GBA, Indigenous Women, Environmental Sustainability, Equitable Project Benefits

This comment is provided in response to the proposed Marmora Clean Energy Hub Project Project. In our review of the IPD summary, we prepared a summary of information and disseminated it to interested parties from nearby communities.? We understand that the energy hub is being created to develop a closed-loop hydroelectric storage facility. We are in support of green energy projects and moving Canada closer to obtaining our net zero emission targets, and hopefully to overshoot these targets and become entirely emission free within the coming decades. The previous Marmoraton mine, which closed in 1978, clearly displays the harmful impact of the resource extraction industry, where mines are given access to destroy the land, eventually being abandoned, and never restored. It is essential that the industry at large take action to rehabilitate land that has been significantly altered from mining processes, and ensures to the greatest extent possible, that the original ecosystem be restored. Projects like this are innovative and meet the demands for increased sustainable energy and widespread environmental restoration. Nevertheless, we seek to ensure that the project is done in an inclusive and authentic way, and that the benefits can reach both the ecosystem and community levels.  

We wish to echo the concerns of the communities related to cultural heritage preservation. Specifically, to preserve and maintain water quality and quantity for localized and downstream water systems. These waterbodies are used for essential traditional and cultural uses including hunting, fishing, and trapping. Therefore, to respect the rights of Indigenous People, as enshrined in section 35 rights, it is imperative that the project ensures that this land will be able to be accessed and used by Indigenous Peoples throughout project development and the project lifespan. The statement that land access “could potentially be used by Indigenous Peoples” is not enough to ease the concerns of these communities. A clear, explicit, and tangible promise must be made that ensures their access to the land, and that the quality of the environment will be maintained to satisfy the claim that there will be “no anticipated effects to traditional use or values as a result of the project”.  

We understand that the economic impact of the project will be great, generating ~32$ million annually. We explicitly wish to understand how these economic benefits will be disseminated to surrounding Indigenous communities, in the spirit of reconciliation.  We would like to request that, to the greatest degree possible, material be sourced locally and ethically, with local, Indigenous construction workers and companies being hired. Prioritizing jobs to Indigenous people who live in the region, who would not have to be relocated for work is essential in minimizing negative social impacts associated with fly in/fly out work schedules, allowing economic benefits to generate at the local level.?The IPD makes specific mention to a commitment to providing beneficial economic opportunities as an extension of engagement agreements, such as training, apprenticeships, or procurement. We look forwards to seeing if these promises become an actionized reality, if IBAs are developed with communities, and what opportunities are made available. 

The IPD states that engagement has been ongoing, and the project has been in collaboration with Alderville First Nation and Williams Treaty First Nations. Our organization explicitly requests that steps are being taken to ensure that Indigenous women, girls, and gender diverse people from these communities are being included in decision making and implementation of this project. Ensuring that their inputs are being thoroughly considered with tangible, measured mitigation of impacts. We would like to ensure that surrounding First Nation communities and urban Indigenous people have been sufficiently informed in advance of project developments and are given support and time to provide input.? Specifically, we request the voices of Indigenous women, girls, and gender diverse people to be intentionally included when assessing the potential impacts from project development and prioritized during the implementation of the project through providing equal hiring access to Indigenous women, providing safe and secure employment throughout project development. We submit this comment to bring attention to the need for intersectional inclusion, which engages with multiple identity holders, not just some, or part of a community. Future IPDs would benefit from more metrics on the extent of engagement, and the identity features of those being engaged with. We suggest applying intersectional identity analysis and GBA+ to develop inclusive, diverse, and equitable processes.  

To focus on the environmental features, we understand that the environment has a variety of aquatic habitats which house a variety of species. We wish to advocate for the preservation of habitat area as much as possible, specifically wetland habitats such as, Beaver Lake and Crowe Lake. Wetlands are the most crucial ecosystems globally for biodiversity preservation, phosphorus and nitrogen processing, pathogen filtration, carbon sequestration, and much more. In consideration of this, any wetland loss would negatively impact the health and wellbeing of not only Canadians, but all the beings of creation with whom we share this Earth. Specifically, the endangered species within the region including the Channel Darter (Percina copelandi), 4 species of bats, and 28 other species at risk identified in the IPD represent the crucial element of habitat preservation. In an era of unprecedented and extreme biodiversity loss, habitat restoration and preservation should be at the forefront of our shared priorities. We understand that a significant area of the mine site is currently occupied by invasive species, and that the results of the project through habitat fragmentation and alteration of forest edge boundaries are an opportunity to reintroduce native species and restore original ecosystem function. The project should employ and include environmental scientists, botanists, wildlife biologists, and traditional land stewards to accomplish these goals during construction.  

We agree with and seek to uplift the key comments and concerns expressed by Alderville First Nation including: 

• The potential for legacy pollution/ contamination of the open pit water from previous mining activities  

• The potential effects on groundwater levels and water wells of nearby residents  

• The inability to swim, hunt, harvest in the open pit area  

• The potential effects on habitat and species composition due to construction  

• Explicit consideration and recognition of the Wild Rice harvest when planning dewatering, construction, and particularly invasive project steps.  

• Explicit consideration and recognition of traditional land use within the region  

• Transparent communication and inclusion in training, apprenticeship, employment, and procurement opportunities to surrounding Indigenous communities 

We await the Indigenous Engagement Plan, Community Engagement Plan, and Agency Engagement Plans, as well as the more detailed social impact assessment reports.  

?Thank you for considering our comments in the Impact Assessment Process.??We look forward to an equitable, sustainable, and just future for all Canadians now and for future generations.???If you have any further questions or concerns, please contact one of our offices, or Britney Zacharuk the Project Coordinator for the Empowered Voices Project by emailing b.zacharuk@keepersofthecircle.com (mailto:b.zacharuk@keepersofthecircle.com) to engage in direct discussion. We value collaboration and transparency as we aim to work together to mobilize for a just, equitable, and sustainable future.???? 

Thank you | Miigwetch???? 

Empowered Voices Project Team???