Peace River Nuclear Power Project

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Attachment Request for Pause in the Impact Statement Phase and Comments on Preliminary Workplan for the Peace River Nuclear Power Project

  • Peace River Nuclear Power Project
  • Author: Administrator on behalf of Peace River First Nations
  • Reference number: 626
  • Submitted: 2026-07-16 - 4:31 PM
  • Project phase: Impact Statement
  • See the attached submission / Veuillez consulter la pièce jointe
  • Attachment included
  • July 16, 2026 SENT VIA EMAIL Energy Alberta #406, 440-10816 Macleod Trail SE Calgary, AB T2J5N Attention: Brenda Walton info@energyalberta.com Re: Request for Pause in the Impact Statement Phase and Comments on Preliminary Workplan for the Peace River Nuclear Power Project We write on behalf of Duncan’s First Nation, Beaver First Nation, Dene Tha’ First Nation, Little Red River Cree Nation, and Tallcree Tribal Government (collectively referred to as the “Peace River First Nations”, “Nations”, and “PRFNs”) to formally request a pause in the Impact Statement Phase of the impact assessment for the Peace River Nuclear Power Project (“Project”). We also write to provide comments on Energy Alberta’s Draft Impact Statement Phase Preliminary Workplan (the “Draft Workplan”) sent to the Peace River First Nations on June 25, 2026. Regulatory Pause Discussion Papers As you are aware, the federal government is considering broad regulatory changes that, if implemented, is expected to have a direct impact on the impact assessment process for the Project. These regulatory changes are overviewed in the following Discussion Papers, released on May 12, 2026: • “Strengthening One Canadian Economy through trade and transportation”; and <contact information removed> 2 • “Getting Major Projects Built in Canada – Discussion Paper on Proposed Legislative, Regulatory, and Policy Reforms” (together, the “Discussion Papers”). As part of the Discussion Papers, Canada is proposing removing the Impact Assessment Agency of Canada (“IAAC”) as the lead for nuclear projects, and transferring that authority directly to the lifecycle regulator, the Canadian Nuclear Safety ...
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Attachment Horse Lake First Nation to Impact Assessment Agency on Impact Assessment Commencement

  • Peace River Nuclear Power Project
  • Author: Administrator on behalf of Horse Lake First Nation
  • Reference number: 625
  • Submitted: 2026-05-05
  • Project phase: Planning
  • Participation notice: Public notice - Public Comments Invited and Information Sessions on the Draft Integrated Tailored Impact Statement Guidelines and Draft Public Participation Plan
  • See the attached submission / Veuillez consulter la pièce jointe
  • Attachment included
  • Please see the attachment to view the content.
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Attachment Nations of the North Peace Comments on Peace River Nuclear Power Plant Revised Initial Project Description

  • Peace River Nuclear Power Project
  • Author: Administrator on behalf of Nations of the North Peace
  • Reference number: 619
  • Submitted: 2026-04-22
  • Project phase: Impact Statement
  • See the attached submission / Veuillez consulter la pièce jointe
  • Attachment included
  • 1 April 22, 2026 Nations of the North Peace Comments on Peace River Nuclear Power Plant Revised Initial Project Description I. BACKGROUND Beaver First Nation, Dene Tha' First Nation, Little Red River Cree Nation, and Tallcree First Nation (collectively, the “Nations of North Peace”) provide the following submission in relation to the Revised Initial Project Description (“Revised IPD”) prepared by Energy Alberta (the “Proponent”) for the Peace River Nuclear Power Project (the “Project”). The Peace River flows through the Nations of North Peace’s Traditional and Treaty Territory and nourishes our land and our People. Our Peoples, which together number over 13,000 members, continue to rely on these lands and waters to hunt, fish, trap, gather, and support other important cultural practices and activities. The Peace River and surrounding lands and tributaries have shaped our unique identity and way of life, including our language, laws, economy, culture, and spirituality. The Crown sought the agreement of the Nations of North Peace’s ancestors to enter into Treaty 8 to open the region up to non-Indigenous settlement. The purpose of Treaty 8 was and remains to provide for the peaceful coexistence of our Peoples and settlers. Our Nations did not surrender the use and care of the waters in our Treaty. In fact, our reserve lands were specifically selected to guarantee continued access to the waters to ensure the present and future economic viability and development of our reserves. The Crown promised that the Nations of North Peace would be ensured the right to carry on our way of life free from interference as well as the rights to hunt, fish, trap, and gather ...
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Attachment Duncan’s First Nation Comments on Peace River Nuclear Power Plant Revised Initial Project Description

  • Peace River Nuclear Power Project
  • Author: Administrator on behalf of Duncan's First Nation
  • Reference number: 621
  • Submitted: 2026-04-22
  • Project phase: Impact Statement
  • See the attached submission / Veuillez consulter la pièce jointe
  • Attachment included
  • 1 April 22, 2026 Duncan’s First Nation Comments on Peace River Nuclear Power Plant Revised Initial Project Description Introduction Duncan’s First Nation (“DFN”) stands to be one of the most impacted First Nations from the proposed Peace River Nuclear Power Plant (the “Project”). The two sites under consideration for the Project are at the heart of our Treaty and Traditional Territories (“DFN Territories”) and adjacent to our Reserve lands where our People live and care for their families. Since the Crown sought agreement from our ancestors in 1899 to open the region up to non-Indigenous persons for settlement, the wellbeing of our lands and our People have been eroding. Given the magnitude of the proposed Project, we are gravely concerned about the threat of further impacts. DFN has and continues to sound the alarm regarding the cumulative impacts in the region, and the devastating consequences rampant resource development is having on our People, lands, and animals. The proposed Project would bring significant change to DFN Territories that would prompt further regional development spurred by access to vast amounts of new electricity. The impacts of this Project would thus be long-lasting and far-reaching—well beyond the Project as scoped in the impact assessment process. As a host community of this Project, DFN is being asked not just to contend with the many anticipated impacts of the proposed Project, but to also live with the threat of low-probability but high-consequence events that could permanently devastate DFN’s homeland. Confidence in the ability of the impact assessment process to effectively grapple with these complex realities and DFN’s position on what ...
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Attachment Energy Alberta's Response to the April 14, 2026 WCFN letter submitted to IAAC

