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.

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:

Review the proposed BOD limit in light of the expected performance of SBR + filtration systems. 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.