To the Ministry of the…

To the Ministry of the Environment, Conservation and Parks
I have lived in Goulais River on the river over 40 years.   In 1985 the flood waters covered a good portion of my property.  I am very concerned about this Proposal of waste.   I am totally against what searchmont is trying to do.  Please don't let them do this.  It will hurt the residents as well as wildlife and our beautiful natural community.  There are many reasons stated below therefore 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.
The expert concluded that while the proposed treatment
technology is commonly used in Ontario and can perform well, several important
design assumptions appear to be incomplete or underestimated. These issues
could / would affect the plant’s ability to reliably meet its effluent limits
and protect the sensitive receiving watercourse.
Below is a summary of our understanding of the key concerns
the expert identified and the considerations and calls to action we are asking
the MECP to consider carefully:
1)     
Concerns About Underestimated Influent
Strength and Commercial Wastewater Impacts
The Design
Brief describes the influent as “typical domestic wastewater.” However, based
on the concentrations presented in Table 5 of the report, the proposed influent
characteristics align more closely with weak to medium strength domestic
sewage according to standard wastewater literature. The report does not
explain whether these values were derived from actual monitoring at the
existing facility or whether they are purely assumed. This lack of clarity is
concerning given the nature of the proposed development.
A significant
portion of the projected wastewater flow—approximately half—will
originate from commercial uses, including restaurants and a conference
centre. These types of facilities are well documented to produce wastewater
with substantially higher concentrations of:
Total Suspended Solids
(TSS)
Biochemical Oxygen
Demand (BOD)
Total Kjeldahl
Nitrogen (TKN)
Total Phosphorus (TP)
Fats, Oils, and Grease
(FOG)
 
Commercial
restaurant wastewater can have BOD concentrations in the several hundreds to
thousands of mg/L, depending on food type, cooking practices, dishwashing
procedures, and grease management. In contrast, the design basis used in the
report assumes an influent BOD of only 110 mg/L, which is typical of
weak domestic sewage and does not reflect the expected contribution from
commercial kitchens.
The expert
review concluded that the influent concentrations used by the proponent and
Napier‑Reid are likely underestimated for a facility with this level of
commercial activity. If 50% of the daily flow originates from restaurants and
food service operations, all influent design concentrations (BOD, TSS, TKN, TP,
FOG) should be re‑evaluated and increased to reflect the higher strength
wastewater expected from these sources.
Underestimating
influent strength has direct implications for:
Nitrification
performance and the ability to meet ammonia limits
Aeration
requirements and blower sizing
Alkalinity demand
Sludge production
rates
SBR cycle timing and
tank sizing
Tertiary filtration
loading
Overall treatment
reliability
 
If actual TKN
concentrations are higher than assumed, the plant may not achieve the required
ammonia removal, and the treatment equipment may be undersized for real‑world
conditions.
Given the
sensitivity of the receiving watercourse and the importance of accurate
influent characterization, I respectfully request that MECP require the
proponent to:
Clarify the basis
for the influent concentrations used in the design (measured data vs.
assumptions).
Reassess influent
strength to account for the substantial contribution from restaurants
and commercial kitchens.
Demonstrate that
the treatment system is adequately sized for realistic BOD, TSS, TKN,
TP, and FOG concentrations.
 
