This letter outlines…

This letter outlines concerns regarding the utter lack of alternative waste management options explored, the scale of the proposed expansion, and the resulting environmental implications. The Ministry should require a more rigorous assessment of options that avoid surface‑water discharge and better align with the site’s hydrogeological capacity.

1. Scale of Proposed Expansion Drives the Need for River Discharge

Searchmont Ski Resort currently operates the following facilities:

- Main Lodge with public washrooms, staff offices, industrial kitchen, restaurant, and an apartment
- Five chalets, each accommodating 10 guests
- Two villas (one 16‑unit and one 12‑unit), with a combined maximum occupancy of 196 guests

The proponent is now pursuing a major commercial and accommodation expansion, including:

- Two 100‑unit hotels, with patio, restaurant, and conference centre
- A new 218‑seat restaurant
- A new 225‑seat patio
- A 274‑person conference room
- An expansion of the existing restaurant, adding 218 seats
- Additional villas, increasing from 12 to 16 units and adding a second 12‑unit villa

This represents a dramatic increase in guest capacity, food service operations, and wastewater generation. The proponent states that the existing septic system cannot accommodate the anticipated sewage flows—but those flows are a direct result of the proponent’s chosen expansion scale, not an inherent limitation of the site. If you know the site, there is a lot of land available.

2. Alternatives and Feasibility of Avoiding River Discharge

The proponent (Searchmont Ski Resort) asserts that a Waste Water Treatment Plant that will dump waste into the Goulais River is the only viable option. This conclusion is based entirely on the very high projected flows associated with the full‑build expansion plan.

This is a critical point: the need for river discharge is not dictated by the land—it is dictated by the proponent’s development choices.

If the resort were to reduce or modify its expansion, total daily flows could fall within a range where non‑river‑discharging alternatives become technically and environmentally feasible, including engineered dispersal systems that avoid direct impacts to the Goulais River.

Under a more modest expansion scenario:

- A treatment plant would still be required
- But final dispersal could occur through engineered subsurface or land‑based systems
- This would eliminate the need for a surface‑water ECA
- And remove the Goulais River as the receiving body

MECP should not assume that the proposed expansion scale is fixed or inevitable. The environmental impact is directly tied to the proponent’s chosen level of development, and alternatives become viable if the resort aligns its plans with the site’s hydrogeological capacity and the community’s priority to protect the river.

Request to MECP.....given the above, I respectfully request that MECP:

1. Require a revised alternatives analysis that evaluates wastewater options under reduced‑flow or phased‑expansion scenarios.

2. Assess whether a non‑river‑discharging system becomes feasible when expansion is scaled to match the site’s natural capacity.

3. Avoid approving a surface‑water discharge that is only necessary because of the proponent’s chosen commercial expansion, not because of site constraints.

4. Prioritize protection of the Goulais River, a valued cold‑water system, by ensuring all reasonable alternatives are fully explored.

Conclusion....The current proposal frames river discharge as unavoidable, but this is a consequence of the proponent’s aggressive expansion plan—not an inherent limitation of the site. MECP should require a more balanced alternatives assessment that considers wastewater solutions compatible with both environmental protection and sustainable development.

There are other ski resorts in North America that successful model better inland options, recycling waste water for snow making and better water conservation. Searchmont Ski Resort pulls a ton of water from the Goulais River to make snow and water supply? How much more will they need to pull if their large expansion plans are approved? They should be allowed a permit to pull water and discharge waste into the same watercourse. They should be looking for options to recycle their waste water. This will reduce their need for fresh water and reduce their need to discharge water. Good for the river in so many ways.

Thank you for considering these comments.