  • Peace River Nuclear Power Project
  • Author: Administrator on behalf of Energy Alberta
  • Reference number: 618
  • Submitted: 2026-04-20
  • Project phase: Impact Statement
  • See the attached submission / Veuillez consulter la pièce jointe
  • Attachment included
  • #406, 440-10816 Macleod Trail SE Calgary, AB T2J 5N8 Info@EnergyAlberta.com EnergyAlberta.com April 20, 2026 SENT VIA EMAIL Impact Assessment Agency of Canada 160 Elgin Street, 22nd Floor Ottawa, Ontario K1A 0H3 Telephone: 613-699-6778 Attention: Claudette Bois, Crown Consultation Coordinator Dear Claudette, Re: Response to letter dated April 14, 2026 from Woodland Cree First Nation Energy Alberta remains committed to building meaningful, mutually beneficial relationships with Indigenous Nations and Communities, guided by respect, integrity and a shared commitment to advancing reconciliation. It is a corporate value of Energy Alberta and a vital component of the project development process. Energy Alberta is providing the following response to the letter dated April 14, 2026 (the “April 14 Letter”) as submitted to the Impact Assessment Agency of Canada (IAAC) by Woodland Cree First Nation (WCFN). Energy Alberta is aware that WCFN has submitted to IAAC a subsequent letter dated April 15, 2026. Energy Alberta will respond to the April 15th letter separately. In the April 14 Letter, WCFN indicated that it does not support resuming Phase 1 of the Federal Impact Assessment process for the proposed Peace River Nuclear Power Project (the Project). WCFN further indicated that Energy Alberta had not taken meaningful steps to address the issues that led to the time-line suspension. Energy Alberta did not receive a copy of the April 14 Letter directly from WCFN and was surprised when it received a notification from IAAC that it had received the April 14 Letter. This is especially the case since Energy Alberta and WCFN met on the afternoon of April 15, 2026 ...
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Attachment Peace River Nuclear Power Project, Project Reference Number: 89430 Woodland Cree First Nation Comments on Impact Assessment Phase 1 Documents

  • Peace River Nuclear Power Project
  • Author: Administrator on behalf of Woodland Cree First Nation
  • Reference number: 609
  • Submitted: 2026-04-17
  • Project phase: Planning
  • See the attached submission / Veuillez consulter la pièce jointe
  • Attachment included
  • Peace River Nuclear Power Project Impact Assessment Agency of Canada 160 Elgin Street, 22nd Floor Ottawa, Ontario K1A 0H3 Telephone: 613-699-6778 Sent via Email: peacenuclear-nucleairepaix@iaac-aeic.gc.ca Re: Peace River Nuclear Power Project, Project Reference Number: 89430 Woodland Cree First Nation Comments on Impact Assessment Phase 1 Documents. Dear Impact Assessment Agency of Canada This letter and attached appendices provide Woodland Cree First Nation’s (Woodland Cree or WCFN) review of and comments on Impact Assessment Phase 1 documents including the Draft Indigenous and Engagement Plan (IEPP), Draft Cooperation Plan, Energy Alberta’s (the Proponent) Response to the Summary of Issues, and the draft Tailored Impact Statement Guidelines. WCFN expects the Agency to review and respond to all comments provided and equal consideration must be given to both the recommendations put forward in this letter and in the attached appendices. As stated in our May 14, 2025 letter regarding the Initial Project Description, Woodland Cree is a signatory to Treaty 8 that will be directly and adversely affected by the proposed Project. The two options proposed for the Project location are both within 40 km of Cadotte Lake, the reserve where most of our people live, and within the lands where we exercise our rights. We have significant concerns about this Project and expect deep and meaningful consultation and accommodation by both the Crown and Proponent. We acknowledge that IAAC has recently released Guidance for proponents: Early engagement with Indigenous Peoples in impact assessments under the Impact Assessment Act, ...
  • Attachment included
  • Comment ID "WC1" etc. Section Section title Comments Recommendations 1 General Consistent with best practice and Canada’s commitments to Indigenous peoples, it is Woodland Cree’s position that regulatory and/or Impact Assessment of proposed projects should be initiated only after potentially impacted parties have been meaningfully engaged by the proponent. Engagement prior to the initiation of formal regulatory or IA processes allows impacted parties to be sufficiently informed to adequately participate in those processes. The importance of early engagement prior to formal regulatory or IA processes is particularly important for projects that have the potential to result in significant adverse and irreversible impacts to a community's rights and interests. A large nuclear reactor in close proximity to Indigenous communities and interests certainly meets that threshold. With the exception of preliminary contacts, the proponent has not yet engaged substantively with Woodland Cree on the proposed nuclear reactor. The Nation’s knowledge of the project is therefore limited to the high-level information presented in the proponent’s Initial Project Description (April 2025). In this context: a) Woodland Cree lacks the information necessary to provide informed feedback on the Draft Integrated Tailored Impact Statement Guidelines (Integrated Timelines); and b) the proposed project that is under review has not been designed to consider the input and interests of Woodland Cree. This represents a substantive deficiency in both the proposed project and the Impact Assessment process of the project. Woodland Cree strongly recommends that the Impact Assessment process for the proposed project, including IAAC ...
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Attachment Requirement to Reinstate the Pause on Phase 1 of the IAA 2019 Process – Peace River Nuclear Power Project

