Anne Cameron
Project Evaluator
Project Review Unit
Environmental Approvals Branch
Ministry of the Environment
2 St. Clair Ave. West, Floor 12A
Toronto, Ontario
M4V 1L5

Thank you for your e-mail message of November 22, and attached letter from Jim Bradley, Minister of the Environment , regarding my Part II Order request for the Enerdu Generating Station Expansion and Redevelopment project.

Although I’m still studying the whole of the Minister’s response, allowing Enerdu to proceed, it’s obvious that the issue of the dying Appleton wetland is still not resolved. All that’s actually required is action.

There’s no need for even further delay on this issue if the intent of the Ministry of the Environment and the Ministry of Natural Resources is to protect this fragile ecosystem. Experience has demonstrated that when there’s a political will, there’s a way.

WHEREAS the Appleton wetland has been a stable ecosystem for a long time, as evidenced by its significant size and the rich diversity of its distinctive flora and fauna over the years; and

WHEREAS the Appleton wetland is dying, as observed from the river shoreline, from the river, and from the air, and

WHEREAS the Appleton wetland is important to the Crown, as evidenced by its designation as a provincially significant wetland (PSW) and an area of natural and scientific interest (ANSI); and

WHEREAS the Appleton wetland is important as a local natural wonder and public treasure, as evidenced by the expressions of concern from municipal residents to the Town of Mississippi Mills, the Mississippi Valley Conservation Authority, the Ministry of the Environment, and the Ministry of Natural Resources; and

WHEREAS silver maples naturally grow well in wetland conditions along river shorelines as long as their root collars are allowed to dry out after the spring floods during the summer and early fall growing period; and

WHEREAS silver maples drown and die under stress from sustained high water levels; and

WHEREAS the river level between Almonte and Appleton was raised with the installation of flashboards by Enerdu in 2004, as evidenced by the increased power draw at the plant; and

WHEREAS in the summer of 2006 dead silver maples were noted at the Appleton wetlands only a short ecological time after the installation of the Enerdu flashboards; in 2007 silver maples were listing and toppling; by 2008 the damage had spread and there were acres of dying, dead, and blown down trees; the destruction continued in 2013; and

WHEREAS something about the river environment between Almonte and Appleton is killing the silver maples of the Appleton wetland, as evidenced by healthy wetland forests above Appleton and growing riverside trees below Almonte; and

WHEREAS insect or disease damage has not been evidenced in the Appleton wetlands, and any higher than normal river water flow over the years has been ruled out as the cause of the silver maple die-off; and

WHEREAS the Appleton wetland looks just like a forest drowning from the sustained high water effects of a new beaver dam, there’s no beaver damn downstream raising the river level;

WHEREAS the zone of influence for the Enerdu project is currently defined as only spanning from the proposed excavation area near the upper limit of the existing weir, upstream of the generating station, down to the end of the tailrace of the station; and

WHEREAS the Mississippi River Standing Advisory Committee (MRSAC) recommended in February 2013 that the zone of influence should include all of Reach 18, the section of the Mississippi River between the Enerdu station and the Appleton generating station; and

WHEREAS the available record of any Crown agencies charged with the protection of the Appleton wetland is quite weak:

– as observed by the massive die-off of its silver maples that’s been allowed; and
– as evidenced by the lack of any meaningful public discourse on the issue by any agencies since the die-offs were reported by municipal residents; and
– as evidenced by the absence of any available documentation to assure the public that applicable information has already been sought/reviewed, and the Appleton wetland site has already been visited, since the massive die-offs were reported by municipal citizens over years; and
– as noted by the delay in addressing the recommendation of the MRSAC in a timely fashion.

THEREFORE BE IT RESOLVED THAT any Crown agencies charged with the protection of the Appleton wetland actually get on with the job; and

THEREFORE BE IT FURTHER RESOLVED THAT consideration of a permitting stage for the proposed Enerdu project be put on hold until, within a publicly posted time frame, the Ministry of Natural Resources:

– seeks and thoroughly reviews all applicable information regarding the massive die-off of silver maples at the provincially significant Appleton wetlands; and
– visits the Appleton wetlands to conduct applicable field work at this locally valued natural treasure; and
– assesses any potential amendments of the Mississippi River Management Plan to aid in the preservation of the Appleton wetlands; and
– assesses any potential changes to the current operating regime of the Enerdu station, such as the water level maintained upstream of the facility, to aid in the preservation of the Appleton wetlands; and
– during this process engages in meaningful public discourse so that municipal residents are regularly informed of progress and have opportunities for dialogue with the Ministry.

I’m copying this reply to other residents who share my concern for the Appleton wetland.

Best wishes for the success of the Ministry of the Environment in its efforts to ensure the protection of our natural environment.


Neil Carleton
P.O. Box 1644
Almonte, Ontario
K0A 1A0