Over 100 Great Lakes Mayors and Elected Officials unite and urge Canadian Minister of Environment and Climate Change to halt the nuclear waste dump on the shore of Lake Huron

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On November 30th, 2017, 104 Great Lake Mayors and elected officials signed an open letter to Catherine McKenna, the Canadian Minister of Environment and Climate Change, urging her to halt the Ontario Power Generation (OPG) proposal to bury nuclear waste on the shore of Lake Huron.

The mayors and elected officials combined represent approximately 16 million people. The letter describes OPG’s failure to consider alternative sites, reminding the Minister that her decision will affect 40 million Canadians and Americans who rely on the Great Lakes for drinking water.

SOS Great Lakes thanks the 104 mayors and elected officials who voiced their opposition and who continue to protect the Great Lakes from nuclear waste.

If you would like to stand with us to fight OPG’s plan, write now: http://www.sosgreatlakes.org/sayno

Great Lakes Congressional leaders urge the U.S. to oppose OPG’s planned nuclear waste dump

A bipartisan coalition of U.S. Congressional representatives from the Great Lakes Region have come together to urge the U.S. Secretary of State to stop plans to bury radioactive waste on the shore of Lake Huron.

Letter to Secretary Rex Tillerson, signed by 32 Members of Congress 

Letter to Secretary Rex Tillerson, signed by 32 Members of Congress 

In a letter to Secretary of State Rex Tillerson, 32 Congressional representatives urged him to protect the Great Lakes and to convince the Canadian government to select an alternative site for the storage of nuclear waste. The letter states that nuclear waste storage within the Great Lakes basin carries heavy risks that could be fundamentally devastating to the entire region and would constitute “a potential catastrophe of epic proportions."

SOS Great Lakes, along with 224 towns, counties, and cities, and millions people in Canada and the United States, is fighting Ontario Power Generation's (OPG) plan to store up to 400,000 cubic metres of radioactive waste in a repository less than 1 km from Lake Huron.

We want to thank the 32 elected representatives for standing up for the Great Lakes and the 40 million people who rely on them for drinking water, jobs, and their way of life. 

Please continue to voice your opposition. The Great Lakes Basin is no place for nuclear waste.


Read more from The Buffalo News

Read more from the Detroit Free Press

Learn more about the plan to store nuclear waste on the shore of Lake Huron.

Want to know more? Listen to Claire McCormack interview the Director of SOS Great Lakes

On January 24th, 2017, Claire McCormack interviewed Rod McLeod, Director of SOS Great Lakes, on The Open Line (560 CFOS).

They discussed our organization and Ontario Power Generation's (OPG) plan to bury nuclear waste in a Deep Geologic Repository (DGR) on the shore of Lake Huron. 

Listen to the rest of the interview with Rod McLeod to learn more about SOS Great Lakes and OPG's plan:

  1. What is the Deep Geologic Repository Project (DGR?)

  2. What is SOS Great Lakes?

  3. What is OPG's Plan to Bury Nuclear Waste in the Great Lakes Basin?

  4. What Goes in the DGR?

  5. What is OPG's Reasoning Behind the DGR?

  6. Hosting the Nuclear Waste Repository

  7. The Great Lakes Community 

The full podcast is available on the 560 CFOS website. 

HAPPY WORLD ENVIRONMENT DAY

IT’S TIME TO STAND WITH NATURE AND WITH THE GREAT LAKES 

Today, June 5th 2017, Canada is hosting World Environment Day and this year the theme is “connect with nature”.

World Environment Day is an annual day of awareness and action for the protection of the environment and has been a catalyst for change since it was established by the United Nations in 1974. 

It is an opportunity for individuals to do something to take care of the environment and became an agent of change. We believe taking care of the environment means protecting the Great Lakes from the threat of nuclear waste.

Today, we ask you to say:

I’m with nature,

I’m with the Great Lakes,

they are no place for a nuclear waste dump.

  • Follow us and share our posts on Facebook and Twitter 
  • Get in touch with your government and tell your elected representative(s) that you oppose the burial of nuclear waste on the shore of Lake Huron. 
  • There are many ways to Get involved

 

For more information about the plan to bury nuclear waste on the shore of Lake Huron click here

Find out what you can do during Canadian Environment Week

Take a picture of a place that matters and share it!

Listen to Ellen Dailey, VP of SOS Great Lakes, discuss the Nuclear Waste Dump on Lake Huron: Environmental Assessment, Risks, and Resistance

On April 5th, 2017, the Canadian Environmental Assessment Agency asked Ontario Power Generation (OPG) to provide additional information regarding their plan to bury nuclear waste in a Deep Geologic Repository (DGR) on the shore of Lake Huron. 

The Agency chastised OPG for its superficial exploration of alternative locations and emphasized that indigenous peoples’ perspectives need to be better represented. This is the SIXTH time OPG has been asked to provide more information on the project. 

Tomorrow, on May 26th, 2017, OPG will respond to the Agency's April 5th request for more information. 

Listen to our Vice President, Ellen Dailey, discuss the risks of building a nuclear waste dump near the lake and why we should fight to protect it. 

SOS Great Lakes attends the Great Lakes People's Summit

On Wednesday May 17th, 2017, Jill Taylor (President of SOS Great Lakes) attended the Great Lake People's Summit hosted at the Canadian Environmental Law Association (CELA) office in Toronto, ON.

The Summit was a wonderful opportunity for SOS Great Lakes to connect with representatives of environmental groups from all around the Great Lakes Basin including Ontario Headwaters Institute, Freshwater Future Canada, Ontario Metis Nation, Environmental Defence, WWF-Canada, Chippewas of the Thames First Nations, Sierra Club Ontario, and Lake Ontario Waterkeeper.

During the day, we work with other experts and stakeholders to strategize on Ontario public policy priorities for the Great Lakes Basin and develop collective action plans. Priorities that were identified included researching fish health and consumption guidelines, reducing exposure to endocrine disrupting chemicals (EDCs), improving storm water management, and increasing education & engagement on issues impacting the Great Lakes.

Over the next 12 months, the priorities will be reviewed and action plans will be implemented. A follow up meeting will take place in the fall of 2017 so that progress can be reviewed and strategies can be updated.

Maude Barlow Statement on Nuclear Waste Storage

“Burying nuclear waste hundreds of meters from Lake Huron is a catastrophe waiting to happen. These and other extreme energy projects such as fracking, tar sands oil pipelines and shipments are putting the Great Lakes in peril. I have traveled to all corners of the Great Lakes Basin and have spoken to people from all walks of life about their love of the lakes. The Great Lakes are a lived Commons and must be shared, protected, carefully managed and enjoyed by all who live around them from generation to generation. We have a responsibility to future generations to stop projects that could harm their drinking water. The waters of the Great Lakes are a public trust and governments have the responsibility to safeguard them for the common good and not allow them to be appropriated for private gain. Minister Catherine McKenna has a momentous decision to make in the coming weeks and I hope she shows communities around the Basin that the Trudeau government is serious about its renewed commitment to protect the Great Lakes and St. Lawrence River Basin.”

Maude Barlow is the National Chairperson of the Council of Canadians and chairs the board of Washington-based Food and Water Watch. She is a board member of the San Francisco–based International Forum on Globalization and a Councillor with the Hamburg-based World Future Council.

Maude is the recipient of twelve honorary doctorates as well as many awards, including the 2005 Right Livelihood Award (known as the “Alternative Nobel”), the 2005 Lannan Foundation Cultural Freedom Fellowship Award, the Citation of Lifetime Achievement at the 2008 Canadian Environment Awards, the 2009 Earth Day Canada Outstanding Environmental Achievement Award, the 2009 Planet in Focus Eco Hero Award, and the 2011 EarthCare Award, the highest international honour of the Sierra Club (US).

In 2008/2009, she served as Senior Advisor on Water to the 63rd President of the United Nations General Assembly and was a leader in the campaign to have water recognized as a human right by the UN. She is also the author of dozens of reports, as well as 17 books, including her latest, Blue Future: Protecting Water For People And The Planet Forever.

