ENVIRONMENTAL ASSESSMENT

PROPOSED REVISION AND RENEWAL

OF PERMIT WA-0007D

John Henry No. 1 Coal Mine

Pacific Coast Coal Company
King County, Washington

Prepared by
The Office of Surface Mining
Reclamation and Enforcement
Western Region
Denver, Colorado

September 2017

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Environmental Assessment John Henry No. 1 Mine
 TABLE OF CONTENTS

1.0 DESCRIPTION OF THE PROJECT AND PROPOSED ACTION ........................... 1

1.1 Background Information ............................................................................................. 4

1.2 Purpose and Need ..................................................................................................... 7

1.3 Proposed Action Alternative ....................................................................................... 8

1.3.1 Mining Method ............................................................................................. 9

1.3.2 Blasting ........................................................................................................ 9

1.3.3 Access and haul roads................................................................................. 9

1.3.4 Utilities ......................................................................................................... 9

1.3.5 Mine Facilities ............................................................................................ 10

1.3.6 Ponds, Impoundments, Diversions ............................................................ 10

1.3.7 Water Source ............................................................................................. 11

1.3.8 Hazardous Materials and Solid Waste ....................................................... 11

1.3.9 Mine Personnel .......................................................................................... 11

1.3.10 Coal Destinations....................................................................................... 11

1.3.11 Transportation............................................................................................ 12

1.3.12 Reclamation ............................................................................................... 12

1.4 No Action Alternative................................................................................................ 12

1.5 Other Alternatives Considered But Not Evaluated ................................................... 12

2.0 PUBLIC COMMENTS AND IDENTIFIED ISSUES ............................................... 14

3.0 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES ........ 16

3.1 Regulatory Framework............................................................................................. 17

3.2 Topography .............................................................................................................. 18

3.2.1 Affected Environment................................................................................. 18

3.2.2 Environmental Consequences ................................................................... 19

3.3 Geology/Paleontology .............................................................................................. 20

3.3.1 Affected Environment................................................................................. 20

3.3.2 Environmental Consequences ................................................................... 21

3.4 Water Resources / Hydrology .................................................................................. 22

3.4.1 Surface Water ............................................................................................ 22

3.4.2 Groundwater .............................................................................................. 32

3.5 Climate and Climate Change ................................................................................... 37

3.5.1 Affected Environment................................................................................. 37

3.5.2 Environmental Consequences ................................................................... 37

3.6 Air Quality................................................................................................................. 46

3.6.1 Affected Environment................................................................................. 46

3.6.2 Environmental Consequences ................................................................... 58

3.7 Soils ......................................................................................................................... 69

3.7.1 Affected Environment................................................................................. 69

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Environmental Assessment John Henry No. 1 Mine
 3.7.2 Environmental Consequences ................................................................... 70

3.8 Vegetation ................................................................................................................ 72

3.8.1 Affected Environment................................................................................. 72

3.8.2 Environmental Consequences ................................................................... 81

3.9 Wetlands and Riparian Zones .................................................................................. 83

3.9.1 Affected Environment................................................................................. 83

3.9.2 Environmental Consequences ................................................................... 87

3.10 Fish and Wildlife Resources ..................................................................................... 88

3.10.1 Affected Environment................................................................................. 88

3.10.2 Environmental Consequences ................................................................... 97

3.11 Land Use................................................................................................................ 100

3.11.1 Affected Environment............................................................................... 100

3.11.2 Environmental Consequences ................................................................. 102

3.12 Socioeconomics and Environmental Justice.......................................................... 102

3.12.1 Socioeconomics ....................................................................................... 103

3.12.2 Environmental Justice .............................................................................. 106

3.13 Transportation ........................................................................................................ 107

3.13.1 Affected Environment............................................................................... 107

3.13.2 Environmental Consequences ................................................................. 111

3.14 Recreation.............................................................................................................. 116

3.14.1 Affected Environment............................................................................... 116

3.14.2 Environmental Consequences ................................................................. 116

3.15 Noise and Vibration................................................................................................ 117

3.15.1 Affected Environment............................................................................... 117

3.15.2 Environmental Consequences ................................................................. 118

3.16 Visual Resources ................................................................................................... 120

3.16.1 Affected Environment............................................................................... 120

3.16.2 Environmental Consequences ................................................................. 121

3.17 Cultural Resources................................................................................................. 121

3.17.1 Affected Environment............................................................................... 121

3.17.2 Environmental Consequences ................................................................. 122

3.18 Human Health and Safety ...................................................................................... 122

3.18.1 Affected Environment............................................................................... 122

3.18.2 Environmental Consequences ................................................................. 123

3.19 Short Term Uses and Long Term Productivity ....................................................... 126

3.19.1 Local Area................................................................................................ 126

3.19.2 Greenhouse Gas Emissions .................................................................... 126

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Environmental Assessment John Henry No. 1 Mine
 3.20 Irreversible or Irretrievable Commitments of Resources ........................................ 127

3.21 Summary of Impacts to the Affected Environment Under the Proposed

Action Alternative ................................................................................................... 127

4.0 Cumulative Impacts ............................................................................................ 133

4.1 Cumulative Impact Assessment ............................................................................. 137

4.1.1 Surface Water .......................................................................................... 137

4.1.2 Air Quality ................................................................................................ 141

4.1.3 Fish and Wildlife....................................................................................... 143

4.1.4 Vegetation................................................................................................ 144

4.1.5 Wetlands and Riparian Zones .................................................................. 145

4.1.6 Special Status Species ............................................................................ 146

4.1.7 Land Use.................................................................................................. 147

4.1.8 Socioeconomics and Environmental Justice............................................ 148

4.1.9 Transportation.......................................................................................... 150

4.1.10 Visual ....................................................................................................... 151

5.0 PERSONS / AGENCIES CONTACTED ............................................................. 153

5.1 OSMRE Western Region Interdisciplinary Review ................................................ 153

5.2 Pacific Coast Coal Company ................................................................................. 153

5.3 Interagency Consultation ....................................................................................... 153

5.4 Tribal Contacts ....................................................................................................... 153

6.0 REFERENCES ................................................................................................... 154

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Environmental Assessment John Henry No. 1 Mine
 LIST OF FIGURES

Figure 1. Vicinity Map of the John Henry No. 1 Mine in Black Diamond, Washington
Figure 2. Mine Plan Map
Figure 3. John Henry No. 1 Mine Timeline
Figure 4. Topography of John Henry No. 1 Mine
Figure 5. John Henry No. 1 Mine Surface Water Control System
Figure 6. OSMRE Water Monitoring Locations
Figure 7. Regional Drainage and Cumulative Hydrologic Impact Area
Figure 8. Class I Areas
Figure 9. Total Mass Budgets for Mount Rainier National Park (2015)
Figure 10. Visibility on Haziest and Clearest Days for Mount Rainier National Park (2015)
Figure 11. Coal Processing Flowchart
Figure 12. Vegetation and Reclamation
Figure 13. Post-Mining Vegetation & Reclamation Map
Figure 14. Potential Roadways Impacted by Truck Traffic
Figure 15. Cumulative Impacts Study Area
Figure 16. Phosphorus Loading TMDL Model

LIST OF TABLES
Table 1. Chemical and Physical Test Requirements for External Fill Approval
Table 2. Environmental Resource Areas Addressed
Table 3. NPDES Permit Effluent Limitations
Table 4. Baseline Surface Water Quality Data for the John Henry No. 1 Mine
Table 5. Triggering Limits for Additional Ground Water Monitoring (NPDES Permit)
Table 6. Baseline Groundwater Quality Data for the John Henry No. 1 Mine
Table 7. Washington State Climate Change Impacts
Table 8. Summary of Direct and Indirect CO2e Emissions Proposed Action Alternative
Table 9. King County, WA Industrial Sector GHG Emissions (2011)
Table 10. Precipitation, Temperature, and Wind for the Study Area
Table 11. National Ambient Air Quality Standards
Table 12. British Columbia Ambient Air Quality Objectives
Table 13. Average Monitoring Values (Seattle, WA)
Table 14. 2010 Average Annual Emissions (Lower Fraser Valley, British Columbia)
Table 15. Class I Areas
Table 16. Total Emissions by Alternative
Table 17. Modeled Particulate and NAAQS
Table 18. Criteria Emissions for Transportation Scenarios Compared to County and State Total
Emissions
Table 19. Current Lehigh Cement Plant Emissions versus Emissions from the Proposed Action
in Relation to the Study Area
Table 20. Summary of Vegetative Communities
Table 21. Federal and State Listed Endangered, Threatened, and Sensitive Plants in King
County, WA
Table 22. Wetland Classification Summary

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Environmental Assessment John Henry No. 1 Mine
Table 23. Observed Wildlife at the John Henry No.1 Mine and Morgan Kame Terrace Sand and
Gravel Mine
Table 24. King County and City of Black Diamond Minority and Low-Income Populations
Table 25. Level of Service
Table 26. Existing Traffic Conditions
Table 27. Proposed Action Traffic Conditions
Table 28. Impact Assessment Summary for the Proposed Action Alternative

LIST OF ABBREVIATIONS AND ACRONYMS

Text Acronym
Ammonium Nitrate Fuel Oil ANFO
Approximate Original Contour AOC
Bald and Golden Eagle Protection Act BGEPA
Bank Cubic Yard BCY
Best Available Control Technology BACT
Carbon Dioxide Equivalent CO2e
Clean Air Act CAA
Code of Federal Regulations CFR
Compacted Cubic Yard CCY
Council on Environmental Quality CEQ
Cumulative Hydrologic Impact Assessment CHIA
East E
Environmental Assessment EA
Environmental Impact Statement EIS
Final Environmental Impact Statement FEIS
Greenhouse Gases GHGs
Growth
wth Management Act GMA
Hydrologic Unit Codes HUD
Interagency Monitoring of Protected Visual IMPROVE
Environments
Intergovernmental Panel on Climate Change IPCC
Interstate I
Kilowatt Hours kWh
King County Department of Permitting and DPER
Environmental Review
Level of Service LOS

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Environmental Assessment John Henry No. 1 Mine
 Text Acronym
Master Planned Development MPD
Microgram Per Liter g/L
Migratory Bird Treaty Act MBTA
Mine Safety and Health Administration MSHA
National Ambient Air Quality Standards NAAQS
National Environmental Policy Act NEPA
National Hydrography Dataset NHD
National Marine Fisheries Service NMFS
National Pollutant Discharge Elimination System NPDES
New Source Performance Standards NSPS
North N
Notice of Construction NOC
Office of Surface Mining, Reclamation and OSMRE
Enforcement
Pacific Coast Coal Company PCCC
Post-mine Lake PML
Probable Hydrologic Consequences PHC
Priority Habitat and Species PHS
Puget Sound Air Pollution Control Agency PSAPCA
Puget Sound Clean Air Agency PSCAA
South S
State Environmental Policy Act SEPA
State Route SR
Surface Mining Control and Reclamation Act SMCRA
Total Maximum Daily Load TMDL
Total Suspended Particulates TSP
United States Army Corps of Engineers USACE
United States Environmental Protection Agency EPA
United States Fish and Wildlife Service USFWS
Washington Department of Fish and Wildlife WDFW
Washington Department of Game WDG
Washington Department of Natural Resources WDNR
Washington Department of Ecology WDOE
Washington Department of Transportation WDOT
West W
Wetland Resources, Inc. WRI

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Environmental Assessment John Henry No. 1 Mine
1.0 DESCRIPTION OF THE PROJECT AND PROPOSED ACTION

Pacific Coast Coal Company (PCCC) submitted a permit revision application to revise Federal
permit WA-0007D on April 18, 2011 to the Office of Surface Mining, Reclamation and
Enforcement (OSMRE). This permit revision would allow the continuation of surface coal
mining operations under authority of the Surface Mining Control and Reclamation Act (SMCRA),
Public Law 95-87.

PCCC has not engaged in substantive coal mining operations since 1999. Environmental
maintenance activities and monitoring have been ongoing since that date. PCCCs permit
renewal applications (2011 and 2016) have been under administrative delay pending the
completion of an Environmental Assessment (EA) of PCCCs proposed permit revision.

John Henry No. 1 Mine is located in King County, Washington, near the City of Black Diamond
(Figure 1). PCCC proposes to continue mining in Pit 1 and Pit 2, as shown in large mining area
on Figure 2. PCCC proposes to mine 737,000 short tons of minable coal reserves (462,000
processed short tons) over a 6-year period and disturb an additional 29.7 acres of land.
Reclamation would occur contemporaneously with active mining.

This EA has been prepared to disclose and analyze the potential environmental effects of
PCCCs proposed permit revision application (hereafter referred to as the Proposed Action).
An EA is a site-specific analysis of potential effects that could result in the implementation of the
Proposed Action or Alternative(s). An EA assists OSMRE in project planning, ensuring
compliance with the National Environmental Policy Act (NEPA), and in making a determination
as to whether any significant effects could result from the Proposed Action. Significance is
defined by the NEPA in regulation 40 Code of Federal Regulations (CFR) 1508.27.

An EA provides analysis for determining whether to prepare an Environmental Impact

Statement (EIS) or a statement of Finding of No Significant Impact (FONSI). If OSMRE
determines in the EA analysis that a project may have significant impacts that cannot be
mitigated to less than significant, then an EIS will be prepared for the project. If OSMRE
determines there will be no significant impacts, then OSMRE may issue a FONSI with the EA.
The FONSI documents the decision that the implementation of the selected alternative would
not result in significant environmental impacts based on the analyses in the EA.

Chapter 1 presents the purpose and need of the Proposed Action and the analysis of Alternative
Actions. Chapter 2 describes the public comments and identified issues. Chapter 3 describes
the existing environment of the project area and the potential direct and indirect environmental
impact from each alternative. Chapter 4 describes the potential cumulative environmental
impacts from the Proposed Action.

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Environmental Assessment John Henry No. 1 Mine
Figure 1. Vicinity Map of the John Henry No. 1 Mine in Black Diamond, Washington

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Environmental Assessment John Henry No. 1 Mine
Figure 2. Mine Plan Map

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Environmental Assessment John Henry No. 1 Mine
1.1 Background Information

The John Henry No. 1 Mine1 consists of 480 acres of privately owned land located in south King
County, Washington adjacent to the City of Black Diamond. Before mining could begin in 1986,
the land was rezoned to a Quarry/Mining designation by King County to allow issuance of a
grading permit. A Washington State Environmental Policy Act (SEPA) EIS was prepared in the
1980s as part of the rezoning application, and included public hearings before a King County
Hearing Examiner. The pre-mining land use was unmanaged forest and fish and wildlife habitat.

In accordance with provisions of Section 504 of SMCRA, OSMRE implemented a Federal

program on May 16, 1983, (48 F.R. 22291) for the regulation of coal mining activities within the
State of Washington. OSMRE analyzed the environmental impacts of mining for the proposed
John Henry No. 1 Mine in the Final Environmental Impact Statement (FEIS) (OSM-EIS-13)
(OSMRE 1985). The John Henry No. 1 Mine permit was issued June 12, 1986 after public input
and mining began in June of that year. A new 150 ton per hour coal processing plant was built
on site in 1990 and the mine reached full production in 1991.

The 1985 FEIS examined the impacts over the entire life-of-mine area including the remaining
29.7 acres that would be disturbed under the Proposed Action analyzed in this EA. Where
applicable, this EA references the 1985 FEIS for relevant background or baseline information.
This EA is not tiering to the 1985 FEIS and is conducting a new environmental analysis of the
current and future conditions of the Alternatives presented in Section 1.3, Proposed Action
Alternative, and 1.4, No Action Alternative.

In accordance with SMCRA regulations, coal-processing wastes would be backfilled in the pits
and covered with at least four feet of clean overburden material prior to final reclamation. The
detailed coal waste disposal plan is described in Section 3.4.8 of the currently approved PAP.
Coal waste was initially deposited with spoil material in the external spoil piles. Beginning in
1994, all coal waste was disposed in the mined out area of Pit 1 and mixed with overburden
material. Before OSMRE approved the 1986 PAP, it required chemical testing of the coal waste,
including toxicity tests. From this testing, OSMRE concluded there were no indications of any
health hazard associated with the coal processing waste. It was determined that the material
contained no acid or toxic forming materials.

PCCC used open-pit mining methods to mine coal in six coal seams from two separate mine
pits. Pit 1 accounted for most mining during the initial 13 years, although some mining occurred
in Pit 2. From 1986 until 1999, PCCC mined 3,047,000 short tons of coal and removed
14,729,000 bank cubic yards (BCY) of overburden. As part of the open pit mining operation that
began in 1986, 8,228,000 BCY of overburden and coal processing waste material were placed
into four temporary spoil piles and referred to as Spoil Pile 1, Spoil Pile 2, Spoil Pile 3 North,

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John Henry No. 1 Mine is referred to as the Mine and the project throughout the EA.

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Environmental Assessment John Henry No. 1 Mine
and Spoil Pile 3 South. Placement of spoil in spoil piles ended in 1992. From 1993 until 1999 all
removed overburden was directly backfilled into mined pits in compliance with
contemporaneous reclamation requirements. During this time (1993 to 1999) 8,563,000 BCY of
overburden was backfilled in Pits 1 and 2. A total of 13 acres of Pit 1 have been backfilled and
graded.

The temporary spoil piles have been covered with topsoil and planted with Douglas fir trees.
The currently approved reclamation plan requires that a portion of each of these piles be
reduced to achieve approximate original contour (AOC). As approved by OSMRE in 2001, Pit 1
would be partially backfilled and reclaimed into a post-mine lake (PML). The PML is the result of
allowing groundwater and rainwater to fill in Pit 1. The reclamation plan requires partial
backfilling and grading of the periphery of the lake to a condition that has been approved by
OSMRE. Pit 2 would be completely backfilled. All disturbed land would be covered with topsoil
and re-vegetated. A total of 3,929,000 compacted cubic yard (CCY) of material is required to be
removed from the temporary spoil piles and used to fill the two pits in accordance with the
approved reclamation plan. The balance of the material left in the spoil piles would be graded,
topsoiled, and planted with Douglas fir. Twenty-one acres along the southwest edge of Spoil
Pile 1 have been fully reclaimed.

In 1999, PCCC began disposing of new sources of fill from off-site construction sites and sand
and gravel washing operations. These included silt from sedimentation ponds, silt from
dewatering systems, and excavated native soils. OSMRE determined external fill disposal was a
surface mining activity because it impacted mine reclamation. OSMREs jurisdiction was
affirmed through a series of administrative law proceedings. Through a December 15, 2000,
permit revision order (OSMRE 2000), OSMRE required PCCC to gain approval of each new
source of clean fill via a minor permit revision application that included sampling and testing
prior to disposal. OSMRE required that PCCC test for the following parameters before it would
allow disposal from a new source (Table 1).

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Environmental Assessment John Henry No. 1 Mine
Table 1. Chemical and Physical Test Requirements for External Fill Approval
Required Tests
Potassium Acid-Base Potential
Neutralization Potential as Calcium Carbonate
Calcium
(CaCO3)
Magnesium Sulfur, Total
Sodium Texture by Hydrometer
Chloride Clay
Acid Generation Potential Sand
Acid Neutralization Potential Silt
Texture Classification

The order also required PCCC to add monitoring and reporting requirements for the disposal of
off-site fill into the PAP. These included a requirement to sign individual truck trip tickets
showing the amount of material hauled, the origin of the material, the time and date the material
was brought in and to submit monthly reports to OSMRE that summarize the amount of material
accepted.

OSMRE authorized a total disposal amount of 100,000 CY average per year for the 2001 to
2006 5-year permit term for a total of 500,000 CY. From 1999 to 2006, PCCC received
approximately 644,000 CY of off-site fill for backfill applying it at the east end of Pit 1. In 2006,
OSMRE rejected PCCCs permit revision application to dispose of an additional 500,000 CY of
clean fill during the next permit term. Backfill of off-site fill material ceased at that time. OSMRE
concluded that additional disposal conflicted with reclamation plans because it would have
increased the backfill volume by 13.9 percent, and that additional disposal conflicted with the
purpose of SMCRA.

In April 2009, OSMRE issued a permit revision order that required PCCC to either begin mining
or commence final reclamation according to the reclamation plan in the PAP (OSMRE 2009). In
that same permit revision order, OSMRE required PCCC to demonstrate that it had a market for
its coal, through evidence of a sales contract, before it would approve additional mining.
OSMRE issued a Cessation Order on May 24, 2010 (OSM C10-141-244-001) directing PCCC
to cease mining operations and to revise its permit to move forward with final reclamation. The
permit was revised and in the fourth quarter of 2010 and January 2011 PCCC reclaimed a
portion of Spoil Pile 2 by backfilling 572,000 CY of fill into Pits 1 and 2.

PCCCs current plans are to renew its surface coal mining permit to allow mining to continue in
accordance with the proposed permit revision application submitted on April 18, 2011. SMCRA
Section 506 provides a surface coal mining operator the right to successively renew its existing,
approved surface coal mining permit. In accordance with the requirements of 30 CFR 774.15,
PCCC submitted a permit revision application on April 18, 2011 and an Application for Permit
Renewal of Surface Coal Mining and Reclamation Operations at John Henry No. 1 Mine to

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Environmental Assessment John Henry No. 1 Mine
OSMRE on August 4, 2011. PCCCs surface coal mining permit (Federal Permit, WA-0007D)
was scheduled to expire on December 7, 2011. On December 4, 2011, OSMRE notified PCCC
that it administratively delayed its decision on the permit renewal application and that PCCC
was permitted to continue activities under the currently-approved permit until OSMRE made a
decision on the permit revision application and permit renewal application. On August 3, 2016,
PCCC submitted an application for permit renewal for years 2016 2021. Both the 2011-2016
and the 2016-2021 permit renewal applications are administratively delayed pending a decision
on the permit revision application (see Figure 3 for a project timeline).

Figure 3. John Henry No. 1 Mine Timeline

1.2 Purpose and Need

The purpose and need of the Proposed Action is established by SMCRA, which requires the
evaluation of PCCCs Application for Permit Revision and Application for Permit Renewal before
PCCC may continue coal removal operations at the John Henry No. 1 Mine. OSMRE is the
regulatory authority that administers Federal Mine Permit WA-0007D. As the regulatory
authority, OSMRE must evaluate the environmental effects resulting from the Proposed Action.

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Environmental Assessment John Henry No. 1 Mine
OSMRE must decide whether or not to approve a Permit Revision Application and must decide
whether or not to approve an application to renew Federal Mine Permit WA-0007D. The need
for this action is to provide PCCC with the opportunity to exercise its valid existing rights to
access and mine coal reserves located within the John Henry No. 1 Mine.

PCCC submitted a permit revision application for the John Henry No. 1 Mine, Federal Permit
No. WA-0007D, dated April 18, 2011 (PCCC 2011a). OSMRE determined that the permit
revision application was administratively complete on April 28, 2011 and began a technical
review of the application. PCCC submitted a permit revision application to resume mining
because coal reserves have become economically recoverable due to changes in market prices
that improved PCCCs competitive position in the regional coal marketplace. Under PCCCs
current permit, additional removal of coal is not allowed and only reclamation activities may be
conducted.

Under SMCRA, OSMRE is required to make a decision to approve or deny the permit revision
application and application for permit renewal. OSMRE determined that the permit revision
application should be designated as a significant permit revision and that an EA was required
under the NEPA. Factors considered in OSMREs determination that the permit revision
application would require an EA included changes in coal production, public interest in the
operation, and resumption of blasting operations. This EA analyzes the impacts that would
result under the alternatives presented and pursued (see Sections 1.3, 1.4, and 1.5).

1.3 Proposed Action Alternative

The Proposed Action Alternative would be continuation of mining at the John Henry No. 1 Mine
and renewal of the John Henry No. 1 Mine surface coal mining permit. Active mining operations
would produce an estimated 84,000 short tons of saleable coal per year. Reclamation activities
would follow until the mine site was fully reclaimed and final bond release was authorized by
OSMRE. A map showing the mining site and mine plan is provided as Figure 2. The permit area
of the Proposed Action is within the currently approved permitted area (480 acres).

Under the Proposed Action, most mining would occur in two coal seams within Pit 2. All
proposed mining activities would occur entirely within the Rock Creek/Lake Sawyer watershed
with no mining activities proposed within the Lake No. 12 watershed. The reclamation plan that
PCCC proposes is similar to that analyzed in the 1985 FEIS (OMSRE 1985). The exception is
that the Mud Lake wetlands would not be mined and a replacement wetland would not be
required (see Section 3.9, Wetlands and Riparian Zones). Overburden created from mining Pit 2
would be used to complete much of the backfilling requirements of Pit 1 in order to create a
PML. Mining in Pit 2 would slowly advance to the west, as shown on Figure 2. 1,454,000 CCY
of material in Spoil Piles 3N and 3S would be backfilled into Pit 2 to accomplish AOC of the two
spoil piles and of Pit 2. 1,049,000 CCY from Spoil Pile 2 would also be used to fill in Pit 2.
782,000 CCY in Spoil Pile 1 would be used to complete backfilling the east end of Pit 1.

