Please considder this…

Please considder this DETAILED – EXPERT INFORMED - ERO SUBMISSION LETTER

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.
The expert concluded that while the proposed treatment technology is commonly used in Ontario and can perform well, several important design assumptions appear to be incomplete or underestimated. These issues could / would affect the plant’s ability to reliably meet its effluent limits and protect the sensitive receiving watercourse.
Below is a summary of our understanding of the key concerns the expert identified and the considerations and calls to action we are asking the MECP to consider carefully:
1) Concerns About Underestimated Influent Strength and Commercial Wastewater Impacts
The Design Brief describes the influent as “typical domestic wastewater.” However, based on the concentrations presented in Table 5 of the report, the proposed influent characteristics align more closely with weak to medium strength domestic sewage according to standard wastewater literature. The report does not explain whether these values were derived from actual monitoring at the existing facility or whether they are purely assumed. This lack of clarity is concerning given the nature of the proposed development.
A significant portion of the projected wastewater flow—approximately half—will originate from commercial uses, including restaurants and a conference centre. These types of facilities are well documented to produce wastewater with substantially higher concentrations of:
• Total Suspended Solids (TSS)
• Biochemical Oxygen Demand (BOD)
• Total Kjeldahl Nitrogen (TKN)
• Total Phosphorus (TP)
• Fats, Oils, and Grease (FOG)

Commercial restaurant wastewater can have BOD concentrations in the several hundreds to thousands of mg/L, depending on food type, cooking practices, dishwashing procedures, and grease management. In contrast, the design basis used in the report assumes an influent BOD of only 110 mg/L, which is typical of weak domestic sewage and does not reflect the expected contribution from commercial kitchens.
The expert review concluded that the influent concentrations used by the proponent and NapierReid are likely underestimated for a facility with this level of commercial activity. If 50% of the daily flow originates from restaurants and food service operations, all influent design concentrations (BOD, TSS, TKN, TP, FOG) should be reevaluated and increased to reflect the higher strength wastewater expected from these sources.
Underestimating influent strength has direct implications for:
• Nitrification performance and the ability to meet ammonia limits
• Aeration requirements and blower sizing
• Alkalinity demand
• Sludge production rates
• SBR cycle timing and tank sizing
• Tertiary filtration loading
• Overall treatment reliability

If actual TKN concentrations are higher than assumed, the plant may not achieve the required ammonia removal, and the treatment equipment may be undersized for realworld conditions.
Given the sensitivity of the receiving watercourse and the importance of accurate influent characterization, I respectfully request that MECP require the proponent to:
1. Clarify the basis for the influent concentrations used in the design (measured data vs. assumptions).
2. Reassess influent strength to account for the substantial contribution from restaurants and commercial kitchens.
3. Demonstrate that the treatment system is adequately sized for realistic BOD, TSS, TKN, TP, and FOG concentrations.

These steps are necessary to ensure the WWTP is designed to handle the actual wastewater characteristics expected from the proposed development.
2) Peak Flows May Be Higher Than the Design Assumes
The design uses a peaking factor of 2.0, but existing data from the resort shows peaks closer to 2.0–2.4, especially on weekends and holidays.
Without flow equalization, underestimating peak flows could lead to hydraulic overloading and reduced treatment performance during busy periods.
The design proposes an average daily flow (ADF) of 180 m³/day and a peak daily flow of 360 m³/day, which represents a peaking factor of 2.0. For a resort facility with highly variable occupancy — including weekends, holidays, and seasonal surges — a peaking factor of 2.0 appears low. Resorts typically experience sharp, shortduration spikes in water use, and the expert review noted that a higher peaking factor would be more realistic for this type of facility.
Based on the existing flow data already collected by the proponent, the actual peaking factor appears to range from approximately 2.0 to 2.4. This means the design is using the lowest end of the observed range, rather than the upper end that would provide a margin of safety. Underestimating peak flows can lead to hydraulic overloading of the SBRs, reduced settling performance, increased solids carryover to filtration, and reduced UV disinfection effectiveness.
Given the sensitivity of the receiving river and the importance of accurate design flows, I request that MECP require the proponent to justify the selected peaking factor and demonstrate that the plant can reliably handle peak flows at the upper end of the observed range (2.4), not just the minimum value.
3) Concerns About Design Flows, OBC Values, and Flow Monitoring
The proposed design flows in Table 3 of the Kresin Design Brief reference the Ontario Building Code (OBC) as the basis for flow generation rates. While the OBC values used for the restaurant and conference room components appear accurate, it is not clear where the value of 225 L/bed for the hotel component was derived. This is not an OBC value. Under the OBC, the applicable design flows are:
• 500 L/person for a resort hotel
• 250 L/room for a regular hotel/motel

