Re: Searchmont Ski Resort –…

Re: Searchmont Ski Resort – Proposed Wastewater Treatment Plant (WWTP)
– Submission to the Environmental Registry of OntarioTo 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:
~ 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 offacilities 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 severalhundreds 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 Napier-Reid 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 re-evaluated 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 real-worldconditions.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.
~ 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 overloadingand reduced treatment performance during busy periods. The design proposes an average daily flow (ADF) of 180 m³/day and a peak daily flow of360 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, short-duration spikes in wateruse, and the expert review noted that a higher peaking factor would be more realistic forthis type of facility. Based on the existing flow data already collected by the proponent, the actual peakingfactor 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 carry over to filtration, and reduced UV disinfection effectiveness. Given the sensitivity of the receiving river and the importance of accurate design flows, Irequest that MECP require the proponent to justify the selected peaking factor anddemonstrate that the plant can reliably handle peak flows at the upper end of the observedrange (2.4), not just the minimum value.3) Concerns About Design Flows, OBC Values, and Flow MonitoringThe proposed design flows in Table 3 of the Kresin Design Brief reference the OntarioBuilding Code (OBC) as the basis for flow generation rates. While the OBC values used forthe restaurant and conference room components appear accurate, it is not clear where thevalue of 225 L/bed for the hotel component was derived. This is not an OBC value. Underthe 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 non-OBC value (225 L/bed) was selected, nor doesit justify why a lower value is appropriate for this facility. This is a significant concernbecause OBC values represent peak or maximum day flows, not average day flows. Since the proposed design does not include any up-front flow equalization, the accuracy of both the average and peak design flows becomes critical to ensuring the plant can reliablyhandle real-world peak conditions.If the development is phased, detailed flow monitoring will be essential to verify actualaverage and peak flows. This is normally a standard ECA condition requiring the owner totrack and report daily flow values. However, the design brief does not specify how daily flows will be measured.The Napier-Reid package appears to include a flow meter as part of the tertiary treatmentequipment, but this meter is located after the treatment process. A post-treatment flowmeter does not represent the true influent entering the plant from the resort and thereforecannot 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 theraw/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 designflows, I request that MECP require the proponent to:1. Justify the use of 225 L/bed and explain why OBC-specified 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 andProper OperationFrom a high-level perspective, the proposed treatment technologies are well-establishedand 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 Napier-Reid 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 willdepend heavily on the accuracy of the design flow and influent quality assumptions. Asnoted 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 contractedwastewater operator will directly influence effluent quality. Even proven technologiescan 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 reflectsrealistic conditions for a resort with substantial commercial wastewater contributions.2. Demonstrate that the treatment system is adequately sized to handlehigher-strength influent if actual conditions exceed the assumed values.3. Provide an operations and monitoring plan that ensures the system will be properlymanaged to achieve consistent performance.These steps are necessary to ensure that the plant’s proven technologies can reliably meet effluent targets under real-world operating conditions.5) Phosphorus Removal Technology Is Proven, but Design Inputs Must BeRe-EvaluatedThe proposed phosphorus removal strategy—chemical precipitation followed by filtration—is a well-established and widely used treatment approach in Ontario. Whilemany facilities historically used sand filters, cloth disc filters such as those proposed hereare also proven technologies and can achieve comparable performance with a smaller footprint. The effluent phosphorus limits proposed for this facility are stringent, but with aproperly designed and operated system, they are technically achievable.The expert review provided two relevant Ontario examples using similar Napier-Reid SBRsystems with chemical precipitation and filtration:
• Havelock WWTPo Technology: Napier-Reid SBR + chemical precipitation + sand filtrationo Dry-season TP limit: 0.14 mg/Lo 2020 performance: 0.07 mg/L average TPo Operating at ~65% of rated capacity• Teeswater-Formosa WWTPo Technology: SBR + chemical precipitation + sand filtrationo TP objective: 0.1 mg/Lo TP limit: 0.15 mg/Lo 2024 performance: 0.1 mg/L average TPo Operating at ~74% of rated capacityThese examples demonstrate that the proposed effluent phosphorus limits aretheoretically achievable with this type of treatment process.However, the expert emphasized that achieving these limits depends heavily on theaccuracy of the influent flow and concentration assumptions used in the design. As notedin earlier comments, the influent BOD, TSS, TKN, and TP values appear to beunderestimated, particularly given that approximately half of the wastewater flow willoriginate from restaurants and commercial kitchens, which are known to producesignificantly higher-strength 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 limitsFor these reasons, I respectfully request that MECP require the proponent to:1. Reassess influent concentrations, particularly BOD, TSS, TKN, and TP, to reflect thesubstantial contribution from commercial food service operations.2. Demonstrate that the phosphorus removal system is adequately sized for realisticinfluent conditions.3. Confirm that the proposed filtration system can reliably meet the effluent TP limitsunder peak flow and peak loading scenarios.