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Environmental Assessment John Henry No. 1 Mine
1.3.1 Mining Method
Under the Proposed Action Alternative, mining operations would last approximately six years. A
shovel, loader, or backhoe, blasting, and truck mining operation would be used for overburden
removal. Overburden material would be used to backfill the eastern portion of Pit 1. Mining
operations would be concentrated in Pit 2; however, the northwest portion of Pit 1 may also be
mined. As Pit 2 is widened from the sub-crop northward, the spoil material would be removed
and hauled to backfill Pit 1. The coal seam would be removed with front-end loaders or a
backhoe. Mined coal would be delivered to an open pile storage area in front of the plant feed
hopper. The coal would be fed to a crusher capable of handling 175 tons per hour. After
crushing, the coal would be conveyed to the preparation plant where it would be cleaned and
then transferred to a clean coal stockpile ready for transport. The coal-processing waste would
be conveyed to a refuse bin and used to backfill the pits.
1.3.2 Blasting
Blasting would be conducted to reduce the overburden and inter-burden to a size that can easily
be removed. Ammonium nitrate mixed with fuel oil (ANFO) would be used in each blast hole.
Detonation would be completed with non-electric detonators and cast boosters by qualified
contractors. In accordance with applicable regulations, a pre-blast survey would be conducted
and the public notified of the blasting schedule. Blasting would be conducted in a controlled
manner and in accordance with all applicable regulations to prevent damage to surrounding
property.
1.3.3 Access and haul roads
The primary access road to the John Henry No. 1 Mine runs from the Black Diamond -
Ravensdale Road to the mine office along the north side of Ginder Lake (see Section 3.9,
Wetlands and Riparian Zones). It is a gravel road approximately 2,450 feet long which was
previously used as a logging road. Because the road existed prior to mining operations, the road
will remain in place after reclamation activities are completed.

Access to Pits 1 and 2 is by a road from the coal preparation plant. The road is constructed of
on-site compacted soils and off-site sand and gravel. There is another road running from the
raw coal storage area south and west to Spoil Pile 3. It is used for transporting raw coal from the
pits to the coal preparation plant and as an access point to the Spoil pile 3 area. This road is
constructed of compacted spoils.

Secondary access is provided by a previously existing roadway running from Highway 169 past
Pond H2 to the primary road south of Spoil Pile 2. It is not used on a regular basis but could be
used in the future for reconnaissance of area conditions. This road existed prior to mining
operations and will remain in place after reclamation activities are complete.
1.3.4 Utilities
Existing utilities at the mine include septic system, electrical system, telephone system, and
buried water routing systems (potable and fire control systems). There are buried transmission
lines previously built along the access road to the facilities area that are owned by PCCC. Two
ground-based step down transformers were installed to provide electricity to the coal
preparation plant, office, and shop facility. One 300 KVA transformer provides 480-volt

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Environmental Assessment John Henry No. 1 Mine
electricity to the preparation plant and the other 75 KVA transformer provides 480-volt electricity
to the office and shop facilities. No additional utilities, transmission lines, or substations would
be required under the Proposed Action Alternative.
1.3.5 Mine Facilities
Existing buildings, structures, and facilities include:
Coal processing plant and coal storage areas
Shale crushing & screening facility
Explosive storage area
Bulk ANFO storage area
Guard house
Truck wheel wash
Office and office trailer
Shop
Oil storage trailer
Wash-down station
Parts trailer
Well and pump house
Water storage tanks (3)
Fire control system
Potable water system
Shale storage facility
Trucks scale facility
Scale house
Pre-existing concrete structure near Ginder lake

Mining equipment proposed for this small-scale operation is readily available to PCCC and/or
contractors and will be brought on site as needed. Mining equipment would include but is not
limited to:
2 front end loaders

1 overburden drill

1 dozer

1 backhoe

1-3 trucks

PCCC has refurbished the coal processing plant and expects that the mine can be back in
operation within a few months of permit approval. No additional site development is required.
1.3.6 Ponds, Impoundments, Diversions
There are eight ponds (A, A, B, F, G, H1, H2, I) at the John Henry No. 1 Mine. These ponds are
used to control sediment runoff from spoil piles, disturbed areas, and backfilled areas prior to
reclamation.

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Environmental Assessment John Henry No. 1 Mine
The truck wheel wash station has a closed-circuit sump which does not discharge. OSMREs
regulations for impoundments at 30 CFR 816.49(b) apply to this structure.
1.3.7 Water Source
The John Henry No. 1 Mine uses a groundwater well as a source of potable water. The water
supply system consists of a well pump, wellhead facilities (i.e. pump house), water line from
wellhead to office and change house, booster pump station and storage tank, and pressure tank
and controls. All systems and appurtenances are designed, constructed, and maintained in
accordance with Chapter 248-54 WAC (Public Water Systems).

Approximately 85 gallons per minute of water are used during operation of the coal processing
plant. Water is pumped from Pit 2, supplemented with water from pond G or from Ginder Lake
when necessary. Water for fire protection (10,000 gallons) is stored in surface tanks at Spoil pile
1.

1.3.8 Hazardous Materials and Solid Waste

All greases, lubricants, paints, and flammable liquids would be disposed of through a
commercial recycling service. Old mining equipment is sold or scrapped by local salvage
operations and other solid wastes are disposed of at approved landfills. PCCC has developed a
spill control and solid waste disposal plan as a condition of the National Pollutant Discharge
Elimination System (NPDES) permit (No. WA 003083-0).

The only potentially combustible material to be disposed of on site is the coal processing waste.
No coal processing waste would be placed on an exposed coal seam in the pit showing any
signs of oxidation or burning. Coal processing waste would be covered with at least 4 feet of
spoil to seal off sources of oxygen and to eliminate any potential for combustion.
1.3.9 Mine Personnel
Under the Proposed Action, the mine would employ 30 full-time workers for up to six years and
20 full time workers for an additional year of reclamation activities after mining ceases.
1.3.10 Coal Destinations
During the 1986-1999 mining period PCCC sold most of its coal to cement producers in
Western Washington. Under the Proposed Action Alternative, PCCC would sell its coal to
existing cement and lime producers in British Columbia, Canada, and Western Washington. It is
anticipated that PCCC would sell approximately 60% of planned coal production to the Lehigh
Cement plant located in Delta, British Columbia under its current contract which expires in 2019
(PCCC 2015b). The remaining 40% of planned coal production would be sold to the Ash Grove
plant located in Western Washington. Typical cement and lime plants use a combination of coal,
natural gas, petroleum products, and used tires as fuel sources to create sufficient heat in the
kiln to produce a cement clinker (Kosmatka, Kerkhoff, and Panarese 2003) which is pulverized
and processed into various cement products that are used in domestic, commercial, and
industrial construction projects.

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Environmental Assessment John Henry No. 1 Mine
The process of making cement and lime is similar in that both require that limestone be crushed
and blended with mineral additives then heated at approximately 1,500 degrees Fahrenheit to
create a cement clinker product.

1.3.11 Transportation
Under the Proposed Action Alternative, there are two transportation scenarios. The first
scenario would entail approximately 10 roundtrips per day by truck transporting materials to the
Seattle or Tacoma, Washington area five days per week for six years. The second scenario
would be a combination of truck and barge transportation to ship coal to the Lehigh Cement
Plant in Delta, British Columbia. Approximately 82 roundtrips by truck would occur within a 36
hour period to transport materials to the Port of Seattle or Tacoma for loading onto a barge once
each year for six years. The barge would travel through Puget Sound docking at the Port of
Richmond, British Columbia where materials would then be transferred to trucks and driven
approximately 10 miles to the plant in Delta, British Columbia. The exact trucking method from
the Port of Richmond to Delta, British Columbia is unknown; however, it is assumed for
purposes of this EA to be similar to those actions in the United States.
1.3.12 Reclamation
The approved reclamation plan requires the complete backfilling of Pit 2, and partial backfilling
of Pit 1 to create a PML. At the completion of mining a portion of each spoil pile is backfilled and
the balance is graded to blend with surrounding topography and meet AOC standards. The post
mining land use would continue to support forestry for the upland area and fish and wildlife
habitat for the lake and riparian area.

As mining advances to the west, mined overburden would be transported directly into Pit 2.
Upon completion of all mining, a portion of each spoil pile would be backfilled into the pits and
all disturbed areas (including spoil piles) reclaimed. Additionally, the 25.2 acres of mine facilities
would be reclaimed upon completion of mining in accordance with the approved plan.
1.4 No Action Alternative

NEPA and the Council on Environmental Quality (CEQ) regulations require that a No Action
Alternative be presented in all environmental analyses to serve as a baseline from which to
compare all proposed action alternatives pursuant to 40 CFR 1502.14(d). Under the No Action
Alternative, the proposed permit revision application to resume and complete mining would not
be approved. PCCC would commence final reclamation of the mine site, including the backfill of
Pits 1 and 2 according to the reclamation plan in the currently approved PAP, estimated to take
two years (see Section 1.3.12, Reclamation). The mine would employ 20 full time workers for
reclamation activities. Additional coal reserves (737,000 tons) would not be mined and an
additional 29.7 acres of mature, deciduous forest would not be disturbed. Under the No Action
Alternative, there would continue to be surface disturbance as reclamation actions are
completed in accordance with the approved reclamation plan.

1.5 Other Alternatives Considered But Not Evaluated

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Environmental Assessment John Henry No. 1 Mine
Under NEPAs requirements, the agency must evaluate the environmental impacts of a
reasonable range of alternatives that meet the project purpose and need. The DOIs NEPA
implementing regulations define reasonable alternatives as those that are technically and
economically practical or feasible and meet the purpose and need of the proposed action (43
CFR 46.420). After reviewing the current status, permit and compliance history, and the
current permit revision application of the John Henry No. 1 Mine, OSMRE determined that there
are no other reasonable alternatives to evaluate in this EA other than the Proposed Action
Alternative and No Action Alternative.

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Environmental Assessment John Henry No. 1 Mine
2.0 PUBLIC COMMENTS AND IDENTIFIED ISSUES

Public comments on the Proposed Action Alternative were solicited from the general public on
the April 18, 2011 permit revision application and surrounding communities via public notice as
required under 30 CFR 947.774.13 for the permit renewal and significant revision. OSMRE
received one comment letter from a citizen of Black Diamond regarding PCCC's permit renewal
application. All concerns expressed by the public on the 2011 permit revision application have
been addressed by OSMRE in either this EA or OSMREs Cumulative Hydrologic Impact
Assessment (CHIA) (OSMRE 2016). OSMRE received an Application for Permit Renewal for
2016 2021 on August 3rd, 2016.

In reviewing the permit revision application, OSMRE coordinated with other Federal, state, and
local agencies. One response was received from the Mine Safety and Health Administration
(MSHA) related to PCCCs ground control plan. MSHA concluded that the changes proposed
are minor in scope. It also noted that PCCC must monitor and inspect the PML to ensure
compatibility with the approved ground-control plan. On June 28, 2011, PCCC met with OSMRE
and the United States Army Corps of Engineers (USACE) who requested an updated wetlands
delineation study. The study (Group Four 2011) was prepared by a third-party consultant and
submitted to the USACE along with PCCCs Pre-Construction Notice (PCCC 2011b). As part of
the permit revision application review process, the City of Black Diamond submitted additional
comments on the Proposed Action Alternative that sought clarification related to water quality,
traffic, and land-use issues. PCCC would not mine coal within the Black Diamond city limits but
would conduct reclamation work within the city limits while reclaiming spoil piles 3 North and 3
South to AOC. PCCC would conduct reclamation within the Black Diamond city limits under
both the Proposed Action Alternative and the No Action Alternative. PCCC responded directly to
the City of Black Diamond to address those concerns. Black Diamond officials are requiring
PCCC to obtain a grading permit issued by the City of Black Diamond prior to any disturbance
and reclamation of spoil piles located within the city limits. These two spoil piles would be
reclaimed in accordance with the approved reclamation plan in the permit (PCCC 2011a). In
response to the City of Black Diamonds comments and requirements, PCCC applied for a
grading permit which was issued on October 24, 2014.

On March 18, 2014, OSMRE published an EA to support OSMREs pending decision on

PCCCs proposed permit renewal application and permit revision application. The availability of
the EA was published in local media during March and April. Public comments were solicited
thru May 13, 2014. OSMRE received over 2,300 comments from the public on the 2014 EA,
indicating strong public interest.

OSMREs review of the public comments identified several resource-specific concerns. These
are addressed in this revised EA. Comment concerns included, but were not limited to, the
following:

1. Groundwater and surface water quality and quantity;

2. Transportation of coal over public roads;

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Environmental Assessment John Henry No. 1 Mine
 3. Air quality and public health;
4. Blasting effects;
5. Noise;
6. Devaluation of surrounding properties;
7. Historic non-mining waste disposal;
8. Climate change;
9. Species of concern;
10. Cumulative impacts.

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Environmental Assessment John Henry No. 1 Mine
3.0 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES

This section provides an overview of the current conditions and pertinent elements of the
affected environment and examines impacts of the Proposed Action Alternative and the No
Action Alternative

The specific resources examined as part of this EA are listed below in Table 2.

Table 2. Environmental Resource Areas Addressed

Resource Areas

Topography Land Use

Geology (Paleontology) Socioeconomics and Environmental Justice
Water Resources/Hydrology Transportation
Climate and Climate Change Recreation
Air Quality Noise and Vibration
Soils Visual Resources
Vegetation Cultural Resources
Wetlands Human Health and Safety
Fish and Wildlife

The affected environment associated with the resources examined in this EA were defined as
being located within the mine permit area or the local area surrounding the mine as defined by
the specific resource (i.e. biological or water resources). With the exception of climate change,
air quality, and transportation, impacts were not evaluated on a regional or statewide level,
given the limited area of mine operations.

Within each resource area, the type and duration of potential impacts (direct, indirect, and short-
term or long-term) as well as potential impact intensity (negligible, minor, moderate, and major)
were evaluated. 40 CFR 1508.8 and 1508.27. Section 3.21, Summary of Impacts to the
Affected Environment under the Proposed Action Alternative, provides detail regarding the
impact intensity metrics. Cumulative impacts are analyzed separately in Chapter 4.

Type of Impact:
Direct impacts are defined as those impacts that are caused by an action that occur at
the same time and in the same general location as the action. 40 CFR 1508.8(a).
Indirect impacts are those that are caused by an action and are later in time or farther
removed in distance, but are still reasonably foreseeable. 40 CFR 1508.8(b).

Duration of Impact:

Short-term impacts refer to those impacts that generally occur over a short period during
a specific point in the mining process and these changes generally revert to pre-

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Environmental Assessment John Henry No. 1 Mine
 Long-term impacts are those that substantially would remain beyond short-term ground
disturbing activities. Long-term impacts would generally last the life of the mine and
beyond.

Intensity of Impact:
Negligible impact is defined as impacts in the lower limit of detection that potentially
could cause an insignificant change or stress to an environmental resource or use.
Minor impact is defined as impacts that potentially could be detectable but slight.
Moderate impact is defined as impacts that potentially could cause some change or
stress to an environmental resource but the impact levels are not considered significant.
Significant impact is defined as impacts that potentially could cause irretrievable loss of
a resource; significant depletion, change, or stress to resources; or stress within the
social, cultural, and economic realm.

The impact analysis presented in this EA generally does not imply or assign a value or
numerical ranking to impacts except in cases where numerical quantification is possible such as
hydrology, air quality, and noise. Impacts that result from, or relate to, the implementation of any
of the alternatives are analyzed in this chapter.

3.1 Regulatory Framework

Different federal, state, and local jurisdictions are responsible for the regulation of resource
areas. Applicable statutes, regulations licenses, and guidance are listed below.

National Environmental Policy Act (42 U.S.C. 4321 et seq.)

Surface Mining Control and Reclamation Act (SMCRA) of 1977 (Public Law 95-87)

Clean Water Act (33 U.S.C)

Executive Order 11988, Floodplain Management

Chapter 508-12, WAC, Administration of Surface and Groundwater Codes

King County, Title 9, Surface Water, Storm Water, and Groundwater Management

Clean Air Act (42 U.S.C. 7401 et seq., as amended in 1977 and 1990)

Washington Department of Ecology (WDOE), Guidance for Ecology Including

Greenhouse Gas Emissions in SEPA Reviews

Executive Order 11990, Protection of Wetlands
Endangered Species Act (16 U.S.C. 531)
Migratory Bird Treaty Act (16 U.S.C 703)
Bald and Golden Eagle Protection Act of 1940 (16 U.S.C 608)
Fish and Wildlife Coordination Act of 1934 (16 U.S.C. 661)
Treaty of Point Elliot of 1855
CEQ 1997: Environmental Justice Guidance under the National Environmental Policy
Act
Executive Order 12898: Federal Actions to Address Environmental Justice in Minority
Populations and Low-Income Populations. 59 Fed. Reg. 7629 (February 16, 1994)
King County, Title 46, Traffic Code

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Environmental Assessment John Henry No. 1 Mine
 King County, Title 14, Roads and Bridges
King County Grading Permit
King County, Title 7, Parks and Recreation
Noise Control Act of 1972 (42 U.S.C. 4910)
State of Washington, Department of Labor and Industries, Magazine Storage License
City of Black Diamond, Business License
Federal Communications Commission, Radio Station License
State of Washington, Department of Licensing, Fuel Tax Section, Special Fuel Tax Bulk
User License
State of Washington, Department of Wildlife, Hydraulics Project Approval
State of Washington, Department of Ecology, Permit to Appropriate Waters of the State
of Washington
Seattle King County Department of Public Health, Permit to Install/Repair Sewage
Disposal System
Occupational Safety and Health Administration, Occupational Noise Exposure Hearing
Conservation Amendment (29 C.F.R. Part 1910.95)
King County, Title 12, Public Peace, Safety and Morals, Section 12.86 Noise
Manual H-8410-1, Bureau of Land Management, Visual Resource Inventory
King County, Title 21A, Zoning
National Historic Preservation Act (54 U.S.C. 300101 et seq.) Section 106 (Public Law
102-575, 54 U.S.C. 306108) and its implementing regulations (36 C.F.R. Part 800)
Antiquities Act of 1906 (16 U.S.C. 431 et seq.)
Archaeological Resources Protection Act of 1979 (54 U.S.C. 300101 et seq.)
American Indian Religious Freedom Act of 1978 (Public Law 95-341)
Archaeological and Historic Preservation Act of 1974 (Moss-Bennett Act)
Executive Order 11593, Protection and Enhancement of the Cultural Environment
Executive Order 13007, Indian Sacred Sites Native American Graves Protection and
Repatriation Act (25 U.S.C. 3001 to 3013)
OSMRE NEPA Regulations, 43 CFR Part 46
OSMRE NEPA Guidance, DOI 516 DM (DOI 2004)

3.2 Topography

3.2.1 Affected Environment

Surface elevations in the permit area ranged from a maximum of 840 feet above mean sea level
to a minimum of approximately 625 feet above mean sea level where Mud Lake creek leaves
the permit area. Ground elevations within the future mining area range from 750 to 825 feet
above mean sea level. Construction of the temporary spoil piles increased the maximum
elevation to 950 feet above mean sea level in those locations (Figure 4).

Figure 4. Topography of John Henry No. 1 Mine

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Environmental Assessment John Henry No. 1 Mine
3.2.2 Environmental Consequences
An additional 29.7 acres of land would be disturbed under the Proposed Action bringing the total
disturbed area to 302.9 acres. During reclamation the disturbed areas would be backfilled and

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Environmental Assessment John Henry No. 1 Mine
graded to AOC, and reclaimed in accordance with the plan proposed in the Revision Application
(PCCC 2011a).
3.2.2.1 Proposed Action Alternative
Potential direct impacts related to the final mine topography have been identified through
consideration of PCCCs permit revision and renewal applications. Pit 1 would be reclaimed to a
PML using overburden mined from Pit 2 and from stockpile material in Spoil Pile 1 and Spoil
Pile 2. Pit 2 would be reclaimed to AOC by complete backfilling from Spoil Pile 2, Spoil Pile 3S,
and Spoil Pile 3N. Because the topography would be reclaimed to AOC, this constitutes a direct,
minor, and long-term impact within the permit area. Elevation would increase from 5 to 20 feet
compared to pre-mining conditions in selected areas across the mine site as a result of the
Proposed Action. Topographic impacts would be restricted to the mine permit area and would
not result in any indirect impacts.
3.2.2.2 No Action Alternative
In terms of final topography, there is no difference between the Proposed Action Alternative and
the No Action Alternative except for timing. Under the No Action Alternative, final reclamation of
the mine site begins immediately and is completed in two years compared to seven years under
the Proposed Action Alternative. The final post-mine configuration is the same as under the
Proposed Action Alternative. Under the No Action Alternative, the relatively small existing void in
Pit 2 would be filled with material from Spoil Pile 2. To achieve AOC of Spoil Pile 3S and Spoil
Pile 3N and to partially fill Pit 1 to its approved configuration, spoil would be hauled to Pit 1. The
amount of backfill in Pit 1 and lake depth would be the same in either the Proposed Action
Alternative or the No Action Alternative. Elevation changes in selected areas from pre-mining
conditions would increase from 5 to 20 feet under the No Action Alternative. The impact is within
the permit area, and is direct, minor, and long-term. Topographic impacts would be restricted to
the mine permit area and would not result in any indirect impacts.

3.3 Geology/Paleontology

3.3.1 Affected Environment

The coal seams are contained within the Eocene Puget formation. Coal is inter-bedded with
shale, siltstone, and sandstone units. In Pit 2, overburden is predominantly sandstone. Vashon
till generally overlays the entire property and ranges in thickness from 10 to 70 feet. This till is
generally referred to as hardpan and must be ripped or blasted to gain access to the underlying
bedrock. The underlying Eocene Puget formation in Pit 2 dips to the north from 25 to 45
degrees. The steepest dips are in the eastern end of Pit 2. Mining from 1986 to 1997 was
focused in Pit 1. This was a large open pit that followed an anticline with an east-to-west axis.
The strata dipped north and south approximately 45 degrees. In this pit, the Franklin No. 7, 8, 9,
10, and 410 seams were mined. Initial spoil from Pit 1 was placed in temporary spoil piles.
Direct backfilling of Pit 1 began in 1992. This prior mining would allow for a quick development
of remaining reserves in Pit 2 where the Franklin No. 12 seam is currently exposed. Plant fossils
are abundant in the Puget formation shale and siltstone units and were observed during mining
operations (Morris 2015). Additional mining of such shale and siltstone units are not anticipated
under the Proposed Action Alternative. Overburden above the Franklin No. 12 seam is

20
Environmental Assessment John Henry No. 1 Mine
predominantly sandstone that contains few plant fossils (OSMRE 1985, Morris 2015). Spoil
material in the backfill and in the spoil piles consists primarily of the overburden units described
above including Vashon till, sandstone, shale, and siltstone.

Geologic-related hazards in King County could include earthquakes, landslides, and volcanic
activity. Earthquakes have historically occurred in Western Washington. The last major
earthquake was in 2001 near Nisqually, Washington with a 6.8 earthquake on the modified
Mercalli intensity scale (1.0 10.0) which is approximately 40 miles away from the City of Black
Diamond (Pacific Northwest Seismic Network 2014). Landslides are most likely to occur during
the rainy season, but can also occur as a result of earthquakes. They occur primarily on steeper
slopes with unstable or loose soil conditions (WA DNR 2014). Two active volcanoes are present
in the Cascade Mountain Range and associated hazards would be falling ash and mudflows
resulting from an eruption.

3.3.2 Environmental Consequences

Vertebrate remains have not been noted in the past and are not expected to be uncovered by
mining under the Proposed Action Alternative. In the event they are uncovered, PCCC would
notify the Burke Museum at the University of Washington to conduct an investigation as
prescribed in 36 CFR 800, Protection of Historic Properties.

According to U.S. Geologic Survey, the probability of an earthquake greater than 5.0 occurring
in the vicinity of the City of Black Diamond in the next 20 years is 30% (USGS 2009). Slope
conditions at the Mine would be steep in areas of active mining under the Proposed Action;
however, measures would have already been taken to secure the area under the mining permit.
According to a Washington Department of Natural Resources (WDNR) study, the area
surrounding Maple Valley is in a low hazard zone from potential eruptions and would not
experience adverse impacts related to mudflows or volcanic ash (Cakir and Walsh 2012).
Therefore, potential impacts from geologic related hazards would cause temporary and
negligible impacts to the Mine and the potential for occurrence at the Mine is very rare.

3.3.2.1 Proposed Action Alternative

Under the Proposed Action Alternative shale and siltstone overburden units that contain
abundant plant fossils would be disturbed by mining of the additional acreage (29.7 acres). The
removal and replacement of overburden and spoil would have moderate impacts to the
properties, structure, and appearance. However, these changes would not result in a loss of
scientific and educational values for geologic and paleontological resources. Therefore, the
effect on the geology and paleontology, within the proposed mining area, is direct, moderate,
and long-term. This is especially the case when compared to previous mining within the permit
area where shale and siltstone were the primary overburden units and fossils were abundant.
Geologic impacts would be restricted to the mine permit area and would not result in any
indirect impacts.

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Environmental Assessment John Henry No. 1 Mine
3.3.2.2 No Action Alternative
Under the No Action Alternative, PCCC would not disturb additional geologic and
paleontological features so there would be no additional impacts. Some fossil bearing material
may be encountered in the external spoil piles which would be partially removed to achieve
AOC. Overall impacts would be direct, negligible, and long-term. Geologic impacts would be
restricted to the mine permit area and would not result in any indirect impacts.

