Damn Dangerous Dam-in-the-Sky for Marmora Mine???

picture of Marmora Mine & surrounding slag pile - site of proposed dam-in-the-sky!!!???

I sent the following letter-to-the-editor to both local papers (EMC and The Community Press) and to the Peterborough and Belleville major papers.


Dear Editors,
Last week I read that Marmora and Lake Council is still considering turning the slag heap at the old Marmora Mine site into a 'lake-in-the-sky' pumped water storage facility. I had honestly thought this project had died a peaceful death, but as it hasn't, I should air some concerns.

Of course we all want jobs for our under-developed area, and everyone wants to be good planetary citizens in this age of global warming and declining energy sources. But I have doubts about many aspects of this project, including its eco-friendliness, its ongoing financial viability, and of course its safety for village residents.

My understanding is that this project will be a net consumer, not creator, of hydro energy. More energy will be consumed pumping water uphill than will be generated when it is released downhill. This doesn't sound like a green energy project in any way. I have heard the terms "green washing", and even "greed energy" applied to schemes which purport to be eco-friendly, but which are really based on making money. In fact, it appears this project is a form of arbitrage, or 'playing' Hydro for its rate differentials. We all know how efficient and well-managed Ontario Hydro is, so what if Hydro suddenly changes its rate structures again, and this 'arbitrage' scheme loses its financial benefits?

Also the very thought of building a reservoir above the old mine site strikes me as completely unsafe. The report on last week's  Council meeting detailed one such dam burst, and the ensuing devastation from the flooding.

When I moved here 23 years ago, there was a proposal to fill the mine site with trash trucked in from Toronto. Marmora residents quickly formed the group MARMORA TAKES NO TRASH (TNT), and one of my first local experiences was marching to the mine site with a large raggle-taggle group of angry and concerned residents. We also held meetings which jammed the town hall, and that particularly nasty idea was eventually discarded.

  I wonder if  our concerns are short-sighted, or if the many people expressing these misgivings are seeing as clear-eyed as the minion who shouted, "Look, the emperor has no clothes!"



Chris Faiers
12 Main St.
Marmora, ON
K0K 2M0


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Note: Following is Marmora resident Kathy Hamilton's letter regarding her concerns over the proposal to build a pumped water storage on the Marmora Mine slag heap.



July 3, 2012
Mrs. Kathy Hamilton,
PO Box 112, 76 Cameron St., Marmora, ON K0K 2M0
Home Phone: (613) 472-5285

To: Hon. Michael Gravelle - Ontario's Minister of Natural Resources:

The main reason I'm writing to you is because my family fears for the future safety of our persons and property. We dread facing catastrophic, man-made flooding potential from the massive, man-made “upper reservoir” for storing water above and very near our home, that Northland Power plans to use for its pumped storage plant – as proposed for construction on property known as the Marmoraton Mine site that is privately owned by project partner Aecon.

Why is this site that was assessed “Not Practical” for pumped storage in 2005 – by Hatch Acres, for the OWA and MNR, deemed appropriate now? See last page-#55: http://www.owa.ca/assets/files/links/Waterpower_Potential_Nov2005.pdf

Northland Power intends to build their new lake-in-the-sky “upper reservoir” by re-sloping the existing “waste rock piles” adjacent to the abandoned mine pit, then applying a layer of gravel and an “impervious” liner of asphalt to its interior.

Northland Power's “upper reservoir” building plan doesn't sound safe for us!

Proponents insist that our protection from upper reservoir flooding will be ensured by your Ministry of Natural Resources because the project will be “ fully subjected to the requirements of the Lakes and Rivers Improvement Act and the associated dam safety guidelines, including all of its most recent revisions.”

That insistence seems based on their focus within this definition that was recently suggested appropriate by a Hatch rep:
“Dam: For the purpose of the administration of the LRIA, a dam is defined as a structure that is constructed which holds back water in a river, lake, pond, or stream to raise the water level, create a reservoir to control flooding or divert the flow of water.”

But I still question the LRIA's applicability to this pumped storage project proposal, as alternately highlighted below:
“Dam: For the purpose of the administration of the LRIA, a dam is defined as a structure that is constructed which holds back water in a river, lake, pond, or stream to raise the water level, create a reservoir to control flooding or divert the flow of water.”


SINCE the proposed “upper reservoir” structure is not being constructed to fulfill any of these 3 functions:
to raise the water level;
to control flooding;
to divert the flow of water.
AND no natural “flow of water” is associated with this project that has been proposed for construction on privately-owned property - might this project and its “upper reservoir” fit through LRIA “loopholes”?

To avoid assumptions or opinions not based on facts, I would appreciate your returning to me, for sharing publicly:
your confirmation of any recent revisions to the LRIA or the above definition, with included and clear explanation of any altered impact on the LRIA's ability to alleviate local flooding fears pertinent to this project;
your confirmation of correct legal interpretations of the latter
So we can be confident that government-enforced LRIA “dam safety” regulations will be applicable to this project and its construction plans – hopefully before any permits, approvals or contract are granted.