2015 PUBLIC COMMENT PERIOD: 98% OF PEOPLE ARE OPPOSED TO THE BURIAL OF NUCLEAR WASTE IN THE GREAT LAKES BASIN.

In January 2017, the Ontario Power Generation stated, "the public doesn’t really care about the proposal for the deep geologic repository (DGR)." This statement was made despite the fact that numerous organizations and individuals have spoken up against the proposed. DGR project.

Between 2012 and 2014, members of the public were allowed to submit comments on OPG’s DGR plan to the Joint Review Panel (JRP), the body tasked with assessing the project under the Canadian Environmental Assessment Act which ultimately gave the project a stamp of approval in spring 2015.

From our experience working with the JRP, we know that the process was biased in favour of OPG from the start. As we have written elsewhere, the JRP allowed OPG to proceed with their plan despite huge problems and omissions in OPG’s case. Additionally, of the well over 500 comments submitted by individuals, environmental organizations, citizens’ groups, city councils of huge cities, and Indigenous organizations, among others, an astounding 98% were opposed to the project. Here are some examples from that 98%:

“The Chippewas of Georgina Island First Nation strongly opposes the OPG-Deep Geological Repository Project. Water is our Mother Earth’s life blood. We are and always will fight to protect Water. To permit the burial of Radioactive Nuclear Waste right beside our Great Lakes goes against everything we believe in and is a crime against humanity.”

Chippewas of Georgina Island First Nation

 

“It is our responsibility, as citizens of the “Great Lakes State,” to be vigilant in protecting our most valuable natural resource --- our clean water. With an economy, reputation and livelihood that are all dependent on the health of the Great Lakes, it would not be prudent or wise to construct this underground nuclear storage facility that puts radioactive waste less than a mile from Lake Huron.”

Michigan League of Conservation Voters

 

“In order to protect the Great Lakes and its tributaries, Toronto City Council urge that neither this proposed nuclear waste repository near Kincardine, Ontario, nor any other underground nuclear waste repository, be constructed in the Great Lakes Basin, in Canada, or in the United States.”

Toronto City Council

The results of public consultation undertaken by the JRP are a strong indication that OPG lacks “social license” for the DGR project. Given that the current government has committed to more transparent, accountable environmental regulation, we hope that Environment Minister Catherine McKenna considers the strong, negative response to OPG’s plan in her future decisions regarding the DGR.

SOS Great Lakes Comments on OPG's Additional Information

After considering the Joint Review Panel Environmental Assessment Report for the Deep Geologic Repository for Low and Intermediate Level Waste, the Honourable Catherine McKenna requested additional information before making her environmental assessment decision. 

OPG had 11 months to respond to the Minister's request. In December 2016, they submitted their report. (To read the full report, click here.)

In January 2017, the CEAA "invite[d] the public, Indigenous groups, and governments to review and comment on the additional information [submitted by OPG]". 

On March 6, 2017, SOS Great Lakes submitted a thorough investigation of OPG's additional information.

The Submission: 

Our Submission to the Minister is comprised of commentary in chapter format relating each of the three primary questions sent to OPG by the Minister in February 2016. Each of our chapters has been written by one of our members. We have been assisted in our submission by Mr. John Jackson, hired through the CEAA Participant Funding Program, to prepare commentary on OPGs Cumulative Effects Analysis.

The topics discussed include: commentary on OPG’s Study of Alternate Locations, the Cumulative Effects Analysis of the DGR for L&ILW in Kincardine, in combination with 3 potential APM used fuel DGRs in the one of the communities of Huron- Kinloss, South Bruce, and Central Huron, and the OPG Mitigation Measures Report.

OPG Has Submitted a Flawed Environmental Assessment. In December 2016,

OPG has presented a deeply flawed addition to its deeply flawed Environmental Impact Statement. We urge the Minister to reject the EA for OPGs Deep Geologic Repository and to reject the licensing of the DGR at Kincardine.

To read the full submission, click here. 

Ontario Power Generation’s Report of Findings of a Public Attitudes Poll Towards the Proposed Nuclear Waste Dump on Lake Huron

Executive Summary

A review of sampling, methodology, and reporting of the Ontario Power Generation Report of the Deep Geologic Repository Study by the Gandalf Group shows:

  • the entire poll, from sampling, through question design, to reporting is highly irregular;
  • most questions are loaded with false or misleading assumptions designed to skew the response in favour of the DGR;
  • there is no evidence to support OPG’s claim that the majority of people are in favour of building a DGR on Lake Huron;
  • the only substantive finding supported by evidence shows most Ontarians (64%) believe the DGR poses a threat to public drinking water and to the health of the Lake.

If this study is to be believed, the data supports only one conclusion about Ontario public opinion on OPG’s proposed nuclear waste dump: it may be okay to build a DGR somewhere in Ontario, but not near Lake Huron.
These views are discussed under the above headings in this report.

 

OPG’s public opinion poll of attitudes about the dgr, from sampling through question design to reporting, is highly irregular.

Accuracy and clarity in design of the questions are important elements in attempting to accurately gauge public opinion. If the questions asked are ambiguous or unnecessarily complex, the results of the study are likely to be erroneous.

The wording of the questions posed in this study often omit essential facts and lack clarity.

After establishing a baseline of attitudes about nuclear waste in the first part of the survey, respondents were then presented with a series of statements which reflect OPG’s response to critical statements by opponents of the project. These statements reflect only a small part of the actual criticism and often ignore the main objections expressed by opponents.

For example, Question 38 C:

Do you strongly agree, somewhat agree, somewhat disagree or strongly disagree with the following statement:

We can’t be confident that Kincardine is a good location for the Deep Geologic Repository because OPG didn’t look at other locations.

Opponents of the project object to the Lake Huron site of the proposed DGR for three main reasons: it is too close to the source of drinking water for 40 million people; the geology of the site is questionable and unproven; and, in selecting the site, OPG ignored Canadian Environmental Law which requires the proponents to examine multiple locations and to provide detailed alternatives to regulatory authorities.

Clearer statements to test public opinion of the site location issue would be:

Since Canada’s Environmental Laws require careful examination of alternative sites, OPG should be required to conduct detailed examination of alternative sites.

Or,

Because 40 million people rely on the Great Lakes for drinking water and since every nuclear waste DGR in the world has failed, building a DGR 1.2 km from the shore of Lake Huron presents unacceptable risks to society, and the environment.

The difference between these statements and those posed by OPG, is that all the information in these statements is factual, provable and true, while OPG’s statements are largely half true, untrue or unsubstantiated statements favouring the DGR. After listening to these statements, respondents were then asked similar questions to the earlier ones.

Naturally their responses between the first set of questions and the second set of questions, changed dramatically. For example, consider Questions 38B and 50A.

Questions 38B asks:

Do you strongly agree, somewhat agree, somewhat disagree or strongly disagree with this argument:

Other Deep Geologic Repositories have failed in other countries, so the science can’t be trusted.

More than half, 56%, of respondents strongly agree or agree with this statement. Among females, 70% of respondents believe it poses a threat. Imagine what the answers would have been if the statement was more accurately phrased as:

Every attempt at burying nuclear waste in a DGR in the world has failed, so OPG’s plans for a DGR can’t be trusted.

Later on, in Question 50A, respondents were asked whether they agreed with the following statement:

Deep Geologic Repositories have safely stored waste around the world including in the United States, Sweden, Germany, Korea and Finland.

This question did not even specify that the waste was nuclear waste.  Because of the intense testing that goes into the wording of survey questions, we do not believe this to be a typo.

While OPG continuously uses these countries as examples of effective DGRs, it is so misleading as to be false. ASSE Germany successfully stored nuclear waste for 30 years,  until it started to leak. Now it presents a growing monumental environmental and health disaster throughout the region and appears to be unstoppable. Carlsbad New Mexico operated safely until it caught on fire. Sweden’s experience was going well until the containers started to fail much sooner than anticipated. France’s test underground research laboratory built in similar geology to OPG’s proposed DGR was progressing well until it collapsed killing workers, and so on. But this information was not presented to respondents.