3.4 Water Resources / Hydrology

3.4.1 Surface Water

3.4.1.1 Affected Environment

The John Henry No. 1 mining area is located in three sub-watersheds: Ginder Lake, Mud Lake,
and Lake No. 12. Ginder Lake and Mud Lake both drain to the west via correspondingly named
creeks, flowing into Ginder Creek then to Rock Creek and then into Lake Sawyer. Lake 12 and
Ginder Creek drainage areas have lost 13 acres (2.9 percent of pre-mine watershed area) and
Mud Lake Creek drainage basin has gained 13 acres (increase of 3.5 percent of pre-mine
watershed area) from previous mining activity. Figure 5 shows the location of surrounding water
bodies, sediment control structures, water-monitoring locations, and major drainage structures.
There are no wild and scenic rivers located within or adjacent to the permit area (National Wild
and Scenic Rivers System 2016).

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Environmental Assessment John Henry No. 1 Mine
Figure 5. John Henry No. 1 Mine Surface Water Control System

All surface water runoff from disturbed areas of the mine is captured by drainage ditches and
conveyed to one of several sedimentation ponds (Pond-B, F, G, I, A, A, H1, and H2) before

23
Environmental Assessment John Henry No. 1 Mine
being discharged from the permit area at NPDES discharge points. Ponds B, F, and G
discharge into Ginder Lake which then discharges into Ginder Creek and Ponds I, H1, and H2
discharge into Mud Lake Creek which discharges into Ginder Creek. Figure 5 illustrates
prominent features in PCCCs surface water control system.

Surface water quality is monitored under sampling programs established by both OSMRE and
Washington Department of Ecology (WDOE) through the OSMRE water-monitoring program
and the NPDES permit (see Appendix B, Water Resources). NPDES permits are issued under
the Clean Water Act by WDOE to regulate discharges and set numerical and other limitations
on water quality to control pollution. From June 1992 through February 2008, OSMRE and
WDOE programs both monitored surface water discharges at the mine. In March 2008, WDOE
implemented a NPDES permit which required an event-driven sampling program. Under this
program, discharge from each sediment pond on the active portion of the permit is sampled
each month during the first two storm events with greater than 0.5 inch of rainfall (WDOE 2008)
(see Appendix B, Water Resources). The A and A' ponds were removed from the NPDES
permit in a modification dated December 28, 2012 and therefore are not included in the current
surface water monitoring schedule. The 2012 NPDES permit is still in effect until WDOE
approves a new permit or modification. Table 3 shows the NPDES permit effluent limitations.
Figure 6 shows the locations of the monitoring points.

Table 3. NPDES Permit Effluent Limitations

Parameter Effluent Limitations

Phosphorus (6 Month Rolling Average) 41 g/L (microgram per liter)
Phosphorus (Maximum Daily) 82 g/L
pH 6.5-8.5
Turbidity 25 NTU
Dissolved Oxygen Minimum 9.5 mg/L
Oil Sheen No visible oil sheen
Hexavalent Chromium 15.3 g/L
Copper 14.5 g/L
Source: WDOE 2008

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Environmental Assessment John Henry No. 1 Mine
Figure 6. OSMRE Water Monitoring Locations

25
Environmental Assessment John Henry No. 1 Mine
There are two lakes located outside of the permit boundary: Lake No. 12 and Lake Sawyer.
Lake No. 12 is situated just east of the permit area and discharges to the east through a wetland
area, eventually flowing to the Green River. Lake Sawyer is a lake located within the City of
Black Diamond limits and offers recreational and other values to the local community. It is
approximately 280 acres in size and has an upstream watershed of 8,130 acres. The John
Henry No. 1 Mine permit area occupies 480 acres or 6 percent of the total watershed area. The
lakes primary inlets are Ravensdale Creek and Rock Creek which enter from the south and the
main outlet is Covington Creek which drains to the west. Figure 7 shows the regional drainage
and cumulative hydrologic impact area as determined by OSMRE in the 2016 CHIA.

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Environmental Assessment John Henry No. 1 Mine
Figure 7. Regional Drainage and Cumulative Hydrologic Impact Area

1
For acronym definitions see LIST OF ABBREVIATIONS AND ACRONYMS

27
Environmental Assessment John Henry No. 1 Mine
Lake Sawyer has had water quality problems since the 1970s related to eutrophication2, with
phosphorus thought to be the main cause. Naturally occurring phosphorus loading, in addition to
the gradual urbanization of the area, prompted the WDOE in 1991 to conduct a study on the
Lake and institute a Total Maximum Daily Load (TMDL) for phosphorus on the incoming
streams. The TMDL was instituted to target a total phosphorus concentration no greater than 16
g/L at Lake Sawyer.

Data representative of baseline conditions was provided in the 1984 CHIA and the 1984
Probable Hydrologic Consequences (PHC) for the John Henry No. 1 Mine (OSM 1984), see
Table 4. Baseline surface water data were collected monthly from February to August 1982 at
five monitoring stations. Surface and groundwater conditions in the permit area are similar to
other areas in central Washington with very little total dissolved solids, low concentrations of
iron and manganese, low trace metals, and low alkalinity. The following table provides data on
the baseline surface water quality conditions in the vicinity of the mine.

2
Excessive richness of nutrients in a lake or other body of water, frequently due to runoff from the land, which causes a dense
growth of plant life and death of animal life from lack of oxygen (Merriam-Webster 2017).

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Environmental Assessment John Henry No. 1 Mine
Table 4. Baseline Surface Water Quality Data for the John Henry No. 1 Mine
Analyte Minimum Maximum Average Standard
n Median 90th 95%
Deviation
Percentile Confidence
Interval

Flow (cfs) 0 5.69 1.48 1.8 21 0.453

4.742 5.06

Temperature (degrees 6.7 20.5 12 4.5

25 11.2
20.2 20.9
C)

pH 5.5 7.9 6.93 0.65 25 7

7.79 8.21

Conductivity 32 195

113

51.7
24 129
172.5
215

(mhos/cm)

Arsenic (mg/L) 0.002 0.005 0.0035 0.0021 2 0.0035

N/A 0.0077

Cadmium (mg/L) 0.001 0.002 0.0015 0.0007 2 0.0015

N/A 0.0029

Calcium (mg/L) 3
16.3 8.32 5.04 10 8.55
16.17 18.2

Chromium (mg/L) 0.01 0.01 0.01 0 2 0.01

N/A 0.01

Total Iron (mg/L) 0.17 2.1 0.5916 0.43 25 0.43

1.22 1.44

Dissolved Iron (mg/L) 0.05 0.78 0.28375 0.187 24 0.23

0.65 0.650

Lead (mg/L) 0.01 0.01 0.01 0 2 0.01

N/A 0.01

Magnesium (mg/L) 1.2 10.3 4.41 3.11 10 4.15

10.05 10.52

Total Manganese 0.01 0.31 0.05692 0.0711 25 0.03

0.182 0.196
(mg/L)

Dissolved Manganese 0.002 0.03 0.0164 0.0107 5

0.02 N/A 0.037
(mg/L)

Mercury (mg/L) 0.001 0.001 0.001 0 2 0.001

N/A 0.001

Potassium (mg/L) 0.03 1.5 0.753 0.416 10 0.85

1.46 1.57

Sodium (mg/L) 2.8 12

5.71 2.81 10
6
11.58 11.2

Zinc (mg/L) 0.005 0.01 0.0078 0.0021 6 0.008

N/A 0.012

Nitrate/Nitrite (mg/L) 0.43 2.9 1.325 0.864 10 1.14

2.85 3.019

Bicarbonate Alkalinity 12
170 58.8

49.1 10 53.5
162.1 155

(mg/L)

TSS (mg/L) 2
96
10.5 18.7 24
5
16.5 47.1

TDS (mg/L) 46
130
85.4 30.5 9
88
130
145

Chloride (mg/L) 1
3
1.9 0.567 10
2
2.9 3.01

Sulfate (mg/L) 4
12
8.9 2.9 10
10
12
14.7

N/A = Not Applicable

Source: OSM 1984

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Environmental Assessment John Henry No. 1 Mine
The water quantity varies seasonally at the John Henry No. 1 Mine due to the precipitation
patterns in the area. The highest average runoff occurs in January whereas the lowest tends to
occur in September towards the end of summer (PCCC 2011a).
3.4.1.2 Environmental Consequences
Protective measures of surface water resources include limiting vegetation clearing and removal
to only those areas immediately required for mining, re-establishing vegetative cover on
disturbed areas as quickly as possible by grass seeding, tree planting and controlling runoff by
implementing and following the approved Drainage and Sediment Control Plan (PCCC 2011a).

Sediment ponds are operated as detailed in the Drainage and Sediment Control Plan approved
in the PAP (PCCC 2011a). Ponds are inspected regularly by PCCC personnel and OSMRE
inspectors to ensure proper functioning. Sediment and water storage capacities are assessed
annually to ensure ponds maintain their designed capacities.
3.4.1.2.1 Proposed Action Alternative
Impacts to surface water flows from the Proposed Action Alternative are estimated to be minor.
The Proposed Action Alternative calls for removal of vegetation and mining-related disturbance
to 29.7 acres which could result in short-term impacts by changing transpiration3, infiltration, and
runoff in the Mud Lake Creek drainage basin; however, the size of the drainage basin areas
would not change.

Potential impacts to surface water quality from the Proposed Action Alternative would include
increases in sediment load and possible increases in total suspended solids, bicarbonate
alkalinity, calcium, magnesium, sodium, specific conductivity, sulfate, chloride, manganese,
zinc, and total phosphorus. Treatment capabilities of sedimentation ponds have been improved
by adopting a variety of enhancements to mitigate suspended solids and other water quality
parameters. These enhancements include construction of sumps just before the ponds, adding
WDOE approved polymers to aid in settling the sediment, placing gravel packs around the
discharge standpipes to capture suspended solids, and, equipping discharge pipes with valves
to control outflow volumes.

All sedimentation ponds have been designed to contain the 10-year, 24-hour storm event, and
to reduce sediment load by providing sufficient detention time and volume to allow sediment to
settle. The drainage control plan map is shown in Figure 5. See Appendix B, Water Resources,
for figures representing water quality trends at John Henry No. 1 Mine associated with sediment
loading, total suspended solids, and total phosphorus loading. Figures B-1 B-6 presented in
Appendix B shows a general downward trend of sediment and total phosphorus loading.

Although the potential effects of the Proposed Action Alternative on surface water quality will be
greater compared to the recent period of inactivity, impacts are anticipated to be less than those

3
the process where plants absorb water through the roots and then give off water vapor through pores in their leaves

30
Environmental Assessment John Henry No. 1 Mine
experienced during prior periods of active mining. Reduced impacts are expected due to the
small area of additional disturbance (29.7 acres), and to additional measures being
implemented to control and treat surface water runoff. See Appendix B, Water Resources, for
more detailed information on surface water quality data.

Impacts to surface water quantity as a result of previous mining and reclamation operations
have been minor (Table 4). The dewatering of mine pits and pumping of water throughout the
mine site impacts discharge into the Mud Lake Creek and Ginder Creek sub-watersheds. Both
of these sub-watersheds discharge into Ginder Creek, which in turn discharges into Rock Creek
and Lake Sawyer. The large-scale effects of runoff variations at the John Henry No. 1 Mine in
the 1993-2015 dataset are minimal when evaluated against their effect in the local area.
Consequently, the Proposed Action Alternative will result in a similar surface water quantity
impact observed during the previous mining period and constitutes a minor and short-term
impact.

Impacts to surface water quality would be minor and short-term, based on the metrics in Table 4
and the analysis of impacts during the previous active phase at the mine. Water quality
exceedances at NPDES outfalls may sometimes occur, but regular exceedances are not
anticipated.

Potential indirect impacts from the Proposed Action Alternative include coal dust deposition in
the surface water regime from coal transportation outside the permit area. Wheel washes will be
used prior to trucks exiting the permit area to reduce mud and dust on the roads. Coal truck
beds will be covered to reduce coal particles which could in turn influence the surface water
regime. Because the amount of coal being hauled under the Proposed Action Alternative is
small (approximately 84,000 tons per year). Negligible indirect impacts to surface water
resources are anticipated.

3.4.1.2.2 No Action Alternative

Similar to the Proposed Action Alternative, actions under the No Action Alternative may increase
the sediment load and certain chemical parameters of the stormwater runoff. Impacts of the No
Action Alternative on surface water quantity and quality could be greater than the Proposed
Action Alternative in the short-term, as the volumes of material and distance for the material to
be moved for reclamation would be greater over a much shorter period of time. These longer
roads are not required under the Proposed Action Alternative. The reclamation plan would be
implemented immediately upon disapproval of the proposed permit revision and year-round
reclamation would commence. However, the long-term effects would be similar. Under the
Proposed Action Alternative mining activities are generally confined within Pit 2 where water is
retained in the Pit and would be pumped dry to facilitate mining. Nonetheless, impacts on
surface water quality are expected to be minor and short-term for the No Action Alternative.

31
Environmental Assessment John Henry No. 1 Mine
Impacts on surface water quantity are expected to be minor and short-term. Indirect impacts to
surface water resources from the No Action Alternative are not anticipated.

3.4.2 Groundwater

3.4.2.1 Affected Environment

Applicable water quality criteria used for comparison to historical datasets was based on
NPDES permit and WDOE criteria listed in WAC-173-200-040 regarding groundwater quality
guidelines for drinking water supplies. These drinking water standards adequately protect the
use of the groundwater resource in the area. The current NPDES permit for the John Henry
No.1 Mine indicates that exceedances of water quality criteria would result in increased
monitoring until such time as the standards are met (WDOE 2012). Triggering limits for
additional groundwater monitoring per the NPDES Permit are summarized in Table 5. No
NPDES water quality violations have occurred for the mine regarding groundwater quality.

Table 5. Triggering Limits for Additional Ground Water Monitoring (NPDES Permit)
Station Name
Parameter Reichert Well PCCC Well 12-4 Well Pit 2
pH 6.5 to 8.5
0.122 0.05
Arsenic 0.05 mg/L 0.05 mg/L
mg/L mg/L
0.05 0.05
Lead 0.05 mg/L 0.05 mg/L
mg/L mg/L
0.05 0.05
Chromium 0.05 mg/L 0.05 mg/L
mg/L mg/L
0.002 0.002
Mercury 0.002 mg/L 0.002 mg/L
mg/L mg/L
0.092 0.05
Manganese 0.113 mg/L 0.135 mg/L
mg/L mg/L
No No
Visible Sheen No Sheen No Sheen
Sheen Sheen

Source: WDOE 2008

Groundwater monitoring of wells within the permit and adjacent area has been conducted at the
mine since 1986. Due to low hydraulic conductivity of saturated portions of the Puget Group,
minimal impact on groundwater quantity has been observed throughout the life of the John
Henry No. 1 Mine. The 1984 CHIA predicted small temporary drawdown of local wells in the
adjacent area could occur due to mine dewatering activities as mining progressed through
potential recharge areas. Original estimates indicated seepage into the mining pits was
projected to be between 3 and 5 gallon per minute; however, during actual mining of the two pits
visual observation indicates that the projections were overstated. Pit 1 was excavated to a depth
32
Environmental Assessment John Henry No. 1 Mine
of over 325 feet with only a few minor wet spots apparent on the pit walls and no measurable
groundwater discharge into the mine pit.

Groundwater is currently monitored under sampling programs established by both OSMRE and
WDOE through the NPDES permit (see Appendix B, Water Resources). WDOE requires
monitoring of the water in Pit 2 as potential discharge to groundwater. OSMRE does not
consider the water in the mining pits to be groundwater and therefore does not require
monitoring.

Comparison to baseline metrics was completed to determine whether water quality constituents
not addressed in WDOE groundwater criteria or the NPDES permit have exhibited increased
concentrations. The only discernable impacts have been increases in calcium and sulfate over
baseline metrics at the Reichert Well.

In the 2016 John Henry No. 1 Mine CHIA, groundwater quality data from Reichert Well, PCCC
Well, 12-4 Well, and Pit 2 was evaluated to determine whether the mining operation had caused
any historic impacts to water quality, specifically during years of active mining. The data
collected at the three wells was compared to water quality criteria to determine impact
designations (OSMRE 2016). In the baseline study conducted for the initial CHIA (Simons Li
and Associates 1984), it was demonstrated that the groundwater conditions within the Puget
Group are highly heterogeneous and a high degree of natural variability is present in terms of
water quality parameter concentrations. To date, only short-term minor impacts to water quality
attributable to mining and reclamation operations at the John Henry No. 1 Mine have been
observed in any of the wells listed in the OSMRE or NPDES monitoring programs.

Baseline studies conducted for initial permitting efforts and environmental analyses indicate no
regional aquifer present and that the glacial drift overlying the area limits groundwater
movement and potential water supply development. The Puget Group bedrock, which underlies
the John Henry No. 1 Mine and surrounding area, is described as having poor water-bearing
characteristics and being a very heterogeneous aquifer, with generally poor permeability4.
Groundwater quality in the area is characterized as relatively high pH (7.7-8.9), presumably due
to high bicarbonate5 concentrations of the marine deposits. PCCCs mining activities since 1986
indicate that there is not a significant, interconnected groundwater resource in the Puget
formation within the permit area (OSMRE 2014). Groundwater occurrence is generally
discontinuous, likely due to the low permeability of the Puget bedrock and reliance on
secondary permeability for water transmission.

Since 2004, PCCC has monitored water quality in Pit 1 to determine if the water quality of Pit 1,
once the PML is fully reclaimed, would comply with 30 CFR 816.49(b)(2), which requires the

4
The state or quality of a material or membrane that causes it to allow liquids or gases to pass through it (Merriam-Webster 2017).
5
A bicarbonate is a salt containing the anion HCO3 (Merriam-Webster 2017).

33
Environmental Assessment John Henry No. 1 Mine
quality of impounded water to be suitable on a permanent basis for its intended use. The
intended use of the lake is fish and wildlife habitat. Projected water quality is discussed more
fully in Section 3.5.8.1 of the PAP (PCCC 2011a). This information supports the determination
that the water quality of the lake would be suitable for its intended use and would meet
applicable State and Federal water quality standards.

Baseline groundwater data was provided in the Appendices of the 1984 PHC. The following
table (Table 6) depicts summary statistics of bi-yearly data collected from four groundwater
monitoring wells in 1982.

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Environmental Assessment John Henry No. 1 Mine
Table 6. Baseline Groundwater Quality Data for the John Henry No. 1 Mine
Analyte Minimum Maximum Average Standard
n Median 95% Confidence
Deviation
Interval

Temperature (degrees 7.2 15

10.1 3.008 8 9.15
16.02
C)

pH 6.2 8.9 7.71 1.19 8 7.9 10

Conductivity 75
673 399

217

8

440
825

(mhos/cm)

Arsenic (mg/L) 0.002 0.064 0.0177 0.031 4 0.0025

0.078

Cadmium (mg/L) 0.002 0.002 0.002 0.000 4 0.002

0.002

Calcium (mg/L) 3.2 60

19.07 27.3 4
6.55 72.6

Chromium (mg/L) 0.01 0.02 0.0125 0.005 4

0.01 0.022

Total Iron (mg/L) 0.04 33

7.04 12.3 8
1.105 31.1

Dissolved Iron (mg/L) 0.01 1.1 0.235 0.394 8

0.04 1.007

Lead (mg/L) 0.01 0.022 0.013 0.006 4 0.01

0.025

Magnesium (mg/L) 1.2 37

10.7 17.533 4
2.35 45.09

Total Manganese 0.006 0.52 0.113 0.182 8 0.035

0.469
(mg/L)

Dissolved Manganese 0.005 0.03 0.0118 0.009 6 0.01

0.030
(mg/L)

Mercury (mg/L) 0.001 0.004 0.00175 0.002 4 0.001

0.005

Potassium (mg/L) 0.6 6.7 2.87 2.66 4

2.1 8.1

Sodium (mg/L) 3
160
75.2 81.4 4
69
234

Zinc (mg/L) 0.019 0.58 0.299 0.397 2

0.299 1.07

Nitrate/Nitrite (mg/L) 0.06 4

2.03 2.78 2
2.03 7.49

Bicarbonate Alkalinity 22
390 280

174

4

355
622

(mg/L)

TDS (mg/L) 57
630 339

234

4

335
798

Chloride (mg/L) 2
8 3.75

2.87 4 2.5
9.38

Sulfate (mg/L) 1
6
3 2.44

4 2.5
7.8

Source: OSM 1984

Baseline groundwater conditions in the Puget Group were highly variable at locations around
the Mine. All but one well exhibited slightly basic pH. Conductivity, TDS, total iron
35
Environmental Assessment John Henry No. 1 Mine
concentrations, hardness, and other analyte concentrations were variable. Results for toxic
constituents were mostly at the MDL; however, a few instances of high arsenic concentrations
were recorded.
3.4.2.2 Environmental Consequences
Historic groundwater data from Reichert Well, PCCC Well, 12-4 Well, and Pit 2 was evaluated
to determine potential impacts from the Proposed Action Alternative. This analysis was
conducted under the assumption that historical impacts documented from when the mine was
previously active are an indicator of whether impacts would occur from the Proposed Action
Alternative.
3.4.2.2.1 Proposed Action Alternative
Mining activities have had negligible impacts on groundwater quantity due to the low
permeability of the bedrock. As presented in the CHIA, the only groundwater losses detected
from the mining operation were at the PCCC well, which occurred when the mine was active
(OSMRE 2016). The PCCC well is used for mine drinking water and mine water supply.

The data collected at the Reichert Well, PCCC Well, and the 12-4 Well was compared to WDOE
drinking water and NPDES water quality criteria to determine impact designations.
Exceedances of water quality criteria at the Reichert well from 1993 2011 were limited to iron
in 2.9 percent of samples, mercury in 2.6 percent of samples, and for manganese in 4.2 percent
of samples. Exceedances of water quality criteria at the PCCC well from 1993 2011 occurred
with iron in 14.5 percent of samples, mercury in 2.6 percent of samples, and in manganese in
1.4 percent of samples. Exceedances of water quality criteria at the 12-4 well from 1993 2011
occurred with iron in 25.7 percent of samples, mercury in 2.56 percent of samples, and in
manganese in 1.4 percent of samples. As such, a minor direct impact to groundwater quality is
predicted from the Proposed Action Alternative.

Groundwater quality in an area adjacent to mining activity could potentially be affected from
mining due to the addition of various chemical constituents from the increased surface area of
spoil material. The process is dependent on the solubility of the minerals in the spoil. Water can
more readily react with rock that has been physically crushed by the surface mining process
than it can with undisturbed rock. The majority of the strata in the John Henry No. 1 Mine area
are alkaline, which limits the potential for additional dissolved metals in groundwater.

Overall, the measured impacts to groundwater quality in the area surrounding the John Henry
No. 1 Mine have been minor and short-term. To date, only short-term minor impacts regarding
groundwater quality have been observed in wells listed in the OSMRE and NPDES monitoring
programs based on the evaluation criteria in Tables 10-11. Under the Proposed Action
Alternative direct impacts are confined within the permit area and would be minor and short-
term for groundwater quality and negligible for groundwater quantity. Indirect impacts to
groundwater are not anticipated because any impacts associated with the Proposed Action
Alternative would be confined to the permit area.

36
Environmental Assessment John Henry No. 1 Mine
3.4.2.2.2 No Action Alternative
The No Action Alternative would not have an additional impact on groundwater resources.
Impacts would be similar to those associated with the Proposed Action Alternative, with the
exception that the potential for groundwater impacts at the Reichert Well would be lower. Direct
groundwater quantity impacts would be negligible, short-term, and confined within the permit
area. Indirect impacts associated with the No Action Alternative are not anticipated because any
impacts associated with the No Action Alternative would be confined to the permit area.
3.5 Climate and Climate Change

3.5.1 Affected Environment

The climate in the area is moderate with relatively cool summers and mild winters.
Measurements at the mine since 1982 show average rainfall of about 51 inches per year. Most
of the rain falls from mid-October until late April.

Carbon dioxide (CO2), Methane (CH4), and Nitrous Oxide (N2O) as well as other manufactured
industrial pollutants are all greenhouse gases (GHGs) and can contribute to the greenhouse gas
effect. These pollutants are characterized according to their global warming potential (GWP), a
relative measure of how effective a gas is at trapping heat. For example, 1 unit of CO2 has a
100-year global warming potential of 1, whereas, an equivalent amount of CH4 has a 100-year
global warming potential of 28 (IPCC 2015).

GHG emissions occur at all stages in a coals life cycle from coal mine construction and
extraction to coal combustion. Under the Proposed and No Action Alternatives CO2, CH4, and
N2O GHGs were evaluated as million tons of carbon dioxide equivalents (CO2e) using 100-year
global warming potentials.

3.5.2 Environmental Consequences

Climate change analysis for the purpose of this EA includes quantification of direct and indirect
greenhouse gas emissions (GHGs). Qualitative and quantitative evaluations of potential
contributing factors are included where appropriate and practicable.

The EPA and other federal agencies estimate the social cost of carbon (SC-CO2) to calculate
the climate benefits of rulemakings and for use in cost-benefit analyses of proposed regulations
that could impact cumulative global emissions. Calculating the SC-CO2 is a way to estimate the
economic damages associated with an increase in CO2 emissions. The calculated dollar cost of
a metric ton of CO2e, typically expressed as one million tons in a single year, represents the
value of damages avoided for an associated carbon emissions reduction.