These steps are necessary to ensure that the phosphorus removal system performs asintended and that the receiving watercourse is adequately protected.6) Buoyancy Control and the Need for Watertight ConstructionThe design appropriately includes anchoring of the lift station and tanks to protect againstbuoyancy, which is necessary given the shallow groundwater conditions at the site.However, the expert review noted that watertightness of all buried tanks and piping isequally 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 disinfectionEven though MECP does not typically regulate construction-level details such as sealingmethods, excess infiltration is an operational and performance risk that can directly affectthe plant’s ability to meet its effluent limits. Given the shallow groundwater table at thissite, watertight construction is essential to prevent inflow and infiltration fromoverwhelming 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 periodsof high groundwater.These steps are necessary to ensure the WWTP can operate reliably and maintaincompliance under real-world site conditions.7) Winter Temperatures, Insulation, and Biological Treatment PerformanceThe design brief does not mention insulation of tanks or process components, aside fromnoting in the Napier-Reid documentation that insulation is excluded from their scope.
Insulation is an important consideration for maintaining wastewater temperatures withinthe biological treatment system. Colder temperatures slow down biological processes,including BOD removal and nitrification, which could affect the plant’s ability to meeteffluent limits—particularly ammonia.Physical and chemical processes associated with solids removal and phosphorus removalare generally less sensitive to cold temperatures, provided that equipment is protectedfrom freezing. However, the biological processes in the SBRs are temperature-dependent,and maintaining adequate wastewater temperature is essential for consistentperformance.The expert review noted that Napier-Reid’s design calculations do consider both winter andsummer conditions, including biological treatment performance at wastewatertemperatures as low as 5°C. If the tanks are buried and insulated, achieving a winterwastewater temperature of approximately 5°C is reasonable, and the modelling appears toappropriately account for the process implications of winter conditions.However, because insulation is not described in the design brief, it is unclear how theproponent intends to maintain the temperatures assumed in the modelling. Withoutinsulation or equivalent construction measures, actual winter temperatures could fallbelow 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 assumptionsused in the Napier-Reid design calculations.2. Confirm whether insulation or other thermal protection measures will be included inthe detailed design of buried tanks and process components.3. Demonstrate that the plant can reliably achieve the required biological treatmentperformance under realistic winter operating conditions.These steps are necessary to ensure that the winter temperature assumptions used in thedesign are achievable and that the plant will perform as intended throughout the year.8) UV Disinfection Limits and the Need for RedundancyThe proposal includes UV disinfection for pathogen removal, which is a well-establishedand standard technology widely used in Ontario. The proposed effluent limit of 200CFU/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 rangeof 100–150 CFU/100 mL. Based on the expert’s experience, an objective of 100 CFU/100mL would be more consistent with similar ECAs, although the final limit should reflect thesensitivity of the receiving watercourse.The expert also noted that well-operated SBR + filtration + UV systems routinely achieve farbetter performance than the proposed limit. For example:• Havelock WWTP and Teeswater-Formosa WWTP, both using similar Napier-ReidSBR systems with chemical precipitation and filtration, regularly achieve <10CFU/100 mL.These examples demonstrate that significantly lower pathogen levels are achievable withthis type of treatment process.However, the proposal includes only a single UV disinfection train sized for maximumflow. This creates a single point of failure. If the UV unit requires maintenance orexperiences an equipment issue, the plant would have no ability to disinfect effluent,which could result in non-compliance and increased pathogen loading to the receivingriver.To improve reliability and ensure continuous disinfection, the expert recommendedconsidering two parallel