Re: Searchmont Ski Resort –…

Re: Searchmont Ski Resort – Proposed Wastewater Treatment Plant (WWTP) –
Submission to the Environmental Registry of Ontario
To the Ministry of the Environment, Conservation and Parks,
I am submitting this comment in response to the proposed wastewater treatment plant
(WWTP) for the Searchmont Ski Resort. These concerns are based on a summary of
findings from an independent wastewater treatment expert who reviewed the design
brief.
The expert concluded that while the proposed treatment technology is commonly used
in Ontario and can perform well, several important design assumptions appear to be
incomplete or underestimated. These issues could / would affect the plant’s ability to
reliably meet its effluent limits and protect the sensitive receiving watercourse.
Below is a summary of our understanding of the key concerns the expert identified and
the considerations and calls to action we are asking the MECP to consider carefully:
1) Concerns About Underestimated Influent Strength and Commercial
Wastewater Impacts
The Design Brief describes the influent as “typical domestic wastewater.” However,
based on the concentrations presented in Table 5 of the report, the proposed influent
characteristics align more closely with weak to medium strength domestic sewage
according to standard wastewater literature. The report does not explain whether these
values were derived from actual monitoring at the existing facility or whether they are
purely assumed. This lack of clarity is concerning given the nature of the proposed
development.
A significant portion of the projected wastewater flow—approximately half—will
originate from commercial uses, including restaurants and a conference centre. These
types of facilities are well documented to produce wastewater with substantially higher
concentrations of:
 Total Suspended Solids (TSS)
 Biochemical Oxygen Demand (BOD)
 Total Kjeldahl Nitrogen (TKN)
 Total Phosphorus (TP)
 Fats, Oils, and Grease (FOG)
Commercial restaurant wastewater can have BOD concentrations in the several
hundreds to thousands of mg/L, depending on food type, cooking practices,
dishwashing procedures, and grease management. In contrast, the design basis used in
the report assumes an influent BOD of only 110 mg/L, which is typical of weak domestic
sewage and does not reflect the expected contribution from commercial kitchens.
The expert review concluded that the influent concentrations used by the proponent and
NapierReid are likely underestimated for a facility with this level of commercial activity.
If 50% of the daily flow originates from restaurants and food service operations, all
influent design concentrations (BOD, TSS, TKN, TP, FOG) should be reevaluated and
increased to reflect the higher strength wastewater expected from these sources.
Underestimating influent strength has direct implications for:
 Nitrification performance and the ability to meet ammonia limits
 Aeration requirements and blower sizing
 Alkalinity demand
 Sludge production rates
 SBR cycle timing and tank sizing
 Tertiary filtration loading
 Overall treatment reliability
If actual TKN concentrations are higher than assumed, the plant may not achieve the
required ammonia removal, and the treatment equipment may be undersized for
realworld conditions.
Given the sensitivity of the receiving watercourse and the importance of accurate
influent characterization, I respectfully request that MECP require the proponent to:
1. Clarify the basis for the influent concentrations used in the design (measured
data vs. assumptions).
2. Reassess influent strength to account for the substantial contribution from
restaurants and commercial kitchens.
3. Demonstrate that the treatment system is adequately sized for realistic BOD,
TSS, TKN, TP, and FOG concentrations.
These steps are necessary to ensure the WWTP is designed to handle the actual
wastewater characteristics expected from the proposed development.
2) Peak Flows May Be Higher Than the Design Assumes
The design uses a peaking factor of 2.0, but existing data from the resort shows peaks
closer to 2.0–2.4, especially on weekends and holidays.
Without flow equalization, underestimating peak flows could lead to hydraulic
overloading and reduced treatment performance during busy periods.
The design proposes an average daily flow (ADF) of 180 m³/day and a peak daily flow of
360 m³/day, which represents a peaking factor of 2.0. For a resort facility with highly
variable occupancy — including weekends, holidays, and seasonal surges — a peaking
factor of 2.0 appears low. Resorts typically experience sharp, shortduration spikes in
water use, and the expert review noted that a higher peaking factor would be more
realistic for this type of facility.
Based on the existing flow data already collected by the proponent, the actual peaking
factor appears to range from approximately 2.0 to 2.4. This means the design is using
the lowest end of the observed range, rather than the upper end that would provide a
margin of safety. Underestimating peak flows can lead to hydraulic overloading of the
SBRs, reduced settling performance, increased solids carryover to filtration, and
reduced UV disinfection effectiveness.