According to the EPA: The SC-CO2 is meant to be a comprehensive estimate of climate

change damages and includes changes in net agricultural productivity, human health, property

37
Environmental Assessment John Henry No. 1 Mine
damages from increased flood risk, and changes in energy system costs, such as reduced costs
for heating and increased costs for air conditioning. However, given current modeling and data
limitations, it does not include all important damages. The models used to develop SC-CO2
estimates, known as integrated assessment models, do not currently include all of the important
physical, ecological, and economic impacts of climate change recognized in the climate change
literature because of a lack of precise information on the nature of damages and because the
science incorporated into these models naturally lags behind the most recent research.
Nonetheless, the SC-CO2 is a useful measure to assess the benefits of CO2 reductions. (EPA
2016g).
While an estimate of the GHG emissions is made, given data and resources available, the net
effect on global GHG emissions or climate change cannot be made. Given the global nature of
climate change, calculating the SC-CO2 from an individual project would require assessing the
impact on the global market for coal and the corresponding global effect on GHG emissions. An
estimation of the SC-CO2 for this project would necessitate speculation and use of assumptions
about (1) the global market for various energy sources, (2) future emissions of GHGs, (3) the
effects of past and future emissions on the climate system, (4) the impact of changes in climate
on the physical and biological environment, and (5) the translation of these environmental
impacts into economic costs or benefits on a global scale.
Although CEQ NEPA regulations allow agencies to use a cost-benefit analysis in a NEPA
analysis in certain circumstances (40 CFR 1502.23), it is not required. The CEQ regulation
states (in part), ...for the purposes of complying with the Act, the weighing of the merits and
drawbacks of various alternatives need not be displayed in a monetary cost-benefit analysis and
should not be when there are important qualitative considerations. Unlike a cost-benefit
analysis, the disclosure of revenue, wages, jobs, and royalties is primarily a regional economic
impact analysis that estimates impacts on economic activity, which are not considered benefits
or costs. The CEQ guidelines recognize that there may be adverse environmental impacts from
the use of fossil fuels and this EA discloses the impacts qualitatively as potential emissions. The
analysis in total for all resources compares and discloses the impacts without converting them
to a monetary value. Without any monetized benefits or costs for other resource impacts,
monetized estimates of the SC-CO2 would be presented in isolation, without any context for
evaluating their significance.
OSMRE did not apply the social cost of carbon protocol in this analysis because the purpose of
an EA is to determine whether to prepare an EIS or a finding of no significant impact (43 CFR
Part 46 Subpart D). Specific threshold levels for the determination of significance based on cost
or benefit have not been established and therefore would not be useful in determining
significance. The SCC would generate numbers that are OSMRE cannot compare to reference
point for determining whether the numbers are significant. Therefore, OSMRE did not apply the
SCC protocol in this analysis. GHG coal combustion emissions are quantified and
contextualized against local GHG emissions in Section 3.4.3.1, Proposed Action Alternative.

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Environmental Assessment John Henry No. 1 Mine
The GHGs associated with coal mining are carbon dioxide (CO2) as a result of coal combustion,
the use of heavy diesel equipment and transport; nitrogen oxides (N2O) as a result of blasting;
and methane (CH4) released into the atmosphere as a result of coal mining and processing.
According to the National Climate Change Viewer, the State of Washington is expected to have
regionally-specific impacts in future years as compared to historical data (see Table 7). Due to
the limited duration of the Proposed (seven years) and No Action Alternatives (two years) it is
not expected that full extent of the climate change impacts described below would be realized
and would therefore not contribute or otherwise create impacts to the projects construction,
operation, or reclamation activities. However, smaller scale weather events such as flooding or
drought may occur during the life of mine and may require the need to consider different seed
mixes during reclamation to account for the higher temperatures and increased precipitation
levels. This change in reclamation would be re-evaluated before beginning reclamation activities
and the Operator would consult with OSMRE if it resulted in changes to the approved
reclamation plan.

Table 7. Washington State Climate Change Impacts

Variable 1950-2005 2050-2074 Change
Snow 3.9 inches 1.6 inches - 2.2 inches
Temperature 56.5 F 62.6 F + 6.1F
Precipitation 12.6 inches per month 13.0 inches per month + 0.4 inches per month

Source: USGS 2014

Lesser known climate change impacts are likely to have the following impacts in the Pacific
Northwest (EPA 2016b):

Water and Snow

Decreased water for irrigation, fish, and summertime hydropower production.

Warmer winter temperatures and increased winter precipitation as rain are projected to
reduce the winter snowpack.

Increased flood risks to rivers that receive waters from both winter rains and peak runoff
in late spring are expected.

Salmon
Increased difficulties for migration and spawning due to increased winter floods,
decreased summer stream flow, and increased water temperatures.

Forests
Increased chance of forest fires, insect outbreaks, and diseases from rising
temperatures, changes in precipitation, and reduced soil moisture.

39
Environmental Assessment John Henry No. 1 Mine
 Decreased forest types and ecosystems at high elevations due to the inability to survive
changing climatic conditions resulting in economic impacts to the timber industry.

Wildlife
Potential for extinction of local populations and loss of biological diversity.

Warming waters and ocean acidification threaten economically important marine species
and coastal ecosystems.

Increased algal blooms due to warmer water temperatures resulting in beach closures
and declines in recreational shellfish harvests.

Coastal Flooding and Erosion

Increased coastal erosion and beach loss due to rising sea levels.

Increased landslides due to increased winter rainfall.

Permanent inundation, especially in south Puget Sound around Olympia.

Increased coastal flooding due to sea level rise, storm surge, and increased winter
streamflow from interior and coastal watersheds.

Agriculture
Longer growing season and higher levels of atmospheric carbon dioxide in the short-
term which may be beneficial to crops.

Reduced water availability for irrigation, higher temperatures, and changes in pests,
diseases, and weeds which may harm crop yields in the long-term.

3.5.2.1 Proposed Action Alternative

3.5.2.1.1 Methane
As coal is produced and processed, it emits methane, a GHG. Per the Intergovernmental Panel
on Climate Change (IPCC) guidelines, Northwest coal contains in-situ methane of
approximately 0.08 cubic meters per metric ton (IPCC 2014, EPA 1996). It is unlikely that this
entire amount will be emitted during mining and processing as some remains within the
processed coal. But for the purpose of this analysis it is assumed that all would be emitted.
CO2e for methane ranges considerably depending on the time horizon over which it is viewed. A
100-year time horizon is commonly used resulting in a conversion factor of 28 metric tons of
CO2e to one ton of methane (IPCC 2014). Expected production under the Proposed Action
Alternative is 84,000 short tons per year of coal. Thus 9,725 cubic meters of methane are
emitted annually. A conversion factor of 0.016929 metric tons of CO2e per cubic meter of
methane is used to convert to CO2e. This is based on published guidelines (EPA 2014, IPCC

40
Environmental Assessment John Henry No. 1 Mine
2014). Estimated annual methane-derived GHGs from coal mining and processing is thus
estimated to be 165 metric tons CO2e.
3.5.2.1.2 Coal Preparation Plant
The coal preparation plant consumed an average of 12 kilowatt hours (kWh) per ton processed
when it operated from 1991 1998 (PCCC 2015a). Planned production under the Proposed
Action Alternative is 84,000 short tons per year. At this rate the plant is estimated to consume
1,560,000 kWh of electricity per year. Entering this into WDOEs calculation worksheet for
electricity use shows 64 metric tons of CO2e emitted annually from electricity use at the coal
preparation plant.

In addition to electricity consumption, the plant would use a front-end loader and a refuse
haulage truck. The loader is expected to operate 1,000 hours per year and consume 10 gallons
of diesel per hour or 10,000 gallons per year. The truck would operate 500 hours per year and
consume 3 gallons per operating hour for an additional 1,500 gallons per year. This total of
11,500 gallons per year yields 118 metric tons of CO2e when entered into the WDOE
spreadsheet. Total CO2e attributed to the plant is 182 metric tons.

3.5.2.1.3 Mining and Reclamation

Under the Proposed Action Alternative, PCCC would operate standard surface mining
equipment including articulated trucks, a dozer, loader, grader, and excavator. Fuel
consumption is estimated from the Caterpillar Performance Handbook (Caterpillar 2013). This
provides annual diesel fuel consumption as shown in Table 8. The 177,700 gallons of diesel fuel
results in 1,820 metric tons per year of CO2e.

Blasting emits N2O which is 298 times more potent than CO2 as a GHG (EPA 2016e). Based on
past operating performance information, PCCC expects that 0.79 pounds of explosives (powder
factor) would be consumed for every BCY of overburden blasted. As noted in Section 1 above,
PCCC would blast 1,021,090 BCY of overburden per year. The 0.79 powder factor results in
806,661 pounds or 403 tons of explosives used per year.

PCCC expects that explosives will be predominately ammonium nitrate fuel oil mixture (ANFO).
It is assumed that explosives would be a 50:50 blend of emulsions and ANFO. Emulsion
explosives are waterproof and are often mixed with ANFO depending on drill hole conditions.
Emulsions emit more N2O per unit than ANFO. This mixture would produce 28.76 pounds of
N2O per ton of explosives used (Arnold et al. 2013). Applying these parameters and converting
to metric units show 5.27 metric tons of N2O emitted from blasting. This is 1,634 metric tons per
year CO2e using the 298x factor.
Once mining is completed and final reclamation begins, one 40,000 ton articulated truck and the
980 loader will not be required to complete remaining reclamation. Additionally, the HCR1500
drill will not be required as active drilling and blasting will not be occurring. During this phase of

41
Environmental Assessment John Henry No. 1 Mine
operation the mine will consume 118,500 gallons and emit 3,137 million metric tons of CO2e as
shown on Table 8.

Under the Proposed Action Alternative, coal is mined, processed, and transported to one of
several potential users. These include three existing regional cement manufacturing plants, an
existing lime kiln, and a pulp mill. PCCC has a contract to supply a portion of the total 84,000
tons of coal to one specific plant located in British Columbia. It will likely sell coal to other plants
as well. These plants currently purchase coal from producers with whom PCCC competes and
are not directly linked to PCCC.

PCCC may also sell coal to one of the other two cement plants, one lime kiln and one pulp mill
that burn coal and are located in the region. Ash Grove Cement in Seattle has been an
important customer for PCCC in the past and would likely buy coal from PCCC in the future
according to PCCC. Ash Grove Cement and Lehigh Cement in Richmond, British Columbia
would emit equivalent amounts of CO2 from burning 84,000 tons of PCCC coal per year. Each
plant has different fuel mixes including a variety of waste products. Ash Grove in particular is a
major consumer of recycled tires as noted in their Air Operating Permit (PSCAA 2004). Each
plant also consumes more than 84,000 tons of coal annually when operating at full production.
This means that PCCC coal would be blended with coal from other coal producers. Under
WDOE guidelines as noted above, it is unlikely that these existing coal consumers would be
considered New sources of GHG emissions. However, for purposes of this EA, indirect
emissions from consuming 84,000 tons per year of coal are quantified.

Indirect emissions include: trucking coal directly to a customer or to a barge loading facility;
loading coal onto barges; hauling coal on barges to British Columbia; and, burning the coal in
cement or lime kilns. To estimate CO2e for transportation components, WDOE recommends that
diesel fuel consumption for each activity be estimated and then applying the conversion factor
built into the calculation model (WDOE 2011a).

3.5.2.1.4 Truck Haulage

Trucks would haul 84,000 tons of coal directly to the customer in case of the cement plant
located in Seattle or lime kiln in Tacoma and to a barge loading facility in either Seattle or
Tacoma for delivery. Mileage to either Seattle or Tacoma is 35 miles. Trucks would carry, on
average, 32 short tons of coal for each trip. This results in 2,625 truck trips per year or 183,750
miles per year for the 70 mile round trip. For highway trucks, WDOE guidance and spreadsheet
inputs vehicle miles traveled for Class 7 8 trucks. This results in an estimated 290 metric tons
per year of CO2e from truck transportation (WDOE 2011b).

3.5.2.1.5 Barge Loading

Direct loading with a front-end loader is typical and would cause the most emissions compared
to a system using loaders and conveyors. Barge capacity is 4,000 tons which would be taken
over 36 hours to load. This results in 21 barges per year and 756 hours of loading time

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Environmental Assessment John Henry No. 1 Mine
assuming all coal produced is transported via barge. The 980 Loader consumes 10 gallons per
hour of fuel according to the Caterpillar Handbook resulting in 7,560 gallons of diesel consumed
per year (Caterpillar 2013). With this input the WDOE spreadsheet shows 77 metric tons of
CO2e emissions for barge loading annually.

3.5.2.1.6 Barge Hauling

Worst-case conditions for this indirect emission would be barging 136 miles from Tacoma to
Richmond, British Columbia, Canada where two cement plants are located. Barging from
Seattle would be approximately 30 miles less than from Tacoma. For purposes of this analysis
the higher number is used. As noted above, 21 barges per year each with 4,000 tons of coal
would be shipped. The average fuel consumption for barges in the U.S. is 616-ton miles per
gallon of diesel (Texas Transportation Institute 2007). Assuming the entire 84,000 tons are
barged over the 136-mile distance results in estimated emissions of 203 tons per year CO2e
from this source. PCCC received input from one barge operator estimating average fuel
consumption of 1,500 gallons per round trip (Island Barge and Tug 2015). At 21 round trips per
year this is 31,500 gallons per year that is equivalent to 323 metric tons CO2e per year from
barging using the WDOE spreadsheet.
3.5.2.1.7 Coal Combustion
Indirect impacts occur from combusting 84,000 short tons of coal per year with heat content of
10,560 British Thermal Units per pound and 45% carbon content. Using WDOE guidelines and
worksheet (WDOE 2011a), yields 167,769 million tons of CO2e emissions annually from coal
combustion. This is the case regardless of which regional cement plant or other end user
consumes the coal.

Table 8 summarizes estimated direct and indirect emissions of GHG under the Proposed Action
Alternative.

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Environmental Assessment John Henry No. 1 Mine
Table 8. Summary of Direct and Indirect CO2e Emissions Proposed Action Alternative

MT CO2e/y

Mining and Reclamation Final Reclamation

(years 1-6) (year 7)

Direct Emissions
Methane 165

CHPP (Electricity and Diesel) 66,709

Mining and Reclamation 4,816

Final Reclamation 3,137

Total Direct 71,690 3,137

Indirect Emissions

Truck Transportation 290

Barge Loading 77

Barge Transport 323

Coal Combustion 167,769

Total Indirect 168,339

Total 240,110

When compared to local King County, Washington direct and indirect GHG emissions from the
Proposed Action Alternative would be less than two percent of total county emissions per year,
see Table 9. Although, indirect emissions from coal combustion and transportation would not
occur entirely within King County it can be expected that other areas would have similar total
GHG emissions.

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Environmental Assessment John Henry No. 1 Mine
Table 9. King County, WA GHG Emissions Inventory (2011)1
Industrial Sector Tons (CO2e)
Fires - Prescribed Fires 1,232.8
Fires - Prescribed Fires 9,006.5
Fires - Wildfires 330.2
Fires - Wildfires 2,215.1
Mobile - Non-Road Equipment - Diesel 741,470.5
Mobile - Non-Road Equipment - Gasoline 398,805.5
Mobile - Non-Road Equipment - Other 135,440.2
Mobile - On-Road Diesel Heavy Duty Vehicles 2,777.3
Mobile - On-Road Diesel Heavy Duty Vehicles 2,104,069.0
Mobile - On-Road Diesel Heavy Duty Vehicles 1,042.0
Mobile - On-Road Diesel Light Duty Vehicles 231.5
Mobile - On-Road Diesel Light Duty Vehicles 173,392.7
Mobile - On-Road Diesel Light Duty Vehicles 183.0
Mobile - On-Road non-Diesel Heavy Duty Vehicles 1,197.1
Mobile - On-Road non-Diesel Heavy Duty Vehicles 355,696.9
Mobile - On-Road non-Diesel Heavy Duty Vehicles 3307.8
Mobile - On-Road non-Diesel Light Duty Vehicles 11,604.0
Mobile - On-Road non-Diesel Light Duty Vehicles 7,646,235.0
Mobile - On-Road non-Diesel Light Duty Vehicles 128,685.7
Total CO2e Emissions 11,716,922.7

1 The table represents those emissions sources as identified according to the EPAs National Emissions Inventory.
Source: EPA 2011

Although total emissions resulting from mining, processing, transporting, and burning are
quantifiable, it is not possible to accurately assess the effects of a specific amount of CO2e
emissions on global warming and climate change. EPA estimates that 6,526 million metric tons
of CO2e were emitted from all sources in the United States in 2012 (EPA 2014). Within
Washington state 91.7 million metric tons of CO2e were emitted in 2011 (WDOE 2014). It is
reasonable to assume that the impact of direct and indirect CO2e emissions from annual
operation of the John Henry No. 1 Mine on climate change would be negligible and short-term.
Negligible is defined as causing no discernible impact on global climate or Washington States
ability to achieve GHG emission reductions by 2020. The duration of the Proposed Action would
be for seven years which is too short of a time frame to create a discernible change in climate
patterns. The Proposed Action would result in emissions below 175,000 tons of CO2e per year
for an approximate total emissions (direct and indirect) of 1 million tons of which would not
exceed Washingtons GHG emission reduction standards.

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Environmental Assessment John Henry No. 1 Mine
3.5.2.2 No Action Alternative
Direct impacts are from fuel consumed by heavy equipment used for reclamation activities. Final
reclamation plan bond calculations, found in Section 3.6 of the PAP, assume that scrapers and
dozers would be the prime items of equipment used to achieve the objectives of the plan (PCCC
2011a). Scrapers would operate 10,487 hours and dozers 4,068 hours over the two-year period.
Dozers and scrapers are each estimated to consume 15 gallons per hour of diesel for total fuel
consumption of 218,325 gallons under OSMREs bonding calculations. A grader and water truck
would be used part time and will consume an additional 10,000 gallons of fuel. This activity
results in total consumption of 228,325 gallons of diesel fuel. Using the WDOE spreadsheet,
2,338 metric tons of CO2e emissions over a two-year period are directly emitted under the No
Action Alternative (WDOE 2011b).

The impact from GHG emissions under the No Action Alternative would be less than the
Proposed Action Alternative and would be negligible and short-term because the duration of the
No Action Alternative would be for two years which is too short of a time frame to create a
discernible change in climate patterns. The No Action Alternative would result in total emissions
2,338 tons of CO2e for two years of reclamation activities which would not exceed Washingtons
GHG emission reduction standards. The No Action Alternative would not create a discernible
change in climate patterns due to its short, two-year duration. No coal would be mined,
processed, transported, or consumed. Therefore there are no indirect impacts under this
alternative.

3.6 Air Quality

3.6.1 Affected Environment

The direct impacts study area for the air quality analysis is King County. The indirect impacts
study area includes King, Snohomish, Pierce, and Kitsap counties in Washington State as well
as the Lower Fraser Valley in British Columbia. The existing environmental conditions related to
air quality in the study area are described below.

3.6.1.1 Meteorology

The Western Region Climate Center (WRCC) provides climate summaries for western states
including Washington State. The closest monitors to the Mine are: 1) the Seattle-Tacoma
International Airport, 2) Seattle-Boeing FLD/King County International Airport, and 3) the
Richmond South monitor, Richmond, BC in the Lower Fraser Valley and operated by Metro
Vancouver (WRCC 2015 and Metro Vancouver 2012).

Table 10 shows precipitation, temperature, and wind data for the Seattle-Tacoma International
Airport and Seattle-Boeing FLD/King County International Airport locations. The Richmond

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Environmental Assessment John Henry No. 1 Mine
monitor (2012 2014 Fraser Valley Air Quality Monitoring) reports a predominately easterly
wind with a smaller component from the west, and very little wind from either the north or south.
Richmond South received on an annual average of 778 1040 millimeters of precipitation per
year and annual average temperature of 10.6 C (51.08 F) 11.2 C (52.16 F) (Metro
Vancouver 2013a, 2014, and 2015b).

Washington State also operates an air monitoring network with the closest monitoring location
being Enumclaw-Mud Mountain in King County, WA. Appendix A includes a wind rose of data
obtained from the Enumclaw station.

Washington State also operates an air monitoring network with the closest monitoring location
being Enumclaw-Mud Mountain in King County, WA. Appendix A includes a wind rose of data
obtained from the Enumclaw station.

Table 10. Precipitation, Temperature, and Wind for the Study Area

Description Monitoring Location

Seattle-Tacoma Seattle-Boeing FLD/King

(yearly average) International Airport County International Airport
(1998-2008) (1998-2008)
Precipitation (inches) 38.18 36.04
Temperature (F) 52.2 53
Wind speed (mph) 7.3 5.6

Sources: WRCC 2015 and Metro Vancouver 2015b

mph = miles per hour; F = degrees Fahrenheit

3.6.1.2 Criteria Air Pollutants

The Clean Air Act (CAA) requires the United States Environmental Protection Agency (EPA) to
set National Ambient Air Quality Standards (NAAQS) (40 CFR part 50) for pollutants considered
harmful to public health and to the environment (Table 11). There are six criteria air pollutants in
the United States, of which ozone is the major concern in the Puget Sound region (PSCAA
2014):

Carbon monoxide Carbon monoxide is largely from motor vehicle exhaust. Carbon
monoxide levels are well below Federal standards and no longer considered a pollutant
of concern in the Puget Sound area. This region was designated as attainment status
in 1996 and has not violated the carbon monoxide standard since 1990. WDOE monitors
carbon monoxide levels (WDOE 2015).
Ozone The bulk of the regions ozone-causing nitrogen oxides and volatile organic
compounds come from the transportation-sector emissions from cars and light trucks,

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Environmental Assessment John Henry No. 1 Mine
 marine vessels, and heavy-duty diesel vehicles. Other sources include gasoline
refueling; industrial solvents; and auto-body paint shops, among others (WDOE 2015).
Lead Lead has not been monitored in the Puget Sound area since 1999 due in large
part to the phase-out of lead in fuel (unleaded) and the closure of the Harbor Island
secondary lead smelter (PSCAA 2014).
Sulfur dioxide Sulfur dioxide levels are well below the Federal health standard for
King County, and have been so for several decades. The Puget Sound Clean Air
Agency (PSCAA) stopped monitoring for sulfur dioxide in 1999. WDOE continues to
monitor for sulfur dioxide at a site on Beacon Hill (PSCAA 2014).
NOx (Nitrogen dioxide and nitrogen oxide) NOx levels are well-below federal air
quality standards, and are monitored by the WDOE (PSCAA 2014).
Particulate matter Particulate matter (PM) includes both solid matter and liquid
droplets suspended in the air. Exhaust from diesel-powered vehicles is a source of
particulates, but the majority is from wood smoke and industrial sources (PSCAA 2014).
The county is in attainment for PM but currently exceeds the PSCAAs more stringent
PM2.5 health goal of 25 micrograms per cubic meter (PSCAA 2015). Total suspended
particles (TSP) were previously monitored and modeled at the Mine and King County
concluded that over 95% of particulate matter would settle out on PCCCs mine site and
that air quality standards for particulate matter would not be exceeded (See Appendix A,
Air Quality Technical Analysis).

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Environmental Assessment John Henry No. 1 Mine
Table 11. National Ambient Air Quality Standards

Pollutant Primary/ Averaging Time Level Form

Secondary

Carbon Monoxide primary 8 hours 9 ppm Not to be exceeded more

(CO) 1 hour 35 ppm than once per year
Rolling 3 month 3
Lead (Pb) primary and 0.15 g/m (1)
period Not to be exceeded
secondary
98th percentile of 1-hour
daily maximum
Nitrogen Dioxide primary 1 hour 100 ppb
concentrations, averaged
over 3 years
(NO2) primary and 1 year 53 ppb(2) Annual Mean
secondary
Annual fourth-highest daily
maximum 8-hour
Ozone (O3) primary and 8 hours 0.070 ppm(3)
concentration, averaged
over 3 years
secondary
3 annual mean, averaged
primary 1 year 12.0 g/ m
over 3 years
annual mean, averaged
secondary 1 year 15.0 g/ m3
over 3 years
3 98th percentile, averaged
Particle Pollution primary and secondary 24 hours 35 g/ m
over 3 years
Not to be exceeded more
3
(PM) primary and secondary 24 hours 150 g/m than once per year on
average over 3 years
99th percentile of 1-hour
daily maximum
Sulfur Dioxide primary 1 hour 75 ppb
concentrations, averaged
over 3 years
3 Not to be exceeded more
(SO2) secondary 1 year 15.0 g/ m
than once per year

Source: EPA 2016c

(1) In areas designated nonattainment for the Pb standards prior to the promulgation of the current (2008) standards, and for which
implementation plans to attain or maintain the current (2008) standards have not been submitted and approved, the previous
standards (1.5 g/m3 as a calendar quarter average) also remain in effect.
(2) The level of the annual NO2 standard is 0.053 ppm. It is shown here in terms of ppb for the purposes of clearer comparison to
the 1-hour standard level.
(3) Final rule signed October 1, 2015, and effective December 28, 2015. The previous (2008) O3 standards additionally remain in
effect in some areas. Revocation of the previous (2008) O3 standards and transitioning to the current (2015) standards will be
addressed in the implementation rule for the current standards.
(4) The previous SO2 standards (0.14 ppm 24-hour and 0.03 ppm annual) will additionally remain in effect in certain areas: (1) any
area for which it is not yet 1 year since the effective date of designation under the current (2010) standards, and (2)any area for
which an implementation plan providing for attainment of the current (2010) standard has not been submitted and approved and
which is designated nonattainment under the previous SO2 standards or is not meeting the requirements of a SIP call under the
previous SO2 standards (40 CFR 50.4(3)). A SIP call is an EPA action requiring a state to resubmit all or part of its State
Implementation Plan to demonstrate attainment of the required NAAQS.

