Thank you for the opportunity to comment on the Initial Project Description (IPD) for the Proposed Deep geological Repository (DGR) for Canada’s Used Nuclear Fuel Project. Given the limited time period to provide comments, I was unable to read the full IPD. Please accept these submissions in response to the Summary of the IPD.

1. Purpose and Need for the Project

1. The proponent states that there is a need for a deep geological repository for the following reasons:

• used nuclear fuel remains radioactive for a very long time and therefore requires careful, permanent management to avoid placing a burden on future generations;
• A deep geological repository represents the internationally recognized best practice for the long-term management of used nuclear fuel.” and
• the DGR supports the continued role of nuclear energy as a reliable, low-carbon source of power and contributes directly to Canada’s climate change commitments and goal of achieving net-zero emissions.

1. The proponent’s description of the underlying problem is cursory and lacks the detail and accuracy that a project of this scale merits. Characterizing the radioactivity of used nuclear fuel as lasting for 'a very long time' is an unacceptable generalization. Given the potential for significant environmental and public health impacts, the proponent should provide a comprehensive characterization of high-level waste. This must include a detailed list of key radionuclides, their specific decay timelines, exposure pathways, and a rigorous analysis of associated risks to human health and ecological integrity.

1. The claim of "permanent management" is misleading given the plan to abandon the site in 2193 after only a century of monitoring, despite the waste remaining radioactive for millennia. The repository's design prevents safe waste retrieval, effectively transferring a multi-thousand-year radiation risk to future generations without a mechanism for technological improvement.

1. The proponent’s characterization of a Deep Geological Repository (DGR) as an 'internationally recognized best practice' is logically inconsistent with the standard definition of the term. According to Merriam-Webster, a best practice must be proven by experience to yield optimal results. Since no high-level waste DGR is currently operational worldwide, the claim lacks the empirical evidence necessary to prove its efficacy in protecting human and environmental health over the long term.

1. The long-term hazards of nuclear waste challenge the desirability of nuclear energy as a primary tool for decarbonization. Canada could more effectively meet its climate commitments by pursuing wind, solar, and battery storage, which offer lower costs and faster deployment. Transitioning to these renewables avoids the intergenerational burden of radioactive waste and the environmental impacts of uranium mining while accelerating the path to net-zero emissions.

1. It is recommended that the proponent revise the project’s purpose and need by:

• Providing accurate data on nuclear waste characteristics and radioactivity timelines.
• Removing unsubstantiated claims regarding permanent management, intergenerational burdens, and international "best practices."
• Excluding the goal of using the project to support nuclear energy for climate targets.

1. Engagement with First Nations

1. The Proponent’s Initial Project Description (IPD) contains a significant gap in its summary of Indigenous engagement by failing to acknowledge the AFN’s 2024 Dialogue Sessions on the transportation and storage of used nuclear fuel.[1] (#_ftn1) These sessions, held across Canada and virtually with the Advisory Committee on Climate Action and the Environment (ACE), identified critical issues regarding the NWMO’s proposed DGR, including the vulnerability of transportation routes through First Nations territories, the need for emergency response planning, the inadequacy of the 70-year monitoring plan, and regional inequality where northern territories bear the transportation and storage risks for nuclear energy primarily consumed in the south. The AFN report explicitly recommends that NWMO obtain consent from all impacted First Nations along transportation corridors, not just those at the repository site. These key concerns are conspicuously absent from the IPD suggesting a failure by the NWMO to consult in good faith with First Nations and to accurately report on the outcomes of their consultations.

1. Throughout the IPD, the proponent expresses its commitment to build respectful relationships, and to seek the free, prior, and informed consent of impacted peoples of Wabigoon Lake Ojibway Nation before proceeding with development of the Project. Clearly, this is not sufficient to satisfy its obligations to respect the rights of all impacted Indigenous Peoples under the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP). In addition to failing to seek free, prior and informed consent from the First Nations along the transportation corridor, the NWMO has virtually ignored the rights of all First Nations in Treaty 3 territory, the site of the proposed DGR, except for WLON. There has been considerable opposition by multiple First Nations along the transportation route and in the vicinity of the site. The NWMO has ignored their objections.