These steps
are necessary to ensure the WWTP is designed to handle the actual wastewater
characteristics expected from the proposed development.
2)     
Peak Flows May Be Higher Than the Design
Assumes
The design
uses a peaking factor of 2.0, but existing data from the resort shows peaks
closer to 2.0–2.4, especially on weekends and holidays.
Without flow
equalization, underestimating peak flows could lead to hydraulic overloading
and reduced treatment performance during busy periods.
The design
proposes an average daily flow (ADF) of 180 m³/day
and a peak daily flow of 360 m³/day, which represents a peaking
factor of 2.0. For a resort facility with highly variable occupancy — including weekends, holidays, and seasonal surges — a peaking factor of 2.0 appears low. Resorts typically
experience sharp, short‑duration spikes in water use, and the expert review
noted that a higher peaking factor would be more realistic for this type of
facility.
Based on the
existing flow data already collected by the proponent, the actual peaking
factor appears to range from approximately 2.0 to 2.4. This means the
design is using the lowest end of the observed range, rather than the
upper end that would provide a margin of safety. Underestimating peak flows can
lead to hydraulic overloading of the SBRs, reduced settling performance,
increased solids carryover to filtration, and reduced UV disinfection
effectiveness.
Given the
sensitivity of the receiving river and the importance of accurate design flows,
I request that MECP require the proponent to justify the selected peaking
factor and demonstrate that the plant can reliably handle peak flows at the
upper end of the observed range (2.4), not just the minimum value.
3)     
Concerns About Design Flows, OBC Values,
and Flow Monitoring
The proposed
design flows in Table 3 of the Kresin Design Brief reference the Ontario
Building Code (OBC) as the basis for flow generation rates. While the OBC
values used for the restaurant and conference room components appear accurate,
it is not clear where the value of 225 L/bed for the hotel component was derived.
This is not an OBC value. Under the OBC, the applicable design flows
are:
500 L/person for a resort
hotel
250 L/room for a regular
hotel/motel
 
The design
brief does not explain why a non‑OBC value (225 L/bed) was selected, nor does it
justify why a lower value is appropriate for this facility. This is a
significant concern because OBC values represent peak or maximum day flows,
not average day flows. Since the proposed design does not include any up‑front
flow equalization, the accuracy of both the average and peak
design flows becomes critical to ensuring the plant can reliably handle real‑world
peak conditions.
If the
development is phased, detailed flow monitoring will be essential to verify
actual average and peak flows. This is normally a standard ECA condition
requiring the owner to track and report daily flow values. However, the design
brief does not specify how daily flows will be measured.
The Napier‑Reid
package appears to include a flow meter as part of the tertiary treatment
equipment, but this meter is located after the treatment process. A post‑treatment
flow meter does not represent the true influent entering the plant from
the resort and therefore cannot be used to verify whether influent assumptions
were correct or whether peak flows are being exceeded.
To ensure
accurate flow tracking, the proponent should install a flow meter on the raw/influent
sewage pumping station, where all wastewater first enters the system. If
such a meter is already included in the lift station package, it is not clearly
shown in the available drawings, and it would not typically be included unless
explicitly specified.
Given the
sensitivity of the receiving watercourse and the importance of accurate design
flows, I request that MECP require the proponent to:
Justify the use of
225 L/bed
and explain why OBC‑specified values were not used.
Demonstrate that
the design flows adequately capture peak conditions, especially in the
absence of equalization.
Include influent
flow monitoring at the raw sewage pumping station to ensure accurate
tracking of actual flows entering the plant.
 
These steps
are necessary to ensure the design is protective, robust, and based on
defensible flow assumptions.
4)     
Technology Is Proven, but Performance
Depends on Accurate Design Inputs and Proper Operation
From a high‑level
perspective, the proposed treatment technologies are well‑established and
capable of meeting the effluent targets if the design assumptions are accurate.
Sequencing Batch Reactors (SBRs) are a reliable and proven biological process
for BOD removal and nitrification, and Napier‑Reid has a long track record of
successfully implementing this technology over the past 25 years.
However, the
expert review emphasized that the ultimate performance of the plant will depend
heavily on the accuracy of the design flow and influent quality assumptions. As
noted in earlier comments, several influent parameters—particularly BOD, TSS,
and TKN—appear to be underestimated given the significant contribution of
wastewater from restaurants and commercial kitchens. If the plant receives
higher or different influent strength than what the design is based on, the
system may experience difficulty meeting its effluent limits, especially for
ammonia.
In addition,
the expert noted that plant operations will play a major role in performance. The
way the facility is operated and maintained by the owner and their contracted
wastewater operator will directly influence effluent quality. Even
proven technologies can underperform if influent assumptions are incorrect or
if operational oversight is insufficient.
Given these
factors, I request that MECP require the proponent to:
Reassess influent flow
and loading assumptions to ensure the design basis reflects realistic
conditions for a resort with substantial commercial wastewater
contributions.
Demonstrate that the
treatment system is adequately sized to handle higher‑strength influent if
actual conditions exceed the assumed values.
Provide an operations
and monitoring plan that ensures the system will be properly managed to
achieve consistent performance.
 
