MECP, please enforce the…

MECP, please enforce the data standards you have.....

Assimilative Capacity Study (ACS) Dataset Length and Seasonal Coverage

The assimilative capacity study (ACS) appears to follow typical methodology; however, the length of the dataset is shorter than what MECP commonly expects for surface water assessments. While MECP does not specify a formal minimum dataset length in guidance, in practice they typically request two to three years of surface water data to capture seasonal and year to year variability, particularly during low flow summer conditions when the receiving river is most sensitive.

The proponent collected 16 months of data, which is a reasonable dataset, but it does not include a second full summer low flow period. As a result, the dataset may not fully represent the range of conditions that influence assimilative capacity. The proponent also had the opportunity to continue collecting data after submitting the initial dataset to MECP, which could have strengthened the ACS by bringing it closer to the two year dataset MECP typically expects.

Given the sensitivity of the receiving watercourse and the importance of accurately characterizing low flow conditions, I respectfully request that MECP consider whether the ACS dataset provides sufficient seasonal coverage, or whether additional data collection is warranted to ensure a robust assessment of assimilative capacity.

We also request that the MECP require 2-3 years of ambient water quality through a quality monitoring program downstream, past the downstream location used in the proponents monitoring program that formed / produced the data in the Assimilative Capacity Study. If Policy #2 is already met where the river crosses Hwy 17 – it is vital to understand what condition the water quality is in beyond that point and within Goulais River before any introduction to effluent into the river is even considered.

Conclusion
The health of this river cannot be an afterthought or a casualty of rushed design work. The proponent is asking for permission to discharge treated wastewater into a small, sensitive watercourse that already experiences low flows and seasonal stress. That privilege comes with a responsibility to demonstrate—clearly, transparently, and with defensible data—that the system will perform reliably under real world conditions, not just on paper.

The expert review shows that the current proposal does not yet meet that standard. Key design assumptions are underestimated, critical components such as pre treatment and redundancy are missing, and the monitoring framework has not been defined. These are not minor details; they are foundational elements that determine whether the plant will protect the river or place it at risk.
Once an ECA is issued, the community and the watershed bear the consequences. There is no undo button. That is why MECP’s role is so essential here: to ensure that the design is thoroughly considered (at the very least strengthened significantly) before approval, not after problems emerge. We need to be proactive.

I urge MECP to require the proponent to address the identified gaps, correct the underestimations, and demonstrate—through robust design, adequate safeguards, and a comprehensive monitoring plan—that this system can truly protect the receiving watercourse. The river deserves nothing less, and neither does the communities that depends on it.
Thank you for carefully considering the content above.