I am writing as a resident,…

I am writing as a resident, with young kids, living on the Goulais River to express serious and urgent concerns regarding the proposed effluent discharge from the Searchmont Resort Wastewater Treatment Plant (WWTP). After reviewing the Goulais River Assimilative Capacity Study (Final Report) prepared by Greenland International Consulting Ltd., it is clear to me that this project poses substantial long-term risks to the river ecosystem, public use of the waterway, and the well-being of our families and friends who rely on the Goulais River every day.

While the study concludes that the Goulais River has the "theoretical" capacity to assimilate treated effluent, this conclusion does not adequately acknowledge the cumulative, chronic, and failure-related risks associated with allowing a permanent point-source discharge into a historically clean and sensitive watershed.

The Goulais River Is Already at Its Phosphorus Limit Downstream

The study acknowledges that the downstream monitoring location at Highway 17 already meets or exceeds the Provincial Water Quality Objective (PWQO) of 0.03 mg/L for total phosphorus. This designates the lower river as a Policy 2 receiver, where no further degradation is permitted.

Even slight increases in phosphorus could worsen eutrophication risk, especially during low-flow warm-season periods, peak tourism occupancy, and treatment system upsets or maintenance issues. The proposed limits leave virtually no margin for error, yet the river and downstream residents would suffer the consequences.

Permanent Surface-Water Discharge Creates Long-Term Risk for Residents and the Watershed

Once approved, a river discharge is permanent. Unlike a septic field, lagoon, or contained system, a surface discharge:
-runs 365 days a year,
-increases with resort expansion,
-depends entirely on mechanical, chemical, and human reliability,
-exposes the river to ongoing risks of untreated or partially treated effluent during equipment failure, power outages, or operator error.

Downstream families should not be expected to absorb this risk for the benefit of a private resort, when alternatives exist but have not been fully explored.

The Study Assumes “Ideal Performance” That Does Not Reflect Real Operational Conditions

The assimilative capacity calculations rely on unrealistic assumptions, including:
-perfect compliance with effluent limits,
-consistently low phosphorus removal (<0.11 mg/L),
-stable ammonia and pH behaviour,
-reliable high river dilution despite climate variability,
-negligible risk of bypass or mechanical failure.

In reality, wastewater treatment plants, especially in northern climates, experience:
-frequent power outages (reference Algoma Power in the past year),
extreme cold impacts on equipment,
mechanical malfunction,
operator error,
seasonal load spikes.

Residents have no assurance that the plant will achieve the “ideal” performance on which the study depends.

Effluent Discharge to a Recreational and Residential River Is Not in the Public Interest

Families use the Goulais River for swimming, fishing, boating, recreation, and shoreline enjoyment. Introducing continuous wastewater discharge, regardless of treatment level, into a natural river that is actively used by residents and visitors is inappropriate and contrary to the preservation of northern Ontario waterways.

Downstream residents gain no benefit from this discharge - all risks are transferred to the public, while the economic gain is directed solely toward a private USA based business.

Alternatives to River Discharge Should Be Fully Explored Before Any Approval

Before granting any Environmental Compliance Approval (ECA), MECP should require a complete assessment and public disclosure of all feasible alternatives, including:

-engineered subsurface disposal fields,
-drip dispersal or shallow bedrock systems,
-membrane bioreactor systems with zero-discharge storage,
-seasonal storage paired with land application,
-connection to regional wastewater services, where feasible,
-scaling development to match safe wastewater capacity.

A private commercial expansion should not default to river discharge simply because it is the cheapest option. The Goulais River is a clean, healthy, and sensitive watercourse, and the families who live along it depend on its integrity for their safety, recreation, children’s well-being, and way of life. Allowing a permanent point-source discharge for the sole benefit of a private resort is entirely inconsistent with long-term watershed protection and with the interests of the community that relies on this river every day.

It is also important to emphasize that this resort is not a locally owned Canadian business. While a limited number of local jobs and procurement dollars may reach the region, the real financial benefits of this expansion flow to owners outside our community and outside our country, while the environmental risks are placed squarely on local families, Canadian residents, and the Goulais River itself. There is no justification for permitting a foreign-owned private company to discharge wastewater into a Canadian river when the people who live here, pay taxes here, and depend on this waterway will bear every consequence if anything goes wrong.

Finally, there is nothing equitable about this proposal. One private resort stands to profit financially, while every downstream resident, families, children, landowners, and long-term community members, would be forced to shoulder the environmental risks, accept the potential decline in water quality, and live with the permanent alteration of a river that is central to their lives and identity. This is not a shared benefit; it is an imposed burden. No Canadian river community should be expected to sacrifice its waterway so that a foreign-owned business can expand at their expense.

Would you make this same approval if your own home, your own children, or your own drinking water source were downstream of this discharge?