UV units. This would allow one unit to remain in operation whilethe other is offline for maintenance or repair.Given the sensitivity of the receiving watercourse and the importance of reliable pathogencontrol, I respectfully request that MECP require the proponent to:1. Re-evaluate the proposed effluent E. coli objective and limit, considering thatsimilar facilities routinely achieve <10 CFU/100 mL.2. Assess whether a lower objective (e.g., 100 CFU/100 mL) is more appropriate forthis site.3. Provide redundancy in the UV system, such as two parallel UV trains, to ensurecontinuous disinfection during maintenance or equipment downtime.These steps are necessary to ensure the WWTP can reliably meet pathogen removalrequirements and protect the receiving watercourse under all operating conditions.9) Ammonia Limits, Nitrification Capacity, and Concerns About UnderestimatedInfluent NitrogenThe proposed summer ammonia limits for this facility are quite low. While these limits aretechnically achievable, the expert review emphasized that reliable nitrification
performance depends heavily on the accuracy of the influent nitrogen assumptions used inthe design.A well-operated biological nitrification process can achieve total ammonia nitrogen (TAN)concentrations below 1 mg/L, and comparable facilities in Ontario routinely achieve evenbetter performance. For example:• Havelock WWTP and Teeswater-Formosa WWTP (both using similar Napier-ReidSBR 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 plantis designed based on accurate influent nitrogen concentrations and has sufficient aerationand alkalinity to support full nitrification.However, the expert noted that the influent nitrogen concentration used in the designappears to be underestimated, particularly given the significant contribution of wastewaterfrom 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 volumeto achieve the required ammonia removal.In the expert’s words:“If the influent nitrogen concentration has been underestimated, modifications may beneeded to the nitrification calculations/design.”The expert also confirmed that alkalinity is essential for nitrification and that theNapier-Reid design appropriately includes chemical alkalinity addition if natural alkalinityis insufficient. However, the adequacy of this provision depends on the accuracy of theinfluent nitrogen assumptions.Given the sensitivity of the receiving watercourse and the importance of meeting lowammonia limits, I respectfully request that MECP require the proponent to:1. Reassess influent nitrogen concentrations, particularly TKN, to ensure the designbasis reflects realistic conditions.
~ Demonstrate that aeration capacity, alkalinity supply, and SBR cycle design aresufficient to achieve full nitrification under peak loading conditions.3. Confirm that the nitrification design has been evaluated for higher influent nitrogenscenarios, given the likelihood that commercial wastewater will increase nitrogenloading.These steps are necessary to ensure the WWTP can reliably meet ammonia limits underreal-world operating conditions.10) Concerns About the Proposed Nitrate Limit and Unit Errors in the ACSNitrate is not typically included as an effluent parameter for surface-water discharges inOntario. Nitrate limits are generally applied to groundwater discharges, not surface water,unless the receiving watercourse is extremely low-flow or highly sensitive. While it is notimpossible for an ECA to include a nitrate limit in a surface-water context, it is unusual andrequires strong technical justification.The expert review also identified a technical issue in the assimilative capacity calculations:the proponent appears to have mixed nitrate-as-N and nitrate-as-NO₃ units. This is acommon source of error, but it has important implications for interpreting water qualitycriteria.Specifically:• The CCME guideline of 13 mg/L applies to nitrate as NO₃.• When expressed as nitrate-as-N, the equivalent value is 2.93 mg/L.• The river data in the ACS is reported as nitrate-as-N, meaning the proponent shouldhave compared it to 2.93 mg/L, not 13 mg/L.Despite this unit error, the expert concluded that correcting the calculation would notchange the overall outcome. The receiving watercourse has sufficient assimilative capacityaccording 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 istechnically correct. Also are the other values used properly.2. Explain why a nitrate limit is appropriate, given that nitrate is not a standardparameter for surface-water discharges and the corrected ACS indicates adequateassimilative capacity.
