Hello Trigon Pacific Review Team,

Northern Health appreciates the opportunity to provide input on the proposed Trigon Pacific LPG Project on Ridley Island near Prince Rupert, British Columbia. These comments support the Impact Assessment process and reflect Northern Health’s interest in protecting population health, supporting healthy communities, and minimizing project impacts on healthcare and community services.

Based on the information available to date, Northern Health offers the following comments and recommendations.

1. Human Health Risk Assessment

Although the project is proposed within an existing industrial footprint on a brownfield site, Northern Health recommends that the proponent complete a Human Health Risk Assessment (HHRA).

The HHRA should consider:

• Existing site contamination and historical land uses;
• Potential exposure pathways during construction, including soil disturbance, dust generation, and contaminated material handling;
• Potential risks to workers, contractors, Indigenous land users, and nearby communities; and
• Potential impacts on surface water, groundwater, marine environments, and traditional food harvesting pathways, where applicable.

The assessment should also identify any risk management measures and long-term monitoring commitments.

The HHRA should be guided by the British Columbia Guidance for Prospective Human Health Risk Assessment Version 2.0 (April 2022), given that the project is located in British Columbia.

2. Workforce Accommodation

The project description indicates that a substantial portion of the workforce may be sourced locally, while non-local workers may be accommodated in a third-party workforce camp or other temporary accommodations. Northern Health supports the use of workforce accommodation as a means of mitigating potential social impacts associated with an influx of non-local workers, while also reducing pressure on local housing and community infrastructure.

To better evaluate potential impacts, additional information is requested regarding:

• More detailed estimates of construction workforce numbers by year;
• Camp location, capacity, and duration;
• Camp ownership and operating arrangements; and
• Transportation between the camp and project site.

Northern Health notes that the B.C. Industrial Camps Regulation may apply to the third-party camp associated with the project. Northern Health recommends that Trigon select a camp with consideration for communicable disease prevention, provision of onsite health and medical services, and compliance with applicable regulatory requirements.

3. Mitigating Impacts on Health and Community Services

Northern Health acknowledges the proponent’s commitment to work with local health and service providers. Northern Health recommends formalizing this commitment through ongoing engagement with Northern Health throughout construction and operations. The best point of contact for Northern Health is the Office of Health and Resource Development at resource.development@northernhealth.ca (mailto:resource.development@northernhealth.ca).

Potential mitigation measures should include:

• Appropriately staffed on-site medical services;
• Mental health and substance use supports;
• Overdose prevention and emergency responses;
• Monitoring of project-related health service utilization and implementation of adaptive management measures;
• Regular communication with Northern Health regarding workforce levels, health service utilization, and emerging issues.

Northern Health recommends that the proponent develop a Health and Medical Services Plan that incorporates the measures outlined above.

Northern Health also notes that the Ridley Island Export Expansion Project (REEF) provides a relevant regional example where on-site medical services and workforce management measures have helped minimize project-related demand on local healthcare resources. Northern Health encourages the proponent to engage with REEF and consider a similar approach. The REEF 2025 Socio-Economic Engagement Summary Report on the EPIC website may also be a good starting point for Trigon to review measures that have been implemented and monitored.

4. Clarification of Healthcare Services

Northern Health notes that Section 5.4.2 of the Initial Project Description appears to classify Prince Rupert Regional Hospital as a primary healthcare service. This characterization should be corrected. Prince Rupert Regional Hospital provides acute care, emergency, inpatient, diagnostic, and specialist services. Primary healthcare is generally delivered through community-based settings such as family physician clinics. Future project documents should clearly distinguish between primary care services and hospital-based acute care services.

5. Missing Potential Adverse Effects in Table 7-1

Northern Health notes that Table 7-1 identifies employment creation as a project effect during both construction and operations; however, potential adverse social effects are not identified. Potential impacts on community infrastructure and services, including healthcare, housing, emergency response, and other community services, should be included as potential project effects and assessed in the Impact Assessment. Northern Health recommends that the proponent evaluate these potential adverse effects and identify appropriate mitigation measures. The recommendations outlined in Comments 2 and 3 of this submission constitute potential mitigation measures that could reduce project-related social and health impacts.

6. Representative Baseline Data Collection

Northern Health recommends that the proponent select representative monitoring locations and collect sufficient baseline data to support the environmental assessment and predictive modelling. For example, air quality monitoring locations should be selected to adequately characterize conditions relevant to the project area and inform air dispersion modelling. Northern Health has observed cases where proponents relied on data from existing community monitoring stations that were not representative of project conditions, resulting in concerns regarding the reliability of air quality assessments and associated conclusions. The same principle should be applied to other environmental value components, such as noise. Baseline data collection should be representative, scientifically defensible, and sufficient to support impact predictions and mitigation planning.

Conclusion

Northern Health recognizes that the project is proposed within an existing industrial area and that workforce accommodation is being considered to reduce community impacts. However, additional information is required to fully assess potential effects on population health, healthcare services, community infrastructure, and community well-being.

Northern Health recommends that the Impact Assessment include:

1. A Human Health Risk Assessment for the brownfield site;
2. Detailed workforce accommodation strategy;
3. A Health and Medical Services Plan;
4. Assessment of potential adverse effects on community infrastructure and services; and
5. Commitments to ongoing monitoring, reporting, and engagement with Northern Health and local service providers.

Thank you for the opportunity to provide comments. Northern Health looks forward to continued engagement as the project advances through the Impact Assessment process.