Searchmont ski resort Waste…

Searchmont ski resort Waste Water treatment Plant Proposal
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.
• The Design Brief describes the influent as “typical domestic wastewater however else where its characteristics align more closely with weak to medium strength domestic sewage .
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)

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

There is a big concern with the peak flows of waste water coinciding with very low flows of the river at certain times of the year. These two factors will greatly influence the subsequent water quality of the river.
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 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.
1. The Goulais River Is Already Showing Signs of Stress Before Any Discharge
The ACS monitoring data shows that the river is not in a condition that can safely and consistently accept additional nutrient or contaminant loading:
• Total Phosphorus (TP)
o Upstream highest sample: 0.044 mg/L
o Downstream highest sample: 0.047 mg/L
o 5 of 20 downstream samples exceeded the Provincial Water Quality Objective (PWQO) of 0.030 mg/L (Appendix A 2 of ACS).
o This means 25% of samples exceeded the PWQO before any wastewater discharge exists.
o The water quality program designated as the downstream location is it the Hwy 17 crossing of the Goulais River. It’s at the PQWO already. What about TP in the rest of the river, past the Hwy 17 crossing?
• Recent boil water advisories in Goulais Bay – Latest one was in May of 2025 which was deemed a result of natural discharge from the Goulais River
• Bacteria
o The ACS documents spikes in fecal bacteria during baseline monitoring.
• Low Flow Conditions
o The Design Brief notes that the Goulais River experiences very low flows in late summer, increasing vulnerability to pollution.

• Winter Data Gaps
o The ACS contains limited winter data, despite winter being the most sensitive period for dissolved oxygen (DO) and ammonia toxicity.

Conclusion:
The river is already stressed. Under Ontario’s Policy 2, when a waterbody is at or above the PWQO, “no further degradation is permitted.”
Given the exceedances documented in the ACS, the assimilative capacity for phosphorus is effectively zero.
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2. The Monitoring Dataset Does Not Meet MECP Expectations

The ACS is based on ~20 samples of data (January 2021–April 2022), with only 20 sampling events and 16–20 samples per parameter.

MECP typically expects:
• 3 years of seasonal data, or
• 2 years of monthly data
Why is this acceptable?
7. Dissolved Oxygen (DO) Impacts on Sensitive Species Not Assessed
In my past education and work experience (Honours BSc in fisheries biology from University of Guelph and Environment Canada and Fisheries and Oceans jobs ) I know Oxygen levels are crucial to species survival and can be influenced by many external factors …water temperature, flow, BOD etc.

Section 4.4 of the Design Brief acknowledges that DO levels depend on:
• River temperature
• DO in the effluent
• DO in the river
• Oxygen consumed as effluent breaks down

However, the Design Brief does not assess how DO changes may affect:
• Lake Sturgeon (Threatened)
• Brook Trout
• Walleye
• Wood Turtle (Threatened)

Request to MECP
Given the gaps identified above, I respectfully request that the Ministry of Environment Conservation and Parks (MECP) require and do the following:

1. Exercise the full extent of your authority to protect Goulais River
2. A revised, scientifically defensible ACS
3. What alternatives were considered? We want to know.
4. Proper mixing zone modeling.
5. Multi year monitoring (including winter and low flow conditions).
6. Water quality monitoring in Goulais Bay
7. Full incorporation of PTTW water withdrawals into flow assumptions.
8. Realistic, achievable effluent limits supported by treatment design data.
9. Completion and public release of the updated SAR study and EIS.
10. A cumulative effects assessment and monitoring strategies
11. Demonstration of compliance with Policy 2 for phosphorus
12. A transparent public consultation process once all documents are available.
13. Make a condition that the proponent must establish a community led, 3rd party local water expert managed, proponent funded water quality monitoring program (ie. NORDIK in Sault Ste. Marie) for a minimum of 10 years or more.
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Final Statement: This is not about opposing development just because. It’s about ensuring that development does not harm the Goulais River — a river that is ecologically significant, culturally important, and directly connected to Lake Superior.

The introduction of effluent waste into the Goulais River will come with multiple long-term consequences. Respectfully, we need the MECP to recognize that this is not a municipality that has Canadian residents and waste management issues and demands that urgently need to be addressed. We are looking at a private, non-Canadian owned business built for profit that wishes to expand extensively. Respectfully, we need the MECP to recognize that the current proposal frames river discharge as unavoidable, but this a result of the proponents’ aggressive expansion plan – not inherit limitations of the land they occupy. We are asking the MECP to require a more balanced alternative assessment that considers wastewater solutions compatible with both environmental protection, preservation, conservation and sustainable development.

The Goulais River, surrounding communities, species at risk and future generations deserve a complete, transparent, and scientifically defensible assessment before this Environmental Compliance Approval is even considered.
I hope the Goulais River will remain a healthy, clean river system for my grandchildren to enjoy as much as I have.
It is a VERY important part of everyone’s life in this area and in Goulais bay and Lake Superior and for all Ontarians.