The assimilative capacity…

The assimilative capacity study have never been approved in the ECA Pre-Submission review. Just based on the fact that Policy 2 for TP was already met downstream. It's also not clear why the data from the monitoring program was accepted when it completely ignores the condition of the river beyond where the proponent chose to set their downstream sampling location.

MECP please honor your own standards and policies, this is not OK. Policy is met already with no waste in the mix. Reject this application and require a new 2-3 year data set with a proper downstream location.

The Goulais River Is Already Showing Signs of Stress Before Any Discharge....

The ACS monitoring data demonstrates that the Goulais River is not in a condition that can safely or consistently accept additional nutrient or contaminant loading.

Total Phosphorus (TP)....Highest upstream concentration: 0.044 mg/L.....Highest downstream concentration: 0.047 mg/L......5 of 20 downstream samples exceeded the Provincial Water Quality Objective (PWQO) of 0.030 mg/L (Appendix A‑2 of the ACS).

This means 25% of downstream samples exceeded the PWQO before any wastewater discharge exists.

The designated downstream monitoring point is at the Highway 17 crossing, which is already at or above the PWQO. There is no information on TP conditions further downstream, where cumulative impacts would be even more relevant.

• Recent Boil Water Advisories
Goulais Bay has experienced multiple boil water advisories, including one in May 2025, attributed to natural discharge from the Goulais River. This indicates existing water quality vulnerability.

• Bacterial Contamination
The ACS documents spikes in fecal bacteria during baseline monitoring, further demonstrating that the river is already under stress.

• Low‑Flow Conditions
The Design Brief acknowledges that the Goulais River experiences very low flows in late summer, a period when the river is most vulnerable to nutrient loading and oxygen depletion.

• Data Gaps
The ACS includes limited winter data, despite winter being the most sensitive period for dissolved oxygen (DO) and ammonia toxicity. Without adequate winter sampling, the assessment cannot fully characterize risk.

Conclusion
The Goulais River is already showing clear signs of environmental stress. Under Ontario’s Policy 2, when a waterbody is at or above the PWQO, “no further degradation is permitted.”

Given the phosphorus exceedances documented in the ACS, the river’s assimilative capacity for phosphorus is effectively zero.

REJECT THIS ECA APPLICATION. You have enough basis with Policy 2 for TP alone.