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.

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. This is not a municipality with active demand and no other alternatives.

Given this context, I respectfully request that MECP:

Acknowledge that the proposed discharge method is tied to the proponent’s very large expansion plans, and that alternative disposal options are feasible at lower flows. Ensure that the design is refined to address the concerns identified in the expert review, particularly regarding influent strength, peak flows, pre‑treatment, redundancy, and monitoring. Confirm that the chosen discharge method is protective of the receiving watercourse, and/or outright rejected given the sensitivity of the river and the scale of the proposed development.

These steps and considerations are necessary to ensure that the selected wastewater management approach is both technically justified and environmentally protective.