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Environmental Assessment John Henry No. 1 Mine
King County, Washington was in nonattainment from 1992 to 2000 for PM10 (1987 standard)
and from 1992 to 1995 for 1-hour Ozone (1979 standard revoked) and Carbon Monoxide
(1971 standard). King County is currently in attainment for all criteria pollutants (PM, CO, O3,
NOx, SO2) (EPA 2016c). According to the 2015 air quality data summary report by the PSCAA6
air quality in the region is generally improving with the greatest air quality challenge associated
with fine particle levels and ozone (PSCAA 2015). The counties within PSCAAs jurisdiction2 are
in attainment with the NAAQSs for PM, CO, O3, NOx, SO2 but currently exceed the PSCAAs
more stringent PM2.5 health goal of 25 micrograms per cubic meter. Ozone levels as monitored
at the Enumclaw Mud Mountain site have the highest regional ozone concentrations
approaching levels close to the Federal standard. The majority of air quality index (AQI) ratings
within the region are within the good percentage (over 50%) indicated by 0-50 AQI values which
equates to air pollution that poses little or no risk to the public (PSCAA 2015).

Potential customers of the coal mined at John Henry No. 1 Mine are located in Washington
State and British Columbia (within the Lower Fraser Valley air quality region). British Columbia,
Canada uses ambient air quality criteria that have been developed for national and provincial
uses to management air emissions. Table 12 below provides a list of all air quality emissions
standards in British Columbia (additional tables are provided in Appendix A). According to the
2014 air quality monitoring report prepared by the Air Quality and Climate Change Division of
Metro Vancouver CO, NO2, SO2, and PM2.5 short-term peak and average concentrations have
declined since the early nineties while average regional O3 levels are slightly increasing. In
2014, emissions in the Lower Fraser Valley were on average below British Columbia Ambient
Air Quality Objectives for O3, NO2, CO, SO2, and PM2.5 with a few instances of daily
exceedances due to environmental factors such as wildfires (Metro Vancouver 2015b).

6
The Puget Sound Clean Air Agencys jurisdiction covers King, Snohomish, Pierce, and Kitsap counties (PSCAA 2015).

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Environmental Assessment John Henry No. 1 Mine
Table 12. British Columbia Ambient Air Quality Objectivesa,b,c,d,e,f
Air
Averaging Date
Contaminant Criteria Level Quality
Period Adopted
Objective
g/m3 ppb
PCOs for Food-processing,
Carbon Monoxide
1 hour Agriculturally Orientated, A 14,300 13,000 1975
(CO)
and Other Misc. Industries
B 28,000 25,000
C 35,000 30,000
PCOs for Food-processing,
8 hour Agriculturally Orientated, A 5,500 5,000 1975
and Other Misc. Industries
B 11,000 10,000
C 14,300 13,000
Formaldehyde 1 hour Provincial AQO Action 60 50 1995
Episode 370 308
Nitrogen Dioxide g
1-hour Interim Provincial AQO - 188 100 2014
(NO2)
Annual Interim Provincial AQO - 60 32 2014
NAAQO Maximum
Ozone (O3) 1 hour Advisory 160 82 1989
Acceptable Level
h
8 hour CAAQS - 123 63 2013

Particulate Matter
i
<2.5 microns 24 hour Provincial AQO - 25 - 2009
(PM2.5)
j 2013
CAAQS - 28 -

Annual Provincial AQO AQO 8 - 2009

Goal 6 2009
k
CAAQS 10 2013
Particulate Matter
24 hour Provincial AQO - 50 - 1995
<10 microns (PM10)

Sulphur Dioxide l
1 hour Interim Provincial AQO - 200 75 2014
(SO2)

Total Reduced
Sulphur (TRS) PCOs for the Forest
1 hour A 7 5 1977
compounds Products Industry
measured as H2S
B 28 20
24 hour A 3 2 1977
B 6 4

Source: British Columbia 2016

Pollution Control Objectives = POCs; Provincial Air Quality Objectives = AQOs; National Ambient Air Quality Objectives = NAAQO;
Canadian Ambient Air Quality Standards = CAAQS; Provincial Level A, B and C Pollution Control Objectives (B.C.) = A, B and C
a http://www.env.gov.bc.ca/epd/main/ema.htm
b For more information, see: http://www.bcairquality.ca/regulatory/air-objectives-standards.html

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Environmental Assessment John Henry No. 1 Mine
c Pollution Control Objectives were developed by the B.C. Ministry of Environment and the B.C. Department of Lands, Forest, and

Water Resources in the 1970s for five source sectors: the Forest Products Industry, the Mining, Smelting and Related Industries,

Food-processing, Agriculturally Orientated and Other Miscellaneous Industries, the Chemical and Petroleum Industries and

Municipal Type Waste Discharges. These criteria, which referred to all discharges to the environment, were rescinded in 2006, but

the ambient air quality objectives continue to be used for reference purposes.

d Canada Gazette, Part I, Department of the Environment, National Ambient Air Quality Objectives for Air Contaminants, August 12,

1989.

e Canadian Ambient Air Quality Standards for 2015 and 2020 were adopted in 2013 by Canadian Council of Ministers of the

Environment, and supersede Canada-wide Standards for Particulate Matter and Ozone (see: http://www.gazette.gc.ca/rp
pr/p1/2013/2013-05-25/html/notice-avis-eng.html#d106).

f Metro Vancouver (2011) Metro Vancouver Integrated Air Quality and Greenhouse Gas Management Plan.

http://public.metrovancouver.org/about/publications/Publications/IntegratedAirQualityGreenhouseGasManagementPlan
October2011.pdf

g Achievement based on annual 98th percentile of daily 1-hour maximum, over one year
h Achievement based on annual 4th highest daily 8-hour maximum, averaged over three consecutive years.
i Achievement based on annual 98th percentile of daily average, over one year
j Achievement based on annual 98th percentile of daily average, averaged over three consecutive years
k Achievement based on annual average, averaged over three consecutive years
l Achievement based on annual 99th percentile of daily 1-hour maximum, over one year

3.6.1.3 Existing Emissions

Table 13 shows existing levels of emissions from all sources in the direct impact study area.
The monitoring location with the most comprehensive data set was located in Seattle, WA on
4103 Beacon Hill Street approximately 32 miles from the John Henry No. 1 Mine (EPA 2016h).
Table 14 presents exiting emissions data from 2011 for the Lower Fraser Valley in British
Columbia. Existing emissions data for the Lower Fraser Valley is also available in the 2012,
2013, and 2014 monitoring reports indicating that on average the annual pollutant emissions are
below British Columbia Ambient Air Quality Standards with exceedances occurring due to
extreme weather events such as wildfires (Metro Vancouver 2013a, 2014, and 2015b).

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Environmental Assessment John Henry No. 1 Mine
Table 13. Average Monitoring Values (Seattle, WA)

Pollutant 2015 2014 2013 2012 2011 2010

Criteria
Pollutants
CO (8-hour; ppm) 0.5607 0.5701 0.2414 0.231 0.2441 0.2434
O3 (8-hour; ppm) 0.0604 0.0285 0.0275 0.0284 0.0271 0.0253
PM2.5
6.7698 9.9639 12.0038 9.7436 8.4406 9.4915
(24-hour; g/m3)
NO2 (1-hour; ppb) 39.4961 40.478 23.4919 12.1736 12.495 13.2118
SO2 (1-hour; ppb) 1.79 0.9 2.1618 3.1402 3.7752 4.0887
PM10
11.2583 10.0862 10.5088 10.6909 8.6119 10.7124
(24-hour; g/m3)
Hazardous
Pollutants (24
hour
measurements;
ppb)
Acetaldehyde 0.7864 0.7656 0.793 0.8233 1.0433 0.8914
Acrolein 0.6921 0.6778 0.855 0.9123 0.811 1.439
Benzene 0.9789 0.947 1.0509 1.0958 1.3359 1.2949
1,3 butadiene 0.1159 0.1255 0.1347 0.1542 0.1592 0.119
Ethyl benzene 0.3616 0.437 0.4384 0.5108 0.5439 0.4437
Formaldehyde 0.4831 0.4934 0.4596 0.435 0.6817 0.5147
Toluene 2.1443 2.1813 2.3874 2.5762 3.017 2.5428
Xylene 0.4277 0.4997 0.4805 0.5737 0.5767 0.445

Source: EPA 2016h

g/m3 = micrograms/cubic meter; ppb = parts per billion; ppm = parts per million

Values rounded.

NO2 was added to monitoring values in 2013, 2010-2012 used nitric oxide 1-hour values.

Table 14. 2010 Average Annual Emissions (Lower Fraser Valley, British Columbia)
Pollutant Lower Fraser Valley (tons)
VOC 87,530
CO 353,760
NOX 60,410
SO2 12,090
PM2.5 7,570
PM10 N/A

N/A = Not reported

Source: Metro Vancouver 2013b

3.6.1.4 Hazardous Air Pollutants

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Environmental Assessment John Henry No. 1 Mine
Hazardous air pollutants (HAPs) are regulated by EPA through emission standards under the
CAA. The most common subset of hazardous pollutants analyzed are those HAPs which fall
under the Mobile Source Air Toxics (MSAT) rule which are typically associated with
transportation sources including motor vehicles, construction equipment, and locomotives and
are: acetaldehyde, acrolein, benzene, 1,3 butadiene, ethyl benzene, formaldehyde, n-hexane,
toluene, and xylene.

Under the Mercury and Air Toxics Standards rule, mercury is considered a hazardous air
pollutant with strict emission standards for power plants. Mercury is a naturally occurring
element found throughout the world with a life of 6 to 24 months in the atmosphere allowing it
travel globally. There are many natural sources that emit mercury into the atmosphere, including
the weathering of mercury-containing rocks, volcanoes when they erupt, and geothermal
activity. Mercury previously deposited from air onto soils, surface waters, and vegetation from
past emissions can be emitted back to the air. Mercury may be deposited and reemitted many
times as it cycles through the environment. Mercury from coal combustion accounts for
approximately 24 percent of the total amount of mercury entering the atmosphere each year
(United Nations Environment Programme 2013).

On December 16, 2011, the EPA issued the final Mercury and Air Toxics Standards (MATS)
and Utility New Source Performance Standards (NSPS) rulemakings which were published in
the Federal Register on February 16, 2012 (77 FR 9304). Promulgated as 40 CFR 63 Subpart
UUUUU National Emission Standards for Hazardous Air Pollutants (NESHAPS) for Coal- and
Oil-Fired Electric Utility Steam Generating Units, the MATS rule establishes emission limitations
and work practice standards for HAPs emitted from coal- and oil-fired electric utility steam
generating units along with requirements to demonstrate initial and continuing compliance with
the HAP emission limits.

3.6.1.5 Visibility

In the context of the prevention of significant deterioration program, all state air quality
jurisdictions are divided into three classes of air quality protection. Class I areas are areas of
natural wonder and scenic beauty, such as national parks, national monuments, and wilderness
areas, where air quality should be given special protection. Class I areas are subject to
maximum limits on air quality degradation called air quality increments which are more stringent
than the NAAQS. Washington State has eight Class I areas including wilderness areas and
national parks (EPA 2016a); see Table 15 and Figure 8.

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Environmental Assessment John Henry No. 1 Mine
Table 15. Class I Areas
Class I Area Distance (from John Henry)
Alpine Lakes Wilderness, Ronald, WA 45 miles
Glacier Peak Wilderness, Snohomish County, WA 77 miles
Goat Rocks Wilderness, Randle, WA 60 miles
Mount Adams Wilderness, South Yakima, WA 83 miles
Mount Rainier National Park, King County, WA 34 miles
North Cascades National Park, Okanogan County, WA 104 miles
Olympic National Park, Port Angeles, WA 81 miles
Pasayten Wilderness, Okanogan County, WA 122 miles

Source: EPA 2016a

Figure 8. Class I Areas

Washington State is part of the Western Regional Air Partnership (WRAP). WRAP is a voluntary
partnership of states, tribes, federal land managers, local air agencies, and the EPA who
research current and future air quality issues within the Western Region. Issues include
planning for the Regional Haze Rule, air quality issues pertaining to ozone, particulate matter,

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Environmental Assessment John Henry No. 1 Mine
mercury, effects of transportation emissions, and impacts of climate change within the region
(WRAP 2016). WRAP is currently working on the revision to the Regional Haze Plan due in
2018 in accordance with the EPAs Regional Haze Regulations. Provisions of the regional haze
rule that require emission controls known as Best Available Retrofit Technology, or BART, for
industrial facilities emitting air pollutants that reduce visibility would apply to the Mine and
indirect coal combustion. Actual project emissions are presented in Section 3.6.2,
Environmental Consequences.

Regional haze impairs visibility and is produced by emissions from numerous sources located
across broad geographic areas. Visibility impacts occur when emissions absorb and scatter light
in the atmosphere reducing the clarity of views. Visibility is measured over 24-hour periods and
calculated as a percent increase in light extinction compared to a pristine background. Impacts
are expressed as the number of days annually that show visibility reductions of 5, 10, or 20
percent.

Interagency Monitoring of Protected Visual Environments (IMPROVE) data shows that from
2010 to 2014 visibility in Mount Rainier, North Cascades, and Olympic National Park. Class I
areas each had approximately 10 worst visibility days (IMPROVE 2016). See Figures 9 and 10
for an example of the composition of total mass contributing to regional haze and visibility trends
at Mount Rainier National Park the closest Class I area to the Mine.

Figure 9. Total Mass Budgets for Mount Rainier National Park (2015)

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Environmental Assessment John Henry No. 1 Mine
Figure 10. Visibility on Haziest and Clearest Days for Mount Rainier National Park (2015)

Federal Standards of Performance for Coal Preparation and Processing Plants (40 CFR, Part
60, Subpart Y 2009) apply to the facility. PCCCs mine contains the following affected facilities:
coal processing and conveying equipment, coal storage systems, coal transfer, and loading
systems that were constructed before April 28, 2008. The facility also contains open storage
piles which are not affected facilities under Federal NSPS; because they were constructed prior
to May 27, 2009 see Table A-5. The facility does not include any thermal dryers or pneumatic
cleaning equipment.

The 2010 application NSPS emission standard (40 CFR 60.254), regarding facilities constructed
before April 28, 2008, sets a limit of 20 percent opacity on coal processing and conveying
equipment (including breakers and crushers), coal storage systems7, and transfer and loading
systems. 40 CFR 60.255(a) requires a performance test of the limits (EPA Method 9) within 60
days after achieving the maximum production rate at which the affected facility would be
operated, but not later than 180 days after initial startup of such facility (40 CFR 60.8). Table A
5 summarizes the NSPS Subpart Y emission standards and the applicable Subpart Y emission
standard for the facilities present at the John Henry No.1 Mine.

The State of Washington implements the NAAQS, and develops air quality attainment and
maintenance plans, in order to keep Washington in compliance with the Federal NAAQS. The
Puget Sound air shed has been in compliance with the annual PM2.5 standard since the EPA
promulgated it in 1997. The Black Diamond area is in compliance with the Federal air quality
standards for CO, O3, PM, SO2, and NOx (PSCAA 2014).

7
Including stock piles, silos, or other covered storage buildings.

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Environmental Assessment John Henry No. 1 Mine
3.6.2 Environmental Consequences
Emissions from employee vehicles, construction equipment, and operational equipment were
calculated for total years of operation including reclamation under the Proposed Action and No
Action Alternatives see Table 16 (EPA 1985; EPA 2010a, b, and c; EPA 2015; EPA 2016f). See
Appendix A, Air Quality Technical Analysis, for detailed emissions tables including emission
factors.

Table 16. Total Emissions by Alternative

Proposed No
Pollutant Proposed Action No Action
Action Action

tons per year total tons

Criteria Pollutants
CO 7.5 6.5 49 13
NOx 36 30 234 60
PM10 1.4 1.2 9.2 2.5
PM2.5 1.4 1.2 8.9 2.4
SO2 8.4 7.1 55 14
VOC 1.5 1.2 9.8 2.5
Hazardous Air Pollutants
Acetaldehyde 0.11 0.09 0.68 0.17
Acrolein 0.015 0.012 0.1 0.02
Benzene 0.02 0.016 0.13 0.03
1,3-Butadiene 0.001 0.001 0.01 0.002
Ethylbenzene 0.01 0.008 0.06 0.015
Formaldehyde 0.33 0.27 2.14 0.54
n-Hexane 0.008 0.007 0.05 0.013
Toluene 0.045 0.037 0.3 0.074
Xylene 0.058 0.047 0.37 0.094

Sources: EPA 1985; EPA 2010a, b, and c; EPA 2015; EPA 2016f

Emissions from the Proposed Action and No Action Alternatives would result in exhaust
emissions from vehicles and operational equipment as well as fugitive dust emissions from wind
erosion of stock piles and coal crushing equipment. The total emissions of PM10 and PM2.5,
presented in Table 16, are the sum of emissions from exhaust and wind erosion. PM emissions
from coal crushing equipment were modeled separately. The effects of operational emissions
would be temporary and at any given time would occur only where operations are occurring or
along roadways traveled by vehicles. The effects of operational emissions on ambient air quality
would vary with time due to the operational schedule, mobility of emission sources, type of
equipment in use, and local meteorological conditions. Operational emissions are not
anticipated to lead to pollutant concentrations that would violate the NAAQS or impair regional
air quality conditions. Emissions from lead are expected to be far below the NAAQS because of
EPAs diesel and gasoline fuel standards regulating fuel use in highway, non-road, and marine

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Environmental Assessment John Henry No. 1 Mine
vessels as well as the CAA amendment (Section 218) in January 1996 which banned the sale of
leaded fuel for use in on-road vehicles (EPA 2016i).

Particulate matter emissions as total suspended particulates (TSP) were modeled when the
original notice of construction permit (NOC) was issued in 1984 by Puget Sound Air Pollution
Control Agency (PSAPCA), the predecessor of PSCAA (PSAPCA 1984). See Appendix A, Air
Quality Technical Analysis, for previous monitoring and modeling data. Upon proposing to
resume mining in 2010 as described under the Proposed Action, PCCC applied to PSCAA for a
permit to operate two coal crushers and associated coal-processing equipment. PSCAA
updated their analysis to include estimates of PM10 and PM2.5 based on previous modeling for
TSP. The new permit was granted on September 6, 2010 (PSCAA 2010). The results of the
modeling are presented in Appendix A. The original modeling for NOC 2390 as modified above
by PSCAA resulted in ambient concentrations of particulate due to the proposed activity that
were less than the ambient air quality standards for PM10 and PM2.5. There has been no
additional modeling required by PSCAA. The original design capacity of the plant was 350,000
tons coal per year. Modeled operations were approximately 134,000 tons coal per year.
Emissions were evaluated in the original permit application for Order of Approval 2390
(PASPCA 1984). At that time, emissions were evaluated as TSP.

For the 2010 NOC application, the TSP emissions were converted to PM10 and PM2.5 emissions
for potential and actual expected operation of the preparation plant and mine. Emissions were
estimated by multiplying the emissions by the ratio of production planned under the Proposed
Action Alternative and the design maximum production. Emissions from the coal cleaning plant
and mine estimated emission sources and rates (including fugitive dust from haul roads) TSP
would be 55.3 tons per year, PM10 emissions would be 23.3 tons per year, and PM2.5
emissions would be 1.4 tons per year (See Appendix A, Air Quality Technical Analysis).

For the purposes of determining Title V and Prevention of Significant Deterioration applicability
as a major source PSCAA followed the example given in EPA guidance dated March 6, 2003
(EPA 2003) and August 9, 2007 (EPA 2007). In the March 6, 2003 guidance it is determined
that for a coal mine and associated coal cleaning plant the coal mining is the primary activity,
see Figure 11. However, because the coal cleaning plant is a listed source category, fugitive
emissions only from the coal cleaning plant are used to determine if the source is a major
stationary source. The August 9, 2007 guidance clarifies that fugitive dust from haul roads
associated with coal cleaning also count toward the major source thresholds.

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Environmental Assessment John Henry No. 1 Mine
Figure 11. Coal Processing Flowchart

Another minor change in the facility since the original emission estimate is that refuse exits the
building in separate fine and coarse streams. The fine refuse stream is sent to a small sump of
about twenty tons. Because the material entering the sump is wet, emissions are expected to be
negligible (PSCAA 2010). According to PCCC, this is filter cake material from a belt press and
contains 20-30 percent moisture by weight.

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Environmental Assessment John Henry No. 1 Mine
The following permit stipulations have been and would continue to be used to reduce potential
adverse impacts from dust:

1. Water and/or an approved chemical suppressant such as ammonium lignin sulfonate

would continue to be applied to unpaved haul roads to control dust. PCCC would
maintain a copy of the Material Safety Data Sheet for any dust suppressant used.

2. Haul trucks would continue to reduce speed in the event roads are not timely applied
with water and/or a dust suppressant.

3. Paved roads would continue to be flushed with water to remove roadway dust.

4. Disturbed areas have been and would be revegetated as soon as weather permits.
Disturbed areas have not been and would not be revegetated during wet weather
conditions.

5. Water sprays would continue to be used to suppress dust at coal dumping and crushing
locations.

6. The coal transfer point would continue to be covered to minimize windblown dust.

7. All conveyors would continue to be covered.

8. Overburden drills would continue to be equipped with a dust collection system.

9. No additional disturbance around the facilities would be required.

10. PSCAA could require monitoring if it deems necessary.

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Environmental Assessment John Henry No. 1 Mine
PSCAA summarized its modeling results as shown in Table 17.

Table 17. Modeled Particulate And NAAQS

Pollutant Averaging Modeled Background Total (g/m3) State or
Period Concentration Concentration NAAQS
(g/m3) (g/m3) (g/m3)
PM10
Annual 13 19 32 50
24-hr 32.4 76 108.4 150
PM2.5
Annual 0.6 4 4.6 15
24-hr 1.6 10 11.6 35

Notes:

1. PM10 derived from TSP using mass fraction if 0.422 for PM15 found in USEPA Region 10, letter dated January 11, 1984. This
should over predict PM10 concentrations.
2. PM2.5 derived from TSP using mass fraction if 0.021 for PM15 found in USEPA Region 10, letter dated January 11, 1984.
3. PM10 background concentration used is from 2006 James Street monitor in Kent. 2006 was the last year the agency monitored
PM10. Annual background is the 2006 average concentration. 24-hr is the maximum 24-hr average for 2006. The urban location of
this monitor should over predict particulate for Black Diamond.
4. PM2.5 background concentration used is from 2006 Mud Mountain monitor. 2006 was the first highest annual average for PM2.5
at the Mud Mountain monitor.
5. PM10 24-hr NAAQS is also a State Ambient Air Quality Standard.
6. PM10 annual is a State Ambient Air Quality Standard.
7. Modeled concentrations based on modeled TSP from USEPA Region 10, letter and analysis dated January 11, 1984.

3.6.2.1 Proposed Action Alternative

3.6.2.1.1 Direct Impacts
Mining at the historic rate of 350,000 tons per year showed negligible impacts on local or
regional air quality. Under the Proposed Action Alternative mining at the proposed rate of
84,000 tons per year would have lower impacts than historic mining rates. Potential emissions
are presented in Table 16. PCCC is not currently required to implement an air quality monitoring
program under 30 CFR 780.15 because it does not produce more than 1,000,000 tons per
year. PCCC does maintain a dust control program.

All active roads within the mine site would be watered as necessary during dry or dusty
conditions. These conditions normally occur from June through September. The temporary spoil
piles have been covered with topsoil, seeded, and re-vegetated. Coal waste would be mixed
with overburden in the backfill area and not stored separately. Coal stockpiles would be watered
as necessary. This is not predicted to occur frequently due to relatively damp weather
conditions and wet process used to separate impurities from the coal in the plant. As topsoil is
spread, it would be immediately reseeded and with optimum growing conditions in the spring
and fall, ground cover would be established quickly. This has proven an effective means of
controlling fugitive dust emissions. No thermal dryers would be used. The preparation plant feed

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Environmental Assessment John Henry No. 1 Mine
hopper and the crushers at the coal preparation plant would continue to be equipped with water
spray devices to minimize dust. The blast hole drill would use water to minimize dust from the
drilling operations. Disturbed acreage would be kept to a minimum, and would be topsoiled and
seeded as soon as possible to eliminate possible sources of dust.

Best Available Control Technology (BACT) would be applied where required at the coal
processing plant. BACT would help to attain limits for Coal Processing and Conveying
Equipment, including breakers and crushers, coal storage systems, transfer and loading
systems, open storage piles (of processed coal and refuse), and associated equipment (40 CFR
60 Subpart Y). PCCCs plant operating and maintenance procedures target no visible emissions
from coal processing and conveying equipment (including crushers), coal storage systems,
transfer and loading systems, open storage piles (of processed coal and refuse), and
associated equipment. Specifically:

The enclosed crusher with water sprays would be BACT;

If the material was dry, fully enclosed conveyors would be BACT, under the Proposed
Action Alternative, given the wetness of handled product conveyor, covers would be
BACT;

Enclosed coal preparation plant would be BACT.

To complete final reclamation, the Proposed Action Alternative reclamation plan requires
relatively short haul distances and a small mobile equipment fleet for haulage and dozer push of
backfill and topsoil materials. The haul profile from Spoil Pile 3N and 3S to Pit 2 is entirely
above the pit perimeter and would average 200 feet and 600 feet respectively. Fugitive dust
from truck hauls would be controlled with water trucks during dry conditions.

