To Whom It May Concern , I…

To Whom It May Concern
,

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.

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 A2 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 used? Were samples collected
consistently (same location, time of day, conditions)? conditions)? How does taking multiple
samples during summer compensate for missing winter and multiyear data?

Conclusion:
The dataset is too limited to support a major surfacewater 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?

3. 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 0196965), 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 lowflow 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.
4. 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 or

5. Effluent Limits in ACS Appear Extremely Low

Table 6.1 of the ACS recommends unusually low effluent limits… is this normal?
• Total Phosphorus (TP)
• Total Ammonia Nitrogen (TAN)

6. Species at Risk (SAR) and Environmental Impact Statement (EIS) Are Missing

Section 4.1.3 of the Design Brief states that a new SAR study and EIS are in progress
and will be attached as Appendix H when complete.

However, these documents were not provided during the ERO comment period.
The 2019 EIS (for the adjacent snowmaking pond) identified potential presence of:
• Barn Swallow
• Bobolink
• Canada Warbler
• Chimney Swift
• Eastern Meadowlark
• Wood Thrush
• Little Brown Bat
• Northern Longeared Bat
• Eastern Smallfooted Bat
• Lake Sturgeon
• Wood Turtle

Significant Wildlife Habitat identified:
• Candidate Turtle Wintering Area
• Candidate Amphibian Breeding Area

Migratory bird nesting windows (C4 Zone):
• Forested: April 14–August 28
• Open: April 19–August 28
• Wetlands: April 14–August 17

Conclusion:
Without the updated EIS and SAR study, the public cannot meaningfully assess
ecological impacts or compliance with the Endangered Species Act, MBCA, or FWCA.

7. Dissolved Oxygen (DO) Impacts on Sensitive Species Not Assessed
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)

Restricted Activity Timing Windows (Section 4.1.2):

• Lake Sturgeon: May 1–June 20
• Walleye: April 1–June 20
• Brook Trout: September 1–June 15

The design brief says: The Ministry of Natural Resources and Forestry (MNRF) will be
consulted to confirm whether permits or approvals are required. In section 6.2 it states
when confirming project submission requirements for the MNRF it was indicated that the
approved ECA application and approval of effluent before any work could be completed.

Conclusion:
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
• Climatedriven low flows
• Resort expansion
• Snowmaking return flows
• Existing contaminants
• Recreational use
• SAR habitat sensitivity
• Downstream impacts to Lake Superior

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

9. Community Engagement Was Insufficient

The public was not provided:
• The updated EIS
• The SAR study
• A public meeting or consultation session with design brief
• Clear explanations of risks or alternatives and mitigation strategies

Meaningful consultation is a core principle of the Environmental Bill of Rights.
Without access to key documents, the public cannot provide informed comment.

10. Goulais Bay Issued Boil Water Advisory – May of 2025

The Goulais River flows into Goulais Bay which was issued an advisory this past year
after the detection of elevated turbidity levels at the community waste treatment facility.
Which can be found on Soo Today. It’s noted in the article that it’s a common
occurrence during that time of year due to natural discharge from the Goulais River.

If natural discharge from the Goulais River is already contributing to the need for boil
water advisories downstream in Goulais Bay – the introduction of wastewater to the
Goulais river will have serious consequences for Goulais Bay.

Whose water quality was not assessed in the water quality program conducted by the
proponent.

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. Multiyear monitoring (including winter and lowflow 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, 3 rd 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.

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.