The design brief does not explain why a nonOBC value (225 L/bed) was selected, nor does it justify why a lower value is appropriate for this facility. This is a significant concern because OBC values represent peak or maximum day flows, not average day flows. Since the proposed design does not include any upfront flow equalization, the accuracy of both the average and peak design flows becomes critical to ensuring the plant can reliably handle realworld peak conditions.
If the development is phased, detailed flow monitoring will be essential to verify actual average and peak flows. This is normally a standard ECA condition requiring the owner to track and report daily flow values. However, the design brief does not specify how daily flows will be measured.
The NapierReid package appears to include a flow meter as part of the tertiary treatment equipment, but this meter is located after the treatment process. A posttreatment flow meter does not represent the true influent entering the plant from the resort and therefore cannot be used to verify whether influent assumptions were correct or whether peak flows are being exceeded.
To ensure accurate flow tracking, the proponent should install a flow meter on the raw/influent sewage pumping station, where all wastewater first enters the system. If such a meter is already included in the lift station package, it is not clearly shown in the available drawings, and it would not typically be included unless explicitly specified.
Given the sensitivity of the receiving watercourse and the importance of accurate design flows, I request that MECP require the proponent to:
1. Justify the use of 225 L/bed and explain why OBCspecified values were not used.
2. Demonstrate that the design flows adequately capture peak conditions, especially in the absence of equalization.
3. Include influent flow monitoring at the raw sewage pumping station to ensure accurate tracking of actual flows entering the plant.

These steps are necessary to ensure the design is protective, robust, and based on defensible flow assumptions.
4) Technology Is Proven, but Performance Depends on Accurate Design Inputs and Proper Operation
From a highlevel perspective, the proposed treatment technologies are wellestablished and capable of meeting the effluent targets if the design assumptions are accurate. Sequencing Batch Reactors (SBRs) are a reliable and proven biological process for BOD removal and nitrification, and NapierReid has a long track record of successfully implementing this technology over the past 25 years.
However, the expert review emphasized that the ultimate performance of the plant will depend heavily on the accuracy of the design flow and influent quality assumptions. As noted in earlier comments, several influent parameters—particularly BOD, TSS, and TKN—appear to be underestimated given the significant contribution of wastewater from restaurants and commercial kitchens. If the plant receives higher or different influent strength than what the design is based on, the system may experience difficulty meeting its effluent limits, especially for ammonia.
In addition, the expert noted that plant operations will play a major role in performance. The way the facility is operated and maintained by the owner and their contracted wastewater operator will directly influence effluent quality. Even proven technologies can underperform if influent assumptions are incorrect or if operational oversight is insufficient.
Given these factors, I request that MECP require the proponent to:
1. Reassess influent flow and loading assumptions to ensure the design basis reflects realistic conditions for a resort with substantial commercial wastewater contributions.
2. Demonstrate that the treatment system is adequately sized to handle higherstrength influent if actual conditions exceed the assumed values.
3. Provide an operations and monitoring plan that ensures the system will be properly managed to achieve consistent performance.

These steps are necessary to ensure that the plant’s proven technologies can reliably meet effluent targets under realworld operating conditions.
5) Phosphorus Removal Technology Is Proven, but Design Inputs Must Be ReEvaluated
The proposed phosphorus removal strategy—chemical precipitation followed by filtration—is a wellestablished and widely used treatment approach in Ontario. While many facilities historically used sand filters, cloth disc filters such as those proposed here are also proven technologies and can achieve comparable performance with a smaller footprint. The effluent phosphorus limits proposed for this facility are stringent, but with a properly designed and operated system, they are technically achievable.
The expert review provided two relevant Ontario examples using similar NapierReid SBR systems with chemical precipitation and filtration:
• Havelock WWTP
o Technology: NapierReid SBR + chemical precipitation + sand filtration
o Dryseason TP limit: 0.14 mg/L
o 2020 performance: 0.07 mg/L average TP
o Operating at ~65% of rated capacity