Even the next statement, Question 50B, is carefully ambiguous but still inaccurate:

Experts from around the world, including the U.S. Environmental Protection Agency agree that this Deep Geologic Repository will protect the environment from nuclear waste.

It is true that some international experts support the DGR. It is equally true that some international experts, particularly those with experience, believe DGRs to be unsafe. While the U.S. EPA has asked questions about the DGR, they have not expressed an opinion that the proposed DGR will be safe.

In all, some 45 statements about the science, geology, safety, danger to the Lake, transportation risks, alternate sites, and community acceptance were all of little or no evidentiary value because they inevitably contained misleading or false assumptions or statements.

 

There is no evidence to support OPG’s claim that the majority of people are in favour of building a DGR on Lake Huron

We have reviewed the Gandalf poll in detail and we can find not a single question which supports OPG’s claim that a majority of the Ontario public support the idea of building a nuclear waste DGR on the shore of Lake Huron. In fact, the findings of this survey clearly and definitively oppose this project.

The only question remotely relevant to OPG’s claim of public support is the response to Question 70.

The question says:

Again, after hearing all of this information, would you say that you strongly support, somewhat support, somewhat oppose, or strongly oppose the proposed Deep Geologic Repository being built in Kincardine, Ontario?

Responses to the question would indicate support or strong support (71%) for the proposed Deep Geologic Repository being built in Kincardine, if it actually represented a random sample of the Ontario public, which, as explained below, it does not.  

Quite apart from the fact that the DGR is being built not in Kincardine but on the shoreline of Lake Huron, this response in no way reflects public opinion in Ontario towards the DGR.  By their own admission, a very large number of Ontarians are unaware of the proposed project.

The only dubious claim of support that OPG can make from this study is that of the 805 people who responded to this telephone survey, 71%, or 572 people support the DGR after being exposed to a number of inaccurate or untrue statements about the DGR provided by OPG. This claim is not supported by the data.

While they claim their sampling method is representative of public opinion with a reliability of 95%, they do not offer detailed information of their sampling methodology. The industry norm is to provide full details of all methodology which they do not. Furthermore, 805 people is a very small sample and their regional analysis, because of margins of error that are in the mid to high teens, are not reliable measures.

 

the only substantive finding supported by evidence shows most Ontarians (64%) believe the DGR poses a threat to public drinking water and to the health  of the lake.

 

Early on in the study, respondents were asked a number of questions about their views on nuclear energy, their knowledge of nuclear waste management and their opinion about DGRs. In question 26 some respondents were asked:

And based on what you know, would you say that you strongly support, somewhat support, somewhat oppose, or strongly oppose a Deep Geological Repository being built in Ontario to store the waste produced by Ontario's nuclear generation of electricity?

Responses showed 59% of those who were asked the question, approve a DGR being built in Ontario. This is the only question that probes public opinion of the DGR and shows support, in the entire survey.

Let’s look at what it actually supports and how much support is really there.

The question was only asked of those who said they knew something about DGRs (56% of respondents) even though most of those people admittedly knew little. In professional terms, it is called unaided awareness.  Among pollsters, unaided awareness carries a lot of weight because it means people are aware of the information being tested. Normally, the level of unaided awareness would be probed. Pollsters would normally attempt to separate those who said they are aware from those who actually are aware. In this study, there were no attempts to verify unaided awareness. If respondents said they had heard of DGRs they were considered knowledgeable.

Notice that the wording of this question fails to provide a specific location for the DGR.  This is not support for the Lake Huron DGR. It is support for a DGR somewhere in Ontario.

Question 26 was asked to the 56% of respondents who said they were aware of DGRs.  Only 33% of all respondents, expressed support for a DGR somewhere in Ontario. According to the actual data in this study, aside from the 266 respondents who approve of a DGR somewhere in Ontario, there is no evidence in this study that a single person in Ontario actually supports construction of a DGR on Lake Huron.

Whatever support OPG reports from this study is manufactured from highly biased, unsubstantiated and inaccurate statements fed to respondents.

Moreover the responses from those manufactured statements cannot be projected to reflect the opinion of the Ontario public. Again, to be clear, all respondents were asked a series of questions. Then all respondents were asked about their support for a series of statements, almost all of which were unsubstantiated, inaccurate or ambiguous. From these latter responses based on questionable information, OPG erroneously claims strong support for the DGR on the shore of Lake Huron.

This claim is not only unsupportable by the evidence in the study, but it is preposterous and false. While the respondents, some 805 people from Ontario, were presented with some questionable information and as a result, changed their opinions about the DGR, those results cannot possibly be projected to represent the views of the Ontario public because the information used to manufacture those views, has not been presented to or accepted by the Ontario public.

In the final analysis, there are only two questions relevant to the DGR whose responses can be considered a reflection of the broader public opinion.

Question 26, asked to 56% of respondents:  

And based on what you know, would you say that you strongly support, somewhat support, somewhat oppose, or strongly oppose a Deep Geological Repository being built in Ontario to store the waste produced by Ontario's nuclear generation of electricity?

 

Roughly 33% of respondents showed support for a DGR somewhere in Ontario.

Question 38A asked all respondents:

Do you strongly agree, somewhat agree, somewhat disagree or strongly disagree with this argument?

The DGR will be built 1.2 km away from Lake Huron, it will pose a threat to our drinking water and to the health of the Lake.

About two thirds of Ontarians  (64%) believe a DGR built 1.2 kms away from Lake Huron will pose a threat to drinking water and the health of the Lake.

If this study is to be believed, the data supports only one conclusion of Ontario public opinion on OPG’s proposed nuclear waste dump: It may be okay to build a DGR somewhere in Ontario to store nuclear waste, but not near Lake Huron.

 

To view the original Gandalf Survey click here. 

To view a PDF of the analysis, click here

 

WRITE TO YOUR MP NOW AND SHARE THIS STORY. CLICK HERE TO ACCESS OUR CAMPAIGN

Video Launch: Great Lakes Threatened With Radioactive Waste - SOS Great Lakes

Right now, there is a plan to bury nuclear waste on the shore of Lake Huron. A plan that could result in the pollution of the largest basin in the world for 100, 000 years, the Great Lakes Basin.

Ontario Power Generation (OPG) is a Canadian power company that plans to bury up to 400, 000 cubic metres of radioactive nuclear waste less than 1 km from Lake Huron. This means building a nuclear waste dump on the shore of the Great Lakes, a source of drinking water for 40 million people in Canada and the United States. 


We are SOS Great Lakes. We are challenging OPG’s dump. 


We are among more than 100 organizations, 100 communities and 150 000 people in Canada and the U.S. who want Catherine McKenna, the Canadian Minister of the Environment and Climate Change, to say NO to the dump. 

We believe that if the 40 million people who rely on the Great Lakes for drinking water knew about this highly risky and needless threat to the Great Lakes, they would never allow it to happen.

We can’t reach those people by ourselves. Join us. Share this story. 

Your lakes, your choice. 


Read about 8 reasons to stop the DGR: http://www.sosgreatlakes.org/8-reason...

Follow SOS Great Lakes for updates: http://www.sosgreatlakes.org/tell-you...

Reach out to your government: http://www.sosgreatlakes.org/government/

January 9, 2016 - OPEN LETTER TO THE HONOURABLE CATHERINE MCKENNA - REGARDING THE OPG DECEMBER 2016 RESPONSE ON THE DGR 1, KINCARDINE, ONTARIO.

January 9th, 2017

Honourable Catherine McKenna

Minister of Environment and Climate Change

House of Commons

Ottawa   ON   K1A 0A6

 

OPEN LETTER TO THE HONOURABLE CATHERINE MCKENNA - REGARDING THE OPG DECEMBER 2016 RESPONSE ON THE DGR 1, KINCARDINE, ONTARIO.  

 

Dear Minister McKenna:

  1. It is time for the Canadian government to do its job and enforce the Environmental Assessment Act. This is at least the fifth time OPG has been asked to identify specific alternate sites and they have again refused to do so, as they have done every time. Their entire proposal should be rejected now.

