Please take these comments…

Please take these comments very seriously.

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 discussed
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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)
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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 Long eared Bat
• Eastern Small footed 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.
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7. Dissolved Oxygen (DO) Impacts on Sensitive Species Not Assessed
Section 4.4 of the Design Brief acknowledges that DO levels depend on:
• River temperature
• DO in the effluent
• DO in the river
• Oxygen consumed as effluent breaks down

However, the Design Brief does not assess how DO changes may affect:
• Lake Sturgeon (Threatened)
• Brook Trout
• Walleye
• Wood Turtle (Threatened)

Restricted Activity Timing Windows (Section 4.1.2):

• Lake Sturgeon: May 1–June 20
• Walleye: April 1–June 20
• Brook Trout: September 1–June 15

The design brief says: The Ministry of Natural Resources and Forestry (MNRF) will be consulted to confirm whether permits or approvals are required. In section 6.2 it states when confirming project submission requirements for the MNRF it was indicated that the approved ECA application and approval of effluent before any work could be completed.

Conclusion:
These windows cover most of the year, yet the Design Brief does not analyze how effluent discharge may affect spawning, incubation, or early development. No approvals or permits should be granted – though with an approved ECA in hand, it may make it easier for to achieve. The MNRF needs to consider this is not a municipality, this is private owned business.________________________________________
8. Cumulative Effects Were Not Assessed
The ACS does not evaluate cumulative impacts from:
• Resort water withdrawals (11.5 million L/day)
• Upstream and downstream septic systems
• Stormwater runoff
• Forestry and land disturbance
• Hydro One Northshore Link
• Climate driven low flows
• Resort expansion
• Snowmaking return flows
• Existing contaminants
• Recreational use
• SAR habitat sensitivity
• Downstream impacts to Lake Superior

Conclusion:
A cumulative effects assessment is required for a river with this ecological significance, above what was considered in the Assimilative Capacity Study.
________________________________________
9. Community Engagement Was Insufficient

The public was not provided:
• The updated EIS
• The SAR study
• A public meeting or consultation session with design brief
• Clear explanations of risks or alternatives and mitigation strategies

Meaningful consultation is a core principle of the Environmental Bill of Rights.
Without access to key documents, the public cannot provide informed comment.
________________________________________
10. Goulais Bay Issued Boil Water Advisory – May of 2025

The Goulais River flows into Goulais Bay which was issued an advisory this past year after the detection of elevated turbidity levels at the community waste treatment facility.
Which can be found on Soo Today. It’s noted in the article that it’s a common occurrence during that time of year due to natural discharge from the Goulais River.

If natural discharge from the Goulais River is already contributing to the need for boil water advisories downstream in Goulais Bay – the introduction of wastewater to the Goulais river will have serious consequences for Goulais Bay.

Whose water quality was not assessed in the water quality program conducted by the proponent.
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Request to MECP

Given the gaps identified above, I respectfully request that the Ministry of Environment Conservation and Parks (MECP) require and do the following:

1. Exercise the full extent of your authority to protect Goulais River
2. A revised, scientifically defensible ACS
3. What alternatives were considered? We want to know.
4. Proper mixing zone modeling.
5. Multi year monitoring (including winter and low flow conditions).
6. Water quality monitoring in Goulais Bay
7. Full incorporation of PTTW water withdrawals into flow assumptions.
8. Realistic, achievable effluent limits supported by treatment design data.
9. Completion and public release of the updated SAR study and EIS.
10. A cumulative effects assessment and monitoring strategies
11. Demonstration of compliance with Policy 2 for phosphorus
12. A transparent public consultation process once all documents are available.
13. Make a condition that the proponent must establish a community led, 3rd party local water expert managed, proponent funded water quality monitoring program (ie. NORDIK in Sault Ste. Marie) for a minimum of 10 years or more.
________________________________________

Final Statement: This is not about opposing development just because. It’s about ensuring that development does not harm the Goulais River — a river that is ecologically significant, culturally important, and directly connected to Lake Superior.

The introduction of effluent waste into the Goulais River will come with multiple long-term consequences. Respectfully, we need the MECP to recognize that this is not a municipality that has Canadian residents and waste management issues and demands that urgently need to be addressed. We are looking at a private, non-Canadian owned business built for profit that wishes to expand extensively. Respectfully, we need the MECP to recognize that the current proposal frames river discharge as unavoidable, but this a result of the proponents’ aggressive expansion plan – not inherit limitations of the land they occupy. We are asking the MECP to require a more balanced alternative assessment that considers wastewater solutions compatible with both environmental protection, preservation, conservation and sustainable development.

The Goulais River, surrounding communities, species at risk and future generations deserve a complete, transparent, and scientifically defensible assessment before this Environmental Compliance Approval is even considered.