I am submitting this comment…

I am submitting this comment in response to the proposed Environmental Compliance Approval (ECA) for the Searchmont Ski Resort Wastewater Treatment Plant (WWTP).

After reviewing the design brief and supporting materials, I have significant concerns regarding the lack of completed Species at Risk (SAR) assessment, the absence of analysis on the Department of Fisheries and Oceans (DFO) Pathways of Effects, and the incomplete evaluation of dissolved oxygen (DO) impacts on sensitive aquatic species, including Lake Sturgeon.

💦 The SAR and EIS Assessments Are Incomplete

The design brief states that Blue Heron Environmental is still preparing the updated Species at Risk (SAR) study and Environmental Impact Statement (EIS). These documents are not included in the submission and therefore cannot be reviewed by the public or regulators.

🚩 This is a critical gap. A previous 2019 EIS for a nearby project already identified numerous SAR potentially present in the project area, including:

🐦 Barn Swallow
🐦 Bobolink
🐦Canada Warbler
🐦Chimney Swift
🐦Eastern Meadowlark
🐦Wood Thrush
🐦Little Brown Bat
🦇Northern Long‑eared Bat
🦇 Eastern Small‑footed Bat
🐢Wood Turtle
🦈 Lake Sturgeon
🌍 The Ministry of Natural Resources and Forestry (MNRF) also identified two candidate Significant Wildlife Habitats: a Turtle Wintering Area and an Amphibian Breeding Area.

🚩 Despite this, the proponent has submitted an ECA application before the SAR and EIS was completed. This prevents a meaningful assessment of ecological risk. And also did not allow the public fair opportunity to share thoughts and comments these.
Remember... The whole purpose of the Environmental Registry of Ontario to is allow the public the opportunity to comment on actions they take that can affect the environment

💦 The Design Brief Acknowledges Six DFO Pathways of Effects — But Provides No Analysis on SAR
The design brief acknowledges that the DFO (Departmet of Fisheries and Oceans) identifies six major pathways through which effluent can affect fish and aquatic life:
➡️ Changes in dissolved oxygen
➡️ Changes in nutrient concentrations
➡️ Pathogens and disease vectors
➡️ Changes in water temperature
➡️ Disruption of migration patterns
➡️ Changes in contaminant concentrations

🚩 The design brief lists these pathways but does not evaluate how any of them may affect the (SAR) Species at Risk known to inhabit the Goulais River.

🚩 This is a major omission. The proponent asserts that impacts will be “minimal to none,” based on results of the ACS (Assimilative Capacity Study) but it doesn't detail how changes to water quality can effect SAR (Species at a risk)

💦 Dissolved Oxygen (DO) Impacts
The design brief states:

➡️ DO at the discharge point will depend on effluent temperature and effluent DO
➡️ Downstream DO may decline further due to biological oxygen demand (BOD₅)
➡️ Warm‑season DO in the river can be as low as 8.3–8.4 mg/L

🚩 (BOD₅) is characterized as domestic waste but nearly 50% of the proposed output once full expansion happens will likely be commercial grade effluent
🚩This is extremely concerning because it tells us that DO is dependent on multiple factors that can and will fluctuate ....
🚩 Some which the WWTP has no control over... Like the temperature and DO content of the river when the waste enters the water.

💦 WHY DOES THIS MATTER?
Let's look at an example with Lake Sturgeon.
A species at risk that relies on the Goulais River for spawning, habitat and juvenile survival.a species that has existed for 150 million years and is endangered.
🦈Lake Sturgeon eggs and larvae require high, stable DO levels, typically above ~8 mg/L.

💥 The design brief shows:
Warm‑season DO values of 8.3–8.4 mg/L mean the river is already near the lower limit of what this threatened species can tolerate.

Because the WWTP effluent can:
➡️ enter the river at higher temperatures,
➡️ have variable DO levels, and
➡️ further reduce DO downstream through BOD consumption.....
..... even small DO declines could push levels below the threshold needed for Lake Sturgeon survival.

💥 Yet the design brief provides no analysis of:
➡️ how much DO may drop at or below the discharge point,
➡️ how these changes align with Lake Sturgeon spawning periods, or
➡️ whether the effluent could create localized low‑oxygen zones harmful to eggs and larvae.

🚩 This is a critical gap in the impact assessment.

💦 The Proponent Claims “No Impact”

Throughout the design brief, the proponent repeatedly states that the WWTP is “not expected to change water quality” or will have “minimal to negligible impact.”

However:
➡️ The SAR assessment is incomplete
➡️ The EIS is incomplete
➡️ No analysis is provided for the six DFO pathways
➡️ DO impacts are acknowledged but not evaluated
➡️ No assessment is provided for how these changes affect SAR such as Lake Sturgeon, Walleye, or Brook Trout

🚩 A conclusion of “no impact” is based on water quality assessment from the Assimilative Capacity Study... But there is no Species at risk mitigation strategies for Lake Sturgeon available yet. The design brief should include risk mitigation for all SAR which would require the EIS and SAR to be finished
.
💦 Request to the Ministry
Given the incomplete nature of the submission and the absence of required ecological impact analysis, we can respectfully request that the Ministry:

➡️ Deem the application incomplete until the full SAR study and EIS are submitted or at least extend the deadline for public consultation until the EIS and SAR are available and we have the opportunity to review them and sharing thoughts and comments

➡️ Require the proponent to provide quantitative analysis of all six DFO Pathways of Effects on each SAR

➡️ Require dissolved oxygen modelling that includes:
- effluent temperature certainty
- effluent DO certainty
- BOD‑related downstream DO depletion
- seasonal low‑flow conditions
- affects of Lake Sturgeon and other SAR

🐢 Conclusion 🐢

The design brief recognizes that Goulais River supports one of the most diverse fish communities in northern Ontario, including a threatened Lake Sturgeon population.

Approving an ECA without a completed SAR assessment, without analysis of DFO pathways, and without evidence‑based evaluation of DO impacts would be premature and inconsistent with the precautionary approach required under Ontario’s environmental legislation.