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 ACS Does Not Appear to Account for the Resort’s Permit to Take Water (PTTW)

The resort holds an active Permit to Take Water (ERO 019‑6965), allowing withdrawal of:

131,000 L/day for potable water + 11,498,000 L/day for snowmaking Up to 80 days per year

These withdrawals:

Reduce river flow Reduce dilution capacity Occur during winter low‑flow periods Coincide with the most sensitive conditions for ammonia and DO Alter temperature and timing of return flows

 However, the ACS assumes:

Fixed flow No water withdrawals Instantaneous mixing No snowmaking impacts

 Conclusion:
If the ACS does not incorporate permitted water withdrawals, then the calculated assimilative capacity is overestimated, and the effluent limits are based on unrealistic flow assumptions.