I am submitting the…

I am submitting the following comments regarding the proposed Environmental Compliance Approval (ECA) for the Searchmont Ski Resort Wastewater Treatment Plant (WWTP) and its proposed discharge to the Goulais River.

My comments are based on the information provided in the Design Brief (including the Assimilative Capacity Study), publicly available ERO postings, and provincial policies and guidelines. All references below are taken directly from the documents provided to the public.

1. The Goulais River Is Already Showing Signs of Stress Before Any Discharge

The ACS monitoring data shows that the river is not in a condition that can safely and consistently accept additional nutrient or contaminant loading:
• Total Phosphorus (TP)
o Upstream highest sample: 0.044 mg/L
o Downstream highest sample: 0.047 mg/L
o 5 of 20 downstream samples exceeded the Provincial Water Quality Objective (PWQO) of 0.030 mg/L (Appendix A2 of ACS).
o This means 25% of samples exceeded the PWQO before any wastewater discharge exists.
o The water quality program designated as the downstream location is it the Hwy 17 crossing of the Goulais River. It’s at the PQWO already. What about TP in the rest of the river, past the Hwy 17 crossing?
• Recent boil water advisories in Goulais Bay – Latest one was in May of 2025 which was deemed a result of natural discharge from the Goulais River
• Bacteria
o The ACS documents spikes in fecal bacteria during baseline monitoring.
• Low Flow Conditions
o The Design Brief notes that the Goulais River experiences very low flows in late summer, increasing vulnerability to pollution.

• Winter Data Gaps
o The ACS contains limited winter data, despite winter being the most sensitive period for dissolved oxygen (DO) and ammonia toxicity.

Conclusion:
The river is already stressed. Under Ontario’s Policy 2, when a waterbody is at or above the PWQO, “no further degradation is permitted.”
Given the exceedances documented in the ACS, the assimilative capacity for phosphorus is effectively zero.

2. The Monitoring Dataset Does Not Meet MECP Expectations

The ACS is based on ~20 samples of data (January 2021–April 2022), with only 20 sampling events and 16–20 samples per parameter.

MECP typically expects:
• 3 years of seasonal data, or
• 2 years of monthly data

The ACS acknowledges that during consultation, the MECP raised concerns about the short duration, yet the dataset was still accepted.

This raises several questions:
• The downstream location used for the water quality monitoring program done by the proponent was designated where the Goulais River crosses Hwy 17. This is not the end of the river. It continues to flow well past this point and goes into Goulais Bay (with known water quality issues)
• Why was a shortened dataset accepted when it does not meet standard MECP expectations? What sampling protocol was used? Were samples collected consistently (same location, time of day, conditions)? How does taking multiple samples during summer compensate for missing winter and multiyear data?

Conclusion:
The dataset is too limited to support a major surfacewater discharge approval. A strong data set is critical to prove that the river can receive and break down waste safely. With the spikes already showing up above the PWQO with no waste in the river – what will happen once effluent waste is introduced to the Goulais River? What will happen to Goulais Bay?

3. The ACS Does Not Appear to Account for the Resort’s Permit to Take Water (PTTW)

The resort holds an active Permit to Take Water (ERO 0196965), allowing withdrawal of:
• 131,000 L/day for potable water + 11,498,000 L/day for snowmaking
• Up to 80 days per year

These withdrawals:
• Reduce river flow
• Reduce dilution capacity
• Occur during winter lowflow periods
• Coincide with the most sensitive conditions for ammonia and DO
• Alter temperature and timing of return flows

However, the ACS assumes:
• Fixed flow
• No water withdrawals
• Instantaneous mixing
• No snowmaking impacts

Conclusion:
If the ACS does not incorporate permitted water withdrawals, then the calculated assimilative capacity is overestimated, and the effluent limits are based on unrealistic flow assumptions.

4. Modeling Gaps and Unreliable Assumptions

The ACS contains several modeling limitations:
• Appears to use simple dilution calculations instead of proper mixing zone modeling.
• Does not appear to model winter conditions or ice cover.
• Uses unrealistically high pollution values in some calculations.
• The DO model becomes unstable when realistic inputs are used.
• Assumes ideal pH and temperature that do not reflect real river conditions.
Conclusion:
The predictions of “minimal impact” are not dependable and how they are advised in the design brief is not clear or

5. Effluent Limits in ACS Appear Extremely Low

Table 6.1 of the ACS recommends unusually low effluent limits… is this normal?
• Total Phosphorus (TP)
• Total Ammonia Nitrogen (TAN)

6. Species at Risk (SAR) and Environmental Impact Statement (EIS) Are Missing

Section 4.1.3 of the Design Brief states that a new SAR study and EIS are in progress and will be attached as Appendix H when complete.

However, these documents were not provided during the ERO comment period.
The 2019 EIS (for the adjacent snowmaking pond) identified potential presence of:
• Barn Swallow
• Bobolink
• Canada Warbler
• Chimney Swift
• Eastern Meadowlark
• Wood Thrush
• Little Brown Bat
• Northern Longeared Bat
• Eastern Smallfooted Bat
• Lake Sturgeon
• Wood Turtle

Significant Wildlife Habitat identified:
• Candidate Turtle Wintering Area
• Candidate Amphibian Breeding Area

Migratory bird nesting windows (C4 Zone):
• Forested: April 14–August 28
• Open: April 19–August 28
• Wetlands: April 14–August 17

Conclusion:
Without the updated EIS and SAR study, the public cannot meaningfully assess ecological impacts or compliance with the Endangered Species Act, MBCA, or FWCA.