I am submitting these comments in opposition to Surge Copper Corp.'s proposed Berg Copper Project, an open-pit copper-molybdenum mine southwest of Houston, British Columbia.

I am writing as a concerned northern B.C. resident and community planning professional who believes that responsible economic development must consider the long-term health of our communities, natural environments and future generations.

I recognize the importance of copper in the transition to a lower-carbon economy and the need for economic opportunities in rural and remote communities. However, I do not believe that every mineral deposit needs to become a mine, particularly when development threatens intact watersheds and the natural systems that sustain us.

My opposition is based on the following concerns.

1. Protection of the Nanika-Kidprice Watershed

The Nanika-Kidprice area is an ecologically important landscape with significant conservation, recreational and cultural values. Its lakes, rivers and surrounding forests support fish and wildlife populations and contribute to the health of the broader Bulkley watershed.

The proposed mine, tailings and waste storage facilities, access infrastructure and transmission line would introduce a substantial industrial footprint into this relatively intact landscape.

I am particularly concerned about long-term contamination from mine waste, acid rock drainage, seepage or failure of engineered storage facilities. The history of northwest B.C. mining, including Equity Silver and Granisle, demonstrates that environmental liabilities can remain for generations.

We should not be creating additional long-term liabilities in watersheds that currently provide significant ecological and community value.

2. Climate Change and Vulnerable Fish-Bearing Watersheds

Climate change is already affecting northern B.C.'s mountain watersheds. Glacier retreat, declining snowpack, changing seasonal flows and increasing summer temperatures are placing additional pressure on cold-water ecosystems and salmon habitat.

The Nanika River system supports important fish populations, including sockeye salmon. The broader Bulkley watershed also includes the Morice River (Widzin Kwa), where glacier- and snowmelt-influenced tributaries provide important cold-water habitat.

Although these are distinct river systems, their shared watershed context reinforces the need to consider cumulative impacts. We cannot assess this project in isolation from the changing conditions affecting northern B.C.'s rivers.

The assessment must demonstrate how water withdrawals, mine waste management, changes to hydrology and potential contamination will affect fish habitat and aquatic ecosystems under future climate conditions.

Our rivers are natural food systems that sustain wildlife, cultural practices, recreation and local communities. Protecting their long-term health should be a priority.

3. Limited Long-Term Economic Benefits for Northern Communities

Northern B.C. has experienced generations of boom-and-bust resource development. Despite the wealth generated through resource extraction, communities such as Houston and Smithers continue to face challenges with affordable housing, infrastructure, access to services and economic diversification.

Large remote mining operations often rely on specialized rotational and fly-in/fly-out workforces. The number of advertised jobs does not necessarily reflect the number of permanent positions filled by local residents or the lasting economic benefits retained in surrounding communities.

The project assessment should clearly identify how many jobs are expected to go to existing northern residents, where workers will reside, and what lasting investments will be made in local communities.

We must also consider the social impacts of large, predominantly male temporary workforces, including pressures on housing and services and potential safety concerns for women, Indigenous women and girls, and other marginalized populations. These impacts require meaningful gender-based and social assessment.

Economic development should build stronger communities, not simply bring temporary workers into a region to extract resources before moving on.

4. Existing Mineral Resources and Alternatives to New Industrial Development

Northern B.C. already has substantial identified copper resources and a history of mining development. Huckleberry Mine, near Houston, has been on care and maintenance since 2016. Other significant copper-bearing projects include Morrison, Galore Creek, Schaft Creek and KSM, which are at different stages of development.

Before opening another intact watershed to industrial development, we should be asking whether there are better opportunities to invest in existing mine sites and previously disturbed landscapes.

Government, First Nations, industry and investors should be working together to support responsible resource recovery, mine reclamation, remediation of historical liabilities and economic opportunities within existing industrial footprints.

This is not an argument for extending every mine indefinitely. It is a call for a more thoughtful regional approach that considers the cumulative environmental costs of developing multiple projects and prioritizes less damaging alternatives.

I do not believe the Berg Project has demonstrated why its proposed development in an intact watershed is necessary or preferable to these alternatives.

5. A Different Approach to Sustainable Community Development

As someone with a background in community planning, I believe economic development should be measured by more than construction spending, mineral production and temporary employment.

