I am submitting the…

I am submitting the following comments regarding the proposed Environmental Compliance Approval (ECA) for the Searchmont Ski Resort Wastewater Treatment Plant (WWTP) and its proposed discharge to the Goulais River.

 My comments are based on the information provided in the Design Brief (including the Assimilative Capacity Study), publicly available ERO postings, and provincial policies and guidelines. All references below are taken directly from the documents provided to the public

The Goulais River Is Already Showing Signs of Stress Before Any Discharge

The ACS monitoring data shows that the river is not in a condition that can safely and consistently accept additional nutrient or contaminant loading:

Total Phosphorus (TP) Upstream highest sample: 0.044 mg/L Downstream highest sample: 0.047 mg/L 5 of 20 downstream samples exceeded the Provincial Water Quality Objective (PWQO) of 0.030 mg/L (Appendix A‑2 of ACS). This means 25% of samples exceeded the PWQO before any wastewater discharge exists. The water quality program designated as the downstream location is it the Hwy 17 crossing of the Goulais River. It’s at the PQWO already. What about TP in the rest of the river, past the Hwy 17 crossing?

·        Recent boil water advisories in Goulais Bay – Latest one was in May of 2025 which was deemed a result of natural discharge from the Goulais River

·        Bacteria

The ACS documents spikes in fecal bacteria during baseline monitoring. Low Flow Conditions The Design Brief notes that the Goulais River experiences very low flows in late summer, increasing vulnerability to pollution.

Winter Data Gaps The ACS contains limited winter data, despite winter being the most sensitive period for dissolved oxygen (DO) and ammonia toxicity.

Conclusion:
The river is already stressed. Under Ontario’s Policy 2, when a waterbody is at or above the PWQO, “no further degradation is permitted.”
Given the exceedances documented in the ACS, the assimilative capacity for phosphorus is effectively zero.