  2. The opportunity for public input on the OPG Response is wholly inadequate. OPG has had 11 months since your first letter to answer your questions and you have given us 30 days to respond to over 500 pages of material. This is unfair to the public and to the government if you truly want meaningful public input.

  3. You continue to dodge multiple additional errors. For at least 5 years before your appointment, the Harper Government allowed OPG to flagrantly violate the CEAA in multiple ways by refusing, in its EA, to address or seek: 1.) Alternate Sites, 2.) Alternate Means, 3.) Evidence-Based Science, 4.) Critical Health and Safety Issues, 5.) Need/Cost, 6.) International Obligations, - all mandatory requirements of CEAA. Since your appointment, you have been advised of two additional issues:  7.) Bias of the JRP, and 8.) OPG’S deception of the Public about the issue of Community Acceptance. This includes our documentation regarding how OPG was aided in these errors by seriously inadequate regulation by CNSC and the CEAA/CNSC created JRP.

You have chosen to ask OPG for further information re: Issue 1.) Alternate Sites, and important related questions: cumulative effects and mitigation. You have been silent on the other seven issues, thereby creating, rightly or wrongly, a public impression that you are only going to address Issue 1.). This, in turn, has created the further impression that if OPG succeeds on Issue 1.), the remaining seven issues remain unaddressed. If this is wrong, please tell us so. The public is entitled to know whether you have an intention of doing anything about the errors by OPG, CNSC and the JRP with respect Issues 2.) through 8.) as they apply going forward.

When you have acted on Issue 1.), OPG has repeatedly defied you, by re-writing your questions rather than answering them, - precisely what OPG did to the JRP. This has created the public impression, again rightly or wrongly, that the Government of Canada is reluctant to stand up to OPG. This impression is re-enforced by a proposed public consultation process that disadvantages anyone opposed to OPG.
 

We remain committed to working with you in the review of the OPG response that was recently submitted, but are increasingly concerned that this process will not address the outstanding issues that remain or present a fair forum for public input based on the published information regarding the process.  We respectfully urge you to seriously consider our concerns.

 

Yours very truly,

Jill Taylor, President

SOS Great Lakes

On behalf of the Board of Directors

 

With copies to:

 

The Right Honourable Justin Trudeau, Prime Minister of Canada

The Honourable Kathleen Wynne, Premier of Ontario

The Honourable James Carr, Minister of Natural Resources

The Honourable Stephane Dion, Minister of Foreign Affairs

The Honourable Kirsty Duncan, Minister of Science

The Honourable Ralph Goodale, Minister of Public Safety and Emergency Preparedness

The Honourable Dominic LeBlanc, Minister of Fisheries, Oceans and the Canadian Coast Guard

The Honourable Jane Philpott, Minister of Health

The Honourable Glenn Thibeault, Minister of Energy

The Honourable Eric Hoskins, Minister of Health and Long Term Care

The Honourable David Orazietti, Minister of Community Safety and Correctional Services

The Honourable Glen R. Murray, Minister of the Environment and Climate Change

The Honourable Kathryn McGarry, Minister of Natural Resources and Forestry

Marlo Raynolds, Chief of Staff, Environment and Climate Change Canada

Ron Hallman, President, Canadian Environmental Assessment Agency

To view a PDF of this document, click here



 

November 9, 2016 - Submissions to the Expert Panel, November 9, 2016

On November 9, 2016 members of SOS Great Lakes contributed to the review of the Environmental Assessment and presented to the Expert Panel. 

About the Environmental Assessment Review: http://eareview-examenee.ca/

Submissions to the Expert Panel: http://eareview-examenee.ca/submissions-received/

  • Jill Taylor's Submission (President, SOS Great Lakes): 

http://eareview-examenee.ca/view-submission/?id=1482519062.4828

  • Rod McLeod's Submission (Director, SOS Great Lakes): 

http://eareview-examenee.ca/view-submission/?id=1481122183.4676

http://eareview-examenee.ca/view-submission/?id=1481122089.1196

  • Eugene Bourgeois's Submission (Director, SOS Great Lakes): 

http://eareview-examenee.ca/view-submission/?id=1483027342.8058

http://eareview-examenee.ca/view-submission/?id=1481051019.9913

 

 

October 5, 2016 - Great Lakes Public Forum--Jill Taylor, President, SOS Great Lakes

Introduction

SOS Great Lakes, is an organization of Canadian and American Citizens dedicated to keeping the burial of radioactive nuclear waste out of the Great Lakes Basin. We are not anti- nuclear, but are deeply opposed to the reckless plan of the Ontario Power Generation Inc. (OPG) to construct a deep geological repository for up to 400,000 cubic meters of Low and Intermediate Level nuclear waste on the shore of Lake Huron at the Bruce Nuclear Plant. This project, if approved, could begin before 2020. I will refer to this as “the plan”. 

The burial of this vast quantity of radioactive nuclear waste would result in a continuous risk of radiotoxic poisoning of Lake Huron, the Great Lakes and the St. Lawrence River System. The OPG Plan should concern this Forum for at least 3 reasons: 

  1. These Radionuclides Are Persistently Destructive: the extremely destructive character of this waste, the persistence, likely migration, and the long residence of its contaminant properties, (stated by OPG to last over 100,000 years); 
  2. The Plan Violated the Canadian Environmental Assessment Act (CEAA): OPG and the Federal Joint Review Panel (JRP) failed to follow the governing legislation in multiple ways on several occasions; to date, the Minister responsible for CEAA has failed to take appropriate action in response to these violations; 
  3. Deeply Flawed Science: both OPG and the JRP failed to rely on evidence based science. What they did use was demonstrably unreliable. 

 

1. Persistently Destructive

You have said in your Progress Report that you are interested in chemicals that are persistent: no substance is more persistent than the radioactive intermediate and high level waste, in combination with our waters. “Over 100,000 years”, exceeds the definition of ‘persistence’, and cannot be ignored. 

Since the DGR idea was hatched in the 1990s, international experts have consistently derided the science and lack of common sense of a DGR on the Great Lakes, saying that the DGR will NOT be able to contain nuclear waste and prevent the contamination of the ecosystem, including the Lakes and the people around it. Yet, the Ontario and Canadian Governments continue to allow consideration of this plan long past its best before date, if it ever had one. 

2. Multiple Violations of the Canadian Environmental Assessment Act (CEAA) 

 

In a direct affront to the Canadian Environmental Assessment Act, OPG refused to consider alternate sites in addition to the sedimentary geology of the near shore environment of the Bruce. The Minister asked OPG for further and better information about alternate sites. OPG rephrased the Minister’s question and said it would provide a response to its rephrasing by December 2016. 

Citizens groups such as ours have advised the Minister of multiple other violations of CEAA. To our knowledge, the “alternate site violation” is the only one to which the Minister has responded publically. 

OPG has stated that not only will the DGR leak, but that their storm water management system to protect the ground water and Lake Huron in an unplanned event is totally insufficient to handle extreme weather events. In another affront to logic, OPG refused to consider that climate change, including already dramatic patterns of Great Lakes weather and precipitation, would increase the risks to public safety or the environment as they might act on the DGR, or have an effect on plans for emergency management of accidents and malfunctions during the 300 years of institutional control. 

During the Joint Review Panel hearings in the fall of 2013, thousands of pages of testimony were read into the record by citizens, politicians from Canada and the US, scientists of all stripe, including nuclear specialists and former OPG employees, economists, geologists, conservation advocates, sociologists, doctors and indigenous people that refuted the logic and safety of the proposal for the deep underground dump on the shore of Lake Huron in sedimentary rock. 

Evidence of improper adjudication and presentation of evidence, financial coercion by the proponent and the denial of international obligations were rampant. 

We have filed an application for Judicial Review (JR) against the Canadian Government, CNSC and OPG, to challenge JRP’s acceptance of the OPG Nuclear Waste Dump Plan based primarily on these multiple violations. CEAA requires the Minister to either reject or accept the plan. If she rejects it, a Judicial Review Application is moot. If she accepts, the JR is converted automatically to a JR of her decision. 

