Intervention orale par. Oral intervention from. Southampton Residents Association. Southampton Residents Association PMD 13-P1.93

Transcription

1 Deep Geologic Repository Joint Review Panel Commission d examen conjoint du projet de stockage dans des couches géologiques profondes PMD 13-P1.93 File / dossier : Date: Edocs: Oral intervention from Southampton Residents Association Intervention orale par Southampton Residents Association In the Matter of À l égard de Ontario Power Generation Inc. Ontario Power Generation Inc. Proposed Environmental Impact Statement for OPG s Deep Geological Repository (DGR) Project for Low and Intermediate Level Waste Étude proposée pour l énoncé des incidences environnementales pour l Installation de stockage de déchets radioactifs à faible et moyenne activité dans des couches géologiques profondes Joint Review Panel Commission d examen conjoint September 16 to October 12, septembre au 12 octobre 2013

2 Joint Review Panel September 16 to October 12, 2013 In the Matter of: Ontario Power Generation Inc. Proposed Environmental Impact Statement for OPG s Deep Geological Repository (DGR) Project for Low and Intermediate Level Waste Written submission in support of 30 Minute Oral Presentation Prepared by: Kenneth D. Robertson B.A., O.O.M On behalf of: Southampton Residents Association PO Box 1081 Southampton, Ontario N0H 2L0 1

3 July 30, 2013 Memo to: DGR Joint Review Panel Re: DGR Joint Panel Review Hearing Written Submission in Support of Oral Intervention (30 Minutes) Presenter: Ken Robertson has owned property in Saugeen Shores for almost 20 years. After retiring as Chief of Police in the City of Hamilton in 2003, he became a full time resident and member of the Southampton Residents Association. He is past President of the Ontario Association of Chiefs of Police and was a Director on the Canadian Association of Chiefs of Police. He has been recognized with an honorary Doctorate of Laws by McMaster University, a Paul Harris Rotary Fellowship, and the Queens Jubilee Medal in recognition of his community service. He was appointed an Officer in Order of Merit for Police Services by the Governor General of Canada in recognition of his contribution and leadership in public safety services across Canada. Introduction: I am making oral submissions to the Joint Review Panel(JRP) on behalf of the Southampton Residents Association (SRA). I am the elected President of the SRA which has over 750 members, the majority of them are property owners in the Town of Southampton which is part of Saugeen Shores, located on the shores of Lake Huron just 20 miles north of the proposed DGR at the Bruce Nuclear Site. Since the mid 1900 s, the SRA and its predecessors, the Southampton Beach Association and the Southampton Property Owners Association, have been representing the interests of Southampton Residents in many ways. Our Mission statement reads as follows: 1. Protecting the unique nature of Southampton as a community within Saugeen Shores; including the arts, culture, recreation and waterfront. 2. Promoting the appropriate planning and development for Southampton. 3. Assisting Citizens in voicing concerns with the appropriate levels of Government. 4. Supporting and promoting local businesses. Over the years the SRA has provided input and leadership on issues like, The Town s Official Plan, The Proposed Waterfront Master Plan, Water Quality on our Beaches, Public Safety Issues and the Introduction of Development Charges. Each year we raise funds in support of community projects like the 150 th Anniversary Celebrations, 2

