Northwatch Comments on Draft Integrated Tailored Impact Statement Guidelines, NWMO's Proposed Deep Geological Repository for Nuclear Fuel Waste

The Integrated Tailored Impact Statement Guidelines must provide the NWMO with direction that is sufficiently detailed to result in a detailed impact statement which must support an evidence-based assessment of the NWMO’s proposal and its potential effects. The Agency must ensure that the guidelines are sufficiently thorough and comprehensive in order to achieve a credible and scientifically and socially rigorous review process.

In the course of our review we determined that many (or most) of the issues we had raised during the previous comment period on the Initial Project Description have not been addressed in the draft guidelines.

We are concerned that the guidelines as drafted will not result in a robust assessment of the Nuclear Waste Management Organization’s project, which will be to the general disadvantage of Canada and put those along the transportation route and in the vicinity of and downstream from the project at greater risk.

We urge the Impact Assessment Agency to give careful thought to the hundreds of submissions the Agency has received calling for strengthening of the Guidelines. In the case of a project whose agreed upon lifetime is one million years, some extra time, care and attention is warranted in producing guidelines which will direct the proponent in the preparation of an impact statement that will support an informed and evidence-based review of this unprecedented project.

Our comments on the draft guidelines is attached.