  • Peace River Nuclear Power Project
  • Author: Administrator on behalf of Woodland Cree First Nation
  • Reference number: 616
  • Submitted: 2026-04-15 - 11:13 AM
  • See the attached submission / Veuillez consulter la pièce jointe
  • Attachment included
  • April 14, 2026 Peace River Nuclear Power Project Impact Assessment Agency of Canada 160 Elgin Street, 22nd Floor Ottawa, Ontario K1A 0H3 Telephone: 613-699-6778 Re: Requirement to Reinstate the Pause on Phase 1 of the IAA 2019 Process – Peace River Nuclear Power Project To Whom It May Concern, The Woodland Cree First Nation is formally advising the Impact Assessment Agency of Canada that the Nation does not support the resuming of Phase 1 of the federal impact assessment process for the proposed Peace River Nuclear Power Project, date March 2, 2026. The pause must remain in place. The proponent has not met the minimum requirements necessary to justify moving forward, and advancing the process now would undermine the integrity of the assessment and the Nation’s ability to participate meaningfully. The Project was Paused on August 20, 2025, and since that time Energy Alberta has taken no meaningful steps to address the issues that led to the pause in the first place. The Nation provided the proponent with the information required to establish a capacity funding agreement months ago. Despite this, Energy Alberta has not engaged, has not negotiated, and has not finalized any such agreement. This lack of engagement in and of itself prevents the Nation from being able to participate in the assessment in a meaningful way. In addition, no studies have been agreed to, scoped, or initiated, and no substantive engagement has occurred on any aspect of the preparatory work required for the completion of Phase 1, let alone the start of Phase 2, of the IAA-defined process. There has been no progress on readiness and no indication that the proponent intends to meet its ...
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Attachment Peace River Nuclear Power Project, Project Reference Number: 89430; Initial Project Description Comments and Concerns

  • Peace River Nuclear Power Project
  • Author: Administrator on behalf of Woodland Cree First Nation
  • Reference number: 620
  • Submitted: 2026-04-15
  • Project phase: Planning
  • See the attached submission / Veuillez consulter la pièce jointe
  • Attachment included
  • WOODLAND CREE FIRST NATION General Delivery, Cadotte Lake, Alberta, T0H 0N0 Phone: 780-629-3803 Fax: 780-629-3865 Toll Free: 1-800-465-8029 April 15, 2026 Peace River Nuclear Power Project Impact Assessment Agency of Canada 160 Elgin Street, 22nd Floor Ottawa, Ontario K1A 0H3 Telephone: 613-699-6778 Email: peacenuclear-nucleairepaix@iaac-aeic.gc.ca RE: Peace River Nuclear Power Project, Project Reference Number: 89430; Initial Project Description Comments and Concerns Dear Impact Assessment Agency of Canada, Woodland Cree First Nation (WCFN) appreciates the opportunity to review the February 2026 Updated Initial Project Description (IPD) and to continue engaging in this process in good faith. While we acknowledge the revisions made since the original submission, these revisions are focused on the additional information concerning the AP1000 reactor technology only. The Proponent has not taken the opportunity to update the IPD to address Woodland Cree concerns previously submitted on May 14, 2025. These issues continue to limit WCFN’s ability to fully understand the project’s implications and to meaningfully assess potential impacts on our rights, lands, and community well-being. The following provides a summary of WCFN concerns as they relate to the initial letter submitted on May 14, 2025, along with the updated IPD review conducted: • Insufficient engagement and consideration of WCFN concerns. With this being an unprecedented project type in Alberta and located in the heart of the Woodland Cree’s Territory, WCFN expects to be sufficiently engaged and their input to be considered appropriately. The Project process was paused on August 20, 2025, with the resuming of Phase 1 ...
  • Attachment included
  • 1 ANNEX 1: Review of Energy Alberta’s “PEACE RIVER NUCLEAR POWER PROJECT - Initial Project Description”, Report No. CA0038431-24003-R-Rev1, updated February 2026. The following tables provide a summary and review of the adequacy of the response to Woodland Cree First Nation’s (“Woodland Cree” or “WCFN”) comments on the Initial Project Description (“IPD”), sent May 14, 2025 based on the Proponent’s resubmission of an updated IPD. Table 1 outlines and reviews responses to information gaps in the updated IPD (provided February 20261) identified by Woodland Cree. Table 2 identifies and reviews Proponent responses to Woodland Cree requests for studies based on their response to the Summary of Issues and the updated IPD (2026). The Updated IPD (2026) focuses on the additional information concerning the AP1000 reactor technology only and the Proponent has not taken the opportunity to update the IPD to address Woodland Cree Concerns. Firelight recommends that Woodland Cree seek both additional commitments from the Proponent and updates to the Tailored Impact Statement Guidelines before they are finalized by the Agency in-order to assure that these concerns are carried forward in the Impact Assessment process and resolved. Table 1 Review of updated IPD in response to WCFN comments Section/ Page Original WCFN Comment and Request Adequacy of Changes in the IPD Additional Request Resolved? 1. Potential Effects 4.3.5.1 Activities (Decommissio ning); 4.6.6 Alternative Onsite waste storage and management could have critical impacts to Woodland Cree. These plans will contribute to the cumulative impacts of waste storage, disposal and processing facilities in Woodland Cree’s territory, which ...
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Attachment Peace River First Nations Initial Comments on PRPP Siting Matters