4 Period Lighting Project, Jubilee Assessable Park, the Arts School, and this year for the Saugeen Memorial Hospital Foundation. As part of our mission we have made submissions to our local Council voicing opposition to the NWMO process that could bring all of Canada s spent nuclear fuel to a DGR in our Community. We believe that would change the current vision of our community from one that is known for its world class sunsets, pristine beaches, as a tourist destination, as a place for retirees from across Ontario and as a place where employees of Bruce Power and OPG live and raise their families. We are not anti-nuclear, in fact we appreciate the many contributions made in our community by Bruce Power/OPG and their employees and acknowledge the significant positive economic impact they have on our municipality. We recognize the importance of nuclear, as base load power that is vital to the economic success to the Province of Ontario. We are anti-dgr. We believe there must be a better way, - whether by recycling or a better place to put all of Canada s nuclear waste than burying it on the shores of Lake Huron. We strongly disagree with the processes and tactics used by OPG/NWMO. Parts 1 & 2 of our submission is specifically focused in the area of Socio-Economic impacts as a result of DGR and section 3 & 4 address concerns with the public consultations and processes. Our opposition to the DGR for L&IL waste includes the following concerns: 1. The Host Agreement negotiated by the Town of Kincardine is grossly unfair. This is a clear example of powerful industry money overwhelming small town Ontario. 1.1 A review of the Host Agreement signed by OPG and Municipality of Kincardine details a series of Payments to Kincardine and adjacent communities that total approximately $40 million dollars over 30 years. In their submissions both the CNSC and OPG estimate the volume of low and intermediate level nuclear waste to be buried in DGR #1 to be 200,000 cubic metres. It is noted these payments come with strings attached. 1.2 In Kincardine, OPG is paying approximately $40 million over 30 years to dispose of 200,000 cubic metres of Nuclear Waste or $200 per cu. metre. In contrast, in the legislation authorizing construction of a Waste Isolation Pilot Plant (WIPP) 25 miles outside of Carlsbad NM, the National Energy Commission (NEC) is obligated to pay approximately $280 million over 14 years for the storage of a specific amount of 6.2 milllion cubic feet (176,000 cubic metres) of nuclear waste or $1600 per cu. metre. 3

5 The NEC is also committed to paying additional ongoing payments following the initial 14 years and hundreds of millions in transportation upgrades and administration costs. Is the waste that OPG proposes for the DGR in Kincardine any less toxic than waste being stored in the DGR in the US? Is the land and surrounding property in Kincardine and adjacent communities on the shores of Lake Huron less valuable than desert land filled with abandoned mines? 1.3 Section 4.1 section C of the host agreement requires all municipalities named to exercise their best efforts to support construction of the DGR or give up their right to payments detailed in the agreement. More specifically elected officials are committed to supporting approval processes including procedures under the Canadian Environmental Assessment Act and the Canadian Nuclear Safety &Control Act. 3. (B) The parties shall, in good faith, exercise their best efforts to achieve These milestones. Without limiting the generality of the foregoing and in accordance with any legal responsibilities either Party may have, the parties shall provide their cooperation in support of the environmental approvals and licensing application sought as well as any other approvals or licence required to construct or operate the DGR. Further Kincardine shall give due consideration to providing OPG with all approvals within its jurisdiction to grant in order to permit the construction and operation of the DGR and will expeditiously process applications in this regard. Kincardine shall also respond in a timely fashion to all requests by the CNSC, or other competent authority, for information and make appearances at all CNSC hearings relating to the DGR. OPG shall process its applications for the requisite regulatory approvals with due diligence. 3(C) Notwithstanding anything to the contrary in this Section 4 if at anytime OPG determines that the Adjacent Municipalities are not, in good faith, exercising best efforts to achieve any of these milestones OPG may, in its sole discretion acting reasonably, decline to may further annual payments or any further one-time lump sum payments set out in schedule A for any or all of the aforementioned municipalities, as the case may be, in which case the affected municipality will not have any right to receive or recover that payment. OPG shall pay half of any annual lump sum payment not paid to the affected municipality to local community projects and/or charities agreeable to OPG and Kincardine. 4