These steps
are necessary to ensure that the plant’s proven technologies can reliably meet
effluent targets under real‑world operating conditions.
5)     
Phosphorus Removal Technology Is Proven,
but Design Inputs Must Be Re‑Evaluated
The proposed
phosphorus removal strategy—chemical precipitation followed by filtration—is a
well‑established and widely used treatment approach in Ontario. While many
facilities historically used sand filters, cloth disc filters such as those
proposed here are also proven technologies and can achieve comparable
performance with a smaller footprint. The effluent phosphorus limits proposed
for this facility are stringent, but with a properly designed and operated
system, they are technically achievable.
The expert
review provided two relevant Ontario examples using similar Napier‑Reid SBR
systems with chemical precipitation and filtration:
Havelock WWTP
Technology: Napier‑Reid
SBR + chemical precipitation + sand filtration
Dry‑season TP limit:
0.14 mg/L
2020 performance:
0.07 mg/L average TP
Operating at ~65% of
rated capacity
 
Teeswater‑Formosa WWTP
Technology: SBR +
chemical precipitation + sand filtration
TP objective: 0.1
mg/L
TP limit: 0.15 mg/L
2024 performance: 0.1
mg/L average TP
Operating at ~74% of
rated capacity
 
These
examples demonstrate that the proposed effluent phosphorus limits are
theoretically achievable with this type of treatment process.
However,
the expert emphasized that achieving these limits depends heavily on the
accuracy of the influent flow and concentration assumptions used in the design.
As noted in earlier comments, the influent BOD, TSS, TKN, and TP values appear
to be underestimated, particularly given that approximately half of the
wastewater flow will originate from restaurants and commercial kitchens, which
are known to produce significantly higher‑strength wastewater.
If influent
concentrations are higher than assumed, this will directly affect:
chemical dosing
requirements
sludge production
filtration loading
SBR cycle performance
the plant’s ability to
consistently meet low TP limits
 
For these
reasons, I respectfully request that MECP require the proponent to:
Reassess influent
concentrations, particularly BOD, TSS, TKN, and TP, to reflect the
substantial contribution from commercial food service operations.
Demonstrate that the
phosphorus removal system is adequately sized for realistic influent
conditions.
Confirm that the
proposed filtration system can reliably meet the effluent TP limits under
peak flow and peak loading scenarios.
 
These steps
are necessary to ensure that the phosphorus removal system performs as intended
and that the receiving watercourse is adequately protected.
 
6)     
Buoyancy Control and the Need for
Watertight Construction
 
The design appropriately includes
anchoring of the lift station and tanks to protect against buoyancy, which is
necessary given the shallow groundwater conditions at the site. However, the
expert review noted that watertightness of all buried tanks and piping is
equally important and is not addressed in the design brief.
If tanks, joints, or piping are not
fully sealed, groundwater infiltration can enter the system, which can:
·       
significantly
increase hydraulic loading on the treatment plant
·       
reduce
treatment performance
·       
compromise
SBR cycle timing
·       
increase
sludge production
·       
reduce
the effectiveness of tertiary filtration and UV disinfection
 
Even though MECP does not typically
regulate construction‑level details such as sealing methods, excess
infiltration is an operational and performance risk that can directly affect
the plant’s ability to meet its effluent limits. Given the shallow groundwater
table at this site, watertight construction is essential to prevent inflow and
infiltration from overwhelming the system.
 