  • Peace River Nuclear Power Project
  • Author: Administrator on behalf of Peace River First Nations
  • Reference number: 608
  • Submitted: 2026-04-10 - 11:30 AM
  • Updated: 2026-04-13 - 3:45 PM
  • Rationale: Comment updated for administrative purposes
  • Project phase: Planning
  • Good morning Justin and Claudette, Further to our initial information meeting on siting matters related to the Peace River Nuclear Power Project, the Peace River First Nations wished to provide the attached document to you and your colleagues at the Canadian Nuclear Safety Commission and the Impact Assessment Agency of Canada. As you will have gathered from the tenor of our discussions last week, and from the matters raised in the attached document, the Peace River Nations have serious concerns with the approach and methodology adopted by the proponent in relation to siting. While the approach may be considered by your agencies to sufficiently meet existing guidance on siting matters, the Nations remain concerned that this process contains significant gaps and deficiencies. In particular, it fails to adequately consider, evaluate, avoid, and address adverse impacts on the Nations’ rights, culture, and way of life that will certainty flow from siting decisions made at this early, critical, and strategic phase of the Project’s development. The Nations have made the case that more can and should be done through a collaborative approach to address these issues while there is still time, space, and opportunity to do so. We appreciate the opportunity to have met with you to better understand your agencies’ approach to siting matters and to obtain initial information. As noted by your colleagues, siting is a complex matter, and the assessment of siting options, analysis, and decisions can ultimately play a determinative role in where the Project is located and in the range of effects and impacts that flow from that decision. We look forward to ongoing ...
  • Attachment included
  • 1 Peace River First Nations Initial Comments in Respect to Energy Alberta’s Siting Criteria and Methodology For the Peace River Nuclear Power Project Date: April 8, 2026 (REVISED and REISSUED) Prepared for: Energy Alberta in Relation to the proposed Peace River Nuclear Power Project (“Project”) Prepared by: Peace River First Nations (“PRFNs” or “Nations”) which, for purposes of this initial submission, is inclusive of:  Tallcree Tribal Government  Little Red River Cree Nation  Beaver First Nation  Dene Tha’ First Nation  Duncan’s First Nation Copied to: Casey Horseman: Horse Lake First Nation Subject: Initial Comments on the Approach and Methodology for Siting the Peace River Nuclear Power Project 2 1.0 Purpose and Context • These initial comments are provided by the PRFNs in respect of Energy Alberta’s current approach to siting the proposed Project. • The PRFNs understand Energy Alberta has identified two prospective locations for the Project approximately 30 km north of the Town of Peace River, on the west and east banks of the Peace River, and is seeking feedback on the relative merits of these pre-selected options. The two sites identified by Energy Alberta are described as Option 1 and Option 2. (See attached Google Earth Projection Map-Appendix I) • The PRFNs have been informed that once Energy Alberta has evaluated the relative merits of Option 1 and Option 2, it will make a final decision in respect to a preferred site and then commence the preparation of the environmental impact statement based on the preferred site. Energy Alberta has informed the PRFNs that it wishes to be in the position to make this decision by mid-April 2026. ...
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Attachment IAAC Funding Deficiencies

  • Peace River Nuclear Power Project
  • Author: Administrator on behalf of Chris Nel
  • Reference number: 623
  • Submitted: 2026-03-26 - 7:54 PM
  • Project phase: Planning
  • Participation notice: Public notice - Public Comments Invited and Information Sessions on the Draft Integrated Tailored Impact Statement Guidelines and Draft Public Participation Plan
  • See the attached submission / Veuillez consulter la pièce jointe
  • Attachment included
  • From: To: Peace River Nuclear Power Project (IAAC/AEIC) Subject: IAAC Funding Deficiencies Date: Thursday, March 26, 2026 7:54:34 PM Hallo Joe RE: Peace River Nuclear Power Project — IAAC Registry #89430 — Formal Submission on the Structural Impossibility of Meaningful Participation — Request for Agency Response I write as a registered intervenor in the impact assessment of the proposed Peace River Nuclear Power Project (IAAC Registry #89430) and as a resident of the Peace River region of Treaty 8 territory in northern Alberta. This letter raises a formal challenge to the adequacy of the consultation and participation process conducted to date in the planning phase of this impact assessment. It sets out six interlocking grounds on which the process has been, and continues to be, structurally incapable of producing meaningful participation as that term is defined in Canadian constitutional law. At the conclusion of this letter I ask the Agency a direct question and request a direct answer. 1. THE LEGAL DEFINITION OF MEANINGFUL PARTICIPATION The word “meaningful” in the phrase “meaningful consultation” is not aspirational. It carries precise legal content established by the Supreme Court of Canada. In Haida Nation v British Columbia (Minister of Forests), 2004 SCC 73, the Court held at paragraph 46 that consultation must be meaningful “in the sense that there is a possibility of influencing the Crown’s decision.” The word the Court used was “influence.” Not attend. Not comment. Not receive information. Influence the decision. In Rio Tinto Alcan Inc v Carrier Sekani Tribal Council, 2010 SCC 43, the Court confirmed that consultation must allow the affected party “to put forward its views and have ...
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Attachment CONSOLIDATED REPLY TO IAAC RESPONSE — MARCH 18 AND MARCH 20 EMAILS — MATERIAL ADMISSIONS, UNANSWERED QUESTIONS, SHOW STOPPER FUNDAMENTAL ISSUES, AND FORMAL NOTICE — REGISTRY #89430

  • Peace River Nuclear Power Project
  • Author: Administrator on behalf of Chris Nel
  • Reference number: 624
  • Submitted: 2026-03-24 - 8:05 PM
  • Project phase: Planning
  • Participation notice: Public notice - Public Comments Invited and Information Sessions on the Draft Integrated Tailored Impact Statement Guidelines and Draft Public Participation Plan
  • See the attached submission / Veuillez consulter la pièce jointe
  • Attachment included
  • REGISTERED INTERVENOR CONSOLIDATED RESPONSE — IAAC Registry #89430 | Page 2 of 11 3. The failure to answer Question B has a specific legal consequence, because as a registered intervenor I am entitled to know whether IAAC regards the participation process as having met its statutory obligations. Without that answer I cannot make an informed decision about whether to seek judicial review. 4. The invitation to describe what meaningful participation will only end in disputes as to who said what and I ask that you please formally give a written answers to my questions. PART II — FOUR MATERIAL ADMISSIONS IN IAAC'S RESPONSE Admission 1 — Post-Closure Consultations With No Capacity to Influence the TISG 5. IAAC's response contains four admissions that I place formally on the record. 6. IAAC confirmed that: a. The formal comment period on the draft Integrated Guidelines closed on July 23, 2025. b. Two months after the TISG closure, the in-person sessions in Peace River and Manning took place September 25 to 28, 2025. c. IAAC confirmed that staff at those sessions were present only to explain the process and answer questions. d. The comments received outside the formal period will not be guaranteed to be incorporated into the TISG. 7. These statements above confirms my position that the September IAAC consultations were informational theatre, not substantive participation. 8. The consequence is direct. 9. IAAC consulted the Manning community and registered intervenors on their requirements and concerns after the process for incorporating those requirements into the TISG had already closed. REGISTERED INTERVENOR CONSOLIDATED RESPONSE — IAAC ...
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Attachment Peace River Nuclear: 15th Show stopper: New Research ignore / CNSC health protection framework invalidated

