I strongly oppose the…

I strongly oppose the proposed Environmental Compliance Approval (ERO 025-1121) for Searchmont Ski Resort to discharge up to 180 m³/day of treated sewage effluent into the Goulais River. This pristine, high-quality cold-water river must not become a disposal site for wastewater, even if treated.

Violation of Provincial Water Quality Policy

The Goulais River already meets or exceeds Provincial Water Quality Objectives (PWQO) for most parameters, with downstream total phosphorus (TP) at exactly the 0.030 mg/L PWQO threshold. This triggers Policy 2 status, which explicitly prohibits further degradation.

Yet the resort's own Assimilative Capacity Study projects that the proposed discharge—even with recommended effluent TP limits of 0.15 mg/L (objective 0.11 mg/L)—would increase downstream TP to 0.031 mg/L, causing a direct exceedance of PWQO. Any increase in phosphorus loading violates Policy 2 and sets a dangerous precedent for degrading protected waters.

Risk of Eutrophication in a Sensitive Ecosystem

Phosphorus is the limiting nutrient in many Ontario rivers and Lake Superior tributaries. Even small additions from sewage effluent can trigger algal blooms, reduce dissolved oxygen, and shift ecosystems toward undesirable states.

The Goulais River supports a sensitive cold-water fishery, including native brook trout and juvenile steelhead (rainbow trout), species highly vulnerable to nutrient enrichment and temperature changes. Studies on similar cold-water systems show that phosphorus inputs from treated effluent promote excessive periphyton growth, smothering spawning habitats and disrupting food webs.
Unremoved Emerging Contaminants

Standard sequencing batch reactor treatment, as proposed, effectively reduces conventional parameters like BOD and TSS but poorly removes pharmaceuticals, personal care products, and endocrine disruptors commonly found in domestic sewage.

Ontario studies document these compounds persisting in treated effluents and impacting receiving waters, contributing to:

- intersex conditions in fish
- altered behavior
- potential antibiotic resistance

Discharging into an oligotrophic system like the Goulais risks long-term bioaccumulation, especially as it flows directly into Lake Superior—one of the world's most pristine large lakes.

Better Alternatives Exist

In a near-pristine river with limited assimilative capacity (dilution ratios of ~64:1 at low flow), direct discharge is unnecessary and avoidable. Alternatives like enhanced land-based disposal, advanced tertiary treatment for reuse, or zero-discharge systems would protect the river without compromising resort operations.

Approving this would prioritize private development over public environmental values, including recreation, fisheries, and Indigenous rights (as noted by Batchewana First Nation's opposition).
Dumping treated sewage into this pristine river is an abomination that would irreversibly harm a vital northern Ontario treasure. I urge the Ministry to deny this approval and require non-discharge solutions.