As a Searchmont resident for…

As a Searchmont resident for 50 yrs, and my maternal and paternal family for minimum of also 50 yrs before me.. and with intention of continuing the growth of our family with our own 6 children, living on the Goulais River is of great concern for our future if this plan moves forward. We do NOT support this plan!

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.

There are areas of concern affecting the river that are not calculated into the projects impact or mentioned in the assimilative study. Existing contaminants such as the toxic wood mill site immediatly down stream from the proposed discharge site which was active for 100 years before being abandoned in the late 80's. There have been ongoing environmental remediations happening at this site on finn road over the past 10 years. test Drills have discovered high levels of contaminents leeching into the Goulais river and built a power line to run an on site pumping and monitering system.Where is the data for this site and what is leeching into the river? Why is this not considered in the balance of the project? The public has a right to know.

There is also an old abandoned goulais dump which is downstream from the water data collection points used in the assimilative study! The river naturally moves more slowly after that lowest data point , where it warms up, has less natural mixing, less oxygen and much more existing human impacts! Goulais bay should also be considered in monitering as it is where all of the water collects.

The Goulais river is one of the few remaining rivers that is not dammed for power generation. The reason for that is because of its excessively high water flows during rain events and snow melt, and the excessively low levels during summer months and droughts. this volatility would make an effluent dump into the goulais highly risky and a threat to local life, including business and the environment our drinking water, and our grandchildren.

Searchmont Resort has taken and taken and taken from the land for decades; logging for development, harvesting excess amounts of water from the river for snow making, and when spring comes, all of the chemicals used for snowmaking leeches back into the water ways and soil. They have given nothing back to the land they benefit from. Reciprocity is important if we plan on living in harmony with the earth for the decades to come. What can Searchmont Resort give back to the earth in return for all she gives to them.

All of my comments are based on the information provided in the Design Brief (including the Assimilative Capacity Study), publicly available ERO postings, and provincial policies and guidelines. All references below are taken directly from the documents provided to the public.

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.

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

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 use