Concerns about the Environmental Report on the Enerdu GS Expansion and Redevelopment Project

Neil Carleton

January 30, 2013

PREPARED FOR THE MAYOR AND COUNCILLORS OF MISSISSIPPI MILLS

SPECIAL COUNCIL MEETING JANUARY 31

ENVIRONMENTAL CONCERNS

Provincially Significant Wetland (PSW) and Area of Natural and Scientific Interest (ANSI)

Following a review of natural heritage values and data, the Ontario Ministry of Natural Resources (MNR) determined the other year there were no PSW or ANSI within the proposed site area.  This, however, was before the finding of the Public Advisory Committee of the Mississippi River Water Management Plan in defining the zone of influence of the Enerdu project to the entirety of Reach 18.  This would be from the weir to the Appleton Dam, rather than just the 250 m long area between the project site and the bridge by the Almonte old town hall.  The ER does not address the finding of the Committee.

Within the project’s zone of influence is the Appleton wetland, a recognized PSW and ANSI.  The wetland has been a stable ecosystem for a long time, remaining healthy as long as the base of the trees and the top roots could dry out for a period during the growing season in summer and early fall.

Only two years after the installation of modified flashboards on the Almonte weir, a significant tree die-off was documented at this sensitive site upstream.  Insect or disease damage, or any higher than normal river water flow over the years, has been ruled out as the cause.  The trees drowned from summer high water levels.  There’s little doubt the extra high flashboards are responsible for the damage to the Appleton Wetland.

Any rise in river level which might result from the Enerdu project could jeopardize the remaining forest and any natural recovery of this ecosystem that may still be possible.  This is not addressed in the ER.

Fish Nursery Habitat

Reach 18, the project’s zone of influence, is nursery habitat for a variety of fish, including small mouth bass and yellow perch.  The fish sampling for the ER was not representative of the true impact area.  Fish sampling above the weir in Reach 18 and below the immediate powerhouse area were not conducted.  Sampling needs to be undertaken in all areas of the project’s zone of influence.

Other Wildlife Habitat

The project’s actual zone of influence extends beyond the very small sampling area for birds and other wildlife.  As well as any species that would have been missed due to limited area sampling, wildlife often seen in the stated zone of impact is missing.  This includes birds and mammals of the river ecosystem.  In addition, there are many waterfowl nesting areas in the true zone of influence that are adversely affected by frequent water level changes.  Wildlife sampling needs to be undertaken in all areas of the project’s zone of influence.  The effects of frequent water level changes on waterfowl nesting is needed in the ER too.

Endangered Species

River Redhorse  Moxostoma carinatum

Our local fish is of special concern provincially and nationally.  It’s particularly

susceptible to siltation and turbidity which can result from urban development, such as

river disturbance of the magnitude proposed by Enerdu.  This needs to be addressed in the ER.

  •  American Eel  Anguilla rostrata

This endangered species uses the Mississippi River through Almonte as a migratory corridor.  Although general options are proposed in the ER to accommodate eel migration, specifics are missing.  Details are needed in the report on provisions for migration and the means of preventing their access to the turbines.

  •  Eastern Musk Turtle  Sternotherus odoratus

Among the smallest turtles in Ontario, this species is threatened provincially and nationally.  Populations have declined as development has changed shorelines.  One was in fact caught during the MNR 2011 tailrace survey at the Enerdu site.  Details are needed in the report on the means of preventing their access to the turbines.

Mercury Pollution

Any changes to the flow regime of the river that result from the construction, operation, and maintenance of this project have the potential to adversely affect the flora and fauna of the river water, shoreline, and river bed.  This could include the frequent raising / lowering of water levels and permanent flooding of soils with subsequent mercury introduction.  The ER makes no mention of potential effects of mercury pollution.

Elimination of a River Environment

The project has the potential to eliminate a river environment with the creation of a backwater or lake environment above a new dam.  What would be the impact of these new environments on the flora and fauna of the river water, shoreline, and river bed?

ENERDU RESPONSE

These concerns about the Enerdu Environmental Report were communicated by e-mail on January 28 to Ron Campbell, Enerdu Power System Inc., and Muriel Kim, OEL-HydoSys Inc..  Although a response was requested, I have not yet received a reply.

 OTHER RESPONSES

 I wrote on December 21st to learn more about the involvement of any government agencies in the project, express my initial concerns, and ask if information was available to share about the Enerdu project.

Hon. James J. Bradley, Ontario Minister of the Environment

JANUARY 17 LETTER REPLY

Hon. Michael Gravelle, Ontario Minister of Natural Resources

JANUUARY 18 TELEPHONE REPLY

Hon. Keith Ashfield, Federal Minister of Fisheries and Oceans

NO REPLY

Mr. Paul Lehman, Manager, Mississippi Valley Conservation Authority

NO REPLY

Mayor John Levi

NO REPLY

Councillor Bernard Cameron – Almonte Ward

NO REPLY

Councillor Garry Dalgity – Almonte Ward

NO REPLY

Councillor Alex Gillis – Almonte Ward

NO REPLY

Councillor Rick Minnille – Almonte Ward

NO REPLY

Counillor John Edwards – Ramsay Ward

NO REPLY

Councillor Shaun McLaughlin – Ramsay Ward

E-MAIL REPLY

Councillor Paul Waters – Ramsay Ward

NO REPLY

Councillor Val Wilkinson – Ramsay Ward

NO REPLY

Councillor Duncan Abbott – Pakenham Ward

MEETING

Councillor Denzil Ferguson – Pakenham Ward

NO REPLY

Damaged wetlands, photographed last fall.