Concern for quantity and…

Concern for quantity and quality of Water Quality Data used in the Assimilative Capacity Study.

The ACS is based on only ~20 months of water quality data, not the required 2–3 years the MECP typically requires. From my understanding the MECP usually requires: 3 years seasonal, or 2 years monthly.

In fact on page 44 of 461 of the design brief, it states the following:

"The ACS requires characterization of water quality in the receiving water course. From the Provincial Guidelines for wastewater discharge (MOECC, 20162) the 75th percentile concentration is used for this
assessment. Per communications with MECP (2021), samples should be taken seasonally over three years or monthly over two years to develop an adequate period of record. Concentrations of water quality parameters are in flux throughout the year and are dependent on a variety of factors including temperature, contributing runoff areas and other discharge points to the water course. "

However, this study only collected:

Jan 2021 → Apr 2022

Only 20 sampling events
Only 16–20 samples per parameter

This is not compliant with MECP expectations.

There is also consultation records between the MECP and Greenland International further down in the ACS where this topic is touched but it still isn't clear why an exception was made for this proposal.

it shows the MECP addressed duration of sampling, but it sounds like the desire to see the facility operational for the 2022 took priority. To compensate the proponents (we assume the resort + consultants) took extra samples during their sampling events to make up for it.

Later on, there was "general agreement" that adequate samples had been taken characterize water quality.

Can the MECP justify why the water quality data was agreed upon as adequate?

Will the province reestablish the MECP Provincial Water Quality Monitoring Network (PWQMN) that ended in 1990 if the Goulais River is approved to be a receiver of effluent waste?