Impacts on air quality from the Proposed Action Alternative would generally occur within the
permit area but potentially could be local. The direct impacts would be short-term and negligible
due, in part, to the fact that prevailing winds in the dry summer months are from the W to NW
and the land use to the SE is managed forest with no residential development existing or
planned (King County 2012). If reclamation of Spoil Pile 3S occurs during the summer the
impacts would be confined within the permit area due to the prevailing wind conditions and
location of Spoil Pile 3S (see Figure 1).

3.6.2.1.1.1 Transportation
Indirect impacts on air quality from emissions of criteria pollutants would be from transporting
the coal to customers and from coal combustion. Truck transportation would be in Pierce and or
King Counties. In 2014, trucks and buses traveled 582.6 billion miles in King County and 228.1
billion miles in Pierce County (Washington Department of Transportation 2015). As shown
above in Section 3.4, Climate Change, coal haulage trucks are expected to travel 183,570 miles

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Environmental Assessment John Henry No. 1 Mine
per year delivering coal to either Tacoma in Pierce County or Seattle in King County (see Table
18). The EPA has determined that Class V111a trucks, as proposed for use, cause emissions of
criteria pollutants and volatile organic compounds (VOC) (EPA 2008). These are expressed in
terms of grams per mile traveled. Barge transportation is likely from either Tacoma or Seattle to
Vancouver, British Columbia. The U.S. Department of Transportation estimated emissions from
towboat engines for VOC, CO, SOx, Particulates, and NOX based on pounds emitted for every
ton of cargo transported 1,000 miles (USDOT 1994). If the entire 84,000 tons of annual
production are transported by barge from Tacoma, WA to Vancouver, BC, this would result in
11,424 ton-miles8 (see Table 18).

8
Unit of measure used to show the amount of a commodity (tons) traveled over a distance (miles).

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Environmental Assessment John Henry No. 1 Mine
Table 18. Criteria Emissions for Transportation Scenarios Compared to County and State Total Emissions
Total
3,5
Emissions for Vehicles Emissions for Barge Transportation Emissions by County (tons per year)
Emissions
Pollutant Lower
King Snohomish Pierce Kitsap
1, 2 grams/kilowatt Washington Fraser
Grams/Mile Tons/year Tons/year Tons/year County County County County
hour (2011) Valley
(2011) (2011) (2011) (2011)
(2010)
VOC 0.4 0.08 0.5 2.57 2.65 71,472 40,799 36,725 13,554 881,868 87,530
CO 1.8 0.37 1.1 5.7 6.02 362,939 149,472 157,226 55,214 1,736,782 353,760
NOX 3.7 0.75 13.2 67.91 68.66 60,583 22,322 24,801 6,976 285,900 60,410
SO2 0.0066 0.001 1.3 6.69 6.69 2,461 687 1,197 684 28,335 12,090
4
PM2.5 0.2 0.04 0.7 3.59 3.63 10,666 4,559 4,146 1,598 73,173 7,570
PM10 0.26 0.05 0.72 3.7 3.76 27,505 8,069 9,214 2,730 230,957 N/A

N/A = Not reported

Sources: EPA 2009, 2013a, 2013b, Metro Vancouver 2013b, and WDOE 2016a

1
Assumes 183,750 miles for travel distance. Values in this column come from "Updates to Transportation Parameters in GREET" Table 3 which has a representative

emissions factor for all heavy duty diesel trucks, including light commercial, short-haul and long-haul, single-unit and combination trucks.

2
SO2 emissions were provided from Argonne National Laboratory 2013b using 2017 model year diesel single unit long haul trucks.

3
EPA 2009, Table 3-8, Tier 0 Category 2 vessel.

4
PM2.5 is represented as 0.97 of PM10 (EPA 2009)

5
Vessel emission calculation formula: E = P x LF x A x EF (EPA 2009)

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Environmental Assessment John Henry No. 1 Mine
Indirect truck and barge transportation impacts on air quality are expected to be negligible and
short-term because annual vehicle and barge emissions under the Proposed Action Alternative
would account for <1 percent of current emissions within the indirect impact study area whose
counties are all currently in attainment and based on the short-term duration of the Proposed
Action (seven years total).

3.6.2.1.1.2 Coal Combustion

PCCC coal sales would generally be on short-term basis. As explained above Section 3.4,
Climate Change, PCCC has a contract to supply a portion of its production to Lehigh Cement
located in Delta, British Columbia, Canada. Ash Grove Cement located in Seattle and Lafarge
Cement in Richmond, British Columbia, Canada also represent potential customers. PCCC has
stated that there may be potential customers at a lime kiln or pulp mill that burn coal and are
located in the region (actual buyers at these facilities are not known as this time). Due to the
speculative nature of the remaining customers, the EAs analysis provides coal combustion
emissions at the Lehigh Cement Plant because they are a known customer.9 Lehigh is the
larger plant rated at about 3,850 tons of cement clinker per day. Lafarge Cement has a similar
rate of about 3,800 tons of cement clinker per day. Ash Groves capacity is 2,200 tons of clinker
per day. The three plants are modern, energy efficient, dry process plants, that use multi-stage
preheaters and pre-calciners. The three plants are equipped with continuous emission
monitoring equipment that ensures compliance with applicable state and provincial air quality
regulations. Fuel combustion is just one component of the overall emissions and coal use will
vary depending on the price of alternative fuels. The amount of coal used from various sources
is also based on relative costs and can vary on a daily basis.

According to the Lehigh Production Manager, fuel combustion has a lesser impact on emissions
than the chemical makeup of the raw materials that are fed into the kiln. These materials include
limestone, shale or clay, silica sand, and a source of iron. Emissions related to fuel combustion
and cement manufacturing are measured in the stack, including CO, PM, NO2, and SO2 (see
Table 19). Lehigh currently uses natural gas, petroleum coke, wood waste, and some plastic
waste in addition to coal. Lehigh is constantly investing in ways to use more waste fuels in the
mix. Lehigh does not expect a noticeable change in emissions with changes in the fuel mix
(PCCC 2016).

Lehigh Northwest Cement Limited operates a dry process plant in Delta, British Columbia,
Canada that is similar in design to Ash Groves plant with multistage preheaters and a pre
calciner. It also uses multiple baghouses to control particulate matter. Lehigh operates under an
Air Quality Management Permit issued by Metro Vancouver (Metro Vancouver 2010). Lehigh
submits continuous emission monitoring data quarterly. Those reports show emissions in terms
of milligrams per cubic meter for CO and SO2 and kilograms per hour for NOX. Lehigh does not

9
CEQs NEPA Forty Most Asked Questions, Question Number 18 (CEQ 1981).

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Environmental Assessment John Henry No. 1 Mine
monitor for O3 and it is not included in the Lower Fraser Valley Air Monitoring Reports. Lehigh
also reports the number of hours operated each quarter and the average airflow rate through
the stack. Permit restrictions include the following:

NOX 600 kilogram per hour

SO2 500 milligrams per cubic meter
Opacity 10%

A complete set of quarterly emission reports for 2015 are available at the Metro Vancouver web
site (Metro Vancouver 2015a). After conversion from metric to English units the annual quantity
of CO, NOX and SO2 emitted by Lehigh in 2015 is shown below in Table 19. Emission reports
from 2009, 2010, and 2011 are available on Metro Vancouvers website; however, they are not
included in Table 19 due to incomplete and unavailable data and differences in report types
(stack quarterly reports versus continuous emission monitoring reports). Emission reports were
not available on the Metro Vancouver website for years 2012, 2013, and 2014.

Table 19 provides a conservative estimate of emissions that would result from burning PCCC
coal in any of the proposed cement plants, lime kiln, or pulp mill. It excludes emissions related
to the raw fuel mix. The emissions presented in Table 19 are more significant than fuel
combustion at the Lehigh Cement plant because the total amount of coal produced under the
Proposed Action Alternative would exceed Lehighs capacity to burn in a given year which in
2015 was 1,124,681 pounds of coal per year. Emissions from the Lehigh Cement Plant are not
anticipated to lead to pollutant concentrations that would violate the British Columbia Ambient
Air Quality Standards or impair regional air quality conditions (see Table 12).

Table 19. Current Lehigh Cement Plant Emissions versus Emissions from the Proposed
Action in Relation to the Study Area

Emissions by County (tons per year)

Lehigh
John Henry
Cement
Pollutants No. 1 Mine Lower
Plant,
(tons/year) Indirect King Snohomish Pierce Kitsap Fraser
Richmond, Washington
Emissions County County County County Valley,
BC (2015) (2011)
(2011) (2011) (2011) (2011) BC
(2010)
CO 1,104 1,344 362,939 149,472 157,226 55,214 1,736,782 353,760
NOX 2,682 1,050 60,583 22,322 24,801 6,976 285,900 60,410
SO2 60 84 2,461 687 1,197 684 27,964 12,090
1
PM 1,933 N/A 10,666 4,559 4,146 1,598 73,173 7,570

N/A = Not Reported

Sources: Metro Vancouver 2013b and 2015a, WDOE 2016a
1
Emissions by county for PM are reported as PM2.5 and PM value from Lehigh are presented in g/m3.

CO, NOX, and SO2 emission standards in the Puget Sound region are all well below Federal
standards according to PSCAA (2014). Indirect impacts from burning PCCCs coal in varying

67
Environmental Assessment John Henry No. 1 Mine
quantities are negligible and short-term because emission levels from the John Henry No. 1
Mine under the Proposed Action Alternative would account for <1 percent of current emissions
within the indirect impact study area whose counties are all currently in attainment and based on
the short-term duration of the Proposed Action (seven years total).

3.6.2.1.1.2.1 Mercury
The Lehigh Cement Plant is required to provide reports of the measured discharge rate and
concentration of Mercury emissions every three months. The maximum concentration allowed is
0.15 mg/m3. This restriction does not apply to the duration of startup, shutdown, or unavoidable
upset conditions. According to the most recent monitoring report in October 3, 2015, the current
concentration of mercury emitted at the plant averages 0.01 mp/m3, which is well below the
contaminant permit limit.10 Mercury emissions would be negligible and short-term because the
use of coal from the John Henry No. 1 Mine would not increase overall coal combustion rates at
the plant (Lehigh Cement Plant Monitoring Report 2015). The plant would be required to report
and correct any and all violations in adherence with their permit stipulations as soon as
possible. It is assumed for purposes of this analysis that coal from the John Henry No. 1 Mine
combusted at other facilities would have similar air quality impacts to that of the Lehigh Cement
Plant due to similar or smaller plant size (ex. Ash Grove Cement Plant is similar and Lafarge is
smaller).

3.6.2.2 No Action Alternative

3.6.2.2.1 Direct Impacts

Table 16 presents total emissions for the No Action Alternative showing that they are less than
the emissions associated with the Proposed Action Alternatives across all criteria and
hazardous pollutants (see Section 3.6.2, Proposed Action). The effects of operational emissions
from reclamation activities under the No Action Alternative would be temporary and at any given
time would occur only where operations are occurring. The effects of operational emissions on
ambient air quality would vary with time due to the operational schedule, mobility of emission
sources, type of equipment in use, and local meteorological conditions. Operational emissions
under the No Action Alternative are not anticipated to lead to pollutant concentrations that would
violate the NAAQS or impair regional air quality conditions.

The No Action Alternative reclamation plan requires longer haul distances and a larger mobile
equipment fleet for haulage of backfill and topsoil materials for final reclamation than the
Proposed Action Alternative. The haul profile from Spoil Pile 3N and 3S to Pit 1 is entirely above
the pit perimeter and would average 2,400 feet and 2,800 feet respectively. Under the Proposed
Action Alternative, the distances are 200 feet and 600 feet respectively into Pit 2. Fugitive dust

10
Mercury emission monitoring data is not available for quarters and years and therefore the EA presents
the most recent data available.

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Environmental Assessment John Henry No. 1 Mine
emissions associated with the No Action Alternative would be less than that modeled by PSCAA
for mining but could represent a small increase compared to reclamation activities associated
with the Proposed Action Alternative. The Proposed Action Alternative uses dozers and has
shorter hauls than the No Action Alternative. Fugitive dust from long truck or scraper hauls
would be controlled with water spray trucks during dry conditions. These emissions were not
modeled by OSMRE in the FEIS (OSMRE 1985) nor by PSCAA in the NOC Worksheet (PSCAA
2010).

Impacts on air quality from the No Action Alternative would generally occur within the permit
area but also potentially could be local. The direct impacts would be short-term and negligible
due, in part, to the fact that prevailing winds in the dry summer months are from the W and NW
and the land use to the SE is managed forest with no residential development existing or
planned (PSCAA 2010). The coal washing plant would not operate therefore additional PM
emission would be eliminated (aside from those presented in Table 17).

Under the No Action Alternative, the coal processing plant would not be operated and no
emissions would occur from that source. No coal mining would take place so emissions from
mining or coal combustion would not occur. Therefore impacts would be negligible and short-
term.

3.7 Soils

3.7.1 Affected Environment

Soils within the mine site are similar to surrounding areas and are well-developed to support
vegetation given the relatively large amount of rainfall. There is no historical use of the soil for
cropland although some of the soil units located within the Mud Lake wetlands have potential for
cropland. These soils will not be disturbed by mining and reclamation under the Proposed
Action Alternative or by the No Action Alternative. To be considered Prime Farmland it must
have a historical use as cropland as well as be the appropriate soil type. Soils that will be
disturbed under the Proposed Action Alternative have neither characteristic. In 2015 OSMRE
consulted with the Natural Resources Conservation Service (NRCS) concerning the potential for
occurrence of Prime Farmland soils within the permit boundary. NRCS concurred with
OSMREs determination that the property contained no Prime Farmland as that term is defined
in the regulations which require it to have a historic land use of cropland. Because the site is
located in Western Washington it is not subject to Alluvial Valley Floor regulations at 30 CFR
947.701(b)(1). Most of the soils on the site have a well-developed upper or A horizon that is
high in organic matter and ranges from 1-2 feet in thickness (OSMRE 1985). Prior to mining
operations commencing in 1986, soils were mapped by a King County Conservation District
representative. The applicant performed additional sampling and analysis of the soil resource to
supplement the earlier work.

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Environmental Assessment John Henry No. 1 Mine
Prior to beginning mining in 1986, PCCC undertook a soil descriptive and analytical program to
supplement the soil inventory efforts. This is described in more detail in Chapter VII of the PAP.
Plate VII-1 in the PAP provides a map of the soils prior to initial mining (PCCC 2011a). This
includes the 29.7 acres proposed for disturbance under the Proposed Action Alternative.
Samples were taken from soil profiles in areas to be disturbed during the mining operation. The
samples collected were representative of dominant horizons in these soils. The analytical
studies indicated no major limiting chemical or physical characteristics.

Soils that would be disturbed under the Proposed Action Alternative are predominantly
classified as Alderwood Gravelly Sandy Loam. This soil is well-drained and has slight-to
moderate erosion potential. This soil is well-suited for the post mining land uses of forestry.
Wetland soils include the Seattle and Norma series. These would not be disturbed by future
mining and reclamation activities.

Topsoil in the previously disturbed area has been removed and either stockpiled or re-spread in
the backfill area of Pit 1 or on the spoil piles.

The overburden units of the Puget formation consist of sandstone, shale, and siltstone. This is
overlaid by Vashon till that is irregular in thickness. The till is mostly consolidated and
compressed sand and gravel with a clay matrix. Small pockets of unconsolidated sand and
gravel are sometimes encountered. No toxic microelements or acid forming materials were
encountered during past mining.

3.7.2 Environmental Consequences

In 1986, there was concern over the productivity of topsoil that was removed ahead of mining
and then stored. This is no longer a concern as alder trees, which are nitrogen fixing, have
grown over the major topsoil stockpile. Such topsoil was both stored and was also applied
directly over the temporary spoil piles to prevent erosion. Native vegetation has been
established on the stored topsoil piles and Douglas fir was planted on the external spoil piles for
additional erosion control. Native vegetation has also established itself on disturbed land where
topsoil was removed. This includes 8 acres that will be re-disturbed by mining and that are
included in the 29.7 acre mining area. Commercially harvestable trees would be removed by the
landowners from the spoil piles and topsoil piles as required to complete final reclamation. The
remaining vegetation would be cleared and grubbed to the extent necessary to allow
reclamation in accordance with the approved plan.

Under the Proposed Action Alternative topsoil and subsoil would be directly hauled,
redistributed and re-vegetated, and would not be stored or stockpiled. Approximately one to two
feet of topsoil would be removed and directly applied to disturbed areas that have been graded;
topsoil would be handled to preserve its integrity; and topsoil would be tested, if necessary, to
determine if nutrients and amendments are required. Depths are determined by the operator
during topsoil removal based on field observations. When topsoil depths exceed 2 feet then the

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Environmental Assessment John Henry No. 1 Mine
entire topsoil horizon is removed and redistributed (Morris 2015). Re-vegetation monitoring is
planned to determine if nutrients or amendments are required. Stored topsoil has not been
comingled with coal processing wastes. Care would continue to be taken not to mix topsoil with
coal mining wastes during redistribution by covering coal processing wastes with at least 3 feet
of overburden or clean soil before covering with 1 foot of topsoil.

Before mining began in 1986 the King County Conservation District representative, Mr. Robert
Gavenda, indicated that the soil in the area of Mud Lake as shown on the Natural Resources
Conservation Service map consists of Seattle Muck surrounded by a ring of Norma sandy loam.
Both of these soils are considered to be prime farmland soils if the water table is deeper than
1.5 feet below ground surface during the cropping season (Gavenda 1981). However, the area
does not have a historical land use as cropland. Because Mud Lake wetland remains
undisturbed, disturbance of Norma sandy loam and Seattle Muck would also not occur under
the Proposed Action Alternative.

Long-term storage of topsoil in piles may deteriorate chemical and microbiological properties of
soils. In particular long-term storage may negatively impact the mycorrhizal potential of the soil.
This is a symbiotic association between the roots of plants and specialized fungi. If the results of
initial seeding indicate a need, the applicant will conduct a soil fertility sampling program after
topsoil redistribution and add necessary fertilizer as recommended and or plant with mycorrhizal
inoculated seedlings to insure re-vegetation success (Quam 1983). PCCCs reclamation plan
specifies that it will plant 538 Douglas fir seedlings per acre (PCCC 2011a). The performance
based success standard, in accordance with Washington State Forest Practice Regulations is
survival of 190 stems per acre in place after five years (WAC-34-10).

3.7.2.1 Proposed Action Alternative

Under the Proposed Action Alternative, an additional 29.7 acres would be disturbed by mining.
When present, topsoil would be removed ahead of mining and immediately redistributed to
areas in Pit 1 and Pit 2 that have been backfilled and graded. No additional topsoil stockpiles
are proposed. As Pit 2 advances, Spoil Pile 2 would be dozed into Pit 2 and the topsoil
stockpiled on top of Spoil Pile 2 would be distributed over the spoil pile once it reaches AOC.
Topsoil would be placed primarily during the drier summer months. This would only occur if
additional topsoil must be removed to allow mining to advance. Handling wet topsoil is more
costly than handling dry topsoil. Depending on weather and seasonal conditions, replaced
topsoil would be immediately seeded with a grass mixture and then planted with Douglas fir the
following year. Topsoil in existing stockpiles would be utilized for final reclamation and all areas
would be reclaimed using either suitable material or topsoil. Impacts are confined within the
permit area and would constitute a moderate, long-term impact to soils that would be disturbed
under the Proposed Action Alternative due to changes in the properties, structure, and
appearance. Soil impacts would be restricted to the mine permit area and would not result in
any indirect impacts.

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Environmental Assessment John Henry No. 1 Mine
3.7.2.2 No Action Alternative
No additional topsoil would be removed under the No Action Alternative as no mining would
take place. All topsoil needed to reclaim the mine site would come from the topsoil stockpiles or
topsoil that is currently applied on the external spoil piles. Impacts on soil resources, such as
reduced soil productivity, under the No Action Alternative are confined within the permit area,
would be negligible and short-term but would occur sooner (over two years) than the Proposed
Action Alternative (six years for mining operation and one year to complete reclamation). Soil
impacts would be restricted to the mine permit area and would not result in any indirect impacts.

3.8 Vegetation

3.8.1 Affected Environment

The vegetation cover type for the area where the John Henry No. 1 Mine is located has been
mapped as Western Hemlock Zone (Franklin and Dyrness 1973). This vegetation zone
historically covered much of Western Washington. Western hemlock, Douglas fir, and western
red cedar typically dominate old-growth forests in the Puget Sound region. Nearly all of the
Western Hemlock Zone, including the John Henry No. 1 Mine, has been altered by timber
harvests. Current conditions throughout the Puget Sound region consist primarily of a mixture of
even-aged Douglas fir forests and developed lands (WRI 2008).

In 1981 PCCC contracted with what was then Washington Department of Game (WDG), to
conduct a flora and fauna study to be used in the SEPA EIS (WDG 1981). The flora survey was
included as Appendix 8 of the SEPA EIS (King County Department of Planning and Community
Development 1984). This study also served as a basis for the NEPA EIS (OSMRE 1985). The
entire study, including field notes, can be found as Appendix VIII-1 of the PAP (PCCC 2011a).

In 1991, as required by the State of Washington Growth Management Act (GMA), the City of
Black Diamond commissioned a Fish and Wildlife - Critical Areas Inventory of lands located
within the city, including those that are also part of the John Henry No. 1 Mine (David Evans and
Associates, Inc. 1991). This study divided the habitat types within the City of Black Diamond into
five distinct groups: Aquatic Areas; Wetlands; Unforested Open Areas; Managed Forested
Areas; and Unmanaged Forested Areas. This study identified unique habitat areas that provide
special functions for fish and wildlife. These are designated as wildlife corridors and included
Ginder Creek corridor, Mud Lake Creek corridor, and adjacent riparian areas.

Group Four Inc. (2011) completed a wetland delineation study in November 8, 2011, which
included a vegetation survey of the entire mine site including the upland areas. A list of
observed plants was included as Table D-1 and is included herein as Appendix D, Vegetation.

Classification of upland plant communities present on the site are based primarily on the King
County Wildlife Habitat Profile (King County 1987). The King County system was chosen

72
Environmental Assessment John Henry No. 1 Mine
because of its high applicability to habitats local to the Puget Sound region, which cover the
John Henry No. 1 Mine and was used in the recent EISs discussed above.

Vegetation communities and cover types are also identified by the Northwest Regional Gap
Analysis Project (NWReGAP) (USGS 2016) and are described in more detail for the specific
project components in Appendix D, Vegetation. Table 20 provides a summary of the 10
vegetative communities contained within the 480-acre permit area (see also Figure 12). Table
21 provides a list of Federal and State listed threatened, endangered, and sensitive plant
species in King County, WA.

73
Environmental Assessment John Henry No. 1 Mine
Figure 12. Vegetation and Reclamation

74
Environmental Assessment John Henry No. 1 Mine
Table 20. Summary of Vegetative Communities
Vegetative Type Symbol Area (Acres)
Coniferous Forest Fc 101.5
Deciduous Fd 60.9
Mature Deciduous Fd-m 76.0
Mixed Forest Fm 52.3
Shrub/Saplings Fs 22.0
Grass Gu 8.7
Open Water Pw 36.0
Mine/Disturbed M 65.6
Wetlands Fw 45.2
Sediment Ponds Ps 11.8
Total Area 480.0

75
Environmental Assessment John Henry No. 1 Mine
Table 21. Federal and State Listed Endangered, Threatened, and Sensitive Plants in King
County, WA

State Federa Rationale For

Scientific Common
Statu l Habitat Refer. Dismissal from
Name Name
s Status Further Analysis

-1
Limited disturbance
Wetlands swamp.
Arenaria swamp of wetlands, no
X LE No known 56
paludicola sandwort known occurrences
occurrences in WA
in WA

Vancouver
Limited disturbance
Bidens Island Wetlands, swamp
R1 -2 of wetlands, not
amplissima beggar- near coast
near coast
ticks

Gross stands of
Vancouver Mine elevation 625 -
Boschniakia salal near saltwater.
ground- R1 -3 950 ft, no nearby
hookeri Elevation in WA
cone saltwater
120-500 ft.
Forests, wet and
dry meadows, rocky
triangular-
Botrychium soils, next to Mine elevation 625 -
lobed S SC 26
ascendens perennial streams, 950 ft
moonwort
2,100-6,400 ft
elevation

Moist or dry
Botrychium stalked meadows, riparian Mine elevation 625 -
S SC 31
pedunculosum moonwort forests.1640-4340 ft 950 ft
elev

Old logs, base of

red alder, low
Unsuitable habitat.
Roll's elevations, open
Brotherella No floodplains,
golden log T mixed forests of 19
roellii stream terraces of
moss floodplains, stream
valley margins.
terraces and valley
margins

Rock crevices, high

Campanula Alaska Mine elevation 625 -
S elevation, 2,000 79
lasiocarpa harebell 950 ft
6,840 ft

76
Environmental Assessment John Henry No. 1 Mine
 State Federa Rationale For
Scientific Common
Statu l Habitat Refer. Dismissal from
Name Name
s Status Further Analysis

-1

Limited disturbance
Marshes, lake of wetlands or
bristly
Carex comosa S shores, wet 289 lakes. Not observed
sedge
meadows in 2011 vegetative
survey

Seepage areas, wet

large-
Carex meadows, streams, Mine elevation 625 -
awned T 294
macrochaeta lakes, elevation in 950 ft
sedge
WA 1,200-3,200 ft

Limited disturbance
few- of wetlands or
Carex Sphagnum bogs,
flowered S 298 lakes. Not observed
pauciflora acidic peat
sedge in 2011 vegetative
survey.

