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

Dissolved Oxygen (DO) Impacts on Sensitive Species Not Assessed

Section 4.4 of the Design Brief acknowledges that DO levels depend on:

River temperature DO in the effluent DO in the river Oxygen consumed as effluent breaks down

 However, the Design Brief does not assess how DO changes may affect:

Lake Sturgeon (Threatened) Brook Trout Walleye Wood Turtle (Threatened)

Restricted Activity Timing Windows (Section 4.1.2):

Lake Sturgeon: May 1–June 20 Walleye: April 1–June 20 Brook Trout: September 1–June 15

The design brief says: The Ministry of Natural Resources and Forestry (MNRF) will be consulted to confirm whether permits or approvals are required. In section 6.2 it states when confirming project submission requirements for the MNRF it was indicated that the approved ECA application and approval of effluent before any work could be completed.

 Conclusion:

These windows cover most of the year, yet the Design Brief does not analyze how effluent discharge may affect spawning, incubation, or early development. No approvals or permits should be granted – though with an approved ECA in hand, it may make it easier for to achieve. The MNRF needs to consider this is not a municipality, this is private owned business.