~ Ensure that any effluent limits included in the ECA are supported by defensible,receiver-specific technical rationale, rather than by unit errors or assumptions.These steps are necessary to explain why that effluent limits is scientifically justified andaligned for this surface-water discharges.11) BOD Limits and Expected Performance of the Proposed Treatment SystemThe expert review noted that the proposed SBR and filtration system is fully capable ofachieving the required BOD removal. In fact, based on the expected performance of thistechnology, the proposed BOD limit of 25 mg/L appears higher than what similar systemsroutinely achieve.Sequencing Batch Reactors followed by tertiary filtration typically produce effluent BODconcentrations well below 15 mg/L under normal operating conditions. The expertindicated that an objective of 10 mg/L and a limit of 15 mg/L would be more consistent withthe performance expected from this type of treatment process.Given that the receiving watercourse is small and sensitive, and that comparable facilitiesin Ontario routinely achieve BOD levels below 10 mg/L, it would be appropriate for MECP toconsider 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/Lobjective and 15 mg/L limit), consistent with typical performance of similarfacilities.This would ensure that the effluent quality aligns with what the proposed technology iscapable of achieving and provides an appropriate level of protection for the receivingwatercourse.12) Total Suspended Solids (TSS) PerformanceThe expert review noted that the proposed SBR and tertiary filtration system should be ableto meet the Total Suspended Solids (TSS) objectives and limits without difficulty. This typeof treatment process is well established in Ontario and is known to reliably achieve low TSSconcentrations when properly designed and operated.
While TSS removal is not expected to be a limiting factor for this facility, it is important toensure that upstream design assumptions—particularly influent strength, peak flows, andthe absence of pre‑treatment—are accurate, as these factors can influence solids loadingon the SBRs and filters.I request that MECP ensure the proponent demonstrates that the TSS performanceexpectations remain achievable under realistic influent conditions and peak loadingscenarios.13) Missing Pre-Treatment (Screening and Grit Removal)The Kresin Design Brief does not include any information on initial pre-treatment ofsewage before it enters the SBR tanks. For a facility of this type and size, this is a significantomission. Most wastewater treatment plants using SBR technology incorporate screeningand grit removal as standard practice to intercept rags, plastics, food debris, grit, andother solids that are routinely discharged from kitchens, accommodations, and publicwashrooms.The expert review noted that pumping raw, unscreened sewage directly into an SBRbasin 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 upsetsThe Napier-Reid design documentation explicitly states that pre-treatment equipment isexcluded from their scope of supply. This means the proponent must provide it, yet thedesign brief does not address it at all.Given the significant proportion of wastewater expected from restaurants and commercialkitchens—where solids, grease, and debris loads are substantially higher than domesticsewage—pre-treatment is essential to protect downstream equipment and ensure reliableplant performance.I respectfully request that MECP require the proponent to:1. Clarify how raw sewage will be screened and protected before entering the SBRsystem.
2. Include appropriate pre-treatment equipment (e.g., screening and grit removal) inthe design.3. Demonstrate that the SBR and filtration systems will not be exposed todeleterious materials that could compromise treatment performance orequipment longevity.These steps are necessary to ensure the WWTP is designed to operate reliably underreal-world conditions and to prevent avoidable operational failures.14) Redundancy, Multi-Train SBR Design, and the Need for Additional FlexibilityThe expert review noted that the proposed SBR system is divided into four parallel trains,which is a strong design feature. This multi-train configuration provides several operationaladvantages:• It allows the operator to run multiple trains simultaneously while keeping each trainat a different point in the treatment cycle to accommodate incoming flow.• It provides flexibility during start-up and during seasonal variations in flow andloading.• It offers built-in redundancy, allowing the system to remain operational if one trainrequires maintenance or repair.However, the same level of redundancy and operational flexibility is not provided for thetertiary 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 requiresmaintenance or experiences an equipment issue, the plant would have no ability to filter ordisinfect effluent, which could result in non-compliance and increased environmental risk.The expert recommended that the proponent consider splitting the filtration and UVsystems 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 Napier-Reid SBR design does not require up-front equalization due to the multi-train configuration, the proponent should still consider someform 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, Irespectfully 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 up-front flow equalization is warranted, given the expectedvariability in flows and loadings from a resort-based development.3. Demonstrate that the treatment system can maintain compliance duringmaintenance events or equipment downtime.These steps are necessary to ensure the WWTP has adequate operational flexibility andredundancy to protect the receiving watercourse under real-world conditions.15) Consideration of Alternatives and the Implications of the Expansion ScaleThere has been no transparency in the design brief on what other waste managementalternatives have been discussed, explored and considered that balance both resortexpansion and water conservation, environmental protection and good corporate andcommunity citizen responsibility. There doesn’t appear to be any desire or willingness tocompromise 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, businesspurposes. This option should be a last resort; knowing that Goulais River is alreadyshowing significant signs of stress, knowing Goulais Bay already experiences boil wateradvisories because of seasonal flow from Goulais River. Knowing it’s one of the mostdiverse 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 whereGoulais River crosses Hwy 17 – which completely dismisses and ignores all water quality beyond that downstream monitoring location. Knowing that other ski resorts in NorthAmerica 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 theproposed expansion, which includes substantial increases in accommodations,commercial space, and restaurant capacity. The full-blown expansion being proposeddirectly influences the required treatment capacity and the decision to discharge to theriver. 