Given the sensitivity of the receiving river and the importance of accurate design flows, I
request that MECP require the proponent to justify the selected peaking factor and
demonstrate that the plant can reliably handle peak flows at the upper end of the
observed range (2.4), not just the minimum value.
3) Concerns About Design Flows, OBC Values, and Flow Monitoring
The proposed design flows in Table 3 of the Kresin Design Brief reference the Ontario
Building Code (OBC) as the basis for flow generation rates. While the OBC values used
for the restaurant and conference room components appear accurate, it is not clear
where the value of 225 L/bed for the hotel component was derived. This is not an OBC
value. Under the OBC, the applicable design flows are:
 500 L/person for a resort hotel
 250 L/room for a regular hotel/motel
The design brief does not explain why a nonOBC value (225 L/bed) was selected, nor
does it justify why a lower value is appropriate for this facility. This is a significant
concern because OBC values represent peak or maximum day flows, not average
day flows. Since the proposed design does not include any upfront flow equalization,
the accuracy of both the average and peak design flows becomes critical to ensuring
the plant can reliably handle realworld peak conditions.
If the development is phased, detailed flow monitoring will be essential to verify actual
average and peak flows. This is normally a standard ECA condition requiring the owner
to track and report daily flow values. However, the design brief does not specify how
daily flows will be measured.
The NapierReid package appears to include a flow meter as part of the tertiary
treatment equipment, but this meter is located after the treatment process. A
posttreatment flow meter does not represent the true influent entering the plant from the
resort and therefore cannot be used to verify whether influent assumptions were correct
or whether peak flows are being exceeded.
To ensure accurate flow tracking, the proponent should install a flow meter on the
raw/influent sewage pumping station, where all wastewater first enters the system. If
such a meter is already included in the lift station package, it is not clearly shown in the
available drawings, and it would not typically be included unless explicitly specified.
Given the sensitivity of the receiving watercourse and the importance of accurate design
flows, I request that MECP require the proponent to:
1. Justify the use of 225 L/bed and explain why OBCspecified values were not
used.
2. Demonstrate that the design flows adequately capture peak conditions,
especially in the absence of equalization.
3. Include influent flow monitoring at the raw sewage pumping station to ensure
accurate tracking of actual flows entering the plant.
These steps are necessary to ensure the design is protective, robust, and based on
defensible flow assumptions.
4) Technology Is Proven, but Performance Depends on Accurate Design Inputs
and Proper Operation
From a highlevel perspective, the proposed treatment technologies are wellestablished
and capable of meeting the effluent targets if the design assumptions are accurate.
Sequencing Batch Reactors (SBRs) are a reliable and proven biological process for
BOD removal and nitrification, and NapierReid has a long track record of successfully
implementing this technology over the past 25 years.
However, the expert review emphasized that the ultimate performance of the plant will
depend heavily on the accuracy of the design flow and influent quality assumptions. As
noted in earlier comments, several influent parameters—particularly BOD, TSS, and
TKN—appear to be underestimated given the significant contribution of wastewater
from restaurants and commercial kitchens. If the plant receives higher or different
influent strength than what the design is based on, the system may experience difficulty
meeting its effluent limits, especially for ammonia.
In addition, the expert noted that plant operations will play a major role in performance.
The way the facility is operated and maintained by the owner and their contracted
wastewater operator will directly influence effluent quality. Even proven
technologies can underperform if influent assumptions are incorrect or if operational
oversight is insufficient.
Given these factors, I request that MECP require the proponent to:
1. Reassess influent flow and loading assumptions to ensure the design basis
reflects realistic conditions for a resort with substantial commercial wastewater
contributions.
2. Demonstrate that the treatment system is adequately sized to handle
higherstrength influent if actual conditions exceed the assumed values.
3. Provide an operations and monitoring plan that ensures the system will be
properly managed to achieve consistent performance.
These steps are necessary to ensure that the plant’s proven technologies can reliably
meet effluent targets under realworld operating conditions.
5) Phosphorus Removal Technology Is Proven, but Design Inputs Must Be
ReEvaluated
The proposed phosphorus removal strategy—chemical precipitation followed by
filtration—is a wellestablished and widely used treatment approach in Ontario. While
many facilities historically used sand filters, cloth disc filters such as those proposed
here are also proven technologies and can achieve comparable performance with a
smaller footprint. The effluent phosphorus limits proposed for this facility are stringent,
but with a properly designed and operated system, they are technically achievable.
