As someone who has resided…

As someone who has resided in the area most of my life, I feel I need to comment on the detrimental impact this proposed facility will have on the Searchmont area and Goulais River watershed, and I strongly object to the proposed construction and operation of a wastewater treatment plant (WWTP) that would discharge treated effluent to the Goulais River. Recent project documents indicate the resort’s plan includes an on-site sequencing batch reactor (SBR) WWTP with treated effluent discharge to the Goulais River.

My opposition is based on the following facts and concerns.

1) The Goulais River is a high-quality, ecologically sensitive watercourse

Independent studies and provincial management statements characterize the Goulais River as a high-quality watercourse with limited development in its watershed and protected or sensitive areas nearby (including the Goulais River Beach Ridges Conservation Reserve). Existing assimilative capacity work for the river stresses its relatively low levels of development and the need for careful assessment before any effluent discharge is permitted.

Flow and low-flow data are available for the Goulais River near Searchmont (Water Survey of Canada hydrometric station), demonstrating seasonal low-flow periods when dilution capacity is limited — precisely the times when effluent discharges have the greatest ecological impact. Any permit or licence must account for actual low-flow conditions and downstream cumulative effects.

2) Direct and indirect threats to wood (woodland) turtles — an endangered species in Ontario

The wood turtle (Glyptemys insculpta) is listed as endangered in Ontario and uses clear rivers and streams with sand/gravel banks, floodplains, and adjacent woodlands for feeding, nesting, and overwintering. Females nest on sunny sand or gravel bars that receive lots of light; hatchlings and adults depend on clean riverine habitat and riparian foraging areas. Wood turtles are highly sensitive to habitat loss, water quality degradation, and increased human disturbance.

A WWTP discharging into the Goulais River creates multiple pathways for harm to wood turtles and other sensitive species:
• Even treated effluent can change nutrient balances (increasing algal growth, altering macroinvertebrate communities) and chemical composition locally, which may reduce prey availability and habitat suitability.
• Construction and increased vehicle/truck traffic will fragment nesting and foraging habitat on floodplains and sand/gravel bars used by nesting females.
• Accidental spills, bypass events, or insufficient treatment during low-flow periods could cause acute or chronic water quality problems affecting turtles’ survival and reproduction. The Goulais River’s limited development and apparent high baseline quality make it particularly vulnerable.

Because wood turtles are a listed species, any project that may kill, harm, harass, or destroy their habitat would trigger Ontario’s Endangered Species Act protections and require an appropriate impact assessment and permitting process.

3) Project documentation raises questions that must be answered before approval

The proponent’s documents (proposal and assimilative capacity study) acknowledge discharge to the Goulais River and argue the effluent will meet regulatory limits, but they do not replace the need for independent review and complete species-at-risk (wood turtle) assessments conducted by qualified specialists during relevant seasons. Publicly available project documents indicate monitoring was done, but they must be peer-reviewed and must specifically address threatened species habitat and low-flow scenarios.

4) Required actions and requests from the decision-makers

To protect the Goulais River and its species at risk, I ask that decision-makers require the following before any approval:

i) Full independent peer review of the proponent’s Goulais River Assimilative Capacity Study and the WWTP design, paying particular attention to worst-case low-flow dilution scenarios.

ii) A comprehensive Species at Risk (wood turtle) Impact Assessment completed by qualified herpetologists/ecologists, including targeted surveys during nesting (spring–early summer) and movement periods, mapping of nesting sites (sand/gravel bars), and identification of critical habitat. This assessment must be publicly posted and open to comment.

iii) Fulfillment of all obligations under the Endangered Species Act (Ontario) and federal species-at-risk legislation (if applicable) — including avoidance, mitigation hierarchy, and authorization only if harm cannot be avoided and appropriate compensatory measures are in place.

iv) Meaningful consultation with Indigenous communities, in particular Batchewana First Nation and other local Indigenous rights-holders who identify cultural or subsistence values tied to the Goulais River. (There is public concern on social platforms about indigenous interests in the river’s integrity.)

v) Exploration of alternative solutions and locations — including decentralized systems, zero-discharge or land-application options, or locating treatment on already disturbed/industrial lands rather than adjacent to a high-quality river and conservation reserve. If discharge is the only option, require tertiary treatment with redundancy and real-time monitoring and no discharge during low-flow periods.

5) Precise remedy requested now
• Do not approve licensing, Environmental Compliance Approval, or any ERO posting in favour of the current proposal until the independent reviews and species at risk assessments (items 1–3 above) are completed, publicly posted, and subject to a full public comment period.
• If the project proceeds after rigorous review, require legally binding conditions: seasonal/no-discharge windows, enhanced tertiary treatment (including UV disinfection and nutrient limits stricter than minimum standards), continuous effluent monitoring with publicly accessible data, and a binding restoration/compensation plan for any loss of turtle habitat.

In conclusion, the Goulais River is an ecologically valuable, comparatively undeveloped watercourse that supports species at risk such as the wood turtle and contains protected conservation areas. A WWTP with a direct discharge to this system — without independent peer review, a full species at risk assessment, Indigenous and public consultation, and strict, enforced mitigation measures — places irreplaceable habitat, the local economy (recreation, tourism, fisheries), and community values at unacceptable risk. For these reasons I strongly oppose the current proposal and request its rejection or relocation until the conditions and studies above are satisfied.

Sincerely,
A concerned resident and stakeholder of the Searchmont / Goulais River area.