We believe there are ample environmental protection public policy reasons why this matter should never have to go to court.

 

3. Deeply Flawed Science

Every day, new evidence emerges exposing even more faults in the OPG DGR plan, and its woefully inadequate ‘science’. OPG has acknowledged that the physical structure and storage vaults of the planned repository will disintegrate after construction, and that radionuclides will eventually leak into the water and environment. They say it is not if, but when the repository will leak. 

The gravity of this and similar statements in their EIS persists despite tragic failures elsewhere. This year, there was a collapse of a tunnel during an underground scientific pre- test of similar DGR in sedimentary geology in France during which a worker was killed and others injured. In 2014, in Carlsbad New Mexico the DGR that was the design model for the DGR 1 here at the Bruce Plan was closed following radioactive releases into the environment and underground fires that threatened the lives of workers and the public. 

Internationally, the concept of DGRs is in trouble! Multiple other accidents and closures of DGRs challenge the idea that a DGR will ever be built that is successful. 

Conclusion

The regulator, CNSC, has demonstrated bias and protection of industry in its monitoring and categorization of radionuclide emissions into the environment, including into the water of the Great Lakes. Relying on reductive methods they are not diligent in reporting of contamination that in other jurisdictions would be unacceptable. It is imperative that an un-biased party acknowledge the danger of radionuclide contamination and list radionuclides as a chemical of mutual concern. This action must have an effect on the CNSC and the nuclear industry to provide transparent monitoring and emergency planning. It must influence the development review of nuclear projects as a binational concern, and provide sustainable and precautionary protective measures for all sites on the Great Lakes. 

We also ask the Canadian and U.S. Governments to work together to stop the OPG plan, - a plan that was, and is, ill-conceived and does not follow the obligations of binational environmental protection about which you so proudly speak in this Forum. 

By doing so, you will join: 

  • More than 154 municipalities that have signed petitions against the plan, 
  • The Great Lakes and St. Lawrence Mayors who have thrice passed resolutions opposing the plan, and
  • 98 percent of all Canadians and Americans who responded to a letter writing campaign initiated by the Canadian Government in Sept 2015 to express their views about the decision to build this deeply flawed nuclear waste repository. 

 

We urge the Executive Committee of the Great Lakes Forum to list radionuclides as a chemical of mutual concern and immediately act to oppose the OPG’s plan for a Nuclear Waste Dump at Kincardine. 

To view a PDF of this document, click here.  

October 5, 2016 - Great Lakes Public Forum--Eugene Bourgeois, Director, SOS Gret Lakes

Good afternoon,

 

My name is Eugene Bourgeois and I am a retired sheep farmer living in Inverhuron, home to both a nuclear power plant and the proposed Deep Geologic Repository for low- and intermediate-level nuclear wastes, right here beside and below Lake Huron.  

 

It is surprising to me that radionuclides are not already Chemicals of Mutual Concern in the Great Lakes Water Quality Agreement under Annex 3, as recommended by your own Nuclear Task Force 20 years ago.  

 

We learned in the late 1880’s that when we use our rivers as sewers innocent people die.  We were reminded of this recently in Ontario when Walkerton’s water was contaminated by farm sewage and a number of people died.  In each case, the solution to pollution was believed to be dilution.

 

The National Academy of Sciences has established that there are no known safe concentrations of exposure to radionuclides and so, has adopted a Linear No Threshold standard.  The recent KiKK study in Europe demonstrated the strong statistical correlation between exposure to chronic low doses of ionising radiation and childhood leukaemia, effects that increase the closer one lives to a nuclear power station, even when these are operating as permitted.  Even without this, we still manage to be exposed to the harmful effects of chronic, low doses of radiation from both cosmic and solar sources, each of which can cause sickness and death.  

 

During the Hearings for DGR, we learned that OPG’s long-term plans for this radioactivity is for it to be discharged into the groundwater and from there to Lake Huron.  It claims this won’t happen for more than a million years, similar to WIPP.  WIPP failed catastrophically after only 15 years.

 

In the 1950’s, expectant mothers were X-rayed to determine the relative health of their babies.  It was only after Alice Stewart organised the Oxford Survey in England and analysed these data that she showed X-raying foetuses itself led to early childhood death.  Buster Brown shoes offered to X-ray your feet when I was a child and many of those adolescent boys who did so are sterile today.

 

The Great Lakes are the source of drinking water for more than 40 million Canadians and Americans. Water is something each of us needs every day of our lives.  Mothers need it to mix baby food for their children.  It was a mere 75 years ago that we first split the atom, setting the stage for nuclear power production.  In every case our initial concerns about the impacts of exposure to ionising radiation have been far too liberal to safeguard people.

 

Radionuclides must be included and listed as Chemicals of Mutual Concern in Annex 3.  Without having a clearly identified understanding of them and their inventories we will not be able to research their potential adverse health effects on the populations who live near and rely on the Great Lakes for water.  

 

Thank you

o view a PDF of this document, click here. 

October 5, 2016 - Great Lakes Public Forum--Ellen Dailey, Director, SOS Great Lakes

Good afternoon Mr. Goffin, Mr.Davis, and fellow panelists.

 

Thank you for the opportunity to present my comments to the International Joint Commission (IJC) and to aid in the efforts to meet the goals of the Great Lakes Water Quality Agreement.  

 

A number of challenges threaten the sustainability of the Great Lakes. These include toxic chemicals, such as legacy contaminants and substances of emerging concern.

 

The websites of both the Environmental Protection Agency (EPA) and Environment Canada state that chemicals of mutual concern are those that originate from anthropogenic sources and that are potentially harmful to human health or the environment.

 

According to the IJC, hundreds of chemicals have been identified in the Great Lakes ecosystem. As of 1994, 362 contaminants had been confirmed as being present in measurable concentrations in the water, sediments and/or in the tissues of fish, wildlife or humans. At the time of the 1994 report, 126 of these substances had been linked to toxic effects on various life processes.

 

Some of these chemicals have been labeled “critical” and “priority contaminants” based on factors such as presence and ambient concentration, degree of toxicity, persistence in the environment, bioavailabilty, and the potential to bioconcentrate and bioaccumulate in the Great Lakes environment.

 

Yesterday I brought to your attention two reports that were prepared for the IJC in the 1990s about radionuclides in the Great Lakes. Today I would like to elaborate on this topic and why it is imperative that radionuclides be included in Annex 3 of the Great Lakes Water Quality Agreement as a Chemical of Mutual Concern.

 

The “Inventory of Radionuclides in the Great Lakes” (1997) study concluded that radionuclides were present in the lakes and that the majority were from anthropogenic sources. The study also indicated that the radionuclides are bioavailable, toxic, persistent in the environment, and have the potential to bioconcentrate and bioaccumulate.

 

The IJC’s Nuclear Task Force noted that the bioaccumulation, biomagnification, and transfer factors used to describe the cycling of radionuclides and their transfer along exposure pathways to biota, including humans, came from the long history of work done in oceans, estuarine, and river environments. Comparable studies for the Great Lakes freshwater environment were virtually nonexistent. Yet for the Great Lakes, the need for transfer factors that describe lake environments is critical.  

 

Toxicity of radionuclides

 

The Canadian Nuclear Safety Commission (CNSC), World Health Organization (WHO), and the American Cancer Society websites point out that exposure to ionizing radiation carries health risks. The review also states that some populations are more sensitive to the effects of radiation exposure such as women, children and, of course, the fetus.

 

The health risks include cancer, hereditary effects, cataracts, cardiovascular disease and stroke, immune effects, premature aging, radiation sickness, and death. Cancers associated with high dose exposure include leukemia, multiple myeloma, breast, bladder, colon, liver, lung, esophageal, ovarian, stomach, and thyroid cancers. Literature from the U.S. Department of Health and Human Services also suggests a possible association between radiation exposure and skin, prostatic, sinus, laryngeal, and pancreatic cancers.