  • Peace River Nuclear Power Project
  • Author: Administrator on behalf of Chris
  • Reference number: 596
  • Submitted: 2026-03-19
  • Project phase: Planning
  • See the attached submission / Veuillez consulter la pièce jointe
  • Attachment included
  • IAAC COMPLAINT Energy Alberta Peace River Nuclear Power Project SS 15 CNSC Conveniently Ignores the Latest Research Source: INWORKS 2023–2025; Harvard Environmental Health 2025; Harvard Nature Communications 2026; IJMS March 2025; Current Environmental Health Reports Meta-Analysis 2024; European Journal of Epidemiology November 2024 The Argument The Canadian Nuclear Safety Commission’s radiation health protection framework rests on three claims in that:  The CNSCs’ risk coefficient of five percent per Gray adequately captures the cancer mortality risk from chronic low-dose radiation;  The linear no-threshold model is conservative at low doses;  Compliance with dose limits derived from these two claims constitutes adequate provision for the protection of health under the Nuclear Safety and Control Act. The original INWORKS cohort study in August 2023 challenged the CNSC’s radiation health protection framework. The CNSC’s response, posted on its public website, acknowledged that INWORKS found “positive associations” between chronic low-dose radiation and deaths from leukemia, solid cancers, and circulatory disease. The CNSC acknowledged that the INWORKS risk estimate for solid cancer mortality was higher than the estimate currently used in radiation protection, but the CNSC took no regulatory action. Between August 2024 and February 2026, six major peer-reviewed publications materially challenged or removed the scientific basis for each of these claims. Three further papers from the same INWORKS investigator group, using the same cohort, have since been published — each extending and in key respects amplifying the findings the CNSC acknowledged in 2023. The CNSC has not ...
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Attachment Peace River Nuclear: 16th Show stopper: Harm

  • Peace River Nuclear Power Project
  • Author: Administrator on behalf of Chris
  • Reference number: 597
  • Submitted: 2026-03-19
  • Project phase: Planning
  • See the attached submission / Veuillez consulter la pièce jointe
  • Attachment included
  • IAAC COMPLAINT ADDITIONS Energy Alberta Peace River Nuclear Power Project — Registry #89430 SHOW STOPPER 16 The Rights Hierarchy and the Regulatory Vacancy The CNSC has no standard for harm, no instrument to measure it, and no constitutional permission to price the right to life This Show Stopper makes a three-part argument, each part independently sufficient to require the Panel to find that the CNSC’s submission does not answer the question the Impact Assessment Act requires to be answered. Part 1 establishes that the CNSC has never defined a standard for unacceptable harm and that its framework — ALARA and dose compliance thresholds — is structurally incapable of producing a determination of unacceptability. Part 2 establishes that the CNSC’s monitoring framework cannot detect harm to the host community even if it occurs. Part 3 establishes that the constitutional and human rights framework independently prohibits the result the CNSC’s framework would produce, and that every comparable jurisdiction has built what Canada has not. Part 4 states what the Panel must find and do. The cumulative logic is as follows: the CNSC cannot define harm, cannot detect harm, and even if it could do both, the legal and constitutional framework prohibits the answer it would give. There is no level at which deference to the CNSC is appropriate in this proceeding. The CNSC has built a framework for pricing harm. It has built no framework for deciding when harm is unacceptable. That omission is not technical. It is structural. And the right to life — the supreme right from which no derogation is permitted even in armed conflict — cannot be priced. PART 1: NO STANDARD — THE CNSC ...
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Attachment Peace River Show Stopper 30

  • Peace River Nuclear Power Project
  • Author: Administrator on behalf of Chris
  • Reference number: 601
  • Submitted: 2026-03-19
  • Project phase: Planning
  • See the attached submission / Veuillez consulter la pièce jointe
  • Attachment included
  • | Page 1 IAAC COMPLAINT ADDITIONS Energy Alberta Peace River Nuclear Power Project — Registry #89430 A Formal Submission to the Impact Assessment Agency of Canada Registry #89430 — Energy Alberta Peace River Nuclear Power Project March 2026 SHOW STOPPER 30 A PROCESS REDUCED TO A MOCKERY How Energy Alberta treated the Statutory consultation process with disdain, how the CNSC participated and enabled this disdain and how the IAAC allowed it to happen The Impact Assessment Act does not contemplate a proponent that treats the statutory process as a commercial convenience. It does not contemplate a national nuclear regulator that provides technical evidence to a quasi- judicial panel for determinations it knows its own institutional posture precludes it from supporting. And it does not contemplate an assessment agency that watches both of those things happen while continuing the assessment as though nothing has gone wrong. The Act is built on the assumption that these three things cannot happen simultaneously because the system of statutory obligations, disclosure requirements, and procedural safeguards that the Act establishes would prevent it. In this proceeding, all three have happened simultaneously. Energy Alberta has treated the process with contempt across seven documented acts. The CNSC has participated in and enabled that contempt by providing a regulatory imprimatur that Energy Alberta's conduct did not deserve and by staying silent when its section 18 disclosure obligations required it to speak. The IAAC has allowed both — watching a proponent make undisclosed technology shifts, ignore mandatory information requirements, and disregard binding treaty ...
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Attachment Show Stopper 34 - Public Subsidy Needed!!