I respectfully request that MECP
require the proponent to:
1.     
Address
watertightness of all buried tanks and piping in the detailed design.
2.     
Demonstrate
that the system is protected against infiltration, especially during periods of
high groundwater.
 
These steps are necessary to ensure
the WWTP can operate reliably and maintain compliance under real‑world site
conditions.
 
7)     
Winter Temperatures, Insulation, and
Biological Treatment Performance
The design
brief does not mention insulation of tanks or process components, aside from
noting in the Napier‑Reid documentation that insulation is excluded from their
scope.
Insulation is
an important consideration for maintaining wastewater temperatures within the
biological treatment system. Colder temperatures slow down biological
processes, including BOD removal and nitrification, which could affect the
plant’s ability to meet effluent limits—particularly ammonia.
Physical and
chemical processes associated with solids removal and phosphorus removal are
generally less sensitive to cold temperatures, provided that equipment is
protected from freezing. However, the biological processes in the SBRs are
temperature‑dependent, and maintaining adequate wastewater temperature is
essential for consistent performance.
The expert
review noted that Napier‑Reid’s design calculations do consider both winter and
summer conditions, including biological treatment performance at wastewater
temperatures as low as 5°C. If the tanks are buried and insulated, achieving a
winter wastewater temperature of approximately 5°C is reasonable, and the
modelling appears to appropriately account for the process implications of
winter conditions.
However, because
insulation is not described in the design brief, it is unclear how the
proponent intends to maintain the temperatures assumed in the modelling.
Without insulation or equivalent construction measures, actual winter
temperatures could fall below the design basis, potentially compromising
biological treatment performance.
I
respectfully request that MECP require the proponent to:
Clarify how wastewater
temperatures will be maintained to match the assumptions used in the
Napier‑Reid design calculations.
Confirm whether
insulation or other thermal protection measures will be included in the
detailed design of buried tanks and process components.
Demonstrate that the
plant can reliably achieve the required biological treatment performance
under realistic winter operating conditions.
 
These steps
are necessary to ensure that the winter temperature assumptions used in the
design are achievable and that the plant will perform as intended throughout
the year.
 
 
8)     
 UV
Disinfection Limits and the Need for Redundancy
The proposal
includes UV disinfection for pathogen removal, which is a well‑established and
standard technology widely used in Ontario. The proposed effluent limit of 200
CFU/100 mL is consistent with many ECAs; however, the expert review noted
that several comparable facilities in Ontario operate under more stringent
limits, typically in the range of 100–150 CFU/100 mL. Based on the
expert’s experience, an objective of 100 CFU/100 mL would be more
consistent with similar ECAs, although the final limit should reflect the
sensitivity of the receiving watercourse.
The expert
also noted that well‑operated SBR + filtration + UV systems routinely achieve
far better performance than the proposed limit. For example:
Havelock WWTP and Teeswater‑Formosa WWTP,
both using similar Napier‑Reid SBR systems with chemical precipitation and
filtration, regularly achieve <10 CFU/100 mL.
These
examples demonstrate that significantly lower pathogen levels are achievable
with this type of treatment process.
However, the
proposal includes only a single UV disinfection train sized for maximum
flow. This creates a single point of failure. If the UV unit requires
maintenance or experiences an equipment issue, the plant would have no ability
to disinfect effluent, which could result in non‑compliance and increased
pathogen loading to the receiving river.
To improve
reliability and ensure continuous disinfection, the expert recommended
considering two parallel UV units. This would allow one unit to remain
in operation while the other is offline for maintenance or repair.
Given the
sensitivity of the receiving watercourse and the importance of reliable
pathogen control, I respectfully request that MECP require the proponent to:
Re‑evaluate the
proposed effluent E. coli objective and limit, considering that
similar facilities routinely achieve <10 CFU/100 mL.
Assess whether a
lower objective (e.g., 100 CFU/100 mL) is more appropriate for this
site.
Provide redundancy
in the UV system, such as two parallel UV trains, to ensure continuous
disinfection during maintenance or equipment downtime.
 
