To Whom It May Concern:

Northern Health appreciates the opportunity to provide comments on the Initial Project Description (IPD) for the proposed Berg Copper Project submitted by Surge Copper Corp. Northern Health previously participated in the review of the Project through the provincial environmental assessment process led by the BC Environmental Assessment Office (EAO). The comments provided below are based on, and updated from, comments previously submitted through that process and reflect Northern Health's review of the current IPD.

Northern Health's mandate includes protecting and promoting population health and ensuring that potential impacts to health services, community well-being, and environmental determinants of health are appropriately considered throughout all phases of project development. Based on our review of the IPD, Northern Health provides the following comments and recommendations for consideration during the federal impact assessment process.

1. Transportation and Project Access

The IPD indicates that the Project is located approximately 80 km southwest of Houston and is currently accessed by approximately 116 km of existing forest service roads, with a new 17 km mine access road under development.

Northern Health requests additional information regarding:

• The estimated travel time between Houston and the mine site once construction of the 17 km access road is complete.
• Existing and anticipated traffic conditions along the Morice Forest Service Road, including traffic associated with forestry activities, the Huckleberry Mine, resource exploration projects, and other industrial users.
• Potential implications of other industrial traffic volumes on worker transportation, public safety, and emergency response.

2. Recreation and Land Use

Northern Health notes that several recreation sites occur within proximity of the Project Area. Figure 3.2-3 does not identify the recreation sites listed in Table 3.2-3, limiting the reader's ability to understand their proximity and relationship to Project components.

Northern Health recommends that:

• Figure 3.2-3 be revised to identify the recreation sites listed in Table 3.2-3.
• The proponent clarify whether the distances reported in Table 3.2-3 are measured from recreation sites to the Project Area or to the proposed transmission line corridor.

3. Existing Camps and Infrastructure

Section 3.5 references the existing Berg Camp and Camp South (Sibola Camp); however, their locations are not clearly described.

Northern Health requests that the proponent provide:

• The locations of Berg Camp and Camp South (Sibola Camp).
• Their relationship to proposed Project components.
• Any plans for continued use, expansion, replacement, or decommissioning.

4. Existing Forest Service Roads

The IPD excludes existing forest service roads from the assessment on the basis that they are not owned or operated by the proponent.

Northern Health recommends reconsideration of this approach. Existing forest service roads are expected to be used to transport workers, supplies, equipment, and concentrate and therefore represent a pathway through which project-related effects may occur. Potential effects include:

• Motor vehicle accidents and associated injuries.
• Increased demands on emergency response and health services.
• Fuel and hazardous material spills affecting water resources.
• Increased public and worker safety risks.

If these routes are excluded from assessment, Northern Health requests a more robust rationale supported by a project-specific risk assessment.

5. Workforce and Community Health

The IPD identifies a peak construction workforce of approximately 1,060 workers and a peak operations workforce of approximately 783 workers. An onsite accommodation facility is proposed to house approximately 550 personnel.

To support assessment of potential effects on communities and regional health systems, Northern Health requests:

• Phase-specific workforce projections for construction and operations.
• Workforce rotation schedules.
• Worker demographic information.
• Information regarding anticipated travel routes, stopovers, and regional accommodation requirements.
• Assessment of potential demands on healthcare, emergency response, housing, and community services.

6. Industrial Camp and Public Health Requirements

Northern Health recommends revisions to Table 5.4-1 to clarify that drinking water and public health approvals are administered through Northern Health under applicable legislation.

Northern Health recommends early engagement with Northern Health Environmental Health regarding:

• Potable water source assessments.
• Water treatment design.
• Wastewater management.
• Food service facilities.
• Industrial camp requirements.
• Communicable disease prevention and management.

7. Air Quality and Human Health Risk Assessment

Northern Health notes that limited information is provided regarding baseline air quality monitoring and future monitoring programs. Current baseline work appears to rely primarily on desktop assessment activities.

Northern Health recommends that the proponent:

• Develop a comprehensive onsite air quality monitoring program.
• Include monitoring for PM₂.₅, PM₁₀, NO₂, and other relevant contaminants.
• Identify representative local sampling locations and monitoring stations.
• Incorporate monitoring results into the Human Health Risk Assessment (HHRA).
• Apply the most health-protective standards available when evaluating non-threshold pollutants, including PM₂.₅ and NO₂.
• Provide mapped monitoring locations and sampling methodologies.

Northern Health also requests clarification regarding the absence of a dedicated air quality subsection within Section 8.1 of the IPD.

8. Health and Medical Services Planning

Given the remote location of the Project, Northern Health requests additional information regarding:

• Emergency medical response capacity.
• Medevac arrangements.
• Transportation pathways and receiving healthcare facilities.
• Onsite medical capabilities and clinical staffing.
• Telehealth services.
• Mutual aid agreements and emergency response partnerships.

Northern Health continues to support the development of:

• A Health and Medical Services Plan (HMSP); and
• A Communicable Disease Management Plan (CDMP).

Should the Project proceed, Northern Health recommends that both plans be considered as future assessment and approval requirements. The plans should describe onsite clinical services, staffing levels, telehealth capability, medevac arrangements, mental health and substance use supports, communicable disease protocols, and coordination with Northern Health, BC Emergency Health Services, and Health Emergency Management BC.

9. Camp Design, Incineration and Waste Management

Figure 4.1-1 identifies an onsite incinerator near the proposed accommodation facility.

Northern Health recommends that future submissions:

• Identify the distance between the incinerator and worker accommodations.
• Demonstrate health-protective setbacks and consideration of prevailing wind conditions.
• Describe proposed emission controls and monitoring programs.
• Characterize ash handling and disposal practices.
• Clarify anticipated approvals and authorizations associated with waste management infrastructure.

Northern Health further recommends consideration of enhanced indoor air filtration systems, including MERV-13 or HEPA filtration, within worker accommodations to reduce exposure to project-related particulate matter and wildfire smoke.

10. Wildfire Risk

Northern Health recommends that wildfire be evaluated as a stand-alone hazard rather than solely under climate change considerations.

Assessment should consider:

• Smoke exposure and associated health risks.
• Emergency evacuation planning.
• Infrastructure vulnerability.
• Impacts on worker safety and health.
• Demands on health and emergency response systems.

11. Cumulative Effects Assessment

Northern Health supports the inclusion of regional industrial emission sources in the cumulative effects assessment. Given the relative proximity of the Project to the Kitimat airshed, Northern Health recommends consideration of cumulative emissions associated with:

• Rio Tinto;
• LNG Canada; and
• Cedar LNG.

Assessment of cumulative air quality and human health effects should consider regional atmospheric contributions in combination with Project emissions.

Closing

Northern Health appreciates the opportunity to provide input during the Early Engagement phase of the impact assessment process. We look forward to continued engagement as the Project advances and additional technical information becomes available. The requested information will assist Northern Health in evaluating potential effects on health services, environmental health, community well-being, and public health throughout the life of the Project.

Sincerely,

Anna Huang
Technical Advisor, Office of Health and Resource Development
Northern Health Authority