• TeeswaterFormosa WWTP
o Technology: SBR + chemical precipitation + sand filtration
o TP objective: 0.1 mg/L
o TP limit: 0.15 mg/L
o 2024 performance: 0.1 mg/L average TP
o Operating at ~74% of rated capacity

These examples demonstrate that the proposed effluent phosphorus limits are theoretically achievable with this type of treatment process.
However, the expert emphasized that achieving these limits depends heavily on the accuracy of the influent flow and concentration assumptions used in the design. As noted in earlier comments, the influent BOD, TSS, TKN, and TP values appear to be underestimated, particularly given that approximately half of the wastewater flow will originate from restaurants and commercial kitchens, which are known to produce significantly higherstrength wastewater.
If influent concentrations are higher than assumed, this will directly affect:
• chemical dosing requirements
• sludge production
• filtration loading
• SBR cycle performance
• the plant’s ability to consistently meet low TP limits

For these reasons, I respectfully request that MECP require the proponent to:
1. Reassess influent concentrations, particularly BOD, TSS, TKN, and TP, to reflect the substantial contribution from commercial food service operations.
2. Demonstrate that the phosphorus removal system is adequately sized for realistic influent conditions.
3. Confirm that the proposed filtration system can reliably meet the effluent TP limits under peak flow and peak loading scenarios.

These steps are necessary to ensure that the phosphorus removal system performs as intended and that the receiving watercourse is adequately protected.

6) Buoyancy Control and the Need for Watertight Construction

The design appropriately includes anchoring of the lift station and tanks to protect against buoyancy, which is necessary given the shallow groundwater conditions at the site. However, the expert review noted that watertightness of all buried tanks and piping is equally important and is not addressed in the design brief.
If tanks, joints, or piping are not fully sealed, groundwater infiltration can enter the system, which can:
• significantly increase hydraulic loading on the treatment plant
• reduce treatment performance
• compromise SBR cycle timing
• increase sludge production
• reduce the effectiveness of tertiary filtration and UV disinfection

Even though MECP does not typically regulate constructionlevel details such as sealing methods, excess infiltration is an operational and performance risk that can directly affect the plant’s ability to meet its effluent limits. Given the shallow groundwater table at this site, watertight construction is essential to prevent inflow and infiltration from overwhelming the system.

I respectfully request that MECP require the proponent to:
1. Address watertightness of all buried tanks and piping in the detailed design.
2. Demonstrate that the system is protected against infiltration, especially during periods of high groundwater.

These steps are necessary to ensure the WWTP can operate reliably and maintain compliance under realworld site conditions.

7) Winter Temperatures, Insulation, and Biological Treatment Performance
The design brief does not mention insulation of tanks or process components, aside from noting in the NapierReid documentation that insulation is excluded from their scope.
Insulation is an important consideration for maintaining wastewater temperatures within the biological treatment system. Colder temperatures slow down biological processes, including BOD removal and nitrification, which could affect the plant’s ability to meet effluent limits—particularly ammonia.
Physical and chemical processes associated with solids removal and phosphorus removal are generally less sensitive to cold temperatures, provided that equipment is protected from freezing. However, the biological processes in the SBRs are temperaturedependent, and maintaining adequate wastewater temperature is essential for consistent performance.
The expert review noted that NapierReid’s design calculations do consider both winter and summer conditions, including biological treatment performance at wastewater temperatures as low as 5°C. If the tanks are buried and insulated, achieving a winter wastewater temperature of approximately 5°C is reasonable, and the modelling appears to appropriately account for the process implications of winter conditions.
However, because insulation is not described in the design brief, it is unclear how the proponent intends to maintain the temperatures assumed in the modelling. Without insulation or equivalent construction measures, actual winter temperatures could fall below the design basis, potentially compromising biological treatment performance.
I respectfully request that MECP require the proponent to:
1. Clarify how wastewater temperatures will be maintained to match the assumptions used in the NapierReid design calculations.
2. Confirm whether insulation or other thermal protection measures will be included in the detailed design of buried tanks and process components.
3. Demonstrate that the plant can reliably achieve the required biological treatment performance under realistic winter operating conditions.

