How can the Goulais'…

How can the Goulais' Assimilative Capacity Be Modeled Without Accounting for the Permit to Take Up to 11 Million Litres/per day?

How can we model the river’s ability to handle wastewater — while not fully accounting for up to 11 million litres of water being withdrawn every day under a water-taking permit? 🤔

That’s a key question members of the public are rising about the Goulais River ACS being used to justify the WWTP.

This post specifically focuses on how the calculations were done — and most importantly what appears to be unaccounted for.

🌊🌊🌊 THE ACS RELIES ON BACK-CALCULATIONS FROM ONE UPSTREAM LOCATION

The ACS uses water‑quality data from an upstream monitoring point to:

👉🏾 set “background” conditions

👉🏾 determine whether the river meets provincial guidelines

👉🏾 calculate how much pollution the river can “assimilate”

👉🏾 justify the proposed effluent limits

These are back‑calculations — meaning the entire model depends on the accuracy and representativeness of that upstream dataset.

🚩🚩 The upstream location does not seem to reflect real‑world situation and the downstream sampling data comes from the bridge over Hwy 17 N, which is not the mouth of thecriver but kms from it. The actual end of the river already receives boil water advisories. The ACS data should be re-done, for the FULL 2-3 years, using the actual downstream location collection point!

Searchmont Resort actively holds a Permit to Take Water (PTTW) posted on the Environmental Registry of Ontario.

This permit allows the resort to withdraw the following from the Goulais River:

131,000 litres/day for potable water

11,498,000 litres/day for snowmaking

up to 80 days per year

These withdrawals:

reduce river flow

reduce dilution capacity

occur during winter low‑flow periods

coincide with the most sensitive conditions for ammonia and dissolved oxygen

change the timing and temperature of return flows

Yet the ACS assumes:

fixed flow

instantaneous mixing

no water withdrawals

no snowmaking impacts

This suggests the ACS may be modeling conditions that do not fully reflect actual operating system

If the upstream data is used to calculate assimilative capacity, but the river flow is being reduced by permitted withdrawals, then:

The dilution used in the ACS is overestimated and therefore the river’s ability to handle additional discharge is inflated in the study.

The effluent limits being proposed are based on unrealistic assumptions.

The ACS may not fully align with the intent of Ontario’s water-quality policy

The Goulais River flows directly into Lake Superior. If the ACS overestimates the river’s capacity to dilute wastewater, the impacts don’t just affect Searchmont and Goulais — they move downstream right into Lake Superior.

Ontario’s Great Lakes Strategy emphasizes the need to reduce nutrient loading and protect cold‑water systems like the Goulais.

I'm very concerned about whether the Assimilative Capacity Study adequately considered the existing Permit to Take Water. From ERO Posting: 019‑6965.

The ACS is supposed to reflect real conditions in the Goulais River. But if it ignores the resort’s permitted water withdrawals, the calculations simply don’t match reality.

We deserve full reassurance and confidence that the assimilative capacity study is accurate and thorough and have not received this.

The SAR and EIS assessments are also incomplete. This is a critical gap in decision-making data. Approving an ECA without these evidence based evaluations would be premature and inconsistent with the precautionary approach required by Ontario’s environmental legislation.

Please do not allow the uninformed public to be pushed into unhealthy or unsafe development from Searchmont Resort without accurate analyses first, with no opportunity for MEANINGFUL consultation. We cannot drink their money.

Thank you for your time and true consideration.