Commentaire
Algoma District and particularly the Goulais River Watershed is recognized provincially for ecotourism (That Real), which must remain ethical and environmentally sustainable in accordance with the Provincial Policy Statement (PPS 2020/2024) under the Planning Act (Policies 2.1 and 2.2). Future ‘recreational’ development should endeavor to protect natural heritage and water resources of the Goulais River. Discharging treated effluent into the Goulais River must not be supported by the Province where reasonable alternatives to waste water management exist.
Assimilative Capacity Study (ASC) Limitations
The ASC shows that the Goulais River is nearing phosphorus thresholds, with exceedances at 25% of sites sampled. Its 18-month scope is grossly inadequate with limited sample events and locations; best practice requires 2–3 years of data to capture seasonal variability and additional sample sites in closer proximity to the proposed discharge site. The study also fails to account for maximum allowable water draw under the resort’s existing permit. The limited scope of the ACS does not allow for reliable modelling. Under the Ontario Water Resources Act (OWRA), s. 53, effluent approvals must consider assimilative capacity using robust datasets (MECP Procedure B‑1‑5).
Water Taking Concerns
Proposed withdrawals during winter low-flow conditions risk ecological harm. The Goulais River is a sensitive system with low anthropogenic pressures. OWRA s. 34 and O. Reg. 387/04 require permits to consider cumulative impacts (water draw, snow making, proposed effluent discharge) and low-flow protections. Clarify if minimum flow benchmarks exist under provincial guidance for this river.
Monitoring and Oversight
PWQ compliance has been monitored solely by the proponent. Current independent monitoring by MECP or federal authorities should occur before any approval, consistent with EBR, 1993 transparency requirements.
Species at Risk and EIS
No Species at Risk (SAR) data is available for public review. A comprehensive Environmental Impact Study (EIS) must address Lake Sturgeon and Wood Turtle among other aquatic and semi aquatic species, consistent with the Endangered Species Act, 2007 (ss. 9–10) and PPS 2.1. No decision should proceed without a public comment period on the EIS specifically.
Proponent Track Record
The operator has demonstrated poor management:
Frequent ski hill closures and partial closures due to equipment maintenance/operation failures during peak season (ie. December 12th, 13th, 14th, 17th, 20 2025).
Proceeded with resort chalet expansion (2024) without consideration for provincial wastewater capacity or permits. These raise concerns about compliance with EPA Part II.1 and OWRA s. 53 conditions for sewage works.
Basic operational issues (e.g., POS systems failing to issue receipts to customers for basic transactions 2024/2025/2026).
Insufficient engagement. The proponent did not engage the community of Goulais River residents including landowners along the river; engagement was limited to residents in the immediate vicinity of the resort which is inadequate given the scope of the proposed project and ACS. Given the potential for serious consequence and impacts to the River – residents of the watershed downstream of the proposed effluent discharge site must be notified and engaged.
Request
Before any approval is considered, require:
Multi-year ASC and independent PWQ monitoring.
Low-flow and cumulative impact assessment under O. Reg. 387/04.
Full EIS with SAR review and public comment.
Stringent ECA conditions and regulatory monitoring if permitted.
Legislation Referenced: OWRA, EPA, ESA 2007, EBR 1993, PPS 2020/2024, O. Reg. 387/04, MECP PWQO & Procedure B‑1‑5.
Soumis le 11 janvier 2026 11:11 AM
Commentaire sur
Searchmont Ski Resort, Inc. - Environmental Compliance Approval (sewage)
Numéro du REO
025-1121
Identifiant (ID) du commentaire
181435
Commentaire fait au nom
Statut du commentaire