The expert review provided two relevant Ontario examples using similar NapierReid
SBR systems with chemical precipitation and filtration:
 Havelock WWTP
o Technology: NapierReid SBR + chemical precipitation + sand filtration
o Dryseason TP limit: 0.14 mg/L
o 2020 performance: 0.07 mg/L average TP
o Operating at ~65% of rated capacity
 TeeswaterFormosa WWTP
o Technology: SBR + chemical precipitation + sand filtration
o TP objective: 0.1 mg/L
o TP limit: 0.15 mg/L
o 2024 performance: 0.1 mg/L average TP
o Operating at ~74% of rated capacity
These examples demonstrate that the proposed effluent phosphorus limits are
theoretically achievable with this type of treatment process.
However, the expert emphasized that achieving these limits depends heavily on the
accuracy of the influent flow and concentration assumptions used in the design. As
noted in earlier comments, the influent BOD, TSS, TKN, and TP values appear to be
underestimated, particularly given that approximately half of the wastewater flow will
originate from restaurants and commercial kitchens, which are known to produce
significantly higherstrength wastewater.
If influent concentrations are higher than assumed, this will directly affect:
 chemical dosing requirements
 sludge production
 filtration loading
 SBR cycle performance
 the plant’s ability to consistently meet low TP limits
For these reasons, I respectfully request that MECP require the proponent to:
1. Reassess influent concentrations, particularly BOD, TSS, TKN, and TP, to reflect
the substantial contribution from commercial food service operations.
2. Demonstrate that the phosphorus removal system is adequately sized for
realistic influent conditions.
3. Confirm that the proposed filtration system can reliably meet the effluent TP limits
under peak flow and peak loading scenarios.
These steps are necessary to ensure that the phosphorus removal system performs as
intended and that the receiving watercourse is adequately protected.
6) Buoyancy Control and the Need for Watertight Construction
The design appropriately includes anchoring of the lift station and tanks to protect
against buoyancy, which is necessary given the shallow groundwater conditions at the
site. However, the expert review noted that watertightness of all buried tanks and piping
is equally important and is not addressed in the design brief.
If tanks, joints, or piping are not fully sealed, groundwater infiltration can enter the
system, which can:
 significantly increase hydraulic loading on the treatment plant
 reduce treatment performance
 compromise SBR cycle timing
 increase sludge production
 reduce the effectiveness of tertiary filtration and UV disinfection
Even though MECP does not typically regulate constructionlevel details such as sealing
methods, excess infiltration is an operational and performance risk that can directly
affect the plant’s ability to meet its effluent limits. Given the shallow groundwater table at
this site, watertight construction is essential to prevent inflow and infiltration from
overwhelming the system.
I respectfully request that MECP require the proponent to:
1. Address watertightness of all buried tanks and piping in the detailed design.
2. Demonstrate that the system is protected against infiltration, especially during
periods of high groundwater.
These steps are necessary to ensure the WWTP can operate reliably and maintain
compliance under realworld site conditions.
7) Winter Temperatures, Insulation, and Biological Treatment Performance
The design brief does not mention insulation of tanks or process components, aside
from noting in the NapierReid documentation that insulation is excluded from their
scope.
Insulation is an important consideration for maintaining wastewater temperatures within
the biological treatment system. Colder temperatures slow down biological processes,
including BOD removal and nitrification, which could affect the plant’s ability to meet
effluent limits—particularly ammonia.
Physical and chemical processes associated with solids removal and phosphorus
removal are generally less sensitive to cold temperatures, provided that equipment is
protected from freezing. However, the biological processes in the SBRs are
temperaturedependent, and maintaining adequate wastewater temperature is essential
for consistent performance.
The expert review noted that NapierReid’s design calculations do consider both winter
and summer conditions, including biological treatment performance at wastewater
temperatures as low as 5°C. If the tanks are buried and insulated, achieving a winter
wastewater temperature of approximately 5°C is reasonable, and the modelling appears
to appropriately account for the process implications of winter conditions.
However, because insulation is not described in the design brief, it is unclear how the
proponent intends to maintain the temperatures assumed in the modelling. Without
insulation or equivalent construction measures, actual winter temperatures could fall
below the design basis, potentially compromising biological treatment performance.
I respectfully request that MECP require the proponent to:
1. Clarify how wastewater temperatures will be maintained to match the
assumptions used in the NapierReid design calculations.
