Subject Public Comment on…

Subject
Public Comment on Proposed Searchmont Ski Resort Wastewater Treatment Outflow Expansion

I am submitting this comment regarding the proposed Searchmont Resort Wastewater Treatment Process Outflow Expansion.
I am a resident within the Goulais River watershed and have direct waterway access to the river. I am also a long-time fisherman who has relied on and observed this river system for many years.
After reviewing the Goulais River Assimilative Capacity Study (ACS), Final Report, I have several concerns that I believe warrant further consideration.
My primary concern relates to the ACS findings on existing conditions within the Goulais River. The Provincial Water Quality Objective (PWQO) for total phosphorus in streams is 0.03 mg/L.
As stated in Section 4.5, Characterization of the Receiver Conditions, total phosphorus concentrations at the downstream monitoring location meet or exceed this PWQO. As a result, the downstream reach is designated under Policy 2 for Total Phosphorus, which states that
"where water quality does not meet PWQOs, it shall not be further degraded and all practical measures shall be undertaken to improve water quality toward meeting the objective."
This designation raises a significant concern with respect to the proposed expansion. Specifically, the downstream sampling location used in the study—at the Highway 17 crossing of the Goulais River—does not, in my opinion, adequately represent the cumulative impacts on water quality. There is a substantial concentration of residential and commercial development further downstream of this location, all of which contribute additional stressors to the river ecosystem. As such, the selected downstream monitoring point may underrepresent the true phosphorus loading and overall water quality conditions in the lower reaches of the river.
I believe that an additional downstream sampling location, situated below the majority of residential and commercial influences, should be included to provide a more accurate assessment of the river’s assimilative capacity and cumulative effects.
I also have concerns regarding the limited sampling dataset used to characterize multiple conditions, including high and low flow regimes and seasonal water temperature variations. Based on my review, the sampling frequency and duration do not appear sufficient to fully capture these variables or the range of conditions experienced in the Goulais River throughout the year.
Finally, it is important to emphasize that the Goulais River provides habitat for various protected aquatic species and serves as a spawning corridor. Any increase in wastewater effluent—particularly under expanded operations or potential system failure scenarios—poses a risk to these species and the ecological integrity of the river.
Given the existing exceedance of phosphorus objectives, the Policy 2 designation, and the projected increase in effluent volume from the Searchmont Ski Hill, I respectfully request that these concerns be carefully evaluated before any approval is granted.

Thank you for considering my comments.