Comments on DGR proposal

Timelines for assessment inconsistent with scope of project

An inadequate period of time for review and comment for this lenghthy and complex document has been provided.  It should be extended at least 6 months, giving interested parties time to adequately review and discuss before making comments.  Expecially since the early phase of consideration has a potential to set in motion later actions.  Democracy and  citizen participation will require more time.

Transportation needs to be assessed

The proposal does not include a review of the transpsortation plan.  This is a major part of the proposed project that will impact a large number of Canadians, has potential climate impacts, health impacts, and is an essential part of the safety analysis of the project.  By not including it the proposal is not consistent with the need to protect the public which has to be analyzed.

Health Section

The health section does not include a discussion of mental health or mental health impact, but given the short time allowed for review, maybe I missed such a discussion.  In any circumstances, the management and possible accidents associated with dangerous nuclear waste, and its trasnsportation, has the potential to create considerable stress and trauma, which could lead to considerable issues regarding PTSD in populations near the site and in Ignous, as well as in populations in the entire watershed affected by the site.  Such mental health impacts can be very harmful to the democratic process and to the economy if they are widespread.  The potential for radiation contamination to become widespread through transportation accidents or failure at the repository sight mandates a consideration of the mental health impacts of potential accidents or failures.  In addition, the health section does outline some of the current issues facing the populations in the region of the repository, but again, I did not see any analysis of how a boom (and eventually bust) economic change in the region will affect mental health. 

 Final toughts

This document seems to make a number of assumptions  or statements about the need for the repository that do not appear to be based in fact.  For instance, many statments about the positive impact on climate change, or at least the projects necessity as a part of an overall climate change policy, seems to lack consistency and adequate evaluation of what a feasible climate change policy would be.  Making the claim is, therefore, calls into question the relevancy of the project.

The projects value to a policy of continued nuclear power generation is also made with the assumption that such a gnereation is necessary.  That is a highly arguable assumption, and the growth of renewables is making it even more inconsistant with a safe and low emissions policy.