6 1.4 A cursory review of the Host Agreement raises more concerns over quality of the negotiations and lack of detailed analysis in this agreement. Section 3 (C) contains the words, OPG may, in its sole discretion, acting reasonably, decline to make further annual payments. While section3 (D) contains the words, OPG may in its sole discretion, acting reasonably, make further one time payments. Little doubt the words decline to have been left out in error. We believe that OPG s promise of big dollars resulted in a contract that does not protect this financial interest of taxpayers. 1.5 I spent 36 years in Public Service finally retiring as Chief of Police in the City of Hamilton. I was involved in negotiations and approval of contracts involving tens of millions of dollars. In each and every case a report was sent to Municipal Council or the Police Service Board, giving detailed financial justifications and analysis. Council would review and make recommendations prior to our Municipality entering any major contract. Our review of available documentation reveals no such reports to our elected Council in Saugeen Shores. We have sought answers but none are forthcoming from OPG/NWMO or our Councils. The questions we have as taxpayers in Saugeen Shores and Bruce County, include: Who negotiated the financial arrangements on our behalf? What accounting firm or lawyer was employed to negotiate on our behalf? How was the $40 million in payments established? Who set the different levels of payments? What was the criteria used to set these payments? If there was lack of due diligence or financial mismanagement who do we hold accountable and how? 1.6 Comments made by former OPG V/P of Waste Management in the Kincardine News in October 2004 following Kincardine council s approval of the Host Agreement compounds our concerns, When questioned about the payments in the agreement he said, The dispersal of the benefit package is an internationally acceptable practice with nuclear storage facilities, OPG is basing its actions on accepted practices. Its within the range of what occurs elsewhere he said, specifically citing a hosting agreement with the Municipalities of Port Hope, Clarington and Welcome as an example. These three communities received $30 million benefit package for storing low level waste. Once again this logic defies common sense. In Port Hope area nuclear waste is stored above ground. It has been stored in Kincardine above ground for years without compensation, now OPG is proposing to bring all of Ontario s Low and 5

7 Intermediate level waste including decommissioning waste to a proposed DGR in Kincardine. Obviously Ken Nash and OPG are getting a great deal for only $40 million dollars. In the CNSC submissions to the JRP (Page 43) they state clearly that half of the projected waste to be stored in the DGR is currently on the Bruce Site. It is obvious Kincardine has not been compensated for years of on-site storage while other communities have and they will only receive $40 million for storing twice that volume of toxic waste in a DGR. They indicate the actual amount could increase as a result of reactor operations and refurbishments. Recent news reports indicate OPG is considering making it larger to accommodate decommissioning waste from other reactors. Of course we have to acknowledge OPG also indicated they might build a third billion dollar DGR as well. 1.7 In a Kincardine News Article in January 2005, Mr.Larry Kraemer, (2005 mayoralty candidate) had similar concerns. Money isn t the most important thing at stake here. He said that he believed the financial agreement should have encompassed more that the mere allocation of dollars. He suggests additional considerations including investments in long term infrastructure. If we are willing to host this waste facility, then the deal should have included provision for the investment of long term infrastructure in this part of the world. It is sad, but not surprising that he did not follow-up on those issues once he became Mayor. He did not; the Host Agreement restricted his pursuit of changes that could delay this process. In spite of badly needed changes and improvements local Councils hands were tied by a flawed and inadequate Host Agreement. In all of our research and review there is nothing more shocking than to see how the Host Agreement guarantees cooperation from Councils throughout this process. 1.8 A review of the agreement in New Mexico, shows that the rights of their taxpayers are protected in Section 8 d. (3). The State can challenge the decision of the Environmental Protection agency with a Judicial Review. Their legislations details specifics on the volume and kind of waste and, Section 12 specifically bans the transportation to or disposal of high level radioactive waste in their DGR. Members of the SRA are aware that spent nuclear fuel is being stored by OPG as a result of the operations of Bruce Power. We would ask the Federal Government CNSC, to place a similar ban on this growing problem by banning transportation of high level spent nuclear fuel into Bruce County from reactors or waste sites around Canada or the US. 1.9 Many have asked, why did OPG not look at alternative sites during the initial stages, I think the answer is clear, they had negotiated such a great financial deal in Kincardine that no other location would be considered in spite of real concerns with burying this waste just a km. from the Lake Huron shoreline. The information being promoted by OPG was that Kincardine wanted the DGR, this is no justification for OPGs failure to look at alternate sites We don t believe that local Councils acted in bad faith, we believe they were manipulated by big dollars put on the table by OPG. We believe they did not 6