These steps
are necessary to ensure the WWTP can reliably meet pathogen removal
requirements and protect the receiving watercourse under all operating
conditions.
9)     
Ammonia Limits, Nitrification Capacity,
and Concerns About Underestimated Influent Nitrogen
The proposed summer ammonia limits for this facility are
quite low. While these limits are technically achievable, the expert review
emphasized that reliable nitrification performance depends heavily on the
accuracy of the influent nitrogen assumptions used in the design.
A well‑operated biological nitrification process can achieve
total ammonia nitrogen (TAN) concentrations below 1 mg/L, and comparable
facilities in Ontario routinely achieve even better performance. For example:
Havelock
WWTP and Teeswater‑Formosa WWTP (both using similar Napier‑Reid SBR
systems) regularly achieve average effluent ammonia levels in the range of
0.1–0.2 mg/L.
These examples demonstrate that the proposed ammonia limits
are achievable if the plant is designed based on accurate influent nitrogen
concentrations and has sufficient aeration and alkalinity to support full
nitrification.
However, the expert noted that the influent nitrogen
concentration used in the design appears to be underestimated, particularly
given the significant contribution of wastewater from restaurants and
commercial kitchens. If actual influent TKN is higher than assumed, the
plant may not have:
adequate aeration capacity
sufficient alkalinity
appropriate SBR cycle timing
enough biological volume
 
to achieve the required ammonia removal.
In the expert’s words:
“If the influent nitrogen concentration has been
underestimated, modifications may be needed to the nitrification
calculations/design.”
The expert also confirmed that alkalinity is essential for
nitrification and that the Napier‑Reid design appropriately includes chemical
alkalinity addition if natural alkalinity is insufficient. However, the
adequacy of this provision depends on the accuracy of the influent nitrogen
assumptions.
Given the sensitivity of the receiving watercourse and the
importance of meeting low ammonia limits, I respectfully request that MECP
require the proponent to:
Reassess
influent nitrogen concentrations, particularly TKN, to ensure the design
basis reflects realistic conditions.
Demonstrate
that aeration capacity, alkalinity supply, and SBR cycle design are
sufficient to achieve full nitrification under peak loading conditions.
Confirm
that the nitrification design has been evaluated for higher influent
nitrogen scenarios, given the likelihood that commercial wastewater will
increase nitrogen loading.
These steps are necessary to ensure the WWTP can reliably
meet ammonia limits under real‑world operating conditions.
10)  Concerns
About the Proposed Nitrate Limit and Unit Errors in the ACS
Nitrate is
not typically included as an effluent parameter for surface‑water discharges in
Ontario. Nitrate limits are generally applied to groundwater discharges, not
surface water, unless the receiving watercourse is extremely low‑flow or
highly sensitive. While it is not impossible for an ECA to include a
nitrate limit in a surface‑water context, it is unusual and requires strong
technical justification.
The expert
review also identified a technical issue in the assimilative capacity
calculations: the proponent appears to have mixed nitrate‑as‑N and nitrate‑as‑NO₃
units. This is a common source of error, but it has important implications for
interpreting water quality criteria.
Specifically:
The CCME guideline of 13 mg/L applies to nitrate as
NO₃.
When expressed as nitrate‑as‑N, the equivalent
value is 2.93 mg/L.
The river data in the ACS is reported as nitrate‑as‑N,
meaning the proponent should have compared it to 2.93 mg/L, not 13 mg/L.
Despite this
unit error, the expert concluded that correcting the calculation would not
change the overall outcome. The receiving watercourse has sufficient
assimilative capacity according to the ACS so it’s unclear why a nitrate limit
is imposed.
Given
this, I respectfully request that MECP:
Review the nitrate unit conversion issue in the ACS
to ensure the analysis is technically correct. Also are the other values
used properly.
Explain why a nitrate limit is appropriate,
given that nitrate is not a standard parameter for surface‑water
discharges and the corrected ACS indicates adequate assimilative capacity.
Ensure that any effluent limits included in the ECA
are supported by defensible, receiver‑specific technical rationale, rather
than by unit errors or assumptions.
These steps
are necessary to explain why that effluent limits is scientifically justified
and aligned for this surface‑water discharges.
 