These steps are necessary to ensure that the winter temperature assumptions used in the design are achievable and that the plant will perform as intended throughout the year.

8) UV Disinfection Limits and the Need for Redundancy
The proposal includes UV disinfection for pathogen removal, which is a wellestablished and standard technology widely used in Ontario. The proposed effluent limit of 200 CFU/100 mL is consistent with many ECAs; however, the expert review noted that several comparable facilities in Ontario operate under more stringent limits, typically in the range of 100–150 CFU/100 mL. Based on the expert’s experience, an objective of 100 CFU/100 mL would be more consistent with similar ECAs, although the final limit should reflect the sensitivity of the receiving watercourse.
The expert also noted that welloperated SBR + filtration + UV systems routinely achieve far better performance than the proposed limit. For example:
• Havelock WWTP and TeeswaterFormosa WWTP, both using similar NapierReid SBR systems with chemical precipitation and filtration, regularly achieve <10 CFU/100 mL.
These examples demonstrate that significantly lower pathogen levels are achievable with this type of treatment process.
However, the proposal includes only a single UV disinfection train sized for maximum flow. This creates a single point of failure. If the UV unit requires maintenance or experiences an equipment issue, the plant would have no ability to disinfect effluent, which could result in noncompliance and increased pathogen loading to the receiving river.
To improve reliability and ensure continuous disinfection, the expert recommended considering two parallel UV units. This would allow one unit to remain in operation while the other is offline for maintenance or repair.
Given the sensitivity of the receiving watercourse and the importance of reliable pathogen control, I respectfully request that MECP require the proponent to:
1. Reevaluate the proposed effluent E. coli objective and limit, considering that similar facilities routinely achieve <10 CFU/100 mL.
2. Assess whether a lower objective (e.g., 100 CFU/100 mL) is more appropriate for this site.
3. Provide redundancy in the UV system, such as two parallel UV trains, to ensure continuous disinfection during maintenance or equipment downtime.

These steps are necessary to ensure the WWTP can reliably meet pathogen removal requirements and protect the receiving watercourse under all operating conditions.
9) Ammonia Limits, Nitrification Capacity, and Concerns About Underestimated Influent Nitrogen
The proposed summer ammonia limits for this facility are quite low. While these limits are technically achievable, the expert review emphasized that reliable nitrification performance depends heavily on the accuracy of the influent nitrogen assumptions used in the design.
A welloperated biological nitrification process can achieve total ammonia nitrogen (TAN) concentrations below 1 mg/L, and comparable facilities in Ontario routinely achieve even better performance. For example:
• Havelock WWTP and TeeswaterFormosa WWTP (both using similar NapierReid SBR systems) regularly achieve average effluent ammonia levels in the range of 0.1–0.2 mg/L.
These examples demonstrate that the proposed ammonia limits are achievable if the plant is designed based on accurate influent nitrogen concentrations and has sufficient aeration and alkalinity to support full nitrification.
However, the expert noted that the influent nitrogen concentration used in the design appears to be underestimated, particularly given the significant contribution of wastewater from restaurants and commercial kitchens. If actual influent TKN is higher than assumed, the plant may not have:
• adequate aeration capacity
• sufficient alkalinity
• appropriate SBR cycle timing
• enough biological volume

