The Goulais River is one of…

The Goulais River is one of the cleanest, most important rivers in our region. It supports fish, wildlife, and recreation and is already showing signs of stress. The ACS 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

The ACS recommends effluent limits that would worsen water quality:

➡️ 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

The ACS modelling is incomplete:

➡️ 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

The monitoring data collected as part of the ACS 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 ACS assumes the treatment system will function with no negative impacts but 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

The ACS contains several gaps and inconsistencies, and the conclusions do not match the data. The study does not include a fulsome assessment of cumulative impacts.

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

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

Before any approval is considered, I urge 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