1. Indigenous Peoples’ constitutional and Treaty rights must be respected, and all impacted rights holders must be consulted and engaged in accordance with their law and protocol.

1. The project should not be allowed to proceed without the free, prior and informed consent of all impacted rights holders including First Nations along the transportation corridor and those who are signatories to Treaty 3.

1. Engagement with the Public

1. While the proponent contends that they facilitated decades of dialogue, the engagement sessions were often carefully controlled by the proponent with pre-set agendas, rather than open forums where diverse perspectives were presented and the public could freely debate the broader merits of the proposed DGR.

1. The IPD ‘s summary of public concerns downplays the significant opposition to the proposed DGR, including thousands of petition signatures, dozens of resolutions opposing nuclear waste in Northwestern Ontario, and widespread concerns regarding the transportation of nuclear waste.

1. The site selection process has been perceived as fundamentally unfair, because it involved inducing economically vulnerable towns with financial incentives to secure "willing hosts” agreements. The proponent’s agreements with two small communities does not constitute broad social consent, especially given the ongoing resistance from downstream communities and First Nations.

1. In order to be accountable to the people of Canada who are impacted by this proposal, there must be broad, more inclusive public consultations, that respect the principles of free, prior and informed consent for Indigenous people and include all potentially impacted people.

1. For a project of this magnitude that will impact so many people to proceed there should be a demonstration of broad social acceptance with input from all impacted communities.

1. Transportation Must Be Included in the Impact Assessment

1. I strongly disagree with the proponent’s position that transportation should be excluded from the scope of this Impact Assessment.

1. Inclusion of transportation in the impact assessment is absolutely essential because the repository cannot function without it. Transportation is an integral and high-risk part of the entire project lifecycle, affecting communities and the environment along the entire transport route, not just the primary and secondary access roads in the DGR site itself. 

1. The highways in Northern Ontario are notorious for their unsafe and high-risk conditions including segments having only single lane traffic, icy conditions, wildfires, wildlife, and poorly maintained roads – all of which increase the likelihood of crashes.

1. Although the NWMO asserts they will use robust packaging to ensure safety, their containers have not been subjected to full-scale testing. It is inevitable that accidents caused either by human error, equipment failure, extreme weather, or security breaches will occur during the movement of waste over a period of 50 years. A single incident could lead to the release of radioactive material, causing severe and long-lasting contamination of land, air, and water systems that are difficult to contain or clean up. An accident would also put the people living along the transportation route, the wildlife, and environment in these areas at direct risk of contamination and adverse health effects.

1. Communities along the proposed routes have a right to be informed about the risks and have a say in a process that directly impacts them. Including transportation in the assessment ensures that the rights of all affected parties, including the obligation for free, prior, and informed consent for Indigenous rights-holders, are respected.

1. The transport of used nuclear fuel is expected to take place over a period of at least 50 years, involving thousands of shipments. This extended timeframe increases the probability of an accident occurring at some point.

1. Local emergency services in remote or rural areas are not be equipped or trained to handle a nuclear transportation incident, highlighting the need for a full assessment to ensure adequate response capabilities are in place.

1. The cumulative effects of potential routine, low-level radiation exposure during normal transport operations on individuals living and working along the routes need to be evaluated as part of the overall impact. 

Alternatives to the Proposed Project

1. The impact assessment should include a thorough analysis of alternative means to carry out the project to ensure the project is designed, located, and implemented in the most environmentally and socially responsible manner possible.

1. This would allow the Agency to identify the safest, most effective option with the least environmental effects.

1. Among the options to consider is continued on-site storage in more robust facilities with ongoing monitoring. This option enables retrieval of the waste if more advanced methods are discovered for reducing the volume and radioactivity of the spent nuclear fuel.

1. Considering this alternative among others would allow for public input and ensure that concerns from impacted communities and Indigenous groups—such as transportation risks and water safety—are considered.

1. Ultimately, a careful analysis of this option would increase public confidence that the chosen project is the best possible option for managing nuclear waste.