8 apply the principals of effective leadership, as Stephen Covey explained so well. Leaders make good decisions when they start with the end in mind. If the Host Agreement had been negotiated by leaders with the assistance of appropriate professionals, accountants, lawyers who as a team, had started with the end in mind: The agreement would have contained a cost benefit analysis, appropriate compensation, proper PVPP, and guarantee that a DGR for High Level spent nuclear fuel would not be built in Kincardine or adjacent communities We believe OPG Officials, including Ken Nash who is currently the President and CEO of NWMO, negotiated a deal that protects the financial interests of the nuclear industry (OPG) to the detriment of Kincardine and adjacent communities Our members are particularly concerned by the fact two of the signing parties on the host agreement, Ken Nash VP of OPG Waste Management, and former Mayor Glenn Sutton are now deeply involved in the NWMO process that could bring all of Canada s highly radioactive spent nuclear fuel to a DGR in Saugeen Shores. Ken Nash the current President and CEO of NWMO is spearheading that process and Glenn Sutton who was employed in the industry, has a prominent role as a member of the Community Liaison Committee for Huron-Kinloss. There will be coordination between the Community Liaison Committees across Bruce County and yet in Saugeen Shores, persons who challenged the NWMO process were denied membership on CLC. In the case of DGR #1 Ken Nash and OPG controlled opposition from local Councils with a flawed and biased Host Agreement. Now opposition is being blocked by those same Councils selection of members for their Community Liaison Committees for DGR #2; in a flawed and biased process being pushed by NWMO under the direction of Ken Nash. The net result is we have an Executive who negotiated a questionable agreement with Kincardine now negotiating for NWMO and our Council for a process that could bring a DGR for high level waste in an adjacent community. The same Council that is committed financially to support DGR #1; this is patently wrong There should be a full review of the Host Agreement in detail and OPG should explain the $240 million difference in payment for disposing of their waste on land adjacent to the pristine waters of Lake Huron? Your have heard or will hear other submissions expressing concerns over the process used by OPG and local Councils. This financial issue should have been publically debated and dealt with in public opinion surveys. Unfortunately the Host Agreement prevents this kind of discussion. 2. The Property Value Protection Plan negotiated by Kincardine and OPG does not adequately protect property values in the municipalities included in this agreement. One of our biggest risks is losses based on the stigma 7

9 associated to nuclear waste sites and the inherent risk in operations on those sites, not only on property values but on the tourist industry. 2.1 The Kincardine DGR is being proposed in a growing community, with a strong economy and a thriving tourist industry. The DGR will be located 1km. from Lake Huron and close proximity to large communities of Kincardine and Saugeen Shores less than 20 kms. away. In Carlsbad New Mexico a DGR was built outside of a community that had severe economic problems with population decreases of 17 percent during the decade following closure of their potash mines. The DGR is located 41 kms from from any significant population and involves little if any risk to land values in the area of abandoned salt mines. 2.2 The Host Agreement for the Kincardine DGR contains flawed, exclusive and inadequate PVPP that only compensates for exclusive cases of radioactive contamination from the DGR Site. There is no compensation to the Municipality for loss associated to property value assessment from falling property values. PVPP in Port Hope Nuclear Project is comprehensive and inclusive and includes Protection against any financial loss of value in property as a result of the plans or activities of the Initiative. Their Host Agreement provides protection and financial compensation to Municipalities in event of loss of property value assessment. 2.3 OPG submission to JRP on page 55 relies on research conducted by Bezdek and Wendling(2006)to discount any risk to property values. They quote, Recent reviews in the US indicate that the negative imagery surrounding Nuclear plants or stored nuclear facilities does not necessarily have a significant detrimental influence on residential home prices in the immediate vicinity of these facilities. The communities in that research were not in any way like Kincardine or Saugeen Shores with growing populations and a thriving real estate market. (until the NWMO process for DGR #2 started) 2.4 OPG uses research supported by Nuclear Energy Institute and Private Fuel Storage. Closer examination reveals the misleading nature of OPGs use of this research. The authors caution about using the results as evidence, they point out that in their study: Most of these nuclear facilities (which included Carlsbad DGR) were sited in areas with depressed or blighted economies and, indeed, were actively courted by local government officials as a means of rejuvenating the local economy. While the facilities succeeded in doing so it should be realized that the economic benefits reported here are based on local economies that were often severely depressed prior to the siting of the facility. That is, some of these local economies were so relatively poor at time of the facility sitting that only acceptance and positive economic benefits were bound to result. Indeed, most nuclear facilities are located in more rural, sparsely populated, and often, economically depressed locations, rather than more prosperous metropolitan areas, and the siting of such a facility will almost inevitably generate higher paying jobs, and influx of technical and professional staff etc. Our findings confirm this. Further while the nuclear 8