2. Confirm whether insulation or other thermal protection measures will be included
in the detailed design of buried tanks and process components.
3. Demonstrate that the plant can reliably achieve the required biological treatment
performance under realistic winter operating conditions.
These steps are necessary to ensure that the winter temperature assumptions used in
the design are achievable and that the plant will perform as intended throughout the
year.
8) UV Disinfection Limits and the Need for Redundancy
The proposal includes UV disinfection for pathogen removal, which is a wellestablished
and standard technology widely used in Ontario. The proposed effluent limit of 200
CFU/100 mL is consistent with many ECAs; however, the expert review noted that
several comparable facilities in Ontario operate under more stringent limits, typically
in the range of 100–150 CFU/100 mL. Based on the expert’s experience, an objective
of 100 CFU/100 mL would be more consistent with similar ECAs, although the final limit
should reflect the sensitivity of the receiving watercourse.
The expert also noted that welloperated SBR + filtration + UV systems routinely achieve
far better performance than the proposed limit. For example:
 Havelock WWTP and TeeswaterFormosa WWTP, both using similar
NapierReid SBR systems with chemical precipitation and filtration, regularly
achieve <10 CFU/100 mL.
These examples demonstrate that significantly lower pathogen levels are achievable
with this type of treatment process.
However, the proposal includes only a single UV disinfection train sized for maximum
flow. This creates a single point of failure. If the UV unit requires maintenance or
experiences an equipment issue, the plant would have no ability to disinfect effluent,
which could result in noncompliance and increased pathogen loading to the receiving
river.
To improve reliability and ensure continuous disinfection, the expert recommended
considering two parallel UV units. This would allow one unit to remain in operation
while the other is offline for maintenance or repair.
Given the sensitivity of the receiving watercourse and the importance of reliable
pathogen control, I respectfully request that MECP require the proponent to:
1. Reevaluate the proposed effluent E. coli objective and limit, considering that
similar facilities routinely achieve <10 CFU/100 mL.
2. Assess whether a lower objective (e.g., 100 CFU/100 mL) is more appropriate
for this site.
3. Provide redundancy in the UV system, such as two parallel UV trains, to
ensure continuous disinfection during maintenance or equipment downtime.
These steps are necessary to ensure the WWTP can reliably meet pathogen removal
requirements and protect the receiving watercourse under all operating conditions.
9) Ammonia Limits, Nitrification Capacity, and Concerns About Underestimated
Influent Nitrogen
The proposed summer ammonia limits for this facility are quite low. While these limits
are technically achievable, the expert review emphasized that reliable nitrification
performance depends heavily on the accuracy of the influent nitrogen assumptions used
in the design.
A welloperated biological nitrification process can achieve total ammonia nitrogen (TAN)
concentrations below 1 mg/L, and comparable facilities in Ontario routinely achieve
even better performance. For example:
 Havelock WWTP and TeeswaterFormosa WWTP (both using similar NapierReid
SBR systems) regularly achieve average effluent ammonia levels in the range of
0.1–0.2 mg/L.
These examples demonstrate that the proposed ammonia limits are achievable if the
plant is designed based on accurate influent nitrogen concentrations and has sufficient
aeration and alkalinity to support full nitrification.
However, the expert noted that the influent nitrogen concentration used in the design
appears to be underestimated, particularly given the significant contribution of
wastewater from restaurants and commercial kitchens. If actual influent TKN is higher
than assumed, the plant may not have:
 adequate aeration capacity
 sufficient alkalinity
 appropriate SBR cycle timing
 enough biological volume
to achieve the required ammonia removal.
In the expert’s words:
“If the influent nitrogen concentration has been underestimated, modifications may be
needed to the nitrification calculations/design.”
The expert also confirmed that alkalinity is essential for nitrification and that the
NapierReid design appropriately includes chemical alkalinity addition if natural alkalinity
is insufficient. However, the adequacy of this provision depends on the accuracy of the
influent nitrogen assumptions.
Given the sensitivity of the receiving watercourse and the importance of meeting low
ammonia limits, I respectfully request that MECP require the proponent to:
1. Reassess influent nitrogen concentrations, particularly TKN, to ensure the design
basis reflects realistic conditions.
2. Demonstrate that aeration capacity, alkalinity supply, and SBR cycle design are
sufficient to achieve full nitrification under peak loading conditions.