 

Leukemia, a type of cancer that arises in the bone marrow, and thyroid cancer are among the most common radiation-induced cancers.  The reason for this may be sensitivity of the cell line or the cell’s propensity for uptake of a given radioactive element.  The thyroid gland normally takes up iodine and bone takes up strontium. Each of these elements has a radioactive isotope produced by nuclear fission and is found in the Great Lakes.

 

Thyroid cancer is known to be prevalent in the Great Lakes basin population. According to the Canadian Cancer Statistics 2013 report, the incidence rate for thyroid cancer is increasing. Furthermore, the increased incidence observed is more than the increase being seen with other major cancers. There was a 6.8 percent per year increase in males since 1998 and a 7 percent per year increase in females since 2002.

 

Less known are the potential hereditary effects of ionizing radiation. Potential hereditary effects include congenital malformation, cognitive impairment, microcephaly, growth restriction of the fetus, prematurity, infertility and pregnancy loss, including miscarriage, fetal death, neonatal death and infant death. In addition, ionizing radiation may increase the risk of cancers and other health problems in future generations due to the subtle ongoing biological impacts that may become pronounced and irreversible over time through genetic mutations. The insidiousness of radiation injury is seen in its propensity to present only after irreversible genetic damage has already occurred over an unknown period of time.

 

The BEIR VII report on health effects of ionizing radiation concludes that current scientific evidence is consistent with the hypothesis that there is a linear dose response relationship between exposure to ionizing radiation and the development of radiation induced solid cancers in humans.

 

Human activities, both historic and current, have altered and will continue to impact the Great Lakes ecosystem and the biological diversity it sustains.  Ontario Power Generation (OPG)’s proposed Deep Geological Repository (DGR) has the potential to leak radionuclides into the Great Lakes, and will likely leak, as no other DGR in the world has been successful in containing the toxic wastes it stores. The radioactivity and long-term toxicity of these lethal wastes could threaten present and future generations.

 

The Commissioner of Environment and Sustainable Development issued a report yesterday citing the CNSC for not providing appropriate inspections to ensure that nuclear facilities are meeting the regulatory requirements. It is imperative that a binational group be able to look at the data to determine what is truly happening with radionuclides in the Great Lakes.

 

We look to the continued comity between our two countries to motivate Canada and the United States to add Radionuclides to the list of Chemicals of Mutual Concern under Annex 3 of the Great Lakes Water Quality Agreement.

 

 

To view a PDF of this document, click here. 

 

July 27, 2016 - Open Letter to Minister Catherine McKenna Signed by SOS Great Lakes and 46 Other Public Interest Groups

Lake Superior Wetland in the Abbaye Peninsula Michigan

Lake Superior Wetland in the Abbaye Peninsula Michigan

SOS Great Lakes was among 47 organizations in the United States and Canada signatory to an open letter to Catherine McKenna, Minister of Environment and Climate Change, regarding OPG's response to the Minister's request for additional information about the DGR plan.

Read the letter below:

 

July 14th, 2016

Honourable Catherine McKenna
Minister of Environment and Climate Change
House of Commons
Ottawa ON K1A 0A6
 

Dear Minister McKenna,

Thank for your letter of July 4, 2016 in which you respond to Nuclear Waste Watch’s joint letter of November 19, 2015 concerning the Deep Geologic Repository Project for Low and Intermediate Level Radioactive Waste (the Project) proposed by Ontario Power Generation.

We appreciate both your response and your interim actions. In particular, we were very encouraged by the directions set out in your letter of February 18, 2016 in which you requested that the proponent, Ontario Power Generation, provide additional information on three aspects of the environmental assessment:

- technically and economically feasible alternate locations for the Project,
- cumulative environmental effects of the Project, and
- an updated list of mitigation commitments for each identified adverse effect under the Canadian Environmental Assessment Act, 2012.

As you note in your letter to Nuclear Waste Watch, on April 15, 2016 Ontario Power Generation (OPG) wrote to the Canadian Environmental Assessment Agency (the Agency) outlining its intended approach to responding to your request for additional information, and indicating OPG’s intention to provide a response by the end of 2016.

In your letter of July 4th you state that “Ontario Power Generation also noted it intends to file the requested information by the end of 2016,” (emphasis added).

In fact, Ontario Power Generation states in their letter that they do not intend to respond as directed by you. Rather than the requested information, they intend to provide you with yet another set of reports that attempt to side step what is required of them.

More specifically:

Your requirement: A study that details the environmental effects of technically and economically feasible alternate locations for the project, with specific reference to actual locations that would meet Ontario Power Generation’s criteria for technically and economically feasible.

OPG’s Response: OPG has interpreted this request as follows: OPG will assess the environmental effects of two technically and economically feasible geologic regions in Ontario for a new low and intermediate level waste (L&ILW) disposal facility.

OPG has clearly stated they intend to do something other than what you have required of them, i.e. they intend to provide a conceptual comparison, rather than an assessment based on actual locations and stated criteria. If allowed to go this route, we anticipate that OPG will provide you with another iteration of the generic evaluations they provided the Joint Review Panel during the extended hearing, after the Joint Review Panel directed them to conduct a study of alternate locations. While the Joint Review Panel failed to require OPG to follow their direction, as Minister it is essential that you hold them to a reasonable standard of performance.

Your requirement: An updated analysis of the cumulative environmental effects of the Project in light of the results for the Phase I Preliminary Assessments undertaken by the Nuclear Waste Management Organization, which identified three potential host communities that fall within the traditional territory of the Saugeen Ojibway Nation.

OPG’s Response: OPG will assess the cumulative effects of a hypothetical used fuel repository on the L&ILW DGR, within the boundaries of the DGR study area for those communities that are active in the NWMO siting process and which lie within the Saugeen Ojibway Nations (SON) traditional territory (i.e. HuronKinless and South Bruce

OPG is misinterpreting your direction. Simply put, OPG is proposing to assess the effect of one of their projects on another of their projects, rather than doing a cumulative effects study of the two projects in combination (OPG has majority control of the NWMO and owns 90% of the wastes that are subject of the NWMO project; the NWMO is the technical manager for OPG’s proposed DGR for low and intermediate level wastes). OPG’s proposed approach will not provide the information you required in your letter of February 2016.

As outlined in our joint letters of 19 November 2015 and of 6 February 2016 and in many additional public interest submissions, the Joint Review Panel recommendation that you approve Ontario Power Generation’s proposed Deep Geologic Repository for Low and Intermediate Level Radioactive Wastes was in error. Ontario Power Generation failed to meet the requirements of the Canadian Environmental Assessment Act (CEAA 2012), the Environmental Impact Statement (EIS) Guidelines, and the JRP Agreement (as amended), including in the following areas:

- not identifying and evaluating a reasonable range of functionally different “alternatives to” the DGR; 
- failing or refusing to conduct an appropriate site selection as an important component of adequately identifying and evaluating “alternate means” of carrying out the DGR; 
- making insufficient information available to identify and evaluate the likelihood and/or significance of the DGR’s environmental effects; 
- not providing enough information to allow evaluation of mitigation measures that will be effective in preventing significant adverse environmental effects that may be caused by the DGR; 
- not providing information at an appropriate level of detail that would allow evaluation of the adequacy of the follow-up program for the DGR; and
- not meeting the information requirements necessary to demonstrate that the DGR meets the sustainability purposes and precautionary requirements mandated under CEAA. 

We appreciate that the direction you provided Ontario Power Generation in your February 2016 letter was an effort to have OPG address some of their repeated failures to meet the requirements of the Canadian Environmental Assessment Act. However, as evidenced by their response of April 2016, it appears that OPG continues to be unwilling or unable to meet those requirements.

In planning subsequent procedural steps in the review and federal decision-making with respect to this Project, it is imperative that you and your office pay careful attention to the details of Ontario Power Generation’s response and place it within the context of their pattern of nonconformance with both the requirements of the Canadian Environmental Assessment Act and the directions of the previous Joint Review Panel. In addition, there are other gaps in the OPG application which must be filled prior to any approval being possible, such as repository and shaft collar design, final waste characterization, baseline health studies, etc.

