My concerns regarding this project

I am writing to you tonight to express my concerns regarding the Nuclear Waste Management Organization’s proposed deep geological repository for nuclear fuel waste which the NWMO is proposing to construct and operate between Ignace and Dryden in northwestern Ontario.

While I have many concerns about the project itself, the method of selecting the site and the site selection itself. My comments tonight are specifically on the Impact Assessment review process which began on January 5th and the NWMO’s “initial project description”. 

Firstly, the 30-day comment period is far too short. Many people who are concerned about this project, especially when you include the transportation of the radioactive waste to the site, will not have even heard about the comment period before its long over. Not to mention that for those of us who were alerted to the comment period it is a very short period of time to formulate well informed commentary on the initial project description. This is an important project that will have impacts far, far into the future. The review process must be thorough and allow public participation, and a 30-day comment period works against that, at the benefit of the proposers.

Secondarily, the project description was done poorly and leaves out important information about the project.  For one, the NWMO is trying to persuade the Impact Assessment Agency that transportation does not need to be included in the review, even after describing transportation itself as part of their project for more than twenty years. The transportation of the nuclear waste is an integral, fundamentally related component of the project that should not be excluded, especially considering that the transportation of the waste, which would occur daily for 50 years on our dangerous highways.

LONG-DISTANCE TRANSPORTATION NEEDS TO BE INCLUDED IN THE PROJECT REVIEW.  

The NWMO has failed to provide nearly enough information about project activities, and the project activities that pose radiological risk for residents in the area and for those who live downstream from the project site and the workers doing all of the work on and around the nuclear material. There is not enough information about the Used Fuel Packaging Plant, like how wastes will be transferred into the underground and placed in the emplacement rooms, how the containers will be monitored after they are underground, and how they will be retrieved or repaired in the event of a container failing.  

I ask that Section 22 of the Impact Assessment Act, and all other relevant sections of the Act, be taken into account. This section in particular requires assessments of projects to take into account environmental, health, social, and economic conditions and the rights of Indigenous peoples/concerns of the public, as well as alternatives or alternative means of carrying out the project like site selection, etc. 

THE NWMO MUST BE REQUIRED TO PROVIDE A DETAILED PROJECT DESCRIPTION.  

I am humbly requesting that this project is the subject of a full and complete impact assessment, including an (independent) integrated review panel according to section 43 of the Impact Assessment Act. As well as a public hearing, and that the Impact Assessment Agency makes sure that the public is able to participate in a way that our voices are heard through each step of the process.  

Finally, I greatly ask the people in charge to remember the United Nations Declaration on the Rights of Indigenous Peoples [UNDRIP] that has been adopted into domestic Canadian law through the UNDRIP Act as confirmed by the Supreme Court of Canada in Reference re An Act Respecting First Nations, Inuit and Métis children, youth and families. 

Article 29.2 of UNDRIP says that "states shall take effective measures to ensure that no storage or disposal of hazardous materials shall take place in the lands or territories of indigenous peoples without their free, prior and informed consent." The Federal Court of Canada in Kebaowek First Nation v Canadian Nuclear Laboratories recently held that, in the context of the disposal of nuclear waste, the honour of the Crown requires that the Crown deeply consult with the objective of obtaining the consent of the Indigenous peoples affected AND consultations must be conducted in a manner which is tailored to indigenous laws, knowledges, and practices. 

The Nuclear Waste Management Organization [NWMO] has, so far, disregarded this constitutional obligation. The NWMO can acknowledge reconciliation all they want in their initial project description, but this means nothing when Eagle Lake First Nation, who shares their traditional territory with Wabigoon First Nation and whose traditional territory overlaps with the project area, has been left out of the consultation and site selection processes. Other First Nations communities will experience nothing short of devastation if this unprecedented project goes awry. 

Thank you for your consideration of my comments and concerns.

Hetty Blundell