I am submitting the…

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
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.

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

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

The ACS acknowledges that during consultation, the MECP raised concerns about the short duration, yet the dataset was still accepted.

This raises several questions:
• The downstream location used for the water quality monitoring program done by the proponent was designated where the Goulais River crosses Hwy 17. This is not the end of the river. It continues to flow well past this point and goes into Goulais Bay (with known water quality issues)
• Why was a shortened dataset accepted when it does not meet standard MECP expectations? What sampling protocol was used? Were samples collected consistently (same location, time of day, conditions)? How does taking multiple samples during summer compensate for missing winter and multi year data?

Conclusion:
The dataset is too limited to support a major surface water discharge approval. A strong data set is critical to prove that the river can receive and break down waste safely. With the spikes already showing up above the PWQO with no waste in the river – what will happen once effluent waste is introduced to the Goulais River? What will happen to Goulais Bay?

2. The ACS Does Not Appear to Account for the Resort’s Permit to Take Water (PTTW)

The resort holds an active Permit to Take Water (ERO 019 6965), allowing withdrawal of:
• 131,000 L/day for potable water + 11,498,000 L/day for snowmaking
• Up to 80 days per year

These withdrawals:
• Reduce river flow
• Reduce dilution capacity
• Occur during winter low flow periods
• Coincide with the most sensitive conditions for ammonia and DO
• Alter temperature and timing of return flows

However, the ACS assumes:
• Fixed flow
• No water withdrawals
• Instantaneous mixing
• No snowmaking impacts

Conclusion:
If the ACS does not incorporate permitted water withdrawals, then the calculated assimilative capacity is overestimated, and the effluent limits are based on unrealistic flow assumptions.
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3. Modeling Gaps and Unreliable Assumptions

The ACS contains several modeling limitations:
• Appears to use simple dilution calculations instead of proper mixing zone modeling.
• Does not appear to model winter conditions or ice cover.
• Uses unrealistically high pollution values in some calculations.
• The DO model becomes unstable when realistic inputs are used.
• Assumes ideal pH and temperature that do not reflect real river conditions.
Conclusion:
The predictions of “minimal impact” are not dependable and how they are advised in the design brief is not clear .

These windows cover most of the year, yet the Design Brief does not analyze how effluent discharge may affect spawning, incubation, or early development. No approvals or permits should be granted – though with an approved ECA in hand, it may make it easier for to achieve. The MNRF needs to consider this is not a municipality, this is private owned business.

8. Cumulative Effects Were Not Assessed
The ACS does not evaluate cumulative impacts from:
• Resort water withdrawals (11.5 million L/day)
• Upstream and downstream septic systems
• Stormwater runoff
• Forestry and land disturbance
• Hydro One Northshore Link
• Climate driven low flows
• Resort expansion
• Snowmaking return flows
• Existing contaminants
• Recreational use

Conclusion:
A cumulative effects assessment is required for a river with this ecological significance, above what was considered in the Assimilative Capacity Study.

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.

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