11)  BOD
Limits and Expected Performance of the Proposed Treatment System
The expert
review noted that the proposed SBR and filtration system is fully capable of
achieving the required BOD removal. In fact, based on the expected performance
of this technology, the proposed BOD limit of 25 mg/L appears higher than what
similar systems routinely achieve.
Sequencing
Batch Reactors followed by tertiary filtration typically produce effluent BOD
concentrations well below 15 mg/L under normal operating conditions. The expert
indicated that an objective of 10 mg/L and a limit of 15 mg/L would be more
consistent with the performance expected from this type of treatment process.
Given that
the receiving watercourse is small and sensitive, and that comparable
facilities in Ontario routinely achieve BOD levels below 10 mg/L, it would be
appropriate for MECP to consider whether the proposed BOD limit of 25 mg/L is
sufficiently protective.
I
respectfully request that MECP:
Review the proposed BOD limit in light of the
expected performance of SBR + filtration systems.
Consider establishing a more protective BOD
objective and limit (e.g., 10 mg/L objective and 15 mg/L limit),
consistent with typical performance of similar facilities.
This would
ensure that the effluent quality aligns with what the proposed technology is
capable of achieving and provides an appropriate level of protection for the
receiving watercourse.
 
12)  Total
Suspended Solids (TSS) Performance
The expert review noted that the proposed SBR and tertiary
filtration system should be able to meet the Total Suspended Solids (TSS)
objectives and limits without difficulty. This type of treatment process is
well established in Ontario and is known to reliably achieve low TSS
concentrations when properly designed and operated.
While TSS removal is not expected to be a limiting factor
for this facility, it is important to ensure that upstream design
assumptions—particularly influent strength, peak flows, and the absence of pre‑treatment—are accurate, as these factors can influence solids loading on
the SBRs and filters.
I request that MECP ensure the proponent demonstrates that
the TSS performance expectations remain achievable under realistic influent
conditions and peak loading scenarios.
13)  Missing
Pre‑Treatment (Screening and Grit Removal)
The Kresin
Design Brief does not include any information on initial pre‑treatment
of sewage before it enters the SBR tanks. For a facility of this type and size,
this is a significant omission. Most wastewater treatment plants using SBR
technology incorporate screening and grit removal as standard practice
to intercept rags, plastics, food debris, grit, and other solids that are
routinely discharged from kitchens, accommodations, and public washrooms.
The expert
review noted that pumping raw, unscreened sewage directly into an SBR basin
is not typical and presents several risks, including:
damage to pumps, valves, and aeration equipment
reduced settling performance within the SBR
increased solids carryover to tertiary filtration
higher maintenance requirements
potential operational upsets
The Napier‑Reid
design documentation explicitly states that pre‑treatment equipment is
excluded from their scope of supply. This means the proponent must provide
it, yet the design brief does not address it at all.
Given the
significant proportion of wastewater expected from restaurants and commercial
kitchens—where solids, grease, and debris loads are substantially higher than
domestic sewage—pre‑treatment is essential to protect downstream equipment and
ensure reliable plant performance.
I
respectfully request that MECP require the proponent to:
Clarify how raw sewage will be screened and
protected before entering the SBR system.
Include appropriate pre‑treatment equipment
(e.g., screening and grit removal) in the design.
Demonstrate that the SBR and filtration systems
will not be exposed to deleterious materials that could compromise
treatment performance or equipment longevity.
These steps
are necessary to ensure the WWTP is designed to operate reliably under real‑world
conditions and to prevent avoidable operational failures.
14)  Redundancy,
Multi‑Train SBR Design, and the Need for Additional Flexibility
The expert
review noted that the proposed SBR system is divided into four parallel trains,
which is a strong design feature. This multi‑train configuration provides
several operational advantages:
It allows the operator to run multiple trains
simultaneously while keeping each train at a different point in the
treatment cycle to accommodate incoming flow.
It provides flexibility during start‑up and during
seasonal variations in flow and loading.
