal lands, noting that the site will transition from provincial Crown land to private ownership under the Nuclear Waste Management Organization (NWMO). Furthermore, the text states that no environmental changes are expected outside of Ontario or Canada. This conclusion is primarily justified by the project’s geographic location—specifically, its distance of over 210 km from the Manitoba border and 140 km from the United States border. The proponent indicates that future modeling will confirm these assertions.
Underlying Assumptions
- That linear distance (kilometers) is a sufficient proxy for safety without immediate scientific pathway analysis.
- That the absence of designated “Reserve lands” equates to an absence of Indigenous interests, Traditional Territories, or Treaty rights in the area.
- That transboundary impacts can be definitively ruled out before the completion of comprehensive environmental modeling.
- That physical environmental changes are the only relevant transboundary risks, potentially overlooking socio-economic perceptions of risk in neighboring jurisdictions.
Community Assessment
Our review identifies a critical gap in the reliance on linear distance rather than hydrogeological or atmospheric pathway analysis. Simply stating the project is 140 km from a border does not account for complex water systems or air currents that could potentially transport contaminants. Furthermore, the language used—stating impacts “will not” occur—appears to pre-judge the outcome of the ongoing Impact Assessment modeling, which can signal bias to regulators and the public.
From a community and cultural perspective, the narrow definition of “Reserve lands” fails to recognize Traditional Territories that often transcend provincial and national borders. Ignoring these broader rights could lead to significant legal and social challenges, as Indigenous land use is not confined to administrative boundaries.
Path Forward
To ensure a rigorous and transparent process, we recommend the proponent replace definitive statements with conditional language (e.g., “is not expected to”) until modeling is complete. A preliminary conceptual model is required to scientifically justify why specific distances act as sufficient buffers against transboundary risks.
Crucially, the assessment scope must expand beyond administrative Reserve boundaries to include Traditional Territories and Treaty rights. Finally, a transparent plan for validating results with neighboring jurisdictions—specifically Manitoba and the United States—is necessary to address distal environmental and socio-economic concerns effectively.
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