Wet meadows,
long-styled wetlands, rock, Mine elevation 625 -
Carex stylosa S 303
sedge elevations in WA 950 ft
2,760-5,200 ft

Rock faces, high

Cassiope clubmoss Mine elevation 625 -
T elevations 1,900 80
lycopodioides cassiope 950 ft
2,200 ft in WA

77
Environmental Assessment John Henry No. 1 Mine
 State Federa Rationale For
Scientific Common
Statu l Habitat Refer. Dismissal from
Name Name
s Status Further Analysis

-1

Grasslands, does
Castilleja golden not tolerate closed Mine elevation 625 -
E LT 82
levisecta paintbrush canopy, elevations 950 ft
in WA 10-300 ft

Limited disturbance
of lakes or
Ceratophyllum smooth
R1 Aquatic -4 wetlands. Not
echinatum hornwort
observed in 2011
vegetative survey

Chrysolepis
chrysophylla golden Prairies, forests, Unsuitable habitat,
S 85
var. chinquapin one location in WA no prairies
chrysophylla

Unsuitable habitat,
tall
Cimicifuga elata S SC Old growth forests 88 no old growth
bugbane
forests

Moist cool old

spleenwort forests, riparian Unsuitable habitat,
Coptis
-leaved S areas. Mostly found 94 no old growth
aspleniifolia
goldthread along coast or in forests
North Cascades.

Limited disturbance
Nuttall's to wetlands. Not
Elodea nuttallii R1 Wetlands -5
waterweed observed in 2011
vegetative survey.

78
Environmental Assessment John Henry No. 1 Mine
 State Federa Rationale For
Scientific Common
Statu l Habitat Refer. Dismissal from
Name Name
s Status Further Analysis

-1

Limited disturbance
Fritillaria Wet meadows, to wetlands. Not
black lily S 317
camschatcensis wetlands, riparian observed in 2011
vegetative survey.

River sand and

Oregon Mine elevation 625 -
Heterotheca gravel bars at
goldenaste T 147 950 ft and
oregona higher elevations in
r unsuitable habitat
WA above 2,600 ft.

Limited disturbance
Canadian
Hypericum to wetlands. Not
St. John's S Wetlands 150
majus observed in 2011
wort
vegetative survey.
Lathyrus Dry wooded forest
Mine elevation 625-
vestitus var. Pacific pea E edges. Elevation in 156
950 ft.
ochropetalus WA 250-565 ft
Limited disturbance
Lobelia water to wetlands. Not
T Aquatic 159
dortmanna lobelia observed in 2011
vegetative survey.
Limited disturbance
Lycopodiella bog to wetlands. Not
S Wetlands 36
inundata clubmoss observed in 2011
vegetative survey.
Limited disturbance
Wet rock outcrops,
to wetlands. Not
Lycopodium treelike ecotone between
S 37 observed in 2011
dendroideum clubmoss meadow and
vegetative survey.
wetland
No meadows.

Mine elevation 625

Open grasslands to
950 ft. No
Meconella white open forestland.
E SC 172 permanent
oregana meconella Elevations in WA
grasslands or open
60-620 ft
forestland.

Grows at higher
Douglas-fir forests.
branching elevations. Not
Montia diffusa S Elevations in WA 183
montia identified on 2011
850-2,900 ft.
vegetation survey
Glacial outwash,
Texas prairies with well Mine elevation 625-
Nuttallanthus
(blue) S drained soils. 187 950 ft. No glacial
texanus
toadflax Elevations in WA outwash or prairies.
16-200 ft
Limited disturbance
Wetlands.
Platanthera Choris' of wetlands. Mine
T Elevations in WA 327
chorisiana bog-orchid elevation 625-950 79
2,540-4,300 ft.
Environmental Assessment John Henry No. 1 Mine ft.
 State Federa Rationale For
Scientific Common
Statu l Habitat Refer. Dismissal from
Name Name
s Status Further Analysis

-1
Wetlands. Limited disturbance
Platanthera Choris'
T Elevations in WA 327 of wetlands. Mine
chorisiana bog-orchid
2,540-4,300 ft. elevation 625-950 ft.
aquatic Moist conditions.
Racomitrium Mine elevation 625 -
racomitriu R1 Elevation in WA -6
aquaticum 950 ft.
m moss 2,000-6,400 feet.
Occurs on mineral
soil in crevices on
the lower and more No caves. Will not
sheltered parts of disturb mature
Schistostega luminous
R1 the root mass of -7 deciduous forests
pennata moss
fallen trees. It also with root mass of
has been found on fallen trees.
soil around cave
entrances.
Open grasslands.
Sericocarpus white-top Mine elevation 625
S SC Elevations in WA 255
rigidus aster 950 ft.
30-550 ft
humped
Utricularia Aquatic. Elevations Mine elevation 625
bladderwor R1 -8
gibba in WA 160-490 ft 950 ft.
t
Limited disturbance
flat-leaved
Utricularia to wetlands. Not
bladderwor S Wetlands, aquatic 273
intermedia observed in 2011
t
vegetative survey.

Notes:
State Status
State Status of plant species is determined by the Washington Natural Heritage Program. Factors considered include abundance,

occurrence patterns, vulnerability, threats, existing protection, and taxonomic distinctness. Values include:

E = Endangered. In danger of becoming extinct or extirpated from Washington.

T = Threatened. Likely to become endangered in Washington.

S = Sensitive. Vulnerable or declining and could become endangered or threatened in the state.

X = Possibly extinct or extirpated from Washington.

R1 = Review group 1. Of potential concern but needs more field work to assign another rank.

R2 = Review group 2. Of potential concern but with unresolved taxonomic questions.

Federal Status
Federal Status under the U.S. Endangered Species Act (ESA) as published in the Federal Register:

LE = Listed endangered. In danger of extinction.

LT = Listed threatened. Likely to become endangered.

PE = Proposed endangered.

PT = Proposed threatened.

C = Candidate species. Sufficient information exists to support listing as endangered or threatened.

SC = Species of Concern. An unofficial status, the species appears to be in jeopardy, but insufficient information to support listing.

References
(1) The primary reference is Department of Natural Resources, Field Guide to the Rare Plants of Washington (WDNR 2011). Page
numbers are shown except for numbers in parentheses with corresponding references: (2) Klinkenberg 2015; (3) WDNR 2003; (4)
Naturalist.org 2016; (5) USDA 2013; (6) BLM 1996; (7) USFS 2005; (8) WDNR 2005.

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Environmental Assessment John Henry No. 1 Mine
3.8.2 Environmental Consequences

Approximately 29.7 acres of vegetation clearing and removal would occur as a result of
continued mining under the Proposed Action. All vegetation removal would consist of mature
deciduous forest and would occur within the permit boundary for the John Henry No. 1 Mine.
During reclamation under either alternative, the disturbed areas would be backfilled and graded
to AOC. The John Henry No. 1 Mine would be reclaimed in accordance with the currently
approved reclamation plan. Following final grading, topsoil will be redisturbed uniformly over
areas disturbed by mining to an average depth of approximately one foot. Seeding will be
accomplished via broadcast (i.e. hand spreader; helicopter, and/or mobile equipment (i.e. dozer)
within 30 days following topsoil placement. Douglas Fir seedlings would be planted at
approximately 538 stems per acre. Red alder is expected to establish naturally forming mixed
stands with Douglas fir (Figure 13). All active sites disturbed during construction or mining will
be seeded to temporary cover crops (PCCC 2011a).

81
Environmental Assessment John Henry No. 1 Mine
Figure 13. Post-Mining Vegetation & Reclamation Map

82
Environmental Assessment John Henry No. 1 Mine
3.8.2.1 Proposed Action Alternative
Under the Proposed Action Alternative, vegetation would be disturbed by mining and
reclamation activities. The primary long-term and short-term impacts to vegetation would be
from the removal of mature deciduous trees as a result of the continued mining of coal at the
John Henry No. 1 Mine. Because of the high precipitation and large propagule pressure11,
herbaceous colonizing species become established relatively quickly (approximately two years
for 70-100% cover). However, for the expected time of recovery starting from bare-ground is
within 10-15 years, Douglas fir is expected to completely occupy the site following plantings (i.e.
planting 538 stems per acre). For the forest industry, tree thinning is recommended at 35 years
and final harvest start at age 45, 55, or 65 years. Potential impacts would be minor and long
term and would be limited to areas disturbed by proposed mining and reclamation with no
changes in the plant community structure or composition elsewhere within the permit boundary.

The Proposed Action Alternative would result in an increased amount of wind-borne fugitive
dust. Indirect impacts to surrounding vegetation would occur from the fugitive dust released due
to proposed mining activities. Fugitive dust negatively impacts nearby vegetation by coating
leaves reducing photosynthetic activity. PCCC would implement dust suppression measures on
mine roads which would minimize impacts to surrounding vegetation from fugitive dust therefore
potential impacts would be negligible and long-term.

3.8.2.2 No Action Alternative

Under the No Action Alternative, there would be no need to clear and remove vegetation from
the 29.7 acres proposed for coal mining. However, under the No Action Alternative, there would
continue to be direct impacts to vegetation from surface disturbance as reclamation actions are
completed in accordance with the approved reclamation plan. Vegetation would be cleared from
the external spoil piles used to achieve AOC as part of the reclamation plan, the impacts of
which were analyzed in Section 3.7.1, Affected Environment. Potential impacts would be minor
and long-term and would be limited to areas disturbed by reclamation with no changes in the
plant community structure or composition elsewhere within the permit boundary. There would be
no indirect impacts to vegetation as a result of the No Action Alternative as proposed mining
activities would not occur.

3.9 Wetlands and Riparian Zones

3.9.1 Affected Environment

The Army Corps of Engineers (USACE) and EPA have defined wetlands as those areas that
are inundated or saturated by surface or groundwater at a frequency and duration sufficient to
support, and that under normal circumstances do support, a prevalence of vegetation typically

11
a composite measure of the number of individuals of a species released into a region to which they are not native

83
Environmental Assessment John Henry No. 1 Mine
adapted for life in saturated soil conditions (EPA 2017). According to the FEMA flood zone
online mapping tool, there are no floodplains present within the permit boundary (FEMA 2016).
Group Four Inc. completed a wetland delineation study September 1, 2011. This was required
by the USACE before it could issue a Nationwide 21 permit or require a Clean Water Act (CWA)
Section 404 individual permit (Gresham 2011). The survey identified 11 wetlands within the
permit area not including the sediment control ponds. These are discussed in more detail in
Appendix E and summarized in Table 22 with their locations shown on Figure 12.
The study showed three small wetlands had established themselves within the disturbed area
after mining temporarily ceased in the late 1990s. Following review of the September 2011
wetland delineation study, the USACE requested additional information from PCCC. Group Four
Inc. completed supplemental field work in November 2011, revised the study and identified two
additional wetlands that had been established in previously disturbed mine areas (Group Four
2011). The 45.22 acres of wetlands that were delineated in the study include five wetlands
totaling 3.72 acres that have developed on areas previously disturbed by mining. These five
wetlands would be eliminated under the currently approved reclamation plan under the
Proposed Action and No Action Alternatives. Any future requirements or permit renewals would
occur between the Operator and USACE. See Appendix C, Consultation.

Table 22 presents the identified wetlands on the John Henry No. 1 Mine and their
classifications. More detail on the wetland characteristics is provided in Appendix E, Wetlands
and Riparian Zones.

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Environmental Assessment John Henry No. 1 Mine
Table 22. Wetland Classification Summary
Wetland/Open Size Cowardin Class1 Hydrogeomorphic Ecology
Water Name (acres) Class2 Category3

Mud Lake 22.74

PEM4/PSS5/PFO6 Depressional II

IB Wetland 0.33
PEM
Slope IV

Pit 1 Berm 1.14

PEM/PSS
Depressional III

Pit 2 Fringe 2.19

PEM/PSS
Depressional III

Wetland A 0.22
PSS
Depressional III

Wetland B 0.06
PEM
Slope IV

Ginder Lake 15.99

PUB7, PEM, PSS, Depressional I

PFO
Wetland C 1.54
PUB, PEM, PSS, Depressional I

PFO
Wetland D 0.36
PEM/PSS
Slope III

Wetland E 0.01
PSS
Depressional III

Wetland F 0.30
PSS/PEM
Depressional III

Wetland G 0.03
PSS
Depressional IV

Wetland 0.31
PSS/PFO
Depressional III

Mitigation

Notes:
1
Cowardin et al. (1979).
2
Hydrogeomorphic classes according to Brinson (1993). Depressional wetlands typically occur in topographic depressions and
whose water sources are precipitation, ground water discharge, and both interflow and overland flow from adjacent uplands. Slope
wetlands normally are found where there is a discharge of ground water to the land surface. They normally occur on sloping land;
elevation gradients may range from steep hillsides to slight slopes. Principal water sources are usually ground water return flow and
interflow from surrounding uplands, as well as precipitation (NRCS 2008).
3
Wetland category according to Washington Department of Ecology (Hruby 2004). The criteria for assigning points to categories
changed in 2014 effective January 1, 2015 although the categories remain the same. The January 1, 2015, effective date means
that if a wetland is rated on or after that date, the 2014 updates are required for projects needing Ecology authorization according to
the updated Washington State Wetland Ratings System (WDOE 2014b).
4
PEM - palustrine emergent
5
PSS - palustrine scrub/shrub
6
PFO - palustrine forested
7
PUB - palustrine unconsolidated bottom

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Environmental Assessment John Henry No. 1 Mine
3.9.1.1 Open Water (Pw)
Mud Lake and Ginder Lake are classified as wetlands and both, especially Ginder Lake, are
comprised partly of open water. Under the Proposed and No Action Alternative, neither wetland
would be disturbed by mining or reclamation activities.

3.9.1.1.1 Ginder Lake Wetland (15.99 acres)

Ginder lake wetland is an open water wetland complex located at the northwest edge of the
mine site. This wetland is bordered on the west by Black Diamond-Ravensdale Road, on the
north by SE Ginder Lake Road, and on the east by storm water Pond B. The Ginder Lake
Wetland is hydrologically connected to Wetland C on the north side of SE Ginder Lake Road
and is part of a larger wetland system that extends off-site to the north. Ginder Lake is
considered wetlands aquatic habitat priority area and the surrounding area is considered
regular concentration priority area for Elk (Cervus elaphus) by WDFW. Under the Proposed
Action and No Action Alternatives, this wetland would not be disturbed by mining or reclamation
activities. This large wetland has permanent open water with submerged macrophytes, a
shoreline dominated by emergent plants, and a fringe of scrub/shrub and forested vegetation on
higher ground. Plant species in the open water and emergent areas include yellow pond lily,
floating-leaved pondweed, cattail, woolly sedge, soft stem bulrush (Scirpus tabernaemontanii),
marsh cinquefoil (Potentilla palustris), narrow-leaved burreed, reed canarygrass, small-fruited
bulrush, skunk cabbage, tapertip rush, broadleaf water plaintain, daggerleaf rush, horsetail
sedge (Dulichium arundinaceum), and bigleaf sedge (Carex amplifolia).

Trees bordering the shoreline of Ginder Lake include western red cedar, red alder, black
cottonwood, Pacific willow, and cascara. The shrub understory includes Sitka willow, hardhack,
salmonberry, vine maple, black twinberry, and Devils club. Invasive plants near the wetland
boundary include Himalayan blackberry, evergreen blackberry, Cascade mountain ash, holly,
and Japanese knotweed (Polygonum cuspidatum).
3.9.1.1.2 Wetland C (1.54 acres)
Wetland C is a linear depression located at the northern edge of the mine site that extends
offsite to the north. Wetland C is hydrologically connected to Ginder Lake by a culvert
underneath the roadway. The wetland boundary on both the east and west edges is defined by
steep slopes that are covered with second-growth upland forest. Under the Proposed and No
Action Alternative, this wetland would not be disturbed by mining or reclamation activities.
Wetland C contains standing water with submerged macrophytes, emergent, and scrub/shrub
vegetation. Wetland C is considered priority wetland aquatic habitat as well as priority habitat for
Elk (Cervus elaphus) regular concentration. The open water area contains yellow pond lily and
floating-leaved pondweed, while the emergent area includes reed canarygrass, skunk cabbage,
lady fern (Athyrium filix-femina), cattail, and field horsetail. Higher on the banks of this
depression there are shrub thickets that include Sitka willow, vine maple, hardhack, black
twinberry, salmonberry, and Himalayan blackberry. On the highest ground near the wetland
boundary there are trees such as, black cottonwood, red alder, Pacific willow, Sitka spruce
(Picea sitchensis), and western red cedar.

86
Environmental Assessment John Henry No. 1 Mine
3.9.1.1.3 Sediment Ponds
Stormwater runoff from disturbed area flows through one of six (i.e. A, A, B, F, I, H1, H2)
sediment control ponds (12 acres). Sediment ponds are not considered to be waters of the U.S.
by the USACE. The sediment ponds would be removed under the approved reclamation plan for
the Proposed and No Action Alternatives. However, it should be noted all sediment control
ponds have wetland characteristics. Sediment control Pond B is scheduled to be filled, graded,
and planted with Douglas fir in accordance with the approved final reclamation plan (PCCC
2011a).

3.9.1.1.4 Streams
Mud Lake Creek flows approximately 1,800 feet from the northwest corner of Mud Lake to the
mine boundary near State Route (SR) 169. The wetted channel averages 3 feet wide and 2
inches deep and is located in a steep ravine. Ginder Creek flows from the southwest corner of
Ginder Lake to the mine boundary near Black Diamond Ravensdale Road. The wetted
channel averages 4 feet wide and 3 inches deep and parallels Black Diamond Ravensdale
Road (Group Four 2011). Group Four (2011) determined Mud Lake Creek and Ginder Creek
are Waters of the United States (WOTUS). Under both the Proposed Action Alternative and No
Action Alternative, Ginder Creek would not be disturbed by mining or reclamation activities.
Impacts to Mud Lake wetlands from mining activities on adjacent lands would be minimal. Water
from pit 1 will be pumped into I-pond during the winter months. Water would be released into
Mud Lake post-mine.

3.9.2 Environmental Consequences

Apart from Ginder and Mud Lakes, thirteen wetlands have been identified at the John Henry No.
1 Mine. The Pit 2 Fringe, B, F, and G wetlands totaling 2.58 acres would be eliminated as a
result of continued mining under the Proposed Action. All of the wetlands that would be
eliminated are located within the permit boundary of the mine. During reclamation, the disturbed
areas would be backfilled and graded to AOC. The balance of the property will be reclaimed in
accordance with the currently approved reclamation plan (PCCC 2011a).

After reviewing PCCCs Pre-Construction Notice (PCCC 2011b) supported by the Wetland
Delineation Study (Group Four 2011), the Army Corps of Engineers (USACE) determined that
PCCC could continue to operate under a Nationwide permit 21 (USACE 2013). PCCC would
continue to operate in accordance with the requirements of the USACE Nationwide permit 21.
Any additional permit requirements or renewals would be coordinated between PCCC and
USACE, see Appendix C, Consultation.
3.9.2.1 Proposed Action Alternative
Under the Proposed Action, non-jurisdictional wetlands would be disturbed and/or eliminated by
mining and reclamation activities. Potential impacts would be limited to areas disturbed by
proposed mining and reclamation with no changes in the plant community structure or
composition elsewhere within the permit boundary. No wetlands outside the permit boundary of
the mine would be affected. Under the Proposed Action, there would be no direct, adverse

87
Environmental Assessment John Henry No. 1 Mine
impacts to streams and riparian zones as the proposed mining activities would not disturb these
areas within the permit boundary. Under the Proposed Action, potential impacts to wetlands
within the permit boundary would be minor and long-term.

Indirect impacts from the Proposed Action Alternative include fugitive dust and coal dust
deposition on wetlands and riparian zones from coal hauling vehicles leaving the permit area.
Wheel washes will be used prior to trucks exiting the permit area to reduce mud and dust on the
roads and the coal truck beds will be covered to reduce coal particles. Under the Proposed
Action, there would be no indirect, adverse impacts to streams and riparian zones as the
proposed mining activities would not disturb these areas within the permit boundary. Under the
Proposed Action, potential indirect impacts to wetlands within the permit boundary would be
minor and long-term.

3.9.2.2 No Action Alternative

Under the No Action alternative, there would be no direct, adverse impacts associated with the
mining of that coal. Under the No Action Alternative, there would continue to be surface
disturbance as reclamation actions are completed in accordance with the approved reclamation
plan. As part of reclamation, certain wetlands and all sediment ponds would be eliminated from
within the permit boundary. Potential impacts would be minor and long-term. Indirect impacts to
wetlands and riparian zones from the No Action Alternative are not anticipated.

3.10 Fish and Wildlife Resources

3.10.1 Affected Environment
The terrestrial wildlife analysis area for big game, small game, and nongame species, including
raptors and other migratory birds, indicates that suitable habitat exists within the mine footprint.
The analysis area for assessing potential impacts to fish in this EA is the Lake Sawyer
watershed (King County 2015b). The mine footprint is located in three sub-watersheds of the
Lake Sawyer and Green River watersheds: Ginder Lake, Mud Lake, and Lake No. 12. Ginder
Lake and Mud Lake both drain to the west via correspondingly named creeks, eventually flowing
to Rock Creek and then into Lake Sawyer. Lake No. 12 is situated just east of the permit area
and discharges to the east through a wetland area, eventually flowing to the Green River. The
Lake Sawyer watershed does not include Lake No. 12; mining activities that would occur under
the Proposed Action would not be located in the area of the mine that is adjacent to and within
the Lake No. 12 watershed. The wildlife habitat located within the mine footprint is
predominately composed of the mixed deciduous/needle leaf and mixed deciduous
communities. Other habitat types include Douglas shrubland/grassland and wetland
communities.

The three SEPA EISs (Parametrix 2009a, Parametrix 2009b, Black Diamond 2009c) for
projects adjacent to and near John Henry No. 1 Mine all contained wildlife studies including field
observations of wildlife. For a historical perspective, Table 23 provides a listing of fauna
observed in 1981by WDG consultants (WDG 1981) and by consultants for the Morgan Kame
sand and gravel mine expansion EIS (Raekeke 2009, ELS 2008).

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Environmental Assessment John Henry No. 1 Mine
Historical field observations were also augmented with information about species habitat
preferences, in order to determine the potential occurrence of additional wildlife species.
Previous Wetland Resources, Inc. (WRI) wildlife studies conducted on similar properties were
reviewed (WRI 2006, 2007, 2008). Also, data regarding habitat-species relationships was
obtained from Maser (1998) and Johnson et al. (1997) for mammals, Peterson (1990) for birds,
and Stebbins (1966) for reptiles and amphibians.