It offers built‑in redundancy, allowing the system
to remain operational if one train requires maintenance or repair.
However, the
same level of redundancy and operational flexibility is not provided for the
tertiary filter or the UV disinfection system. The design includes:
one single tertiary filter, and
one single UV disinfection unit,
each sized
for maximum flow. This creates two single points of failure. If either unit
requires maintenance or experiences an equipment issue, the plant would have no
ability to filter or disinfect effluent, which could result in non‑compliance
and increased environmental risk.
The expert
recommended that the proponent consider splitting the filtration and UV systems
into two parallel units, if feasible based on equipment sizing. This would
provide:
operational flexibility,
redundancy during maintenance, and
improved reliability during peak flow periods.
The expert
also noted that while the Napier‑Reid SBR design does not require up‑front
equalization due to the multi‑train configuration, the proponent should still
consider some form of flow equalization. Equalization would help:
manage seasonal and weekend/holiday flow
variations,
stabilize influent loading,
improve chemical dosing consistency, and
support more reliable performance across the
treatment train.
Given the
sensitivity of the receiving watercourse and the importance of system
reliability, I respectfully request that MECP require the proponent to:
Evaluate the need for redundancy in the tertiary
filter and UV disinfection systems, including the feasibility of using two
parallel units.
Assess whether up‑front flow equalization is
warranted, given the expected variability in flows and loadings from a
resort‑based development.
Demonstrate that the treatment system can maintain
compliance during maintenance events or equipment downtime.
These steps
are necessary to ensure the WWTP has adequate operational flexibility and
redundancy to protect the receiving watercourse under real‑world conditions.
15)  Consideration
of Alternatives and the Implications of the Expansion Scale
There has
been no transparency in the design brief on what other waste management
alternatives have been discussed, explored and considered that balance both
resort expansion and water conservation, environmental protection and good corporate
and community citizen responsibility. 
There doesn’t appear to be any desire or willingness to compromise proposed
expansion to avoid relying on the Goulais River to be responsible for receiving
and breaking down the waste, they intend to produce for private, business
purposes.  This option should be a last
resort; knowing that Goulais River is already showing significant signs of
stress, knowing Goulais Bay already experiences boil water advisories because
of seasonal flow from Goulais River. Knowing it’s one of the most diverse fish
habitats and spawning grounds for Species At Risk. Knowing the data shows us
that Policy #2 is already met for Phosphorus at the downstream monitoring
location where Goulais River crosses Hwy 17 – which completely dismisses and
ignores all water quality beyond that downstream monitoring location. Knowing
that other ski resorts in North America are successfully and actively using
sophisticated waste management models to conserve, protect fresh water and
reuse wastewater.
It is
important to note that the choice of river discharge is driven by the scale of
the proposed expansion, which includes substantial increases in accommodations,
commercial space, and restaurant capacity. The full-blown expansion being
proposed directly influences the required treatment capacity and the decision
to discharge to the river. If the expansion were smaller, subsurface options would
be viable and would eliminate direct impacts to the river entirely. This is not
a municipality with active demand and no other alternatives.
Given this
context, I respectfully request that MECP:
Acknowledge that the proposed discharge method is
tied to the proponent’s very large expansion plans, and that alternative
disposal options are feasible at lower flows.
Ensure that the design is refined to address the
concerns identified in the expert review, particularly regarding influent
strength, peak flows, pre‑treatment, redundancy, and monitoring.
Confirm that the chosen discharge method is
protective of the receiving watercourse, and/or outright rejected given
the sensitivity of the river and the scale of the proposed development.
These steps and
considerations are necessary to ensure that the selected wastewater management
approach is both technically justified and environmentally protective.
 
