Comments on Draft Integrated Tailored Impact Statement

The most disheartening sentences in this document occur in Section 2.8.3 Alternatives to the project:

IAAC will rely on the proponent’s Initial Project Description demonstrating that there are no alternatives to the project that are technically and economically feasible to meet the need for the project and achieve its purpose. The selection of electricity generation technologies and the broader energy supply mix in Ontario are matters determined through provincial energy planning and policy processes, including Ontario’s Integrated Energy Plan.

It will not reassess provincial energy policy or determine the appropriate electricity generation mix for the province. On this basis, the information provided in the Initial Project Description is considered sufficient to address alternatives to the project for the purposes of these Integrated Guidelines, and no additional information is required.

This is an absolute abdication of the purpose of the IAAC process. If we are not using facts and science to consider the potential alternatives then truly, what is the point? The IESO study did not show that nuclear was the only way for Ontario to proceed and certainly not the fastest or most cost-effective way to meet our energy needs. This decision reveals the IAAC process as a sham.

Instead of demanding an even-handed analysis of alternatives, you are enabling a purely political decision by an Ontario government with a record of running rough-shod over environmental protections. Is putting virtually all of Ontario’s energy eggs (investments) in the very expensive nuclear basket really the best approach?  

Furthermore, so far, Canada only has “a plan” to deal with a portion of the existing nuclear waste created over the lifetime of our nuclear sector. There is a high risk (I would guess a 50/50 chance) that the NWMO’s plan for the DGR at Ignace will not come to fruition this century. I expect the odds are even lower of developing the barely conceived Low and Intermediate level repositories and a second DGR for all the used fuel from the newly planned reactors and refurbishments.

And yet it seems, according the to section on decommissioning plans in Section 2.5.1 (p. 12) it seems the federal government is likely to continue, inexplicably, to allow the nuclear sector to continue to expand this toxic legacy of nuclear waste. This apparently will be permitted if the Impact Statement simply describes “reasonably foreseeable long-term management pathways”. The proponent will undoubtedly allude to existence of the recently updated federal nuclear waste policy and repeat the vague promises of the NWMO (i.e., the generators) of their plans and pathways, none of which has yet to be approved, no less executed.

In section 5.7.1, p. 33, mention is made of studies required relating to ground and surface waters including Lake Ontario, which include

“modelling, such as hydrodynamic modelling, to characterize coastal processes, including a quantitative sediment movement and size spectrum through littoral transport, flow directionality, velocity, and shear stress. Modelling should also examine shoreline recession rates and sediment inputs;”

It was not clear at what scale this kind of study would be done. If any lake infilling, shoreline hardening, construction of piers, intake and outfall structures are to be part of the project, it will be critical to consider impacts on currents and sediment transport, wave action and potential flooding along the shoreline well beyond the limits of the site. Flooding of shoreline neighbourhoods was experience in Clarington a few years ago during very high lake levels. With more extreme weather events, including rain and wind, as result of climate change, changes to the shoreline at NNW could have impacts further afield. This needs to be studied.

As a general comment, impacts of the project will affect the human community (e.g. impacts on demand for housing, schools, health care, social services) and physical environment well beyond the site. These must be considered in scope for the IA.