In preparing this letter, we consulted with the 179 individual intervenors, intervening organizations, and co-signors to Nuclear Waste Watch’s joint letters of November 2015 and February 2016 on the advice we would provide you with respect to the review process following OPG’s submission, now expected by year-end of 2016.

The following points summarize our collective advice:

a) The Joint Review Panel appointed in 2012 is now functus with respect to their responsibilities and mandate under CEAA 2012; 
b) Indigenous peoples, past intervenors in the review process and the public more generally must be consulted on the OPG response and other related matters prior to the issuing of your decision statement; 
c) Direct consultation by you as Minister is the most appropriate course of action under these circumstances;
d) Given the technical nature of the decisions to be made and in light of your Government’s commitment to making decisions based on sound science, we encourage you to seek – in particular – the advice of the Minister of Science, the Hon. Kirsty Duncan;
e) There may be a role of the Canadian Environmental Assessment Agency in acting as support and secretariat for the actual consultation activities (e.g. discussion documents, public meetings, webinars, etc.), based on your direction and requirements.

We remain committed to working with you and other elected officials to achieve an informed outcome of this review process. Thank you for your continued consideration.

Respectfully submitted on July 14th, 2016 by the undersigned organizations:

Algoma Manitoulin Nuclear Awareness Canada 
Algonquin Eco-Watch Canada 
Bluewater Coalition Against Deep Geological Repositories Canada 
Bruce Peninsula Environment Group Canada 
Canadian Coalition for Nuclear Responsibility Canada 
Canadian Environmental Law Association, Theresa McClenaghan Canada 
Citizens Environment Alliance of Southwestern Ontario Canada 
Citizens Network on Waste Management Canada 
Coalition for a Nuclear Free Great Lakes U.S. 
Concerned Citizens of Big Bay (Michigan) U.S
Concerned Citizens of Renfrew County Canada 
Council for Public Health in Mining Communities Canada 
Council of Canadians Canada 
Council of Canadians, Peterborough and Kawarthas Chapter Canada 
Don't Waste Michigan U.S.
Don't Waste Michigan- Sherwood Chapter U.S. 
Durham Nuclear Awareness Canada 
Fairmont Minnesota Peace Group U.S. 
FLOW (For Love Of Water) U.S. 
Friends of Bruce Canada 
Grand River Environmental Network Canada
Great Lakes Environmental Alliance Binational 
Greenpeace Canada Canada 
Huron Environmental Activist League U.S.
Huron-Grey-Bruce Citizens' Committee on Nuclear Waste Canada 
Inter-Church Uranium Committee Educational Cooperative Canada 
Lambton Shores Residents Against the Nuclear Dump on Lake Huron U.S. 
National Council of Women Canada 
Northwatch Canada
Nuclear Hotseat U.S. 
Nukewatch U.S. 
Ontario Clean Air Alliance Canada 
Port Hope Community Health Concerns Committee Canada 
Prevent Cancer Now Canada 
Provincial Council of Women of Ontario Canada 
Redwood Alliance U.S. 
SOS Great Lakes Binational 
Save Our Sky Blue Waters U.S. 
Sierra Club Nuclear Free Michigan U.S.
Sierra Club US U.S. 
Southampton Residents Association Canada 
Stand Up/Save Lives Campaign U.S. 
The Inverhuron Committee Canada 
Toledo Coalition for Safe Energy U.S. 
Uranium Watch U.S. 
Watershed Sentinel Educational Society Canada 
Zero Waste 4 Zero Burning Canada

 

Click here for a PDF version of this letter

July 27, 2016 - SOS Great Lakes' Submission to the Canadian Environmental Assessment Agency's Review of Environmental Assessment Processes

Red Dusk Over the River in the Upper Peninsula, Michigan

Red Dusk Over the River in the Upper Peninsula, Michigan

 

The Canadian federal government is reviewing the environmental assessment processes established by the government of former Prime Minister Stephen Harper in 2012. The existing environmental assessment legislation was used by the Joint Review Panel on the OPG DGR to give the project a stamp of approval despite the huge gaps in OPG's plan and clearly biased role of the Canadian Nuclear Safety Commission in the review process.

SOS Great Lakes is participating in the public consultation on the review of environmental assessment processes. Below is the text of the letter sent to the CEAA on July 20.


Review of Environmental Assessment Processes
Canadian Environmental Assessment Agency
160 Elgin Street, 22nd Floor
Ottawa, ON K1A 0H3

SOS Great Lakes (SOSGL), formerly known as Save Our Saugeen Shores, Inc. commends the federal government for proceeding with the long-promised and highly anticipated review of the Canadian Environmental Assessment Act, 2012 (CEAA 2012) and related regulatory processes.

SOSGL is an organization opposing the deep burial of nuclear waste in the Great Lakes Basin, currently focusing on OPG’s plan to construct a deep geological repository (DGR) for nuclear waste by the shore of Lake Huron. SOSGL maintains that nuclear waste should not be buried anywhere in the Great Lakes Basin due to the potential for contamination of the world’s largest supply of fresh water. In spite of this risk, a Joint Review Panel (JRP) under CEAA 2012 approved the DGR plan after what we argue was a deeply flawed review process.

Our participation in OPG DGR EA review process involved multiple written and oral presentations. The research and analysis we have conducted is extensive and includes expert legal and scientific opinion. Our experience at the hearings and concerns over the independence and quality of the JRP Report led to our filing for a Judicial Review in 2015.  We believe this body of work and our direct experience with the EA process would be of benefit to the upcoming review of the 2012 CEAA and the EA process. 

We broadly concur with the concerns regarding the Expert Panel’s draft Terms of Reference (TOR) raised by CELA and Lake Ontario Waterkeeper. Additionally, based on our particular experience, we have specific concerns with respect to the new EA regime: the scope of EA powers; scientific verification / scientific process, sustainable development; use of Adaptive Management Measures, the partiality of industry regulators; and the need to consider catastrophic events.

In our engagement in the JRP for the OPG DGR, we observed that key issues of purpose, need, alternatives to, and alternative methods were routinely ignored, and that the OPG was given a stamp of approval without demonstrating that the DGR was necessary; that it had selected the best possible location for the DGR; or that it had chosen the best available method of nuclear waste storage. To remedy this, we recommend that those key criteria be enshrined in legislation and that EA be empowered to stop projects that don’t meet the criteria.

SOSGL is concerned with the project-level focus of EA in the TOR. This is a critical flaw which discounts a more holistic approach to EA that recognizes the interdependence of natural systems and the cumulative, ecosystem-wide effects of EA decisions. In SOSGL’s experience, OPG was allowed to move forward with its DGR plans despite inadequately accounting for the cumulative effects of the project (a deficiency that was acknowledged by Minister McKenna in her letter requesting additional information from the OPG in February 2016). SOSGL supports the establishment of strategic- and regional-level EA planning as well as cumulative effects assessments in the new EA regime.

Additionally, SOSGL is concerned with the appropriateness of EAs conducted by entities such as the CNSC. Over the years, we have observed a too-close relationship between the CNSC and the industry which it regulates, including a documented instance of a CNSC executive who was integral to the appointment of the JRP expressing bias in favour of the project at a secret meeting. Our experience has lead us to question the competency of industry regulators such as the CNSC to undertake impartial EAs. The Expert Panel should consider stripping away these entities’ current EA responsibilities and vesting them in another body (e.g. the administrative tribunal outlined in CELA’s submission).

Finally, in SOSGL’s experience the JRP allowed OPG to “screen out” many potentially catastrophic events that could affect the DGR and endanger the drinking water of over 40 million people. For the limited number of events that OPG was required to consider, the JRP failed to require OPG to adequately describe the magnitude, geographic extent, timing, duration, frequency and degree of irreversibility of any of them. We believe that the interpretation of the legislation which allows for such laxity is fundamentally at odds with the precautionary principle. Accordingly, SOSGL supports a new EA regime which takes seriously low-probability catastrophic events.

In summary, the CEAA review process presents an opportunity to develop new, forward-thinking legislation that results in an impartial EA process that reflects the government’s policy objectives in the areas of climate change; transparency and accountability to the public; the rights and interests of Indigenous Peoples, and sustainable development. SOSGL is looking forward to participating in the review process and working toward the next generation of EA legislation.

