This ECA application should…

This ECA application should be rejected for the poorly conducted data set. It does not meet MECP expectations and it is not clear why this data set was approved in the assimilative capacity study either.
The downstream location was at Hwy 17... which completely ignores water quality beyond this point. This is not OK. A whole new 2-3 data set should be conducted using the true end of the river, even if just before it enters Goulais Bay to get a true understanding of ambient water quality downstream.

Do not let a private American business violate MECP policies for the sake of business expansion. Please hold them to the highest extent of environmental law.

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 multi year data?

Conclusion:
The dataset is too limited to support a major surface water 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?