Transportation Is the Project! Exclusion of Transportation from the DGR Impact Assessment is Unacceptable.

To the Impact Assessment Agency of Canada,

We are writing to express serious concern regarding the transportation of high-level radioactive waste associated with the proposed Revell Deep Geological Repository (DGR), and the absolutely unacceptable exclusion of transportation risks from the formal scope of the Impact Assessment. Transportation impacts and risks must never be decoupled or excluded from the Impact Assessment process and a full impact assessment of transportation must be included and publicly studied.

The Government of Canada must not allow the proponent to proceed without the inclusion of transportation in the IA.

The logistics of moving high-level nuclear waste from Southern Ontario to the proposed site have generated substantial opposition from Canadians across the spectrum, particularly with respect to the suitability of Highway 17 and Highway 11 as primary transport corridors. These routes are frequently cited by community members as hazardous, with regular closures due to severe winter weather, ice, whiteout conditions, and limited visibility. Much of this infrastructure consists of narrow two-lane highways with limited shoulders, constrained rock cuts, and long stretches without safe pull-off areas. Commenters have consistently identified these conditions as incompatible with the proposed volume of heavy transport—estimated at two to three shipments per day for multiple decades.

Wildlife collisions, especially involving moose, were repeatedly described as a statistical inevitability over the operational lifespan of the project. Given the known risks of serious accidents on these highways, the long-term probability of a significant incident cannot reasonably be dismissed.

Safety concerns related to the transport of radioactive materials have been frequently characterized as a potential “mobile Chernobyl” scenario. Many submissions from Canadians are expressing deep apprehension that a derailment or trucking accident could result in a radiological release with severe environmental and social consequences. In particular, there is widespread concern about potential contamination of the Lake Superior watershed and the possibility that a major accident could sever the Trans-Canada Highway, isolating northern communities and disrupting a critical national transportation and supply corridor.

A recurring and serious socio-economic concern raised in submissions is the lack of emergency response capacity along the transportation corridors and at the Revell site itself.

Many rural and northern communities rely on volunteer fire departments with limited resources, equipment, and specialized training. Commenters questioned whether these communities could realistically respond to a high-level radioactive transport incident, particularly under winter conditions, and noted the absence of demonstrated preparedness for containment, evacuation, or long-term remediation.

Many participants are raising strong regulatory objections to the exclusion of transportation risks from the Impact Assessment. We urge you to listen and force the inclusion of transporation as a key process of the DGR and its Impact Assessment.

Numerous submissions describe this as “project-splitting,” arguing that the repository and the transportation of waste to the site are inseparable components of the same undertaking. Excluding transportation from the assessment precludes a comprehensive evaluation of cumulative risk to corridor communities and undermines public confidence in the review process. Without a rigorous federal assessment of accident scenarios, routine radiation exposure during transit, emergency preparedness, and security risks over a 50-year shipping timeline, the assessment cannot reasonably be considered complete.

For these reasons, we urge the Impact Assessment Agency of Canada to include the transportation of high-level nuclear waste as a core component of the Impact Assessment for the Revell DGR.

A credible, transparent, and precautionary review must fully evaluate the risks borne not only by the potential host communities, but by the many communities and ecosystems along the transportation corridors that would be affected for generations. Anything less is a disservice to Canadians who expect a fair, objective and thorough public assessment of this critical nation building program.

Thank you for the opportunity to provide this comment.