Re: Searchmont Ski Resort –…

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 CONTINUED 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:

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 owner-level 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, 3 rd monitoring program through a reputable water expert 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 surface water assessments. While MECP does not specify a formal minimum dataset length in guidance, in practice they typically request two to three years of surface water data to capture seasonal and year-to-year variability, particularly during low-flow 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 low-flow 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 two-year dataset MECP typically expects.

Given the sensitivity of the receiving watercourse and the importance of accurately characterizing low-flow 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 of 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 real-world 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.

Thank you for carefully considering the content above.