I am submitting this comment…

I am submitting this comment to highlight the importance of the Provincial Water Quality Objective (PWQO) for Total Phosphorus (TP) and to outline the implications of TP concentrations that meet or exceed this threshold in the Goulais River.

This river feeds into Lake Superior and it is an important part of the Lake Superior wastershed. Please consider and leverage the Ontario Great Lakes Strategy and TP reports when considering this ECA application. The Great Lakes are already facing issues with algae blossoms as a result of phosphorus.

Protecting Goulais River is protecting the Great Lakes. We must honor the Canada-Ontario Great Lakes agreement.

https://www.ontario.ca/page/ontarios-great-lakes-strategy
https://www.ontario.ca/page/total-phosphorus-report?id=71010001
https://www.ontario.ca/page/protecting-great-lakes
https://www.ontario.ca/page/summary-canada-ontario-great-lakes-agreement

Ontario’s PWQO for TP is 0.030 mg/L. This value is established to prevent eutrophication — the accelerated growth of algae and aquatic plants that occurs when phosphorus levels become elevated. Excessive phosphorus is widely recognized as the primary driver of algae growth in freshwater systems.

From my understanding the PWQO is intended to:
- maintain water clarity
- protect dissolved oxygen levels
- support healthy aquatic ecosystems
- prevent nuisance algae growth
- protect recreational water quality
- reduce treatment challenges for drinking water systems

With this in mind, I am asking the MECP to use the authority they have to carefully consider TP that already exists within the Goulais River and most importantly that it is already at the PWQO downstream. Table 4-2 in the ACS shows the highest TP sample for the upstream location was 0.044 mg/L. Table 4-4 shows highest TP sample for downstream was 0.047 mg/L and appendix A-2 (on page 60 of the 461 page design brief) shows 5 of 20 samples were above the PWQO of 0.030 mg/L. This means 25 % of the samples collected were over the PWQO already with no WWTP depositing waste into the river.

I am also asking the MECP to consider TP related to human health.
While phosphorus itself is not directly harmful to human health at concentrations found in natural waterbodies. Elevated phosphorus indirectly affects human health by promoting conditions that: increase the risk of harmful algal blooms (some of which produce toxins), increase turbidity and organic matter, complicating drinking‑water treatment. coincide with elevated pathogen levels (e.g., E. coli) and degrade recreational water quality.

Thus, while phosphorus is not toxic on its own, its ecological effects have clear implications for human health and water safety. Which will impact those who utilize the river for recreational purposes and those whom have their well water sourced from the river.

I am also asking the MECP to carefully consider the consequences of exceeding the PWQO with respect to the affect it will have on aquatic life and water quality.

We know that when TP meets or exceeds 0.030 mg/L: algae growth accelerates, dissolved oxygen declines as algae decompose, fish and sensitive aquatic species experience stress, habitat quality deteriorates, water treatment requirements increase, the waterbody becomes more vulnerable to further degradation. These impacts are well‑documented in Ontario’s phosphorus management guidance and ongoing project work.

Please MECP team, I am begging you to consider and honor Policy 2 requirements where the
Ontario’s water‑quality management framework states:

If a waterbody is at or above the PWQO, no further degradation is permitted.
This means that any new or expanded discharge must demonstrate: no increase in phosphorus loading, no measurable deterioration of water quality, no additional risk to aquatic life or downstream users.

If the TP concentrations in the Goulais River are already at or above the PWQO, and showing major strikes; the assimilative capacity for phosphorus is effectively zero based on policy 2.

In summary, given the importance of the PWQO and the consequences of exceedances, I respectfully request that MECP:

1) Confirm and acknowledge whether TP concentrations in the Goulais River exceed the PWQO.
2) Apply and honor Policy 2 where applicable, ensuring no further degradation is permitted.
3) Require this proponent to demonstrate that proposed effluent will not increase phosphorus loading or contribute to eutrophication
4) Ensure that phosphorus limits in the ECA reflect the river’s current condition and its limited assimilative capacity.
5) Should you ignore the Policy 2 and approve this ECA. I am asking you to hold the proponent responsible to funding an year-around monitoring program through a reputable 3rd party partner, not a sampling program that they are responsible for managing themselves.

Thank you for considering these comments.