10 facilities provided a major stimulus and continuing economic benefits to the local areas, similar benefits would have resulted from the siting of other types of major facilities such as large manufacturing plants, telemarketing/call centers, casinos, government operations facility, etc. In addition since all of the facilities were located in rural sites, the employees would probably have no other realistic housing choices. If the facilities had been in urban areas, the results might have been different and this cannot be generalized to nonrural areas. 2.5 The OPG submission chose to ignore a decade of research on these issues Conducted by the State of Nevada in regards to proposed Yucca Mountain DGR. I will quote from A Mountain of Trouble: A National Risk. This report represents the culmination of an impact assessment research effort that spanned two decades and involved scientists and professionals from universities and organizations throughout the country, representing almost every social science discipline. The State of Nevada wishes to acknowledge the contributions of all of these extremely talented and dedicated researchers, with a very special acknowledgment and thanks to Dr. Gilbert F. White, the first chairman of the technical review committee that oversaw the design and implementation of the research effort. Dr. White s unimpeachable integrity and sense of purpose, his wisdom, and his firm hand in guiding the Nevada studies set the tone for the effort from the first and contributed immeasurably to the ultimate success of this extraordinary set of studies. Impacts to Nevada s Economy A radioactive waste accident in or near Las Vegas would almost inevitably produce significant visitor losses. Even without such an accident, the mere presence of a repository, less than 90 miles from the State s major economic center, would have a negative effect on the economy of the region and the State. Given the unique reliance of the Nevada economy on the State s ability to attract tens of millions of tourists and visitors annually, any impacts that reduce the number of visitors, especially to southern Nevada, would have major consequences for the State s economy. Consequently, the most serious and possibly catastrophic economic risk for Nevada stemming directly from the Yucca Mountain project is the potential for stigma impacts on the tourist and visitor industry. Such impacts would produce significant losses to an economy dominated by visitor-based revenues. Dozens of studies spanning two decades show that populations important to Nevada s economic well being are highly sensitive to the radioactive risks associated with a repository and spent fuel/hlw transportation. These studies have interviewed thousands of residents, visitors tourists, convention planners and hundreds of convention attendees, professional investors, loan officers, and real estate appraisers. Studies have measured actual behaviours of people who hold positive and negative images of places, like Las Vegas, and the considered opinions of people in response to scenarios ranging from a successful, no adverse event case to radiation and non-radiation accidents. In every case and condition, the studies recorded responses that threaten the attractiveness of the State as a place to visit, move to, or invest in. In every case, the responses pointed to major socioeconomic impacts. 9

11 A radioactive waste program by itself would produce significant adverse economic impacts. An accident or incident that caused Las Vegas to become even moderately associated with radioactive imagery would have major negative economic Impacts for the area s visitor economy, in-migration, and economic development. Estimates between 5 and 30 percent or larger reductions in key economic sectors are consistent with the empirical evidence gathered. Annual losses to the Las Vegas and Nevada economy would be expected to reach $39 billion or more in the event of a nuclear waste accident. Even without an accident, the Nevada economy stands to lose upwards of $5.5 billion annually as a result of the stigmatizing effects of the repository and high- level nuclear waste shipments through the State. Reductions in Property Values Along Transportation Routes State of Nevada and Clark County researchers have found that the value of property, especially along potential nuclear waste shipping routes in Clark, Washoe, and Elko counties, stands to be dramatically affected should the Yucca Mountain project go forward. Even under the most benign conditions (i.e., where there are no projected radioactive waste accidents), significant property value losses are likely along shipping corridors, as well as at distances up to three miles from the actual highway or rail route. The findings indicate that an accident, even without a release of radioactive waste, would significantly affect property values. If a major accident involving radiological contamination were to occur, property value losses would be devastating. These studies found that residential property values along nuclear waste shipping routes in Clark County alone could decline an average of 3.5% even without a major accident or incident, due to the irreducible risks from a designated HLW shipping route. In the event of an accident, losses in real market value could be between $5.6 billion and $8.8 billion. In Washoe and Elko Counties, the estimated residential property value losses are between $1.9 billion and $2.2 billion and between $110 million and $129 million, respectively. Percentage declines of comparable magnitudes can be expected in counties and Communities all along Yucca Mountain transportation routes, with total property value impacts state-wide totalling in the tens of billions of dollars. 2.6 Why would OPG downplay the risk to property values or more importantly ignore years of research and a Supreme Court Decision in New Mexico that upheld a case where property owners along the transportation routes for I&LLW DGR in Carlsbad were compensated for losses in property values. Once again OPG protects their interest by limiting the scope of the coverage in the Kincardine agreement but, providing comprehensive coverage in Port Hope agreement. 10