3. Confirm that the nitrification design has been evaluated for higher influent
nitrogen scenarios, given the likelihood that commercial wastewater will increase
nitrogen loading.
These steps are necessary to ensure the WWTP can reliably meet ammonia limits
under realworld operating conditions.
10) Concerns About the Proposed Nitrate Limit and Unit Errors in the ACS
Nitrate is not typically included as an effluent parameter for surfacewater discharges in
Ontario. Nitrate limits are generally applied to groundwater discharges, not surface
water, unless the receiving watercourse is extremely lowflow or highly sensitive. While it
is not impossible for an ECA to include a nitrate limit in a surfacewater context, it is
unusual and requires strong technical justification.
The expert review also identified a technical issue in the assimilative capacity
calculations: the proponent appears to have mixed nitrateasN and nitrateasNO₃ units.
This is a common source of error, but it has important implications for interpreting water
quality criteria.
Specifically:
 The CCME guideline of 13 mg/L applies to nitrate as NO₃.
 When expressed as nitrateasN, the equivalent value is 2.93 mg/L.
 The river data in the ACS is reported as nitrateasN, meaning the proponent
should have compared it to 2.93 mg/L, not 13 mg/L.
Despite this unit error, the expert concluded that correcting the calculation would not
change the overall outcome. The receiving watercourse has sufficient assimilative
capacity according to the ACS so it’s unclear why a nitrate limit is imposed.
Given this, I respectfully request that MECP:
1. Review the nitrate unit conversion issue in the ACS to ensure the analysis is
technically correct. Also are the other values used properly.
2. Explain why a nitrate limit is appropriate, given that nitrate is not a standard
parameter for surfacewater discharges and the corrected ACS indicates
adequate assimilative capacity.
3. Ensure that any effluent limits included in the ECA are supported by defensible,
receiverspecific technical rationale, rather than by unit errors or assumptions.
These steps are necessary to explain why that effluent limits is scientifically justified and
aligned for this surfacewater discharges.
11) BOD Limits and Expected Performance of the Proposed Treatment System
The expert review noted that the proposed SBR and filtration system is fully capable of
achieving the required BOD removal. In fact, based on the expected performance of this
technology, the proposed BOD limit of 25 mg/L appears higher than what similar
systems routinely achieve.
Sequencing Batch Reactors followed by tertiary filtration typically produce effluent BOD
concentrations well below 15 mg/L under normal operating conditions. The expert
indicated that an objective of 10 mg/L and a limit of 15 mg/L would be more consistent
with the performance expected from this type of treatment process.
Given that the receiving watercourse is small and sensitive, and that comparable
facilities in Ontario routinely achieve BOD levels below 10 mg/L, it would be appropriate
for MECP to consider whether the proposed BOD limit of 25 mg/L is sufficiently
protective.
I respectfully request that MECP:
1. Review the proposed BOD limit in light of the expected performance of SBR +
filtration systems.
2. Consider establishing a more protective BOD objective and limit (e.g., 10 mg/L
objective and 15 mg/L limit), consistent with typical performance of similar
facilities.
This would ensure that the effluent quality aligns with what the proposed technology is
capable of achieving and provides an appropriate level of protection for the receiving
watercourse.
12) Total Suspended Solids (TSS) Performance
The expert review noted that the proposed SBR and tertiary filtration system should be
able to meet the Total Suspended Solids (TSS) objectives and limits without difficulty.
This type of treatment process is well established in Ontario and is known to reliably
achieve low TSS concentrations when properly designed and operated.
While TSS removal is not expected to be a limiting factor for this facility, it is important to
ensure that upstream design assumptions—particularly influent strength, peak flows,
and the absence of pre‑treatment—are accurate, as these factors can influence solids
loading on the SBRs and filters.
I request that MECP ensure the proponent demonstrates that the TSS performance
expectations remain achievable under realistic influent conditions and peak loading
scenarios.
13) Missing PreTreatment (Screening and Grit Removal)
The Kresin Design Brief does not include any information on initial pretreatment of
sewage before it enters the SBR tanks. For a facility of this type and size, this is a
significant omission. Most wastewater treatment plants using SBR technology
incorporate screening and grit removal as standard practice to intercept rags, plastics,
food debris, grit, and other solids that are routinely discharged from kitchens,
accommodations, and public washrooms.
