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.

No Monitoring Plan Is Included

The expert noted that the design brief does not include a monitoring plan, which would at a minimum, include an influent and effluent monitoring program. Based on the recommendations of the Assimilate Capacity Study, a surface water monitoring plan should also be included.

The design brief and the Assimilative Capacity Study (ACS) do not include any discussion of the proposed monitoring plan noted as a condition of approval during consultation in the ACS. For a facility of this type, a monitoring program is an essential component of ensuring that the treatment system is performing as intended and that the receiving watercourse is protected.

At a minimum, the proponent should be proposing:

Influent monitoring to verify actual flows and loading rates and to confirm whether the design assumptions are accurate. Effluent monitoring to demonstrate compliance with ECA limits and to track treatment performance over time. Surface water monitoring, if required based on receiver sensitivity, to confirm that the discharge is not adversely affecting the river.

The absence of a monitoring plan in both the design brief and the ACS leaves a significant gap in understanding how the proponent intends to verify performance and compliance once the system is operational. Our expert notes that neither consultant articulated what they propose that monitoring program will include.  The ECA should not be issued until a full comprehensive monitoring program is presented.  

I respectfully request that MECP require the proponent to provide a clear and comprehensive monitoring plan that includes influent, effluent, and, where appropriate, surface water monitoring.

We ask the MECP to consider it a condition that the proponent funds a community led, 3rd monitoring program through a reputable water experts local to the area. There are institutes like N.O.R.D.I.K. in Sault Ste. Marie that could help facilitate, organize, and manage this program with full transparency, subject matter expertise, accountability and equipment. This program would also build relation between the community and the proponent.