I am writing to express some of my multiple concerns about the Initial Project Description  of the Deep Geological Repository (DGR) for Canada's Used Nuclear Fuel Project (December 2025). As a Canadian citizen living along the route that trucks carrying radioactive waste will be travelling and as a taxpayer funding the project I would like to outline some of those concerns below.

First, although the IPD claims to address the need for, and the purpose of, this project I found that the reasons given were either technically inaccurate or not based on scientific, economic or political realities. For example, the IPD states that the DGR operate for 160 years and provides no details regarding the long term monitoring of nuclear waste that will remain dangerous for thousands, or even millions, of years.  Given these simple facts, stating that the DGR provides a ‘permanent and safe’ disposal solution or addresses long term environmental risk and provides intergenerational equity is just false. Claiming that nuclear energy is a solution to climate change is also a fantasy. It takes too long to build and is economically uncompetitive with renewable energy alternatives. Investing in nuclear doesn’t just divert money and resources away from real climate solutions and prolong dependance on fossil fuels. The current plan to build US small modular nuclear reactors, dependant on buying fuel from Russia or the US, puts those provinces who potentially rely on them in a very energy insecure position. If, in the future, the US blocks our import of the nuclear fuel, increases the price and/or throws a kill switch on their operations people are going to be placed in very difficult positions - especially if it is -20 C in the middle of January.

Second, there doesn’t seem to be a firm commitment in the IPD to conducting a full impact assessment of the DGR project. Given the environmental, economic, social and indigenous impacts associated with the DGR there needs to be an unambiguous commitment to refer the project to an Integrated Review Panel (section 43 of the Impact Assessment Act). Consideration of need and purpose of a project is an important component of the Impact Assessment Act (section 22) . As mentioned above, the ‘need and purpose’ briefly outlined in the IPD are not objectively sound. Unless there is a demonstrable, public need for a such a risky undertaking as the DGR it should not be undertaken. The IPD also takes only a short, inadequate look at alternatives. Alternative solutions should be looked at seriously, with a comprehensive, independent analysis of the situation (section 22, Impact Assessment Act).

Third, the issue of transportation has been excluded from the IPD and the reason given doesn’t make sense. Transportation of radioactive waste needs to be included in a complete impact assessment. Under the Impact Assessment  Act, any physical activity that is incidental to the project is an integral part of the assessment. Transportation of nuclear waste is necessary for DGR’s stated purpose and, as such, transportation risks, haul routes and alternatives all need to be assessed and evaluated.  The NWMO intends to send 2-3 trucks per day for fifty years to the DGR. The trips will average 1,800 km over mostly two-lane public roads, travelling from nuclear generating stations in southern Ontario and eastern Canada. The transportation of this amount of waste over such large distances has not happened before in Canada, or elsewhere, so scrutiny is needed.

Forth, very little detail is provided regarding the environmental and health impacts of the DGR project along the whole chain of the events - from packaging at the original site, through transporting the material (including what are the risks of an accident en route to the DGR), through repackaging at the DGR (something not proposed anywhere else in the world), placing it underground and then the issues with long term storage. No details are given regarding the monitoring of the release  of radioactive gas during repackaging or from the DGR. Water is treated as if it will not be contaminated by repackaging or storage.

In conclusion, I have other concerns over the IPD but the ones that I would like to most express now are:

• the need for a full impact assessment under the Impact Assessment  Act
• transportation needs be included in the assessment
• the need and purpose of a DGR has to be looked at objectively and independent of industry and political interference
• environmental and health impacts must be identified, recognized and treated seriously in the assessment.

Thank you for the opportunity to submit my comments regarding the concerns about the Initial Project Description  of the Deep Geological Repository (DGR) for Canada's Used Nuclear Fuel Project.