Subject: Opposition to…

Subject: Opposition to Proposed Sewage Treatment Plant Discharge to Goulais River (ERO #025-1121)

I strongly oppose the proposed discharge of treated effluent from the Searchmont Resort sewage treatment plant into the Goulais River. This river is ecologically, culturally, and recreationally significant, and this proposal introduces unnecessary threats to the watershed.

Species at Risk:
- Lake Sturgeon (Acipenser fulvescens): The Goulais River supports a significant Lake Sturgeon population that spawns below Whitman Dam. Spawning success depends on clean, cold, well-oxygenated water and natural spring flows (USFWS; IJC, 2023). Effluent discharge—even treated—can cause ammonia toxicity, dissolved oxygen (DO) sag, and thermal changes during critical spawning windows (Greenland ACS, 2022). The proximity of the known spawning location to the downstream effluent discharge site, is likely to influence survival of lake sturgeon during larval drift, as this keystone species encounters changes in flow, temperature and water chemistry at the proposed discharge location during this sensitive lifestage. The Goulais Bay Lake Sturgeon population is critical to Lake Superior’s overall sturgeon recovery, representing one of the most resilient Great Lakes populations.
- Wood Turtle (Glyptemys insculpta): Listed as Endangered in Ontario (COSSARO, 2020), Wood Turtles overwinter in the Goulais River near shore in shallow depths, requiring stable cold temperatures and high DO (Greaves & Litzgus, 2007, 2008). Alterations to flow, temperature or water quality threaten survival and conflict with recovery objectives under Ontario’s ESA and federal SARA (ECCC Recovery Strategy, 2020). The Algoma wood turtle population represents the northernmost population of this species in Ontario, making its conservation essential for maintaining range and genetic diversity of this endangered species.

Cumulative Effects:
This new proposal adds to existing pressures on the Goulais River Watershed from Searchmont Resort, including water withdrawals for snowmaking and resort operations (Permit to Take Water No. 8654-BFBRPR). Combined with effluent discharge, these activities will further alter natural flow, change thermal regimes, and compound risks to spawning sturgeon and overwintering turtles. Recovery strategies emphasize maintaining natural hydrology; the cumulative impacts from the existing water draw permit and the proposed effluent discharge undermine these objectives. Water quality analyses in the ACS was limited in scope; while the focus was on standards related to nutrient loading further consideration of other sources of pollution in treated effluent needs to be considered such as pathogens, microplastics and chemicals such as residual chlorine, pharmaceuticals, personal care products, and industrial chemicals which can remain, harming aquatic organisms. I would also propose that an assessment of chemical inputs to the Goulais from the snowmaking process be further investigated in a cumulative effects context.

Legal and Policy:
Ontario’s Endangered Species Act and federal recovery strategies require reducing human-related threats and maintaining viable populations. Approving any discharge in the Goulais River watershed contradicts these commitments. The Algoma Headwaters Signature Site Management Plan and Goulais River Beach Ridges Conservation Reserve Plan also prioritize protecting riverine natural values.

Recreational Value:
The Goulais River is more than a waterway—it is a cornerstone of the Algoma Highlands’ outdoor experience. Its clean, free-flowing waters and scenic forested valleys provide an intrinsic backdrop for canoeing, kayaking, and fishing, as well as photography and hiking along its rugged shoreline and adjacent trails. The river’s natural character attracts residents and visitors seeking solitude, wildlife viewing, and iconic northern landscapes, supporting Regional tourism and businesses beyond downhill skiing. Effluent discharge risks degrading water quality, diminishing the clarity and beauty that make the Goulais a destination for other recreational user groups, and erodes the sense of wilderness that defines the Algoma Highlands.
As a resident of Goulais River, these recreational activities are deeply connected to local quality of life and community identity (and its namesake), offering affordable, accessible recreation for families and supporting mental and physical well-being. The river’s natural character also underpins local businesses that cater to outdoor enthusiasts (Moutainview Lodge, Blueberry Hill Campground…), complementing winter skiing with four-season recreation. Effluent discharge risks degrading water clarity, shoreline aesthetics, and fish habitat, eroding both the intrinsic wilderness experience and the economic and social benefits that Goulais and Searchmont residents value. Protecting the Goulais River means protecting the lifestyle and heritage that define Algoma.

In closing, please note that I am also a regular patron of Searchmont Resort (season pass holder); my family and I love the benefits of spending time together on the hill and at the resort each winter – but NOT at the expense of the river we call home. Alternative solutions for waste water treatment exist. Closed-loop systems, off-site hauling to a municipal WWT facility, or advanced land-based treatment options can meet wastewater needs without discharging to the Goulais River.

I urge MECP to mitigate these risks:
- Deny approval for direct discharge to the Goulais River, and
- Require a no-discharge solution that fully protects aquatic species at risk habitat, the natural values of the Goulais River Watershed and a decision that respects the voices of the residents of the communities of Searchmont, Batchewana FN (Goulais Bay Reserve) and Goulais River.