Reviewing Greenhouse Gas Estimates and Net-Zero Alignment
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 22 of the Initial Project Description, the Nuclear Waste Management Organization (NWMO) outlines a preliminary assessment of Greenhouse Gas (GHG) emissions for the proposed project. The assessment currently focuses on Scope 1 (direct emissions) and Scope 2 (indirect electricity emissions).
The proposal estimates maximum annual emissions of 14,480 tonnes of CO2 equivalent during construction and 10,834 tonnes during operations. Notably, the assessment identifies that the vast majority of these emissions—88% during construction and 95% during operations—will stem from the heating plant, which is proposed to run on propane and natural gas. The proponent frames the project as a critical component of Canada’s transition to a low-carbon future by supporting the nuclear energy cycle.
Underlying Assumptions
Our review of the provided text identifies several key assumptions made by the proponent regarding the calculation and management of the project’s carbon footprint:
- Scope Limitation: It is assumed that Scope 3 emissions (indirect emissions occurring in the value chain) are not currently relevant enough to include in the preliminary estimate, despite the massive material requirements of the project.
- Heating Standards: The proposal assumes that fossil-fuel-based heating (propane and natural gas) is the standard or necessary choice for the facility, rather than low-carbon alternatives.
- Net-Zero Alignment: There is an assumption that the project inherently supports net-zero goals solely by virtue of managing nuclear waste, regardless of the facility’s own operational carbon intensity.
Community Assessment
Through our engagement process, community members and technical reviewers have identified significant gaps in the current GHG assessment. The primary concern is the omission of Scope 3 emissions. For a major infrastructure project involving deep geological excavation, the “embodied carbon” found in the lifecycle of construction materials—specifically cement and steel—is substantial. By excluding these figures, the current assessment likely underestimates the total carbon footprint of the repository.
Furthermore, there is a noted contradiction in the project’s narrative. While the DGR is presented as a pillar of a low-carbon future, the facility itself relies heavily on the combustion of fossil fuels for heating. With heating accounting for up to 95% of operational emissions, the choice to use propane and natural gas rather than clean technologies appears inconsistent with the project’s stated environmental goals.
Path Forward
To ensure the project aligns with federal net-zero targets and community expectations for environmental stewardship, we recommend the following corrective measures:
- Expand the Assessment: The proponent must include a preliminary analysis of Scope 3 emissions, specifically focusing on the lifecycle impacts of carbon-intensive materials like cement and steel.
- Evaluate Alternatives: Given that heating is the primary source of emissions, the proponent should provide a detailed justification for fossil-fuel systems and rigorously evaluate low-carbon alternatives, such as industrial heat pumps or geothermal systems.
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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