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.

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.

2)      Missing Pre‑Treatment (Screening and Grit Removal)

The Kresin Design Brief does not include any information on initial pre‑treatment 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 Napier‑Reid design documentation explicitly states that pre‑treatment 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—pre‑treatment is essential to protect downstream equipment and ensure reliable plant performance.

I respectfully request that MECP require the proponent to:

Clarify how raw sewage will be screened and protected before entering the SBR system. Include appropriate pre‑treatment equipment (e.g., screening and grit removal) in the design. 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 real‑world conditions and to prevent avoidable operational failures.