Re: Searchmont Ski Resort –…

Re: Searchmont Ski Resort – Proposed Wastewater Treatment Plant (WWTP) – Submission to the Environmental Registry of Ontario

To the Ministry of the Environment, Conservation and Parks,

I am submitting this comment in response to the proposed wastewater treatment plant (WWTP) for the Searchmont Ski Resort. These concerns are based on a summary of findings from an independent wastewater treatment expert who reviewed the design brief.

Assimilative Capacity Study (ACS) Dataset Length and Seasonal Coverage

The assimilative capacity study (ACS) appears to follow typical methodology; however, the length of the dataset is shorter than what MECP commonly expects for surface‑water assessments. While MECP does not specify a formal minimum dataset length in guidance, in practice they typically request two to three years of surface‑water data to capture seasonal and year‑to‑year variability, particularly during low‑flow summer conditions when the receiving river is most sensitive.

The proponent collected 16 months of data, which is a reasonable dataset, but it does not include a second full summer low‑flow period. As a result, the dataset may not fully represent the range of conditions that influence assimilative capacity. The proponent also had the opportunity to continue collecting data after submitting the initial dataset to MECP, which could have strengthened the ACS by bringing it closer to the two‑year dataset MECP typically expects.

Given the sensitivity of the receiving watercourse and the importance of accurately characterizing low‑flow conditions, I respectfully request that MECP consider whether the ACS dataset provides sufficient seasonal coverage, or whether additional data collection is warranted to ensure a robust assessment of assimilative capacity.

We also request that the MECP require 2-3 years of ambient water quality through a quality monitoring program downstream, past the downstream location used in the proponents monitoring program that formed / produced the data in the Assimilative Capacity Study.  If Policy #2 is already met where the river crosses Hwy 17 – it is vital to understand what condition the water quality is in beyond that point and within Goulais River before any introduction to effluent into the river is even considered.