  • Peace River Nuclear Power Project
  • Author: Administrator on behalf of Chris
  • Reference number: 605
  • Submitted: 2026-03-18 - 12:49 PM
  • Project phase: Planning
  • See the attached submission / Veuillez consulter la pièce jointe
  • Attachment included
  • Energy Alberta Peace River Nuclear Power Project — IAAC Registry #89430 | SHOW STOPPER 34 — Commercial Unviability | March 2026 1 | P a g e ENERGY ALBERTA PEACE RIVER NUCLEAR POWER PROJECT IAAC Registry File No. 89430 March 2026 SHOW STOPPER 34 PERMANENT PUBLIC SUBSIDY NEEDED THE PEACE RIVER NUCLEAR POWER PROJECT CANNOT COMPETE IN ALBERTA'S DEREGULATED ELECTRICITY MARKET WITHOUT A PERMANENT PUBLIC SUBSIDY. NO GOVERNMENT HAS BEEN COMMITTED BY ANY SUCH GOVERNMENT SUBSIDY. HE GAP BETWEEN WHAT NUCLEAR COSTS AND WHAT ALBERTA'S MARKET WILL PAY IS APPROXIMATELY $76 TO $156 PER MEGAWATT-HOUR — LARGER THAN ALBERTA'S ENTIRE 2025 AVERAGE POOL PRICE. THE TISG DOES NOT REQUIRE THE PROPONENT TO DISCLOSE A REVENUE MODEL, QUANTIFY THE SUBSIDY REQUIRED, OR DEMONSTRATE THAT THE PROJECT CAN ATTRACT PRIVATE FINANCE WITHOUT A COMMITTED GOVERNMENT REVENUE GUARANTEE. THESE OMISSIONS IN THE TISG ARE FATAL TO THE PUBLIC INTEREST DETERMINATION. EXECUTIVE SUMMARY — WHAT THIS SUBMISSION SHOWS 1. The Peace River Nuclear Power Project requires a minimum revenue floor inferred from Vogtle and Hinkley Point C cost experience of approximately $120–200/MWh to be commercially financeable at a first-of-kind AP1000 greenfield site in northern Alberta. AESO reports a 2025 average pool price of $43.68/MWh — 30 per cent below 2024 — in a deregulated, energy-only market with no capacity payment mechanism. The gap between what nuclear requires and what the market will pay is approximately $76–156/MWh, larger than the entire current average pool price. 2. The subsidy required to close this gap — a contract for difference, long-term power purchase agreement, or equivalent ...
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Attachment Peace River: Show Stopper 33

  • Peace River Nuclear Power Project
  • Author: Administrator on behalf of Chris
  • Reference number: 604
  • Submitted: 2026-03-18 - 12:28 PM
  • Project phase: Planning
  • See the attached submission / Veuillez consulter la pièce jointe
  • Attachment included
  • Energy Alberta Peace River Nuclear Power Project — IAAC Registry #89430 | SHOW STOPPER 33 — No Demonstrated Need | March 2026 1 | P a g e ENERGY ALBERTA PEACE RIVER NUCLEAR POWER PROJECT IAAC Registry File No. 89430 March 2026 SHOW STOPPER 33 THERE IS NO SUCH ELECTRICITY NEED ENERGY ALBERTA'S CLAIM THAT IT WILL SUPPLY 25 PER CENT OF ALBERTA'S ELECTRICITY IS ARITHMETICALLY INVALID: IT IMPLIES A BASELINE THAT DOES NOT EXIST. THIS FOUNDATIONAL ERROR CORRUPTS THE ENTIRE NEED JUSTIFICATION. THE CAPACITY GAP ENERGY ALBERTA ALLEGES AND PROPOSES TO FILL DOES NOT EXIST ON AESO'S OWN DATA. THE ONLY IDENTIFIABLE FUTURE GAP BEFORE AND AFTER 2038 — A 3,078 MW COAL-TO- GAS RETIREMENT RISK IN 2038 — ARRIVES BEFORE ENERGY ALBERTA CAN PRODUCE ELECTRICITY AND PROVISION FOR THIS IS ALREADY MADE BY THE PROJECTS ALREADY IN THE PIPELINE. THE IAAC TISG FALLS SHORT BECAUSE IT DOES NOT REQUIRE ENERGY ALBERTA TO CONDUCT A VERIFIED NEEDS ASSESSMENT OR THE MANDATORY REGDOC 2.5.2 §2.2.2 SOCIETAL RISK COMPARISON. BOTH THESE ARE REQUIRED AND PROVISION MUST BE MADE BY IAAC IN THE TSIG. EXECUTIVE SUMMARY — WHAT THIS SUBMISSION SHOWS 1. Energy Alberta's need justification rests on a claim that the project will supply approximately 25 per cent of Alberta's electricity, implying a total provincial capacity of approximately 19,200 MW. AESO's actual published installed capacity as of April 2025 is 23,164 MW — more than 20 per cent higher than EA's implied baseline. This arithmetic error is not a minor discrepancy. It is the foundation of the entire need argument, and it is wrong. Energy Alberta Peace River Nuclear Power Project — IAAC Registry #89430 | SHOW ...
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Attachment Peace River: Show Stopper 32

  • Peace River Nuclear Power Project
  • Author: Administrator on behalf of Chris
  • Reference number: 602
  • Submitted: 2026-03-18 - 11:53 AM
  • Project phase: Planning
  • See the attached submission / Veuillez consulter la pièce jointe
  • Attachment included
  • Energy Alberta Peace River Nuclear Power Project — IAAC Registry #89430 | SHOW STOPPER 32 — Temporal Overreach & Methodology Defect | March 2026 1 | P a g e ENERGY ALBERTA PEACE RIVER NUCLEAR POWER PROJECT IAAC Registry File No. 89430 March 2026 SHOW STOPPER 32 TEMPORAL OVERREACH THREE TECHNOLOGIES THAT SOLVE THE PROBLEMS CREATED BY SOLAR, WIND, AND NUCLEAR WILL BE COMMERCIALLY MATURE BEFORE THE PEACE RIVER PROJECT OPENS IN THE 2040s. IAAC'S TISG DOES NOT REQUIRE THE PROPONENT TO COMPARE THE PEACE RIVER PROJECT AGAINST ANY OF THESE ALTERNATIVE TECHNOLOGIES. THE REGDOC §2.2.1 COMPARISON METHODOLOGY IS ALSO STRUCTURALLY DEFECTIVE: IT DOES NOT WEIGHT FOR THE DURATION, MAGNITUDE, OR IRREVERSIBILITY OF NUCLEAR RISK. 32.1 The Starting Point: Two Problems That Need Solving To understand why Show Stopper 32 matters, a reader needs to understand two technology problems that currently shape Alberta's electricity options. Every major competing technology described in this stopper exists to solve one or both of these problems. Once the problems are clear, the technologies are easy to understand. 32.1.1 The Problem with Solar and Wind: They Stop Working When You Need Them Most THE PROBLEM: Solar panels produce electricity only when the sun shines. Wind turbines produce electricity only when the wind blows. On a still winter night — exactly when Alberta households need the most heat and light — both produce nothing. This is called the intermittency problem, and it is the single biggest barrier to replacing conventional power stations with renewable energy. Energy Alberta Peace River Nuclear Power Project — IAAC Registry #89430 | SHOW ...
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Attachment TISG Amendment: Third Request (Impact Statement)