to achieve the required ammonia removal.
In the expert’s words:
“If the influent nitrogen concentration has been underestimated, modifications may be needed to the nitrification calculations/design.”
The expert also confirmed that alkalinity is essential for nitrification and that the NapierReid design appropriately includes chemical alkalinity addition if natural alkalinity is insufficient. However, the adequacy of this provision depends on the accuracy of the influent nitrogen assumptions.
Given the sensitivity of the receiving watercourse and the importance of meeting low ammonia limits, I respectfully request that MECP require the proponent to:
1. Reassess influent nitrogen concentrations, particularly TKN, to ensure the design basis reflects realistic conditions.
2. Demonstrate that aeration capacity, alkalinity supply, and SBR cycle design are sufficient to achieve full nitrification under peak loading conditions.
3. Confirm that the nitrification design has been evaluated for higher influent nitrogen scenarios, given the likelihood that commercial wastewater will increase nitrogen loading.
These steps are necessary to ensure the WWTP can reliably meet ammonia limits under realworld operating conditions.
10) Concerns About the Proposed Nitrate Limit and Unit Errors in the ACS
Nitrate is not typically included as an effluent parameter for surfacewater discharges in Ontario. Nitrate limits are generally applied to groundwater discharges, not surface water, unless the receiving watercourse is extremely lowflow or highly sensitive. While it is not impossible for an ECA to include a nitrate limit in a surfacewater context, it is unusual and requires strong technical justification.
The expert review also identified a technical issue in the assimilative capacity calculations: the proponent appears to have mixed nitrateasN and nitrateasNO₃ units. This is a common source of error, but it has important implications for interpreting water quality criteria.
Specifically:
• The CCME guideline of 13 mg/L applies to nitrate as NO₃.
• When expressed as nitrateasN, the equivalent value is 2.93 mg/L.
• The river data in the ACS is reported as nitrateasN, meaning the proponent should have compared it to 2.93 mg/L, not 13 mg/L.
Despite this unit error, the expert concluded that correcting the calculation would not change the overall outcome. The receiving watercourse has sufficient assimilative capacity according to the ACS so it’s unclear why a nitrate limit is imposed.
Given this, I respectfully request that MECP:
1. Review the nitrate unit conversion issue in the ACS to ensure the analysis is technically correct. Also are the other values used properly.
2. Explain why a nitrate limit is appropriate, given that nitrate is not a standard parameter for surfacewater discharges and the corrected ACS indicates adequate assimilative capacity.
3. Ensure that any effluent limits included in the ECA are supported by defensible, receiverspecific technical rationale, rather than by unit errors or assumptions.
These steps are necessary to explain why that effluent limits is scientifically justified and aligned for this surfacewater discharges.

11) BOD Limits and Expected Performance of the Proposed Treatment System
The expert review noted that the proposed SBR and filtration system is fully capable of achieving the required BOD removal. In fact, based on the expected performance of this technology, the proposed BOD limit of 25 mg/L appears higher than what similar systems routinely achieve.
Sequencing Batch Reactors followed by tertiary filtration typically produce effluent BOD concentrations well below 15 mg/L under normal operating conditions. The expert indicated that an objective of 10 mg/L and a limit of 15 mg/L would be more consistent with the performance expected from this type of treatment process.
Given that the receiving watercourse is small and sensitive, and that comparable facilities in Ontario routinely achieve BOD levels below 10 mg/L, it would be appropriate for MECP to consider whether the proposed BOD limit of 25 mg/L is sufficiently protective.
I respectfully request that MECP:
1. Review the proposed BOD limit in light of the expected performance of SBR + filtration systems.
2. Consider establishing a more protective BOD objective and limit (e.g., 10 mg/L objective and 15 mg/L limit), consistent with typical performance of similar facilities.
This would ensure that the effluent quality aligns with what the proposed technology is capable of achieving and provides an appropriate level of protection for the receiving watercourse.