The expert review noted that pumping raw, unscreened sewage directly into an SBR
basin is not typical and presents several risks, including:
 damage to pumps, valves, and aeration equipment
 reduced settling performance within the SBR
 increased solids carryover to tertiary filtration
 higher maintenance requirements
 potential operational upsets
The NapierReid design documentation explicitly states that pretreatment equipment is
excluded from their scope of supply. This means the proponent must provide it, yet the
design brief does not address it at all.
Given the significant proportion of wastewater expected from restaurants and
commercial kitchens—where solids, grease, and debris loads are substantially higher
than domestic sewage—pretreatment is essential to protect downstream equipment and
ensure reliable plant performance.
I respectfully request that MECP require the proponent to:
1. Clarify how raw sewage will be screened and protected before entering the
SBR system.
2. Include appropriate pretreatment equipment (e.g., screening and grit removal)
in the design.
3. Demonstrate that the SBR and filtration systems will not be exposed to
deleterious materials that could compromise treatment performance or
equipment longevity.
These steps are necessary to ensure the WWTP is designed to operate reliably under
realworld conditions and to prevent avoidable operational failures.
14) Redundancy, MultiTrain SBR Design, and the Need for Additional Flexibility
The expert review noted that the proposed SBR system is divided into four parallel
trains, which is a strong design feature. This multitrain configuration provides several
operational advantages:
 It allows the operator to run multiple trains simultaneously while keeping each
train at a different point in the treatment cycle to accommodate incoming flow.
 It provides flexibility during startup and during seasonal variations in flow and
loading.
 It offers builtin redundancy, allowing the system to remain operational if one train
requires maintenance or repair.
However, the same level of redundancy and operational flexibility is not provided for the
tertiary filter or the UV disinfection system. The design includes:
 one single tertiary filter, and
 one single UV disinfection unit,
each sized for maximum flow. This creates two single points of failure. If either unit
requires maintenance or experiences an equipment issue, the plant would have no
ability to filter or disinfect effluent, which could result in noncompliance and increased
environmental risk.
The expert recommended that the proponent consider splitting the filtration and UV
systems into two parallel units, if feasible based on equipment sizing. This would
provide:
 operational flexibility,
 redundancy during maintenance, and
 improved reliability during peak flow periods.
The expert also noted that while the NapierReid SBR design does not require upfront
equalization due to the multitrain configuration, the proponent should still consider some
form of flow equalization. Equalization would help:
 manage seasonal and weekend/holiday flow variations,
 stabilize influent loading,
 improve chemical dosing consistency, and
 support more reliable performance across the treatment train.
Given the sensitivity of the receiving watercourse and the importance of system
reliability, I respectfully request that MECP require the proponent to:
1. Evaluate the need for redundancy in the tertiary filter and UV disinfection
systems, including the feasibility of using two parallel units.
2. Assess whether upfront flow equalization is warranted, given the expected
variability in flows and loadings from a resortbased development.
3. Demonstrate that the treatment system can maintain compliance during
maintenance events or equipment downtime.
These steps are necessary to ensure the WWTP has adequate operational flexibility
and redundancy to protect the receiving watercourse under realworld conditions.
15) Consideration of Alternatives and the Implications of the Expansion Scale
There has been no transparency in the design brief on what other waste management
alternatives have been discussed, explored and considered that balance both resort
expansion and water conservation, environmental protection and good corporate and
community citizen responsibility. There doesn’t appear to be any desire or willingness
to compromise proposed expansion to avoid relying on the Goulais River to be
responsible for receiving and breaking down the waste, they intend to produce for
private, business purposes. This option should be a last resort; knowing that Goulais
River is already showing significant signs of stress, knowing Goulais Bay already
experiences boil water advisories because of seasonal flow from Goulais River.
Knowing it’s one of the most diverse fish habitats and spawning grounds for Species At
Risk. Knowing the data shows us that Policy #2 is already met for Phosphorus at the
downstream monitoring location where Goulais River crosses Hwy 17 – which
completely dismisses and ignores all water quality beyond that downstream monitoring
location. Knowing that other ski resorts in North America are successfully and actively
using sophisticated waste management models to conserve, protect fresh water and
reuse wastewater.
It is important to note that the choice of river discharge is driven by the scale of the
proposed expansion, which includes substantial increases in accommodations,
commercial space, and restaurant capacity. The full-blown expansion being proposed
directly influences the required treatment capacity and the decision to discharge to the
river. If the expansion were smaller, subsurface options would be viable and would
eliminate direct impacts to the river entirely.