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 demandand 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, pre-treatment,redundancy, and monitoring.3. Confirm that the chosen discharge method is protective of the receivingwatercourse, and/or outright rejected given the sensitivity of the river and the scaleof the proposed development.These steps and considerations are necessary to ensure that the selected wastewatermanagement approach is both technically justified and environmentally protective.16) No Backup Power Is MentionedThe design does not mention backup power. For a continuous discharge system, loss ofpower would mean loss of treatment, pumping, and disinfection. It is not clear from thereport whether or not the owner intends to include provision for backup power for waterand sewage systems to permit continued operation during a power outage, and if not, whatare the contingency plans for periods of power outage.While backup power is not typically required by MECP for private systems, and manysimilar 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 duringa power outage. Maintaining wastewater operations during an outage generally requiresthat 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, ratherthan 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 issomething the owner and their consultant need to consider ensuring operational continuityduring power interruptions – especially during peak flow season.The public should also be informed on what back up power is chosen to address how theresort intends to manage the business in the event of a power outage. A commonoccurrence in our region given the rural location and heavy snow bearing conditions.17) No Monitoring Plan Is IncludedThe expert noted that the design brief does not include a monitoring plan, which would at aminimum, include an influent and effluent monitoring program. Based on therecommendations of the Assimilate Capacity Study, a surface water monitoring planshould also be included.The design brief and the Assimilative Capacity Study (ACS) do not include any discussion ofthe proposed monitoring plan noted as a condition of approval during consultation in theACS. For a facility of this type, a monitoring program is an essential component of ensuringthat the treatment system is performing as intended and that the receiving watercourse isprotected.At a minimum, the proponent should be proposing:• Influent monitoring to verify actual flows and loading rates and to confirm whetherthe design assumptions are accurate.• Effluent monitoring to demonstrate compliance with ECA limits and to tracktreatment performance over time.• Surface water monitoring, if required based on receiver sensitivity, to confirm thatthe discharge is not adversely affecting the river.The absence of a monitoring plan in both the design brief and the ACS leaves a significantgap in understanding how the proponent intends to verify performance and complianceonce the system is operational. Our expert notes that neither consultant articulated whatthey propose that monitoring program will include. The ECA should not be issued until afull comprehensive monitoring program is presented.I respectfully request that MECP require the proponent to provide a clear andcomprehensive 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 CoverageThe assimilative capacity study (ACS) appears to follow typical methodology; however, thelength of the dataset is shorter than what MECP commonly expects for surface-waterassessments. 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 captureseasonal and year-to-year variability, particularly during low-flow summer conditions whenthe receiving river is most sensitive.The proponent collected 16 months of data, which is a reasonable dataset, but it does notinclude a second full summer low-flow period. As a result, the dataset may not fullyrepresent the range of conditions that influence assimilative capacity. The proponent alsohad 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 MECPtypically expects.Given the sensitivity of the receiving watercourse and the importance of accuratelycharacterizing low-flow conditions, I respectfully request that MECP consider whether theACS dataset provides sufficient seasonal coverage, or whether additional data collection iswarranted to ensure a robust assessment of assimilative capacity.We also request that the MECP require 2-3 years of ambient water quality through a qualitymonitoring program downstream, past the downstream location used in the proponentsmonitoring program that formed / produced the data in the Assimilative Capacity Study. IfPolicy #2 is already met where the river crosses Hwy 17 – it is vital to understand whatcondition the water quality is in beyond that point and within Goulais River before anyintroduction to effluent into the river is even considered.ConclusionThe health of this river cannot be an afterthought or a casualty of rushed design work. Theproponent is asking for permission to discharge treated wastewater into a small, sensitivewatercourse 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. Keydesign assumptions are underestimated, critical components such as pre-treatment and redundancy are missing, and the monitoring framework has not been defined. These arenot 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 acomprehensive 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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