12) Total Suspended Solids (TSS) Performance
The expert review noted that the proposed SBR and tertiary filtration system should be able to meet the Total Suspended Solids (TSS) objectives and limits without difficulty. This type of treatment process is well established in Ontario and is known to reliably achieve low TSS concentrations when properly designed and operated.
While TSS removal is not expected to be a limiting factor for this facility, it is important to ensure that upstream design assumptions—particularly influent strength, peak flows, and the absence of pre‑treatment—are accurate, as these factors can influence solids loading on the SBRs and filters.
I request that MECP ensure the proponent demonstrates that the TSS performance expectations remain achievable under realistic influent conditions and peak loading scenarios.
13) Missing PreTreatment (Screening and Grit Removal)
The Kresin Design Brief does not include any information on initial pretreatment of sewage before it enters the SBR tanks. For a facility of this type and size, this is a significant omission. Most wastewater treatment plants using SBR technology incorporate screening and grit removal as standard practice to intercept rags, plastics, food debris, grit, and other solids that are routinely discharged from kitchens, accommodations, and public washrooms.
The expert review noted that pumping raw, unscreened sewage directly into an SBR basin is not typical and presents several risks, including:
• damage to pumps, valves, and aeration equipment
• reduced settling performance within the SBR
• increased solids carryover to tertiary filtration
• higher maintenance requirements
• potential operational upsets
The NapierReid design documentation explicitly states that pretreatment equipment is excluded from their scope of supply. This means the proponent must provide it, yet the design brief does not address it at all.
Given the significant proportion of wastewater expected from restaurants and commercial kitchens—where solids, grease, and debris loads are substantially higher than domestic sewage—pretreatment is essential to protect downstream equipment and ensure reliable plant performance.
I respectfully request that MECP require the proponent to:
1. Clarify how raw sewage will be screened and protected before entering the SBR system.
2. Include appropriate pretreatment equipment (e.g., screening and grit removal) in the design.
3. Demonstrate that the SBR and filtration systems will not be exposed to deleterious materials that could compromise treatment performance or equipment longevity.
These steps are necessary to ensure the WWTP is designed to operate reliably under realworld conditions and to prevent avoidable operational failures.
14) Redundancy, MultiTrain SBR Design, and the Need for Additional Flexibility
The expert review noted that the proposed SBR system is divided into four parallel trains, which is a strong design feature. This multitrain configuration provides several operational advantages:
• It allows the operator to run multiple trains simultaneously while keeping each train at a different point in the treatment cycle to accommodate incoming flow.
• It provides flexibility during startup and during seasonal variations in flow and loading.
• It offers builtin redundancy, allowing the system to remain operational if one train requires maintenance or repair.
However, the same level of redundancy and operational flexibility is not provided for the tertiary filter or the UV disinfection system. The design includes:
• one single tertiary filter, and
• one single UV disinfection unit,
each sized for maximum flow. This creates two single points of failure. If either unit requires maintenance or experiences an equipment issue, the plant would have no ability to filter or disinfect effluent, which could result in noncompliance and increased environmental risk.
The expert recommended that the proponent consider splitting the filtration and UV systems into two parallel units, if feasible based on equipment sizing. This would provide:
• operational flexibility,
• redundancy during maintenance, and
• improved reliability during peak flow periods.
The expert also noted that while the NapierReid SBR design does not require upfront equalization due to the multitrain configuration, the proponent should still consider some form of flow equalization. Equalization would help:
• manage seasonal and weekend/holiday flow variations,
• stabilize influent loading,
• improve chemical dosing consistency, and
• support more reliable performance across the treatment train.
Given the sensitivity of the receiving watercourse and the importance of system reliability, I respectfully request that MECP require the proponent to:
1. Evaluate the need for redundancy in the tertiary filter and UV disinfection systems, including the feasibility of using two parallel units.
2. Assess whether upfront flow equalization is warranted, given the expected variability in flows and loadings from a resortbased development.
3. Demonstrate that the treatment system can maintain compliance during maintenance events or equipment downtime.
These steps are necessary to ensure the WWTP has adequate operational flexibility and redundancy to protect the receiving watercourse under realworld conditions.
15) Consideration of Alternatives and the Implications of the Expansion Scale
There has been no transparency in the design brief on what other waste management alternatives have been discussed, explored and considered that balance both resort expansion and water conservation, environmental protection and good corporate and community citizen responsibility. There doesn’t appear to be any desire or willingness to compromise proposed expansion to avoid relying on the Goulais River to be responsible for receiving and breaking down the waste, they intend to produce for private, business purposes. This option should be a last resort; knowing that Goulais River is already showing significant signs of stress, knowing Goulais Bay already experiences boil water advisories because of seasonal flow from Goulais River. Knowing it’s one of the most diverse fish habitats and spawning grounds for Species At Risk. Knowing the data shows us that Policy #2 is already met for Phosphorus at the downstream monitoring location where Goulais River crosses Hwy 17 – which completely dismisses and ignores all water quality beyond that downstream monitoring location. Knowing that other ski resorts in North America are successfully and actively using sophisticated waste management models to conserve, protect fresh water and reuse wastewater.
It is important to note that the choice of river discharge is driven by the scale of the proposed expansion, which includes substantial increases in accommodations, commercial space, and restaurant capacity. The full-blown expansion being proposed directly influences the required treatment capacity and the decision to discharge to the river. If the expansion were smaller, subsurface options would be viable and would eliminate direct impacts to the river entirely. This is not a municipality with active demand and no other alternatives.
Given this context, I respectfully request that MECP:
1. Acknowledge that the proposed discharge method is tied to the proponent’s very large expansion plans, and that alternative disposal options are feasible at lower flows.
2. Ensure that the design is refined to address the concerns identified in the expert review, particularly regarding influent strength, peak flows, pretreatment, redundancy, and monitoring.
3. Confirm that the chosen discharge method is protective of the receiving watercourse, and/or outright rejected given the sensitivity of the river and the scale of the proposed development.
These steps and considerations are necessary to ensure that the selected wastewater management approach is both technically justified and environmentally protective.

