ADAMS MINE ENVIRONMENTAL ASSESSMENT BOARD

THE DISSENTING OPINION

This hearing had all the earmarks of a political process.
It was extremely narroy in scope and refused to examine the questions of
The economic impact on the district
The cultural, social or ecological effects on the district
The reputation impact on downstream development
The cost and feasibility of repair and cessation in the event of failure

All parties agree that it was reasonable to assume ONE THOUSAND YEARS OF CONTAMINATION RESULTING FROM THE PROJECT

The government of Ontario accepted a two to one decision for conditional approval, even though the gravest risks to a vast area of clean water and human settlement were at stake. The concerns of the dissenting view were ignored instead of being addressed. In other words this hearing was not about protecting the environment but about serving the interests of those few who stood to gain financially by proceeding. Had this not been the case the serious objections in the following dissenting opinion could not have been ignored.

The process was unfair. All the money and expertise it could buy was wildly weighted on the side of those who proposed to ship garbage to Temiskaming. This "expertise" was then paraded as superior to volunteer witnesses for the opposition, to support proceeding.

In a project where the scale of devestation, (environmental, economic and human), is so great, every doubt, every danger, every outcome should have been addressed and every concern satisfied. This hasty hearind did not even come close.

HIGHLIGHTS OF THE DISSENTING OPINION:by Don Smith Pages 56-64 "I believe there is enough evidence to suggest the drainage layer could fail over the 1000 year contamination life span leading to a failure of hydraulic containment and the subsequent migration of leachate out of the pit."p.60

THE PROPOSED HYDRAULIC CONTAINMENT DESIGN IS NOT AN EFFECTIVE SOLUTION FOR HOLDING AND COLLECTING THE LEACHATE BECAUSE OF

1) Uncertainty and risk of 1000 year lifespan of protection
The 1000 year lifespan of protection from contamination suggested was far from precise. A computer model based on data covering a period of 10-30 years.
2) Possible failure of the drainage layer which cannot be replaced once buried under tonnes of waste
-The estimate of the effects of clogging of the layer also used computer modeling based on lab experiments and very short term landfill experience.
-A specialist in the design of material haulage and transport systems suggests the sheer forces from the settling of the waste would seriously damage the drainage layer thereby causing failure of the hydraulic containment and subsequent escape of leachate.
3)Ineffecient leakage monitoring beneath the pit means no warning of escape of the leachate in the event of containment failure.
4)Uncertain groundwater levels
I don't believe 2 more deep angled boreholes beneath a 27 hectare pit, sited in fractured bedrock with possible fault and dykes, is sufficient to effectively monitor groundwater levels.
5)Lack of design detail on contingency plans.
Of the several possible contingency plans suggested, there has been no level of design detail provided to assess their effectiveness. "The proponent's contingency plans have not proceeded beyond the conceptional stage."
6)Lack of Financial Assurance Information
The proponent wanted these matters to be declared "outside the jurisdiction of the Board.' and that Coalition evidence on financial matters be declared 'inadmissable'. Given the stringent timelines imposed on the hearing it was decided to be 'not practicle' to engage in detailed costing.