Healthy communities require affordable housing, reliable infrastructure, local employment, accessible services and opportunities for future generations. They also depend on clean water, healthy rivers, fish and wildlife, and intact natural landscapes.

Slow, thoughtful and sustainable community development is not an argument against economic progress. It is an acknowledgement that growth must be appropriate to the capacity of the community and the environment that supports it.

The economic benefits of a mine may be temporary, but the environmental and social consequences can last for generations. We need to be more deliberate about which landscapes we industrialize and which natural assets we protect.

6. Federal Oversight and Canada's National Interest

I do not support B.C.'s request to substitute its provincial assessment process for the federal impact assessment of the Berg Copper Project. I believe the federal government must retain a meaningful and substantive role in leading and overseeing the assessment of a project of this scale and significance.

Copper is an important strategic resource for Canada and the global transition to a lower-carbon economy. Decisions about the development of these resources should not be considered solely through a provincial economic development lens. They should also reflect Canada's broader interests in responsible mineral development, critical mineral supply chains, environmental protection and the long-term sustainability of our natural resources.

The potential impacts of a project of this scale extend beyond local and provincial boundaries. Federal responsibilities relating to fish and fish habitat, aquatic species at risk, Indigenous rights, migratory birds and other matters of federal jurisdiction require meaningful federal assessment, expertise and accountability.

I believe a nationally significant resource development decision warrants national oversight. The federal government has a responsibility to consider how mineral development aligns with Canada's long-term economic and environmental objectives, rather than focusing primarily on the provincial benefits and priorities associated with an individual project.

A coordinated federal-provincial assessment makes sense and can avoid unnecessary duplication. However, coordination should not mean transferring primary assessment responsibility to the province and reducing the federal role.

I want to see the federal Impact Assessment Agency of Canada retain a substantive role in the assessment, including direct oversight, independent federal expertise, meaningful consideration of cumulative and transboundary impacts, and transparent federal decision-making.

I believe this is particularly important when considering the long-term consequences of industrial development in sensitive watersheds and the rights and interests of Indigenous Peoples.

7. Recommendations to the Environmental Assessment Authorities

I ask the Impact Assessment Agency of Canada and the B.C. Environmental Assessment Office to:

1. Fully consider the no-project alternative and the environmental, social and economic consequences of not proceeding with the Berg Project.

2. Assess cumulative impacts on the Nanika-Kidprice watershed and broader Bulkley River system, including historical mining liabilities and climate change.

3. Require rigorous assessment of water quality, tailings and waste storage, acid rock drainage, fish habitat and long-term closure responsibilities.

4. Require transparent evidence of local employment benefits, community infrastructure demands and the social impacts of temporary industrial workforces.

5. Include meaningful assessment of gender-based violence risks and impacts on Indigenous women, girls and marginalized populations.

6. Evaluate alternatives that prioritize existing mine sites, previously disturbed industrial areas, responsible resource recovery and environmental remediation.

7. Reject the proposed substitution of the federal assessment process and retain meaningful federal leadership, oversight and independent assessment of the project's impacts within federal jurisdiction.

Conclusion

I oppose the Berg Copper Project because I do not believe its anticipated economic benefits justify the environmental and social risks associated with developing this particular landscape.

I want northern B.C. to have a prosperous future, with opportunities for young people, affordable places to live and communities that can support families for generations. But prosperity should not come at the expense of the rivers, watersheds and natural food systems that sustain us.

We have an opportunity to take a different approach to resource development: one that prioritizes responsible investment in existing industrial sites, environmental restoration, meaningful local economic benefits and the protection of intact watersheds.

Not every mineral deposit needs to become a mine, and not every economic opportunity represents good community development.

I oppose the development of the Berg Copper Project and do not support transferring the federal assessment process to the Province of British Columbia. Canada must retain a meaningful role in assessing projects of national significance and ensuring that our mineral resources are developed in a manner that respects our collective environmental responsibilities and the interests of future generations.

Our responsibility is not simply to extract the resources available to us today, but to ensure that future generations inherit clean water, healthy rivers, thriving communities and a natural environment that can continue to sustain them.

For these reasons, I ask that the Berg Copper Project not proceed.

Thank you for considering my submission.