  • Peace River Nuclear Power Project
  • Author: Chris Nel
  • Reference number: 592
  • Submitted: 2026-03-13 - 6:10 PM
  • Project phase: Planning
  • The current IAAC TISG document in draft is entire deficient
  • Attachment included
  • Page 1 of 9 IAAC CURRENT DRAFT TISG THE DOCUMENT IS DEFICIENT AS A REGULATORY INSTRUMENT AN IMPACT STATEMENT PRODUCED UNDER IT CANNOT SUPPORT A LAWFUL PUBLIC INTEREST DETERMINATION UNDER IAA SECTION 63 March 2026 SHOW STOPPER STATEMENT The draft Integrated Tailored Impact Statement Guidelines for the Peace River Nuclear Power Project are deficient as a regulatory instrument in twenty-seven identified respects. An Impact Statement produced under the draft TISG as written cannot provide the Review Panel with the evidentiary foundation required to discharge its independent functions under IAA section 46, cannot demonstrate compliance with mandatory CNSC regulatory requirements for an initial licence application, and cannot support a lawful public interest determination by the Minister under IAA section 63. IAAC cannot approve this project on the basis of an Impact Statement produced under deficient guidelines. Approval would constitute an unreasonable decision reviewable under Vavilov (2019 SCC 65). The show stopper is remedied only by finalising the TISG with all identified deficiencies corrected before the Impact Statement phase commences. SECTION 1 — THE LOGICAL STRUCTURE OF THIS SHOW STOPPER Show Stopper 32 operates at a different level from Show Stoppers 1 through 31. Each of SS1–31 identifies a specific scientific, regulatory, or procedural deficiency that independently bars approval of the project. SS32 makes a structural argument: even if the Review Panel were to accept the proponent’s position on each of those individual matters, the process itself cannot produce a valid outcome because the instrument governing it — the TISG — is deficient. A deficient TISG ...
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Attachment TISG Amendment: Second Request

  • Peace River Nuclear Power Project
  • Author: Chris Nel
  • Reference number: 591
  • Submitted: 2026-03-13 - 5:48 PM
  • Project phase: Planning
  • The flexible gas and storage alternatives are mandatory requurements for TISG
  • Attachment included
  • Page 1 of 12 TISG AMENDMENTS – SECOND REQUEST Peace River Nuclear Power Project — IAAC Registry File No. 89430 Submitted to the Impact Assessment Agency of Canada and the Canadian Nuclear Safety Commission MANDATORY COMPARATIVE ASSESSMENT OF FLEXIBLE GAS WITH CCS AND LARGE-SCALE ENERGY STORAGE AS VIABLE COMPETING TECHNOLOGIES March 2026 SCOPE OF THIS SUBMISSION This submission requests two amendments to the final Integrated Tailored Impact Statement Guidelines. Both amendments are mandatory, not discretionary: one arises from a ‘shall’ requirement in CNSC REGDOC-2.5.2 Version 2.1, the other from IAA section 22(1)(f) and (i) in conjunction with the IAAC’s own Summary of Issues. Neither requirement appears in the draft TISG. Amendment 1 (REGDOC-2.5.2 §2.2.1): The proponent must demonstrate by quantitative probabilistic safety assessment that MONARK societal risk is comparable to or less than the risk of generating equivalent electricity by flex gas with CCS and by large-scale energy storage in the Alberta grid context. This is a mandatory CNSC licensing requirement. The draft TISG omits it. Amendment 2 (IAA s.22(1)(f)/(i)): The proponent must assess flex gas with CCS and large-scale BESS as technically and economically feasible alternatives to the designated project, and must assess the AP1000 as an alternative means of carrying out the project. The IAAC’s own Summary of Issues raised whether other technologies are more appropriate for the Peace River region. IAAC has not translated this stated concern into a TISG requirement. Under Vavilov (2019 SCC 65), that unexplained omission is reviewable. PART 1 — THE REGULATORY FRAMEWORK: TWO INDEPENDENT MANDATORY REQUIREMENTS 1.1 ...
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Attachment TISG Amendment: First Request

  • Peace River Nuclear Power Project
  • Author: Chris Nel
  • Reference number: 590
  • Submitted: 2026-03-13 - 5:34 PM
  • Project phase: Planning
  • I ask IAAC please amend their TISG in line with the document attached.
  • Attachment included
  • Page 1 of 16 FORMAL REQUEST TO AMEND THE FINAL INTEGRATED TAILORED IMPACT STATEMENT GUIDELINES Peace River Nuclear Power Project IAAC Registry File No. 89430 March 2026 STRUCTURE OF THIS SUBMISSION This submission is divided into two Parts. Part 1 — The Foundational Error: IAAC has structured the draft TISG on the assumption that CNSC- published science constitutes settled fact. This is a legal and scientific error. Section 46 of the Impact Assessment Act confers Commission powers on the Review Panel independently of CNSC staff. The Review Panel is not bound by CNSC published conclusions and must be capable of forming its own independent scientific judgments. The draft TISG, as written, does not equip the proponent to provide the evidentiary foundation required for the Review Panel to discharge this function. Part 1 identifies this structural deficiency and specifies the mandatory amendments required to correct it. Part 2 — Specific TISG Shortfalls: Part 2 identifies seventeen specific regulatory, scientific, and procedural requirements that are absent from the draft TISG and must be inserted into the final guidelines. Each is presented with its regulatory or statutory basis, the factual foundation, and the precise amendment sought. The amendments in Part 2 are independent of Part 1 but are reinforced by it: where a TISG requirement currently relies on CNSC-published positions that are disputed on this registry, Part 2 requires independently validated substitutes. Page 2 of 16 PART 1 THE FOUNDATIONAL ERROR: CNSC PUBLISHED ADVOCACY TREATED AS SETTLED SCIENCE AND THE MANDATORY CORRECTION REQUIRED 1. THE STATUTORY FRAMEWORK: REVIEW PANEL INDEPENDENCE UNDER IAA ...
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Attachment Show Stoppers 1 -31

