I am providing a detailed…

I am providing a detailed technical response to the Assimilative Capacity Study (ACS) submitted in support of the proposed Environmental Compliance Approval (ECA) for the Searchmont Resort Wastewater Treatment Plant (WWTP) discharge to the Goulais River.

This letter integrates:

- The full ACS package
- The 2021–2022 MECP–consultant consultation record
- The October 2022 MECP internal review memo
- The final proposed effluent limits and modeling assumptions

After reviewing the complete record, it is clear that the ACS remains interim, incomplete, and non‑compliant with MECP’s own Assimilative Capacity Guideline, Policy 2, and standard expectations for surface water discharge approvals.

For these reasons, I respectfully request that MECP not approve the proposed discharge until a revised, scientifically defensible ACS is completed.

1. The ACS is an Interim Submission and Does Not Meet MECP Requirements
MECP’s October 2022 memo confirms that the ACS is based on interim monitoring data and that the dataset was accepted for review, not approval. The ACS does not meet MECP expectations for:

- 2–3 years of seasonal data
- Winter DO and temperature
- Storm-event sampling
- Continuous DO/temperature monitoring
- Hydrodynamic mixing zone modeling
- Cumulative effects assessment

Despite these gaps, the ACS was advanced to the ECA stage. This is premature and places the Goulais River at risk.

2. Policy 2 Is Violated — Downstream Phosphorus Already Exceeds PWQO

The ACS and MECP both confirm:

- Downstream TP = 0.030–0.043 mg/L
- PWQO = 0.030 mg/L
- ACS proposes effluent TP = 0.15 mg/L
- Resulting downstream TP = 0.031 mg/L

Under Policy 2, no further degradation is permitted when a parameter is at or above its objective.

The proposed discharge increases phosphorus concentrations and therefore cannot be approved under Policy 2.

3. Ammonia Toxicity Is Near Acute Thresholds
The ACS proposes:

- TAN = 15 mg/L
- Resulting un-ionized NH₃ = 0.155 mg/L
- Acute toxicity threshold = 0.161–0.200 mg/L
- This is within 0.005 mg/L of acute toxicity.

MECP’s memo recommends toxicity testing after exceedance, rather than requiring protective limits up front. This is reactive, not preventative, and does not meet the intent of the PWQO for un-ionized ammonia (0.02 mg/L).

4. No Hydrodynamic Mixing Zone Modeling Was Completed

Despite MECP guidance, the ACS includes:

- No CORMIX modeling
- No acute or chronic mixing zone delineation
- No ice-cover mixing analysis
- No near-field toxicity assessment

Greenland asserts that high dilution makes modeling unnecessary. This contradicts MECP’s own ACS expectations and is not scientifically defensible.

5. Dissolved Oxygen (DO) Modeling Is Unstable and Incomplete

The ACS uses:

- Unrealistic BOD₅ = 569 mg/L to stabilize the model
- No winter DO modeling
- No sediment oxygen demand (SOD)
- No NBOD
- No identification of the critical DO sag point

MECP requested that DO modeling be redone using actual effluent limits. This was not completed in the ACS.

6. Monitoring Dataset Is Insufficient

The ACS includes:

- 20 samples over ~16 months
- Limited winter data
- No storm-event sampling
- No continuous DO/temperature data

MECP accepted this dataset for review but did not confirm it meets ACS guidance. It does not.

7. Treatment Feasibility Is Unproven

MECP’s memo states:

- It is unclear whether the proposed WWTP can achieve TP = 0.15 mg/L
- No treatment approach has been provided
- No cold-weather performance data is included
- No ammonia control strategy is described

Without treatment design details, effluent limits cannot be considered achievable or protective.

8. Cumulative Effects Are Not Assessed
The ACS does not evaluate:

Upstream septic systems

- Forestry and land disturbance
- Runoff
- Climate-driven low flows
- Downstream communities

This is a required component of a defensible ACS.

9. MECP Is Relying on Post-Approval

Monitoring Instead of Pre-Approval Science
MECP proposes:

- Upstream, near-field, and far-field monitoring after approval
- Conductivity monitoring to confirm mixing zone after startup

This approach shifts risk to the river and community. Proper modeling must occur before approval.

10. Conclusion and Request
Based on the full ACS package, MECP consultation record, and internal review memo, it is clear that:

- The ACS is interim and incomplete
- Policy 2 is violated
- Ammonia toxicity is near acute thresholds
- Mixing zone modeling is absent
- DO modeling is unstable
- Monitoring data is insufficient
- Treatment feasibility is unproven
- Cumulative effects are ignored

I respectfully request that MECP require a revised, scientifically defensible ACS before any approval is considered.

This is necessary to protect the Goulais River, uphold MECP policy, and ensure that effluent limits are both achievable and protective.