Additional Recommendations for the Draft Tailored Impact Statement Guidelines and Public Participation Plan

This additional submission for the Draft Tailored Impact Statement Guidelines (DTISG) for The Deep Geological Repository (DGR) for Canada's Used Nuclear Fuel Project (Project 88774) is provided to address perceived deficiencies in the current regulatory framework. These comments build upon our previous submission (954).

We provide these recommendations to ensure the Impact Assessment Agency of Canada (IAAC) and the Canadian Nuclear Safety Commission (CNSC) uphold the requirements of the Impact Assessment Act by accurately capturing the socio-economic and environmental realities of those living closest to the proposed project.

Mandating a Baseline for 'Quietude' in Melgund Township

The Agency must require the Proponent to establish a specific baseline for "Quietude" as a distinct Valued Component for receptors within Melgund Township. The current reliance on standard industrial noise permissible levels, such as NPC-300, is fundamentally inappropriate for this "intrinsically quiet" Boreal environment. Residents have consistently identified the absence of industrial sound as a primary factor in their mental well-being and the valuation of their properties. The guidelines must be amended to require a minimum of one full year of seasonal acoustic data to capture how sound propagation is uniquely enhanced by snow cover and atmospheric inversions in this specific geography, ensuring the wilderness character of the township is not permanently degraded by industrial noise.

Groundwater Security and Forensic Isotopic Fingerprinting

The Draft Tailored Impact Statement Guidelines must be updated to require forensic isotopic fingerprinting of all local water sources within the township. Because the residents of Borups Corners and Dyment and the surrounding area are 100% dependent on private groundwater wells, a generalized regional water management plan does not provide sufficient protection for human health. The Proponent must be directed to establish a unique chemical and isotopic "signature" for every domestic well within a 20-kilometer radius of the project site. This forensic baseline is the only scientific method available to distinguish future project-related leakage from natural variations or legacy fallout, providing an essential safeguard for the only source of potable water available to these communities.

Economic Impacts: Inflation and the Stigma Effect

Regarding socio-economic stability, the guidelines lack a rigorous mechanism to evaluate "Project-Induced Food Price Inflation" and the resulting strain on the local subsistence economy. In an area where many residents live on fixed incomes or rely on local harvesting, the influx of a high-salaried industrial workforce threatens to drive up the cost of basic goods, fuel, and services. Furthermore, the Impact Statement must include a quantitative analysis of "Nuclear Stigma" and its potential to devalue local food products and residential assets. Without a mandatory framework for property value protection, the residents of Melgund Township bear the entirety of the project's economic risk without the formal benefit-sharing structures afforded to incorporated municipalities.

Rectifying Data Deficiencies

Finally, the Proponent must be directed to rectify the systemic failure in data collection regarding those in Melgund Township communities and local peoples living closest to the site. As referenced in our previous submission, the issue of "Data Not Available" for nearly 60 key metrics is a procedural failure that renders the most impacted people and their representative organizations invisible.

To ensure the credibility of the assessment, the guidelines must mandate primary data collection within the township and involve local peoples in the co-design and collection of data. The communities must also have resources and ability to verify raw data and methodologies in real-time, ensuring that the unique socio-economic and environmental realities of Melgund are accurately represented and protected.

We also feel the current Draft Tailored Impact Statement Guidelines fail to adequately address the profound risks to local food security, diet and the stability of the subsistence economy within Melgund Township and the immediate local area which is the closest and most impacted of all.

In a region where a significant portion of the population—including seniors, low-income households, and Indigenous community members—relies heavily on the harvesting of species such as moose, fish, and berries, the project threatens to disrupt both the availability and the affordability of these essential resources. The influx of a high-salaried industrial workforce will inevitably trigger "Project-Induced Food Price Inflation," driving up the cost of commercial goods and fuel at local outlets, which disproportionately impacts those on fixed incomes. Furthermore, the guidelines must mandate an assessment of the "Nuclear Stigma" effect, which can render locally harvested foods undesirable in the broader market and diminish the perceived safety of traditional diets. Without site-specific baseline studies and a robust mitigation framework to protect these informal economic systems, the project risks causing long-term nutritional and financial precariousness for the residents living closest to the site.

Amendment to Line 1276: Mandatory Collaboration with Local Service Boards and Communities

The Draft Tailored Impact Statement Guidelines must be amended at Line 1276 to replace the discretionary term "should" with the mandatory "must." The line should be revised as follows: "The proponent must work with, at minimum, the Township of Ignace, City of Dryden, Municipality of Sioux Lookout, Municipality of Machin, Village of Wabigoon Local Services Board, Melgund Local Services Board... and other self-identifying local communities, as well as local peoples, when fulfilling the requirements of Section 7."

The rationale for this change is based on the critical need for procedural fairness and the rectification of documented data gaps. As previously identified, the Melgund Local Services Board and the residents of Melgund Township have been effectively rendered invisible in preliminary baseline reports, with over 50 key metrics cited as "unavailable." Leaving the collaboration with these representative organizations as a discretionary "should" allows the Proponent to continue a pattern of exclusion and desktop-based modeling that ignores the unique socio-economic and environmental realities of those living in the immediate project footprint.

This amendment aligns with Section 22(1)(n) of the Impact Assessment Act, which mandates the consideration of any other matter relevant to the assessment, including the necessity of ensuring that the data used to predict impacts is accurate and verified by those most affected. Given that the Melgund Local Services Board is the primary representative body for the residents closest to the proposed site, their participation in fulfilling Section 7 requirements must be an enforceable obligation. Mandatory inclusion is the only mechanism that ensures the resulting Impact Statement is not built upon a "knowledge vacuum," but rather on the lived experience and local knowledge of the people who bear the greatest long-term risk.