16) No Backup Power Is Mentioned
The design does not mention backup power. For a continuous discharge system, loss of power would mean loss of treatment, pumping, and disinfection. It is not clear from the report whether or not the owner intends to include provision for backup power for water and sewage systems to permit continued operation during a power outage, and if not, what are the contingency plans for periods of power outage.
While backup power is not typically required by MECP for private systems, and many similar facilities operate without it, the absence of any discussion in the report is notable.
Backup power is important if the owner intends for the facility to continue operating during a power outage. Maintaining wastewater operations during an outage generally requires that the water supply system also have backup power; otherwise, no sewage is generated. The decision to include a generator is usually an ownerlevel operational choice, rather than a regulatory requirement.
However, given the expansion plans proposed, and visitor capacity. I am suggesting that the MECP mandates a backup power for this ECA (if it is approved). At the very least, it is something the owner and their consultant need to consider ensuring operational continuity during power interruptions – especially during peak flow season.
The public should also be informed on what back up power is chosen to address how the resort intends to manage the business in the event of a power outage. A common occurrence in our region given the rural location and heavy snow bearing conditions.
17) 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.

18) Assimilative Capacity Study (ACS) Dataset Length and Seasonal Coverage
The assimilative capacity study (ACS) appears to follow typical methodology; however, the length of the dataset is shorter than what MECP commonly expects for surfacewater assessments. While MECP does not specify a formal minimum dataset length in guidance, in practice they typically request two to three years of surfacewater data to capture seasonal and yeartoyear variability, particularly during lowflow summer conditions when the receiving river is most sensitive.
The proponent collected 16 months of data, which is a reasonable dataset, but it does not include a second full summer lowflow period. As a result, the dataset may not fully represent the range of conditions that influence assimilative capacity. The proponent also had the opportunity to continue collecting data after submitting the initial dataset to MECP, which could have strengthened the ACS by bringing it closer to the twoyear dataset MECP typically expects.
Given the sensitivity of the receiving watercourse and the importance of accurately characterizing lowflow conditions, I respectfully request that MECP consider whether the ACS dataset provides sufficient seasonal coverage, or whether additional data collection is warranted to ensure a robust assessment of assimilative capacity.
We also request that the MECP require 2-3 years of ambient water quality through a quality monitoring program downstream, past the downstream location used in the proponents monitoring program that formed / produced the data in the Assimilative Capacity Study. If Policy #2 is already met where the river crosses Hwy 17 – it is vital to understand what condition the water quality is in beyond that point and within Goulais River before any introduction to effluent into the river is even considered.
Conclusion
The health of this river cannot be an afterthought or a casualty of rushed design work. The proponent is asking for permission to discharge treated wastewater into a small, sensitive watercourse that already experiences low flows and seasonal stress. That privilege comes with a responsibility to demonstrate—clearly, transparently, and with defensible data—that the system will perform reliably under realworld conditions, not just on paper.
The expert review shows that the current proposal does not yet meet that standard. Key design assumptions are underestimated, critical components such as pretreatment and redundancy are missing, and the monitoring framework has not been defined. These are not minor details; they are foundational elements that determine whether the plant will protect the river or place it at risk.
Once an ECA is issued, the community and the watershed bear the consequences. There is no undo button. That is why MECP’s role is so essential here: to ensure that the design is thoroughly considered (at the very least strengthened significantly) before approval, not after problems emerge. We need to be proactive.
I urge MECP to require the proponent to address the identified gaps, correct the underestimations, and demonstrate—through robust design, adequate safeguards, and a comprehensive monitoring plan—that this system can truly protect the receiving watercourse. The river deserves nothing less, and neither does the communities that depends on it.
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