  • Peace River Nuclear Power Project
  • Author: Chris Nel
  • Reference number: 589
  • Submitted: 2026-03-13 - 5:14 PM
  • Project phase: Planning
  • The entire IAAC process is compromised and cannot be cured, the CNSC is dysfucntional and cannot perform its functions
  • Attachment included
  • Page 1 IAAC COMPLAINT ADDITIONS Energy Alberta Peace River Nuclear Power Project — Registry #89430 A Formal Submission to the Impact Assessment Agency of Canada IAAC Registry #89430 — Energy Alberta Peace River Nuclear Power Project March 2026 SHOW STOPPER 31 THE IAAC PROCESS IS INVALID AND CANNOT BE CURED Seven Independent Grounds of Structural Invalidity, Institutional Failure, and the Case for a Full Process Restart Show Stoppers 1 through 29 establish, across three categories — the evidence, the institution, and the law — that this project cannot be approved. Show Stopper 30 establishes something prior to all of them: that the process through which approval is being sought has been corrupted in ways the IAAC cannot cure by proceeding. This Show Stopper — SS31 — makes the cumulative legal case. It does not repeat the factual analysis of Show Stoppers 1 through 30 in full. It integrates the conclusions of those submissions into a structured argument for invalidity and restart, with each of the seven grounds of invalidity stated in terms of the statutory provisions it violates, the facts on the record that establish the violation, and the reason no supplementary process can cure it. The IAAC is not merely in the position of a decision-maker with an incomplete record. It is trapped in the precise legal sense — every path available to it on the current record produces a consequence it cannot lawfully defend. The IAAC cannot proceed to a positive finding without producing a knowingly invalid approval. The seven grounds are as follows. First, the project description does not satisfy the substantive requirements of IAA s. 10 and Regulation 7 of the Physical ...
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Attachment NB!!!: Show Stopper 31 IAAC process invalid and uncurable

  • Peace River Nuclear Power Project
  • Author: Administrator on behalf of Chris
  • Reference number: 603
  • Submitted: 2026-03-13 - 4:25 PM
  • Project phase: Planning
  • See the attached submission / Veuillez consulter la pièce jointe
  • Attachment included
  • Page 1 IAAC COMPLAINT ADDITIONS Energy Alberta Peace River Nuclear Power Project — Registry #89430 A Formal Submission to the Impact Assessment Agency of Canada IAAC Registry #89430 — Energy Alberta Peace River Nuclear Power Project March 2026 SHOW STOPPER 31 THE IAAC PROCESS IS INVALID AND CANNOT BE CURED Seven Independent Grounds of Structural Invalidity, Institutional Failure, and the Case for a Full Process Restart Show Stoppers 1 through 29 establish, across three categories — the evidence, the institution, and the law — that this project cannot be approved. Show Stopper 30 establishes something prior to all of them: that the process through which approval is being sought has been corrupted in ways the IAAC cannot cure by proceeding. This Show Stopper — SS31 — makes the cumulative legal case. It does not repeat the factual analysis of Show Stoppers 1 through 30 in full. It integrates the conclusions of those submissions into a structured argument for invalidity and restart, with each of the seven grounds of invalidity stated in terms of the statutory provisions it violates, the facts on the record that establish the violation, and the reason no supplementary process can cure it. The IAAC is not merely in the position of a decision-maker with an incomplete record. It is trapped in the precise legal sense — every path available to it on the current record produces a consequence it cannot lawfully defend. The IAAC cannot proceed to a positive finding without producing a knowingly invalid approval. The seven grounds are as follows. First, the project description does not satisfy the substantive requirements of IAA s. 10 and Regulation 7 of the Physical ...
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Attachment Peace River Show Stoppers - 23 to 29

  • Peace River Nuclear Power Project
  • Author: Administrator on behalf of Chris
  • Reference number: 600
  • Submitted: 2026-03-13 - 1:45 PM
  • Project phase: Planning
  • See the attached submission / Veuillez consulter la pièce jointe
  • Attachment included
  • SUPPLEMENTARY SHOW STOPPERS 23 – 29 A Formal Submission to the Impact Assessment Agency of Canada Registry #89430 — Energy Alberta Peace River Nuclear Power Project Submitted by: Christofeel Gerhardus Nel Peace River Region, Alberta — Treaty 8 Territory | March 2026 SHOW STOPPER 23 Technology Indeterminacy: The Project Description Does Not Identify the Designated Project IAA s. 10 and Physical Activities Regulations r. 7 — uncommitted reactor technology — participation resource depletion The Statutory Requirement Section 10(1) of the Impact Assessment Act requires a proponent to provide the Agency with an initial project description that includes the information prescribed by the Physical Activities Regulations. Regulation 7(c) requires identification of the designated project's physical components, including the type and dimensions of permanent structures. Regulation 7(d) requires identification of the physical activities carried out in connection with the project. The project description filed by Energy Alberta in April 2025 named the CANDU MONARK as the proposed reactor technology. No technology commitment has been made since. As of this submission, Energy Alberta's own project page lists two technologies — the CANDU MONARK and the AP1000 — as simultaneously under consideration. The IAA's project description requirements cannot be satisfied by a description that names two mutually exclusive physical configurations. The reactor is not a component ancillary to this project. The reactor is the project. The technology selection determines the applicable safety case, the radiological source term, the tritium emission profile, the spent fuel volume and isotopic ...
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