16)  No
Backup Power Is Mentioned
The design does not mention backup power. For a continuous
discharge system, loss of power would mean loss of treatment, pumping, and
disinfection. It is not clear from the report whether or not the owner intends
to include provision for backup power for water and sewage systems to permit
continued operation during a power outage, and if not, what are the contingency
plans for periods of power outage.
While backup
power is not typically required by MECP for private systems, and many similar
facilities operate without it, the absence of any discussion in the report
is notable.
Backup power is
important if the owner intends for the facility to continue operating during a
power outage. Maintaining wastewater operations during an outage generally
requires that the water supply system also have backup power; otherwise,
no sewage is generated. The decision to include a generator is usually an owner‑level
operational choice, rather than a regulatory requirement.
However,
given the expansion plans proposed, and visitor capacity. I am suggesting that
the MECP mandates a backup power for this ECA (if it is approved).  At the very least, it is something the owner
and their consultant need to consider ensuring operational continuity during
power interruptions – especially during peak flow season.
The public
should also be informed on what back up power is chosen to address how the
resort intends to manage the business in the event of a power outage.  A common occurrence in our region given the
rural location and heavy snow bearing conditions.
17)   No Monitoring Plan Is Included
The expert noted that the design brief does not include a
monitoring plan, which would at a minimum, include an influent and effluent
monitoring program. Based on the recommendations of the Assimilate Capacity
Study, a surface water monitoring plan should also be included.
The design
brief and the Assimilative Capacity Study (ACS) do not include any discussion
of the proposed monitoring plan noted as a condition of approval during
consultation in the ACS. For a facility of this type, a monitoring program is
an essential component of ensuring that the treatment system is performing as
intended and that the receiving watercourse is protected.
At a minimum,
the proponent should be proposing:
Influent monitoring to verify actual flows
and loading rates and to confirm whether the design assumptions are
accurate.
Effluent monitoring to demonstrate
compliance with ECA limits and to track treatment performance over time.
Surface water monitoring, if required based
on receiver sensitivity, to confirm that the discharge is not adversely
affecting the river.
The
absence of a monitoring plan in both the design brief and the ACS leaves a
significant gap in understanding how the proponent intends to verify
performance and compliance once the system is operational. Our expert notes
that neither consultant articulated what they propose that monitoring program
will include.  The ECA should not be
issued until a full comprehensive monitoring program is presented.  
I
respectfully request that MECP require the proponent to provide a clear and
comprehensive monitoring plan that includes influent, effluent, and, where
appropriate, surface water monitoring.
We ask the
MECP to consider it a condition that the proponent funds a community led, 3rd
monitoring program through a reputable water experts local to the area. There
are institutes like N.O.R.D.I.K. in Sault Ste. Marie that could help facilitate,
organize, and manage this program with full transparency, subject matter
expertise, accountability and equipment. This program would also build relation
between the community and the proponent.
 
18) 
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.
Conclusion
The health of
this river cannot be an afterthought or a casualty of rushed design work. The
proponent is asking for permission to discharge treated wastewater into a
small, sensitive watercourse that already experiences low flows and seasonal
stress. That privilege comes with a responsibility to demonstrate—clearly,
transparently, and with defensible data—that the system will perform reliably
under real‑world conditions, not just on paper.
The expert
review shows that the current proposal does not yet meet that standard. Key
design assumptions are underestimated, critical components such as pre‑treatment
and redundancy are missing, and the monitoring framework has not been defined.
These are not minor details; they are foundational elements that determine
whether the plant will protect the river or place it at risk.
Once an ECA
is issued, the community and the watershed bear the consequences. There is no
undo button. That is why MECP’s role is so essential here: to ensure that the
design is thoroughly considered (at the very least strengthened significantly) before
approval, not after problems emerge. We need to be proactive.
I urge MECP
to require the proponent to address the identified gaps, correct the
underestimations, and demonstrate—through robust design, adequate safeguards,
and a comprehensive monitoring plan—that this system can truly protect the
receiving watercourse. The river deserves nothing less, and neither does the
communities that depends on it.
Thank you for
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