Subject: Comments on…

Subject: Comments on Proposed ECA – Searchmont Ski Resort Wastewater Treatment Plant

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 Design Brief and Assimilative Capacity Study (ACS), publicly available Environmental Registry postings, and applicable provincial policies and guidance.

### 1. The Goulais River Is Already at or Near Its Capacity for Phosphorus

Baseline monitoring presented in the ACS shows repeated exceedances of the Provincial Water Quality Objective (PWQO) for total phosphorus at the downstream monitoring location, even in the absence of any wastewater discharge. When a waterbody is already at or above PWQOs, Ontario’s Policy 2 clearly states that further degradation is not permitted.

Despite this, the proposal does not identify a clear, enforceable plan for how phosphorus loading will be offset, reduced, or managed over the long term. Without such a plan, approval of a new discharge risks incremental degradation of a river that is already stressed. In practical terms, the assimilative capacity for phosphorus appears to be effectively zero.

### 2. Monitoring Is Insufficient for a High-Risk, Seasonal Discharge

The ACS relies on a limited dataset (approximately 20 samples over roughly 16 months). This does not meet typical MECP expectations for establishing baseline conditions in support of a major surface water discharge, particularly for a system with strong seasonal variability.

Of particular concern is the lack of robust winter data. Winter represents the most sensitive period for this system due to:

* naturally reduced river flows,
* active water withdrawals for snowmaking,
* peak wastewater generation during ski operations, and
* ice-covered conditions that reduce mixing and dissolved oxygen replenishment.

An assimilative capacity study that does not explicitly evaluate these critical winter conditions cannot be relied upon to represent worst-case impacts.

### 3. Water Withdrawals for Snowmaking Were Not Integrated into the Analysis

The resort holds a Permit to Take Water allowing substantial winter withdrawals for snowmaking. These withdrawals reduce instream flow and dilution capacity precisely during the period when wastewater loading would be highest.

However, the ACS does not appear to incorporate these permitted withdrawals into its flow assumptions or dilution calculations. As a result, the assimilative capacity of the river is likely overestimated, and the proposed effluent limits may be based on unrealistic hydrologic conditions.

### 4. No Clear or Credible Monitoring and Adaptive Management Framework

Given the existing phosphorus exceedances, seasonal stressors, and modeling uncertainties, the proposal should include a detailed, transparent monitoring and adaptive management plan. This should clearly define:

* what will be monitored,
* how frequently,
* where monitoring will occur (including downstream areas such as Goulais Bay),
* trigger thresholds for action, and
* enforceable responses if objectives are not met.

At present, this level of detail is lacking. Given the proponent’s history of expanding operations beyond existing wastewater capacity, a higher standard of oversight and accountability is warranted to rebuild public trust.

### 5. Alternatives and Reuse Were Not Adequately Considered

The proposal frames river discharge as unavoidable, yet there is no transparent assessment of alternatives. In particular, it is unclear why wastewater reuse for snowmaking was not meaningfully evaluated. Reusing treated wastewater could reduce both effluent discharge and additional water withdrawals from the Goulais River, directly addressing two of the project’s primary environmental pressures.

Without a documented alternatives analysis, it is not possible to conclude that river discharge represents the least-impact option.

### 6. Species at Risk, Cumulative Effects, and Downstream Impacts Remain Unresolved

Updated Species at Risk studies and the Environmental Impact Statement were not made available during the public comment period. In addition, cumulative effects from withdrawals, effluent discharge, existing development, climate-driven low flows, and downstream impacts to Goulais Bay and Lake Superior were not adequately assessed.

Meaningful public review is not possible without this information.

### Request to MECP

Given the issues outlined above, I respectfully request that MECP require, prior to any approval:

1. A revised assimilative capacity assessment that explicitly evaluates winter low-flow conditions and incorporates permitted water withdrawals.
2. A clear phosphorus management and offsetting strategy consistent with Policy 2.
3. A transparent alternatives analysis, including wastewater reuse for snowmaking.
4. A robust, multi-year monitoring and adaptive management program, with independent third-party oversight and public reporting.
5. Completion and public release of updated Species at Risk and Environmental Impact studies.
6. Assessment of cumulative effects and downstream impacts, including Goulais Bay.

### Closing

This submission is not opposition to development in principle. It is a request for a complete, transparent, and scientifically defensible assessment that reflects the ecological significance of the Goulais River and the legitimate concerns of the surrounding community. This is a privately owned resort proposing expansion-driven infrastructure, not a municipal system addressing essential public services. As such, a higher standard of environmental scrutiny and accountability is both reasonable and necessary.