My family should not remain ever less assured of government prioritization of personal and property protection from potential man-made catastrophic flooding than we were last fall – after we had first learned of this project June 10, 2011, 3 days after local council's June 7, 2011 unannounced granting of its approval. Longterm, undisclosed negotiations between “the municipality” and Northland Power had apparently succeeded. This was neatly wrapped up with local council's June 21, 2011 decision to pay for a marketing campaign to promote this private developer's project with our tax dollars and ignore any “negativity”. Upon being locally silenced by isolation through discrimination, all objections were rendered socially marginalized, politically irrelevant and publicly non-existent.
Please note that wilderness forest and a campground below the Taum Sauk, Missouri pumped storage plant deserved far superior and more modern standards for ensuring upper reservoir “dam safety” - as was provided by roller-compacted concrete upper reservoir reconstruction following the catastrophic 2005 breach of its original, that was built in the '60's and the last newly constructed dumped rockfill CFRD in the USA:
http://www.ferc.gov/industries/hydropower/safety/projects/taum-sauk/ipoc-rpt/design.pdf
http://www.npr.org/templates/story/story.php?storyId=5055409&ft=1&f=1003
http://en.wikipedia.org/wiki/Taum_Sauk_Hydroelectric_Power_Station#Upper_reservoir_breached
http://en.wikipedia.org/wiki/Taum_Sauk_Hydroelectric_Power_Station#Reconstruction

Why do Marmora's villagers deserve only re-sloped, existing “waste rock pile” upper reservoir construction?

Is it really any wonder there remain to date only 3 “Letters of Support Received” that were written and submitted by actual local residents of Marmora and Lake – in clear, public demonstration of unevidenced “overwhelming support from the community” of 4-5,000 total population – and that there remain zero from any local residents to be in this project's potential “danger zone” (which is a large portion of the village)?

I hope you will swiftly ensure my family and other ratepayers of more acceptable “dam safety” reassurances that are government-confirmed applicable to this project proposal and it's “upper reservoir” than we've received to date!

It would also help if you would confirm whether local ratepayer and OPA knowledge that the mine pit is spring-fed or our repeated public contradiction by this project's proponents that this proposed “lower reservoir” is “highly impervious” and has merely been filled by precipitation is factual – also whether your clarification of that discrepancy could make any difference to government approvals for, or regulation of, this project and/or its “upper reservoir” construction plan.
See pdf pg 97: http://www.ontla.on.ca/library/repository/mon/15000/267938.pdf

Sincerely,
Mrs. Kathy Hamilton

Non-reassuring references of “dam safety” pertinent to this Northland Power project proposal:
- the 3rd being a Hatch webpage “snapshot” and the first 2 listed amongst the “Letters of Support Received” displayed on Marmora and Lake's “Marmora Pumped Storage Project” promotional webpage:
http://www.marmoraandlake.ca/view.cfm?Prod_Key=3849&PROD_DETAIL_KEY=5080&TEMP=Content%20Single&KeyWord=N%2FA

#1) re Letter dated August 24, 2011 - from yourself, as former Minister of Northern Mines, Development and Forestry:
http://www.wmakers.com/94/files/Other/Marmora%20Support%20Ministry%20of%20NDM.pdf
- no further mention of, nor report from any such project review as yet, but the MMAH now knows I'm still waiting

#2) re Letter dated Sept 1, 2011 – from Linda Jeffries, as former Minister of Natural Resources:
http://www.wmakers.com/94/files/Other/Marmora%20Support%20Ministry%20of%20Natural%20Resources.pdf
- “ this project does not involve provincial Crown land”, [ergo the MNR] “has no direct role in the proposal at this time”... [however the MNR] “MAY have a regulatory role” [if it proceeds].
- Northland Power has stated in their own documentation: "Important for approvals that entire project is on private land"

#3) re Hatch webpage that was linked from my site since summer 2011 – titled “Parks Canada Dam Safety Standards”
- Original url now invalid: http://www.hatch.ca/energy/hydroelectric/projects/ds_dam_safety_std.htm
Contents excerpts: “dams are a provincial responsibility”... “Although all provinces have Water Acts under which dams can be regulated, only British Columbia, Alberta and Québec had enacted regulations specific to dam safety...  Ontario has been working on its new system for more than a decade."
- Identical page contents “snapshot” from Web Archive's visit of Dec 16, 2010 can still be viewed at:
http://web.archive.org/web/20101216132851/http://hatch.ca/Energy/Hydroelectric/Projects/ds_dam_safety_std.htm


CC'd to Ontario Provincial Officials: MMAH Kingston office; Minister of MAH; Minister of NDM; Minister of Energy; Minister of the Environment; Premier Dalton McGuinty; MPP for PE-H Todd Smith
Also to Federal Officials: Prime Minister Stephen Harper; MP for PE-H Daryl Kramp
FWD's to: upper” & “lower” Municipal Interests & Others BCC's to: Select Organizations, Ratepayers, Media &Others