12 A Lexpert article on PPVP by Epstein,Becker and Green, explains why PVPP, or as they describe them, Property Value Assurance Plans are important when there are environmental concerns in a community. The PVPP are a contractual promise made to assure homeowners that the equity in their homes will be protected if they sell their homes for less than full market value. Their review of the Port Hope PVPP reveals the importance of having a plan that would cover losses from any activities in the Port Hope Project. In fact the existence of a comprehensive PVPP prevented panic selling by the 5800 affected homes. Homeowners who knew their properties values were protected have remained in the community and there has only been 58 claims. 2.7 While the PVPP would protect properties that were contaminated as a result of an accident within the 8km of the center of the DGR. Our concerns are once an accident occurs and problems become public what happens to the values of homes outside of the contaminated area? If there is a major collision and release of nuclear waste what happens if public perception changes and Kincardine is no longer a destination for tourists and retirees? CNSC does acknowledge some risk in their submission to the JRP on page 112 they state, OPG acknowledges that the presence of the DGR project may affect tourism and facilities such as Inverhuron Provincial Park, because the DGR Project as a whole has the potential to influence community Character, and has the potential to change people s feelings of personal Health and/or sense of safety, making visiting tourist features less attractive. Tourism is the largest employer in Bruce County and any threat to the tourism or the growing number of retirees from across North America who are coming to this area should be a major concern and represents real risk to property values in this area. 2.8 The OPG s submission to the JRP on page 77 contains the following comments, The realtors interviewed indicated increasing property values were attributable to the restart of the Bruce A as well as the growing attractiveness of the area to retirees. Their data up until 2012 would appear to support that premise. Our members have noticed a significant change in the real estate market and Many of us have had friends and family who have expressed a reluctance to move to Saugeen Shores, while the possibility exists that 2 DGRs for nuclear waste could be located within 20 kms of each other in a community that could become known as the Nuclear Waste Capital of Canada. I reviewed the statistics provide by the Grey Bruce Realtors Association and the sales history in Saugeen Shores during the last 14 months, since the announcement that a second DGR could be planned for this area. I also examined sales history for the 14 month prior to Saugeen Shores Council entering the NWMO process. We believe the impact of this areas potential to be the host to 2 DGRs is having a significant negative influence on property values 11

