What the Assimilative…

What the Assimilative Capacity Study Really Shows About the Proposed Wastewater Discharge to the Goulais River

If you read anything in this group... May it be this one...

The Goulais River is one of the cleanest, most important rivers in our region 🌊

It supports fish, wildlife, recreation, and the health of downstream communities 🐟🚣🏾‍♀️🛶🏊🏾‍♀️

Searchmont Ski Resort is applying for an ECA (Environmental Compliance Approval) to discharge treated sewage wastewater into the river, and an Assimilative Capacity Study (ACS) was completed to assess whether the river can safely handle it.

After reviewing the full ACS and its supporting data, here are the key things the community needs to know.

‼️‼️ 1) THE RIVER IS ALREADY SHOWING SIGNS OF STRESS.

The study’s own monitoring data shows:

➡️ Phosphorus levels downstream already exceed provincial water quality objectives

➡️ Fecal bacteria spikes occurred multiple times

➡️ Winter oxygen levels were not properly measured, even though winter is the most sensitive time for fish

➡️ The river runs very low in late summer, making it more vulnerable to pollution

❌ This means the river is not in a condition where it can safely accept more nutrients or contaminants.

‼️‼️ 2) THE STUDY RECOMMENDS DISCHARGE LIMITE THAT WOULD WORSEN WATER QUALITY.

The ACS recommends effluent limits that:

➡️ Increase phosphorus levels in a river that already exceeds the safe limit

➡️ Allow ammonia levels that come within a hair of toxic thresholds for fish

➡️ Assume bacteria levels of 6,000 CFU/100 mL (before treatment), far above safe recreational standards

➡️ Allow suspended solids (sediment) at 320 mg/L, which is not realistic or protective

❌ These recommendations do not meet provincial policies designed to protect rivers.

‼️‼️ 3) THE MODELING USED IN THE STUDY IS INCOMPLETE AND SOMETIMES UNRELIABLE.

The ACS:

➡️ Uses simple dilution math instead of proper mixing zone modeling

➡️ Does not model winter conditions or ice cover

➡️ Uses unrealistically high pollution levels in its calculations

➡️ Shows its own oxygen model becomes unstable when realistic numbers are used

➡️ Assumes ideal conditions (perfect pH, perfect temperature) that won’t happen in real life

❌ This means the study’s predictions about safety are not dependable.

‼️‼️ 4) THE MONITORING DATA IS NOT ENOUGH TO SUPPORT A MAJOR DISCHARGE.

The study collected:

➡️ Only 20 samples over about 16 months

➡️ Very little winter data

➡️ No continuous monitoring

➡️ No storm‑event sampling

➡️ No multi‑year seasonal coverage

➡️ Provincial guidance expects 2–3 years of data for a study like this.

❌ The dataset is simply too small to make decisions about the future of the river.

‼️‼️ 5) THE STUDY ASSUMES THE TREATMENT SYSTEM WILL PERFORM FROM PERFECTLY - WITHOUT EVIDENCE.

The ACS assumes the proposed wastewater treatment system (an SBR) will:

➡️ Remove phosphorus to extremely low levels

➡️ Control ammonia under all conditions

➡️ Disinfect bacteria effectively

➡️ Operate reliably in winter

❌ But the study provides no design details, no performance data, and no cold‑weather analysis. THIS IS A MAJOR GAP

‼️‼️ 6) THE STUDY DOES NOT ASSESS CUMULATIVE IMPACTS

The ACS does not consider:

➡️ Upstream septic systems

➡️ Forestry and land disturbance

➡️ Stormwater runoff

➡️ Downstream communities

➡️ Climate‑driven low flows

➡️ Volume of water the resort themselves pull from the river for water supply and snow making purposes... Or how much more than will extract as they expand

❌ A river is affected by everything in its watershed — not just one discharge. This study treats the river as if nothing else exists.

‼️‼️ 7) THE STUDY'S CONCLUSIONS DO NOT MATCH ITS OWN DATA

The ACS claims:

➡️ The river has “considerable assimilative capacity”

➡️ The monitoring dataset is “adequate”

➡️ The recommended limits “achieve water quality objectives”

But the study’s own tables show:

➡️ Phosphorus already exceeds safe levels

➡️ Ammonia is near toxic thresholds

➡️ Bacteria spikes occur

➡️ Sediment recommendations are unrealistic

➡️ Models are unstable

❌ The conclusions simply do not reflect the evidence.

💦 🌍 WHAT THIS MEANS FOR THE COMMUNITY

If approved as‑is, the proposed discharge could:

➡️ Increase nutrient pollution

➡️ Harm fish and aquatic life

➡️ Reduce water clarity

➡️ Increase bacteria levels

➡️ Stress the river during low‑flow periods

➡️ Create long‑term cumulative impacts that are hard to reverse

💦 🌍 CONCLUSION

The Goulais River is too important — ecologically, culturally, and recreationally — to accept a discharge based on a study with this many gaps.

📣 📣 WHAT WE NEED TO ASK FOR .....

Before any approval is considered, we are asking the MECP to require:

➡️ A revised, scientifically defensible study

➡️ Proper mixing zone modeling

➡️ Multi‑year monitoring

➡️ Winter and low‑flow analysis

➡️ Realistic effluent limits

➡️ Clear breakdown, and evidence that provides proof that the chosen treatment technology will perform properly

➡️ A phosphorus plan that complies with Policy 2

♥️ LETS BE CRYSTAL CLEAR .....

This is NOT about opposing development — it’s about ensuring development does not harm the river that our communities depend on.

🌍 Let's ensure the water remains accessible to all

🌍 Safe for the Species at risk that in and around it

🌍 Protect the families who live on/around the river

🌍 Preserve this fresh water for generations to come

🌍 Advocate for those who cannot do it themselves

🙏🏾DISCLAIMER:

This summary is shared in good faith for community awareness and engagement. The information shared here reflects my understanding of publicly available reports, studies and consultation materials. All information is based on publicly available documents, meeting materials and statements from the proponent and MECP found within the supporting documentation for this ECA application on the ERO. I make no claims about the completeness or accuracy of third-party documents and do not intend to defame or misrepresent any person, company or agency. I am not alleging wrongdoing by any individual or organization. If any information is later found to be inaccurate, I will update it promptly.