Yours truly,

Jill Taylor, President

 

Click here for a PDF version of this letter.

July 15, 2016 - An Open Letter to Minister Catherine McKenna re: Her Letter to OPG Requesting Further Information on the DGR and OPG's Inadequate Response

July 15, 2016
The Honourable Catherine McKenna,
Minister of Environment and Climate Change,
Environment Canada,
Minister’s Office
200 Sacre-Coeur Blvd., 2nd Floor,
Gatineau, QC, K1A 0H3

AN OPEN LETTER TO THE MINISTER RE 1) HER FEBRUARY 18, 2016 LETTER TO OPG REQUESTING FURTHER INFORMATION RE THE PROPOSED KINCARDINE DGR, AND 2) OPG’S RESPONSE OF APRIL 15, 2016 SENT TO RON HALLMAN, PRESIDENT OF THE CANADIAN ENVIRONMENTAL ASSESSMENT AGENCY (CEAA), DODGING 2 OF THE MINISTER’S 3 QUESTIONS

Dear Minister:

Please note our new name, SOS GREAT LAKES. This reflects the rapidly growing concern about a Kincardine DGR shared by Canadians and Americans, especially the 40 million people who receive their drinking water from the Great Lakes. SOS began as a local citizens’ group, Save Our Saugeen Shores, dedicated to keeping buried nuclear waste out of the Great Lakes Basin. From 2012 to 2014, we fought to stop the proposed DGR for high level nuclear waste in Saugeen Shores, a few kilometres north of Kincardine. That battle was won. Now, as explained at http://www.sosgreatlakes.org, we are working to bring to your attention the voices of thousands of Canadians and Americans throughout the Great Lakes Basin and beyond who are appalled at the notion of nuclear waste being buried so close to the world’s largest supply of fresh drinking water.

We urge you to instruct Mr. Hallman to reject OPG’s April 15 letter as completely inadequate. You made specific requests relating to:

a) “alternate locations…”, - that is, specific locations when you noted “...with specificreference to actual locations...”, and;

b) “…cumulative environmental effects of the Project in light of the results of the Phase 1 of the Preliminary Assessments undertaken by the Nuclear Waste Management Organization, which identified three potential host communities that fall within the traditional territory of the Saugeen Ojibway Nation.”

You and Mr. Hallman received answers to neither.

Instead of following your instructions regarding “alternate locations”, OPG misinterprets by stating OPG will look at “geologic regions”, - granite in the north and sedimentary rock in the south. This replicates OPG’s performance before the Joint Review Panel (JRP) when it routinely promised to answer the JRP’s questions but always seemed to manage to duck or dodge.

OPG should be instructed to follow the directions given.

Similarly, with respect to your question about “cumulative effects”, instead of following yourinstructions, OPG stated it will look at the cumulative effects of a hypothetical used fuel repository on its Project in two of the three communities. It not only arbitrarily reduced the number of communities from three to two but twists the requests from ‘cumulative environmental effects of two repositories on the communities’ to the ‘effect of a DGR2 on its DGR1’.

Again, OPG should be instructed to follow the directions given.

With respect to the scope of your February 18 letter, we would respectfully point out you could have requested more information, consistent with the Act’s requirements, about alternative means of storage in addition to alternative locations. OPG’s material and the JRP report are both as deficient in their analysis of alternate means as they were about alternate locations.

In November 2015 we sent you a detailed Briefing Document on 8 major public policy errors that we believe are present in this OPG proposal for a Kincardine Nuclear Waste Repository and the JRP Report approving it. Your February 18 letter seeks more information on a major part, but not all, of 1 of those 8 errors. The remaining 7 may have been acceptable to the Harper Government. However, all 7 of these errors appear to be inconsistent with your Government’s election platform and post-election policy statements. This leads us to believe that in the unlikely event that OPG is able to satisfy you on the February 18 questions, you would have multiple other reasons to reject the JRP Report.

To date, you have declined our request for a meeting, presumably on the advice of counsel, because we have applied for Judicial Review of the JRP decision by the Federal Court and Environment Canada is a respondent. We respect that advice, but want you to know we have confidence that, after thorough review of our information, your Government will share our view that the issues we raised in the detailed Briefing Document call for a Public Policy decision rejecting this OPG proposal.

Respectfully,

Jill Taylor, President
SOS Great Lakes
On behalf of the Board of Directors

 

With copies to:
The Right Honourable Justin Trudeau, Prime Minister of Canada
The Honourable Kathleen Wynne, Premier of Ontario
The Honourable James Carr, Minister of Natural Resources
The Honourable Stephane Dion, Minister of Foreign Affairs
The Honourable Kirsty Duncan, Minister of Science
The Honourable Ralph Goodale, Minister of Public Safety and Emergency Preparedness
The Honourable Dominic LeBlanc, Minister of Fisheries, Oceans and the Canadian Coast Guard
The Honourable Jane Philpott, Minister of Health
The Honourable Glenn Thibeault, Minister of Energy
The Honourable Eric Hoskins, Minister of Health and Long Term Care
The Honourable David Orazietti, Minister of Community Safety and Correctional Services
The Honourable Glen R. Murray, Minister of the Environment and Climate Change
The Honourable Kathryn McGarry, Minister of Natural Resources and Forestry
Marlo Raynolds, Chief of Staff, Environment and Climate Change Canada
Ron Hallman, President, Canadian Environmental Assessment Agency

Click here for the PDF version of this letter

June 21, 2016 - It’s time to speak up. Let your voice be heard.

SOS Great Lakes

It’s time to speak up. Let your voice be heard.
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In April, Canada’s Minister of Environment & Climate Change, received a schedule from Ontario Power Generation indicating that they will submit the information on their proposed nuclear waste deep geologic repository by the end of this year. If we are to successfully oppose OPG’s plan to build a nuclear waste dump on the shore of Lake Huron, we have to move quickly.

 

The good news is, we are prepared.

If you are willing to lend us your voice and help us share our information, we believe we can prevent this threat from becoming a reality. We are writing now to bring you up to date on our strategy and to show you how you can make your voice heard in this important discussion.

 

We changed our name.

Formerly known as SOS Save Our Saugeen Shores, we are now known as SOS Great Lakes. Our original name served us well when we were fighting the idea of a high level nuclear waste dump in Saugeen Shores. The issue now is the threat to drinking water for 40 million people posed by OPG’s planned nuclear waste dump near Kincardine, on the shore of Lake Huron. We changed our name to bring this threat to the attention of the millions of people who rely on the Great Lakes for fresh water through a coordinated campaign. 

 

We launched a new website. 

Our plans are on our new website, sosgreatlakes.org. You will be receiving updates and information going forward. We will launch a video, we will start a web-based fund-raising campaign and we will intensify our efforts with the governments of Ontario, Canada, the United States, Great Lakes states, and all municipalities in the Great Lakes basin on both sides of the border.  Please make sure you receive this information by putting our new name and email address in your address book:

SOS Great Lakes - info@sosgreatlakes.org

 

Let your voice be heard.

By taking a few simple steps, you can help to ensure our success.  Most important, we would like you to share our news.  To be successful we have to alert the millions of people who rely on the Great Lakes, that their drinking water is at risk.  That’s a tall order, but if you tell your friends, and they tell their friends and so on, we can do it. We will give you the tools to help you communicate this message.
 
Please let our voices be heard by sharing the information we give you, with your own network.
 
Your voice is more powerful than you think.

Please help us tell this important story by passing along this information to your friends and networks.  When I hit the send button on my email, I reach out to you, the 2,000 members who are committed to helping us achieve our goals.
 
When you share our information with your friends and networks, you reach out to 200,000 people who know you and trust you.  If they share our messages with their networks, some 20 million people will become aware of this issue. At that point, politicians on both sides of the border will be forced to listen to our concerns.
 
We can do this. You can do this. Please help us save the Great Lakes from nuclear waste.
 
Your lakes.  Your choice.

Sincerely,

Jill Taylor
President, SOS Great Lakes