13 and it may continue, and yet there is no discussion about a PVPP to protect them against huge potential losses in event of panic sell offs. (See summary below) Sales over $400,000 in 14 months prior to NWMO process = 18 Sales over $400,000 in 14 months start of NWMO process= 7 (-60%) Total Sales YTD (July) 2012 = 127 Average Price $313,000 Total Sales YTD (July) 2013= 105 (-17%) $283,000 (-9%) OPG/NWMO continue to put the property values of our homes at risk with no protection of any kind. We believe these early drop in sales and values is only the beginning. 2.9 We deserve to know why our property values, our tourist industry, and the very nature of the current vision of our community is being put at risk; and in spite of that risk, why have our property values not been protected in the Host Agreement? This is particularly concerning when discussions are continuing that could lead to 2 DGRs which would bring all of Canada s nuclear waste to Kincardine and Saugeen Shores. 3. There was a complete lack of adequate consultation by OPG, with adjacent communities which are impacted by this project. Further, there was no consideration of alternative sites. 3.1 The OPG submission suggests there was detailed consultation with adjacent communities. There was no specific consultation with the Southampton Residents Association which is the largest community association in Saugeen Shores, and as far as we know there was no real consultation with any Southampton residents. 3.2 What we were exposed to were press releases and assurances from our local Council in the media. As an example, an article in the Shoreline Beacon Feb 23, 2005 Mayor Mark Kraemer: At the end of the day, not that much is changing. The low and intermediate Waste is already stored on the site. They are planning to take it from temporary storage to permanent storage which is safe and more secure. It is not high level waste that is being discussed. Its coveralls, towels and tools. Based on what I am being told it is an improvement. Or from Councillor Duncan McCallum who said: I believe the federal government is considering a DGR for high level and while I approve of the OPG site for our current problem I don t want to see it extended to high level waste. 3.3 Marie Wilson the current Media Relations Director for NWMO wrote an article in the Kincardine News in January 2005 just prior to the community poll on DGR #1 She said, The WMO (NWMO) is looking at three options: continued storage 12

14 at each site, a geologic repository in the Canadian Shield or one centralized storage facility. If the day were to ever come when the Bruce became the recipient of all of Canada's spent fuel, it would be catastrophic. This community would truly have to embrace not only the generation of nuclear power, but the storage of all of its waste as well because all other economic efforts such as tourism, or the development of agricultural related industries at the BEC such as a meat processing plant or greenhouses would be destroyed - no one is going to want meat that is processed next to a mega size spent fuel facilty - proven safety record or not. Would families vacation at Inverhuron Park campground if a large spent fuel storage facility were next door? 3.4 Apart from the spectre of DGR #2 we now know that DGR #1 proposal: 1. Is not just for local waste. 2. Includes highly toxic radioactive decommissioning waste. 3. That the DGR #1 will get wastes far more toxic than mops and brooms in fact some intermediate waste that will remain dangerous for 100 s of years. 3.5 In January of 2005 the residents of Kincardine and adjacent communities were lead to believe they were dealing with limited amounts of local I&LL waste. They were being told High Level Waste could be stored in the Canadian Shield and not in Bruce County. 3.6 They, like members of the SRA, as pointed out in Rod McLeods submission would be shocked to learn the NWMO was pushing a process that could bring a second DGR to Saugeen Shores to store all of Canada s highly radioactive spent nuclear fuel. 3.7 The question should be addressed to Ken Nash, who negotiated the Host Agreement for DGR #1 in He is now President and CEO of NWMO which is spear heading OPG s application before the JRP today. He is also now leading the NWMO process that could bring DGR #2 for all of Canada s spent nuclear fuel to Saugeen Shores. If your licence to build DGR #1 is approved will you continue with a Plan that could bring a DGR for spent nuclear fuel to Saugeen Shores? 4. I adopt the submission of my SRA colleagues Rod McLeod, Pat Gibbons and Cheryl Grace relating to the misleading consultation about the DGR. I will be referring to the following publications and documents during my submissions; 1. Host Agreement: OPG-Municipality of Kincardine (October 2004) 2.The Waste Isolation Pilot Plant Land Withdrawal Act State of Nevada report on impacts, Yucca Mountain (February 2002) 4. Kincardine News Article October

15 5. OPG Submission to CEAA re:jrp CNSC Submission to CEAA re: JRP Realtors Association of Grey Bruce 2011,12,13 Sales Statistics 8. Research Paper on Nuclear-Property Values (Bezdek and Wendling 2006) 9. Bruce County Submission to CEAA Re: JRP Kincardine News Article Jan. 12, Lexology Value Assurance Plans: Article by Ebstein, Becker & Green 12. City of Sante Fe V. Komis 1992 NMSC -051, 114 NM, (S.Ct. 1992) 13. Port Hope Initiative: Property Value Protection Plan 14. Host Agreement: Canada Port Hope, Hope, Clarington (2009). 14