Table 23. Observed Wildlife at the John Henry No.1 Mine and Morgan Kame Terrace Sand
and Gravel Mine

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Environmental Assessment John Henry No. 1 Mine
 Common Name Scientific Name Observed
WDG Morgan Kame
Raedeke ELS
AMPHIBIANS
Pacific Tree Frog Pseudacris regilla Y N
REPTILES
Northwestern Garder Snake Thamnophis ordinoides Y N
BIRDS
*American White Pelican Pelicanus erythrorhynchos N N N
*Great Blue Heron Ardea herodias N N Y
*Canada Goose Branta canadensis N Y Y
*Mallard Anas playrhynchos N Y Y
Ring-necked Duck Aythya collaris N Y N
Hooded Merganser Lophodytes cucullatus N Y N
Bald Eagle Halianeetus leucocephalus N Y Y
Red-tailed Hawk Bueo jamaicensis Y Y Y
Golden Eagle Aquila chrysaetos N N Y
Band-tailed Pigeon Columba fasciata N Y N
Mourning Dove Zenaida macroura N Y N
Vaux's Swift Chaetura vauxi N Y N
*Rufous Hummingbird Selasphorus rufus Y Y N
Belted Kingfisher Ceryle alcyon Y N Y
Red-breasted Sapsucker Sphyrapicus ruber N Y N
Downy Woodpecker Picoides pubescens Y N Y
Hairy Woodpecker Picoides villosus Y Y N
Northern Flicker Colaptes auratus N Y Y
Pileated Woodpecker Dryocopus pileatus Y Y Y
*Olive-sided Flycatcher Contopus cooperi N Y N
*Western Wood-Pewee Contopus sordidulus N Y N
Pacific Slope Flycatcher Empidonax difficilis N Y N
Tree Swallow Tachycineta bicolor N Y N
Violet-green Swallow Tachycineta thalassina N Y N
Northern Rough-winged Swallow Stelgidopteryx serripennis N Y N
Stellar's Jay Cyanocitta stelleri Y Y Y
Western Scrub-jay Aphelocoma californica N N Y
American Crow Corvus brachyrhynchos N Y Y
Common Raven Corvus corax N Y N
Black-capped Chickadee Poecile atricapillus Y Y Y
Chestnut-backed Chickadee Poecile rufescens Y Y N
Bushtit Psaltriparus minimus N N Y
Red-breasted Nuthatch Sitta canadensis N Y N
Brown Creeper Certhia americana N Y N
Bewick's Wren Thryomanes bewickii Y Y N
Winter Wren Troglodytes troglodytes Y Y Y
Marsh Wren Cistothorus palustris Y Y N
Golden-crowned Kinglet Regulus satrapa Y Y N
Ruby-crowned Kinglet Regulus calendula Y N Y
American Robin Turdus migratorius Y Y Y
Varied Thrush Ixoreus naevius N N Y
European Starling Sturnus vulgaris N N Y
Hutton's Vireo Vireo huttoni N Y N
Orange-crowned Warbler Vermivora celata N Y N
*Yellow-rumped Warbler Denroica coronata N Y N
Black-throated Gray Warbler Denroica nigrescents N Y N
Common Yellowthroat Geothlypis trichas Y Y N

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Environmental Assessment John Henry No. 1 Mine
 Common Name Scientific Name Observed
WDG Morgan Kame
Raedeke ELS
Black-throated Gray Warbler Denroica nigrescents N Y N
Common Yellowthroat Geothlypis trichas Y Y N
*Wilson's Warbler Wilsonia pusilla N Y Y
*Western Tanager Piranga ludoviciana N Y N
*Black-headed Grosbeak Pheucticus melanocephalus N Y N
Evening Grosbeak Coccothraustes vespertinus Y Y N
Spotted Towhee Pipilo maculatus N Y Y
Song Sparrow Melspiza melodia Y Y Y
White-crowned Sparrow Zonotrichia leucophrys Y Y Y
Dark-eyed Junco Junco hyemalsi Y Y Y
Red-winged Blackbird Agelaius phoeniceus Y Y Y
Brown-headed Cowbird Molothrus ater N Y N
Pubple Finch Carpodacus purpureus N Y N
House Finch Carpodacus mexicanus N N Y
Red Crossbill Loxia curvirostra N Y N
Pine Siskin Carduelis pinus Y Y N
American Goldfinch Carduelis tristis N Y N
*Swainson's Thrush Catharus ustulatus Y N N
*Townsend's Warbler Setophaga townsendi Y N N
Common (Northern) Flicker Colaptes auratus Y Y Y
Rufous-sided Towhee Pipilo erythrophthalmus Y N N
Cooper's Hawk Accipiter cooperii N N N
Common Snipe Gallinago gallinago N N N
Sharp-shinned Hawk Accipiter striatus N N N
Willow Flycatcher Empidonax traillii Y N N
Barn Swallow Hirundo rustica Y N N
Long-billed Marsh Wren Cistothorus palustris Y Y N
MAMMALS
Eastern Cottontail Sylvilagus floridamus N N Y
Douglas Squirrel Tamiasciurus douglasii N Y N
Black Bear Ursus americanus Y N N
Raccoon Procyon lotor N Y Y
Coyote Canis latrans N Y Y
Elk Cervus elaphus N Y Y
Columbia Black-Tailed Deer Odocoiluus hemionus Y Y Y
Muskrat Ondatra zibethicus Y N N
Townsend's chipmunk Tamias townsendii Y N N
Shrew-mole Neurotrichus gibbsii Y N N
Mink Neovison vison Y N N

* Migratory Birds

Habitat within the mine footprint supports many types of nongame species (e.g., small
mammals, raptors, passerines, and reptiles). Nongame species serve as predators, prey, and
scavengers in ecosystems. The big game species whose overall range overlap with the mine
footprint include black-tail deer (Odocoileus hemionus), elk (Cervus canadensis), black bear
(Ursus americanus), and mountain lion (Puma concolor). Small game species that occur within
the region include furbearers, upland game birds, and waterfowl. Potential habitat for small
game species (except waterfowl) within the mine footprint includes all of the plant communities

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Environmental Assessment John Henry No. 1 Mine
that occur there. Potential habitat for waterfowl within and near the mine footprint is limited to
small lakes, wetlands, and sediment ponds.
3.10.1.1 Fish Species and Essential Fish Habitat
In 1983, a supplemental baseline study of fish and their habitat was prepared under the
direction of Michael Shepard, a University of Washington Staff Biologist. It was referenced by
OSMRE in the FEIS (OSMRE 1985). It is included as Appendix IX-2 of the PAP (PCCC 2011a).
This study concluded that because of natural sandstone ledge barriers, Mud Lake Creek
provided little habitat for spawning and rearing of salmonids. Ginder Creek, on the other hand,
generally represents good fish habitat provided that a downstream barrier is removed. The
removal of the barrier is not proposed as part of the Proposed or No Action Alternatives and is
not within PCCCs control. The Washington Department of Fish and Wildlife (WDFW)
SalmonScape (2015d) website does not show Ginder Creek or Mud Lake Creek as salmon or
trout habitat.

Coho salmon, steelhead, cutthroat trout, and other resident trout species are known to occur
above the outlet of Lake Sawyer (Covington Creek). Coho salmon and cutthroat trout have been
reported upstream as far as Jones Lake in Rock Creek. Steelhead travel past Lake Sawyer into
Rock Creek but have not been reported as far upstream as Jones Lake. Coho and cutthroat
trout have also been reported in Ravensdale Creek (Raekeke 2009). Resident cutthroat trout
and Coho salmon are the dominant native fish species found in streams and lakes in the Lake
Sawyer watershed, including Black Diamond Lake/Black Diamond Lake Creek, and Rock
Creek. Coho salmon are not a Federal or State listed species. A winter run of Coho salmon
move into Lake Sawyer in December with most fish spawning in Ravensdale Creek (City of
Black Diamond 2009a). Rock Creek is considered essential fish habitat for Coho salmon.
Essential fish habitat includes streams and other water bodies currently or historically
accessible to salmon except areas upstream of long standing, naturally and manmade
impassable barriers (Cedarock 2009). Cutthroat trout is not Federal or State listed as
populations are stable. They are present in Lake Sawyer and tributaries including Rock Creek.
Some cutthroats are living exclusively in fresh water. Some are anadromous (Cedarock 2009).
OSMRE queried the NMFS Northwest Regional Offices current listing data on the West Coast
salmon and steelhead species that may be impacted by the project revision proposal in King
County, Washington. The following species were either listed or considered a species of
concern dependent on the water system (river, lake, fen, sound, or coast): sockeye salmon
(Oncorhynchus nerka), Chinook salmon (Oncorhynchus tshawytscha), Coho salmon
(Oncorhynchus kisutch), and Puget Sound steelhead (Oncorhynchus mykiss). Special status
aquatic species are discussed in Section 3.9.1.5, Special Status Species.

3.10.1.2 Special Status Species

Special status species are those species for which state or Federal agencies afford an
additional level of protection by law, regulation, or policy. Included in this category are federally
listed species that are protected under the Endangered Species Act (ESA) and species that
WDFW has designated as threatened, endangered, or species of concern in Washington State.
The analysis area for state listed sensitive species is the mine footprint within suitable, historic,
or occupied habitat and is coincident with the analysis area described in Section 3.7,
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Environmental Assessment John Henry No. 1 Mine
Vegetation. The analysis area for federally listed fish species includes approximately 2 miles of
buffer surrounding the John Henry No. 1 Mine. The buffer includes portions of the Green River
watershed and Sawyer Lake.

As noted above, WRI conducted vegetative field surveys in 2005 and 2007 for the adjacent
property with similar vegetative habitat (Parametrix 2009a). No federally listed or State listed
endangered, threatened, or sensitive plants species were found during the WRI field surveys. A
USFWS Information for Planning and Conservation (IPaC) species list was obtained in January
2017 that confirmed that no endangered, threatened, or proposed plant species had the
potential to occur within the vicinity of the mine footprint (USFWS 2016). A search of Natural
Heritage Features, which includes rare plants, high quality wetland ecosystems, and high quality
terrestrial ecosystems, in the State of Washington by township, range and section was
conducted in June 2016 and found no features in the sections in which the mine footprint is
located (WDNR 2015a).
The WDFW website was also referenced by OSMRE (WDFW 2016) to confirm WRIs findings
regarding documented information on the presence of Priority Habitats and Species (PHS).
Thus, the WDFW PHS maps do not indicate any records of endangered, threatened, or
sensitive amphibian, reptile, bird, or mammal species on the John Henry No. 1 Mine (WDFW
2016).

3.10.1.3 Federally Threatened, Endangered, and Candidate Species

Using the USFWS IPaC website, a species list was produced showing the federally listed
species that have the potential to occur within or near the mine footprint. In January 2017, the
United States Fish and Wildlife Service (USFWS) updated the list of Federal endangered,
threatened, candidate, or sensitive species for the project site in King County, Washington.
There are currently five federally listed species that could potentially be present at the John
Henry No. 1 Mine including: Marbled-murrelet, Streaked horned lark, Yellow-billed cuckoo, Bull
Trout, and the North American wolverine. Critical habitat has been designated for bull trout and
Chinook salmon in the Green River which is approximately 1.2 miles from the mine footprint at
the closest point. However, there are no critical habitats within the permit boundary area. No
impacts are expected to habitats along the Rock Creek, Green River, or other priority habitats
outside the permit boundary, or to listed species potentially present, from the Proposed or
Alternative actions. Based on the lack of critical habitat in the project area, determinations of no
effect were made for each of the five species. OSMRE has made the determinations of may
affect, not likely to adversely affect for Puget Sound (PS) Chinook salmon (Oncorhynchus
tshawytscha), and designated critical habitat. Letters of consultation with the National Marine
Fisheries Service (NMFS) and USFWS are provided in Appendix C, Consultation.

3.10.1.3.1 Marbled murrelet (Brachyramphus marmoratus) Endangered with Critical Habitat

The marbled murrelet is a Federal endangered species and State threatened species, having
the unique behavior of foraging in marine waters and flying inland to nest in large conifer trees.
Nesting behavior has been detected as far as 55 mi (88 km) from the ocean in Washington.
Murrelets nest mostly on large branches or other suitable platforms in large trees, with a

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Environmental Assessment John Henry No. 1 Mine
preference for mature and old forest in Washington, Oregon, and California. Marbled murrelets
prey primarily on near-shore forage fish (WDFW 2013).
3.10.1.3.2 Streaked Horned lark (Eremophila alpestirs strigata) Threatened with Critical
Habitat
The streaked horned lark, a Federal threatened species, and state endangered species, is a
rare endemic subspecies found only in western Washington and Oregon. It is perhaps the most
distinct subspecies of the horned lark, a small common ground-dwelling passerine that prefers
open grassland habitat.
3.10.1.3.3 Yellow-Billed Cuckoo (Coccyzus americanus) Threatened with Proposed Critical
Habitat
The yellow-billed cuckoo, a Federal threatened species and State candidate species, prefer
open lowland deciduous woodlands with clearings and shrubby vegetation, especially those
near rivers and streams. In western North America, there is a strong preference for large
continuous riparian zones with cottonwoods and willows. The yellow-billed cuckoo nests in
large, contiguous, blocks of riparian habitat (greater than 50 acres), particularly woodlands with
cottonwoods (Populus fremontii) and willows (Salix sp.). A dense multi-layered canopy of
understory foliage appears to be an important factor in nest site selection. The multilayered
canopy provides shade and traps moisture to create the relatively cooler and more humid
streamside conditions that are believed to be important for nesting success. At the landscape
level, the amount of cottonwood-willow-dominated vegetation in the landscape and the width of
riparian habitat appear to influence yellow-billed cuckoo distribution and abundance (USFWS
2014b). Cuckoos appear to avoid nesting in isolated patches of about 1 to 2 acres in size or in
narrow, linear riparian habitats that are less than 33 to 66 ft (10 to 20 m) wide (Halterman et al.
2015). Overall, migration and wintering habitats appear to be less restrictive to this species
(USFWS 2014). Single birds have been detected in isolated habitat patches or linear riparian
corridors during migration or the early breeding season (mid to late June). Migrating yellow-
billed cuckoos also have been found in coastal scrub, second-growth forests, and woodlands,
hedgerows, forest edges, and in smaller riparian patches than those used for breeding (USFWS
2014). Diet consists mainly of large insects such as caterpillars, grasshoppers, katydids,
beetles, and crickets; small frogs and lizards, bird eggs, and nestling birds are also occasionally
eaten.
3.10.1.3.4 Bull Trout (Salvelimus confluentus) Threatened with Critical Habitat
The bull trout is a Federal threatened species and State candidate species. Bull trout have
never been observed in the Lake Sawyer system according to Ted Muller of the WDFW. Also
according to Mr. Muller there have been no documented sightings of bull trout in the lower and
middle portions of the Green River system into which drainage from the mine eventually flows
(Muller 2000). Bull trout require cold clean water and normally reside at much higher elevations
according to Mr. Muller. He stated he has personally electroshock-surveyed the Green River
system up to Howard Hanson dam and has not observed any Bull or Dolly Varden trout. The
Howard Hanson dam is in the upper portion of the Green River and is located about 15 miles
east of the mine site. Bull trout require cold water to survive, so theyre seldom found in waters
where temperatures exceed 59 to 64 degrees (F). They also require stable stream channels,
clean spawning and rearing gravel, complex and diverse cover, and unblocked migratory
corridors (USFWS 2015e). These char require very cold, clean water in relatively pristine
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Environmental Assessment John Henry No. 1 Mine
streams for the spawning and rearing phases of their life cycle, thus limiting the distribution of
this species largely to higher elevations (King County Department of Natural Resources 2002).
3.10.1.3.5 Chinook Salmon (Oncorhynchus tshawytscha)
Chinook salmon is a Federal threatened species and State candidate species. The Green River
Chinook run is a late summer run and is a component of the Puget Sound Chinook run. The run
usually commences in late August and is finished by October. The run on Big Soos Creek is
comprised of both hatchery and wild stocks. When the hatchery quota is filled, fish are allowed
to bypass the hatchery and spawn upstream (WDFW and WWTIT 1994, Ruggerone and
Weitkamp 2004). Some Chinook will spawn in the lower reaches of Covington Creek although it
is physically impossible for the Chinook to reach Lake Sawyer because upper Covington Creek
is either dry or contains extremely low flows in the August through October spawning period.
3.10.1.4 Migratory Birds

Migratory birds are protected by the Migratory Bird Treaty Act (MBTA) and the Bald and Golden
Eagle Protection Act (BGEPA). The following species of migratory birds could potentially be
affected by activities in within the mine footprint (USFWS 2016).

Bald Eagle (Haliaeetus Leucocephalus): Year-round

Black Swift (Cypeseloides niger): Breeding Season
Brewers Sparrow (Spizella breweri): Breeding Season
Calliope Hummingbird (Stellula calliope): Breeding Season
Caspian Tern (Hydroprogne caspia): Breeding Season
Cassins Finch (Carpodacus cassinii): Year-round
Fox Sparrow (Passerella iliaca): Year-round
Olive-sided Flycatcher (Contopus cooperi): Breeding Season
Peregrine Falcon (Falco peregrinus): Breeding Season
Purple Finch (Carpodacus purpureus): Year-round
Rufous Hummingbird (Selasphorus rufus): Breeding Season
Short-eared Owl (Asio flammeus): Year-round
Western Grebe (aechmophorus occidentalis): Wintering
Willow Flycatcher (Empidonax traillii): Breeding Season

3.10.1.4.1 Migratory Birds

The MBTA provides federal legal protection from anthropogenic depredation for more than a
1,000 avian species (16 USC 7.3-712). In addition to the MBTA, bald and golden eagles are
protected under the BGEPA (16 USC 668 et seq). OSMRE and USFWS have a Memorandum
of Understanding since December 7, 2016 to enhance collaboration between the agencies and
strengthen migratory bird conservation. The majority of birds found within the mine footprint and
vicinity are considered migratory under the MBTA. These birds are primarily summer residents
in the region. Many of the summer residents are neotropical migrants that winter in Central and
South America. Many bird species are more vulnerable to disturbance during the breeding
season when anthropogenic disturbances can compromise successful reproduction. The timing
and duration of the breeding season is species-specific and may vary according to latitude,
elevation, and climatic conditions. Table 23 provides a list of observed wildlife at the John Henry
No. 1 Mine and surrounding areas (i.e. Morgan Kame Terrace and Gravel Mine). Species

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Environmental Assessment John Henry No. 1 Mine
marked with an asterisk are migratory bird species known to occur or with potential to occur
within the mine footprint and surrounding region.
3.10.1.4.2 Raptors
Raptors are protected under state and Federal laws including the MBTA and bald and golden
eagle are protected under the BGEPA. A variety of raptor habitats are found within and adjacent
to the mine footprint, from lower elevation grassland and shrublands to montane shrublands and
forests, see Figure 12. As a result, there are a variety of raptor species likely to hunt or breed in
the area including: red-tailed hawk (Buteo jamaicensis), golden eagle (Aguila chrysaetos), bald
eagle (Haliaeetus leucocephalus), sharp-shinned hawk (Accipter striatus), and Coopers hawk
(Accipiter cooperii) [Table 23] (Parametrix 2009a).

3.10.1.5 Priority Habitat and Species (PHS)

The WDFW defines priority habitat as a habitat type with unique or significant value to many
species and priority species as fish and wildlife species requiring protective measures and/or
management guidelines to ensure their perpetuation. Maps showing locations for current
WDFW records of priority habitats and species for the mine footprint were obtained from the
WDFW (2016).

3.10.1.6 Onsite Priority Habitat and Species

Priority Habitat and Species (PHS) maps and information for the region have been consulted on
many occasions in the past for the project and information from the 2000 query are contained in
the PAP at Appendix IX-3 (PCCC 2011a). Up to date information and data are available on line
from WDFW (2016). WDFW maps show locations for current WDFW records of priority habitats
and species (WDFW 2016). PHS maps illustrate the location of priority habitats and species on
the mine site and in surrounding areas. WDFW PHS maps from 2016 do not indicate that any
endangered, threatened, or sensitive amphibian, reptile, bird, or mammal species occur in the
John Henry No. 1 Mine or in surrounding areas. Priority habitats occurring onsite are described
below. Through permit regulations and best management practices, mining and reclamation at
the John Henry No. 1 Mine will have no direct impact to these habitats.
3.10.1.6.1 Caves Or Cave-rich Areas
Because the mine footprint is located in an area that was historically mined underground, the
area is listed as priority habitat for bats. However, there are no underground mine openings on
or near the mine footprint so roosts are unlikely although these bats may forage aerially over the
permit area.
3.10.1.6.2 Elk (Cervus elaphus): Region, Green River
While not a threatened or endangered species (TES), the Rocky Mountain elk is a State
designated game species. These include native and non-native wildlife species of recreational
importance, commercial importance, or recognized species used for tribal ceremonial and
subsistence purposes and that are vulnerable to habitat loss or degradation. While there are
several game species that may inhabit the John Henry No. 1 Mine for all or part of their life
cycle, WDFW has designated the entire mine site as priority habitat for the Rocky Mountain elk
(WDFW 2015a). The mine footprint is within the historic distribution of Roosevelt elk (Cervus

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Environmental Assessment John Henry No. 1 Mine
elaphus roosevelti) but by the turn of the last century they had been eliminated by early settlers
(Bradley 1982, Spencer 2002). Rocky Mountain elk were introduced into western Washington
from Yellowstone National Park in the early part of the 20th century and by the late 1980s and
early 1990s these elk spread to the mine vicinity (Spencer 2002). It is noteworthy that this
species was not observed in the WDG wildlife survey in 1981 (WDG 1981).
3.10.1.6.3 Lakes
Since mining began in 1986, beavers established a colony in Mud Lake. This caused adverse
impacts to PCCCs drainage control system and requires periodic trapping and relocation of
beaver by licensed trappers. Priority habitats identified within the mine footprint include Ginder
Lake (and Wetland C) and Mud Lake wetlands described in the Section 3.7, Vegetation. These
have been designated priority aquatic and Elk habitat since mining began in 1986 and remained
so in 2016.
3.10.1.6.4 Wetlands, Freshwater Emergent, and Freshwater/Shrub
Sediment Control Pond B, with its wetland characteristics, has been added as priority habitat
but was not included in 2000. Sediment Control Pond B, now designated as a priority habitat, is
scheduled to be filled, graded, and planted with Douglas fir in accordance with the approved
final reclamation plan (PCCC 2011a). Mapping shows some non-existent wetlands within the
footprint of Pit 1 and the Pit 1 backfill area indicating that the mapping may be dated. The
riparian border between Mud Lake and the Green River Gorge Road is new priority habitat that
will not be disturbed by mining or reclamation.
3.10.1.7 Off-site Priority Habitats and Species (PHS)
Off-site priority habitats are to the east of the site in and around Lake 12 and the Lake 12
wetlands. Mining and reclamation would not disturb the Lake 12 drainage basin. Upstream from
the Ginder Lake wetland system, priority habitat extends to the north. Additional priority habitats
are identified along Ginder Creek after it leaves the permit area to the west. Mining and
reclamation activities would have no impact on these priority habitats. Ginder Creek flows into
Rock Creek which also contains a number of identified priority habitats. Lake Sawyer is a
designated breeding, nesting, and management buffer area for the bald eagle. The Green River
Watershed and region is priority habitat for a number of species including Chinook, chum, and
Coho salmon, bull trout, harlequin duck, sockeye, steelhead, and elk. The Rock Creek and
Covington Creek watersheds are priority habitats for the western floater (Anodonta kennerlyi),
steelhead, and coastal cutthroat (Oncohryncus clarki) (occurrence and breeding). The Cedar
River wetlands are priority habitat for the western pond turtle. Other priority habitats include
terrestrial land, riverine wetlands, and snag-rich areas within the Green River vicinity. Through
permit regulations and best management practices, mining, and reclamation at the John Henry
No. 1 Mine will have no direct impact to these habitats.

3.10.2 Environmental Consequences

Approximately 29.7 acres of vegetation would be removed and 2.58 acres of non-jurisdictional
wetlands would be eliminated as a result of continued mining under the Proposed Action
Alternative. All vegetation removal would consist of mature deciduous forest and would occur
within the permit boundary for the John Henry No. 1 Mine site. The wetlands that would be
removed are classified as palustrine emergent, forested, scrub, and unconsolidated bottom.

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Environmental Assessment John Henry No. 1 Mine
Removal of vegetation and wetlands would result in loss of habitat. During reclamation, the
disturbed areas would be backfilled and graded to AOC, and replanted as described in the
approved reclamation plan.

3.10.2.1 Proposed Action Alternative

Under the Proposed Action Alternative, vegetation would be removed and wetlands would be
eliminated by mining and reclamation activities. Long- and short-term impacts to mammals
would occur due to the loss of habitat as a result of the removal of mature deciduous forest and
palustrine wetlands from the continued mining of coal at the John Henry No. 1 Mine. Potential
impacts would also occur as the result of mammal fatality during proposed mining activities.
Potential impacts would be long- and short-term and minor and would be limited to areas
disturbed by proposed mining and reclamation with no changes in the plant community structure
or composition elsewhere within the permit boundary.

Therefore, this project would have no effect on murrelets. The project site is outside the range of
the Streaked Horned lark and therefore would have no effect on the species. Because of the
lack of suitable nesting habitat, there is no anticipated use by murrelets; and therefore, no
anticipated exposure to effects. The project is not located in suitable habitat and therefore it is
not anticipated to contain yellow billed cuckoos and would therefore have no effect on cuckoos.
These char require very cold, clean water in relatively pristine streams for the spawning and
rearing phases of their life cycle, thus limiting the distribution of this species largely to higher
elevations (King County Department of Natural Resources 2002). Some Chinook will spawn in
the lower reaches of Covington Creek although it is physically impossible for the Chinook to
reach Lake Sawyer because upper Covington Creek is either dry or contains extremely low
flows in the August through October spawning period.

The direct impacts of surface coal mining activities on wildlife occur during mining and are
therefore short-term and minor. They include road kills by mine-related traffic, restrictions on
wildlife movement created by fences, spoil piles and pits, and displacement of wildlife from
active mining areas. Displaced animals may find equally suitable habitat that is not occupied by
other animals, occupy suitable habitat that is already being used by other individuals, or occupy
poorer quality habitat than that from which they were displaced. The animals may suffer from
increased competition with other animals and are less likely to survive and reproduce.

Big game animals are highly mobile and can move to undisturbed areas. There may be more
restrictions on big game movement on or through the Mine, however, due to additional fences,
spoil piles, and pits related to mining. SMCRA requires that fences, overland conveyors, and
other potential barriers be designed to permit passage for large animals [30 CFR
816.97(e)(3)].

Medium-sized mammals (such as coyotes, foxes, skunks, and raccoons) would be temporarily
displaced to other habitats by mining, potentially resulting in increased competition and
mortality. However, these animals would quickly rebound on reclaimed areas, as forage
developed and small mammal prey species recolonized. Direct losses of small mammals would

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Environmental Assessment John Henry No. 1 Mine
be higher than for other wildlife, since the mobility of small mammals is limited and many retreat
into burrows when disturbed. Therefore, populations of such prey animals as voles, mice,
chipmunks, and rabbits would decline during mining. However, these animals have a high
reproductive potential and tend to re-invade and adapt to reclaimed areas quickly.

Other upland game bird species (i.e., spruce grouse, wild turkey, pheasant, and gray partridge)
that could potentially occur on the Mine could be temporarily displaced to adjacent habitats
during mining. These birds are highly mobile and can move to undisturbed areas. Their
populations are relatively low; therefore, their relocations should not increase competition and
mortality.

Displaced songbirds including those Migratory Bird Species of Management Concern (Section
3.10.1.5, Migratory Birds) would have to compete for available adjacent territories and
resources when their habitats are disturbed by mining operations. Where adjacent habitat is at
carrying capacity, this competition would result in some mortality. Losses would also occur
when habitat disturbance coincides with egg incubation and rearing of young. Impacts of habitat
loss would be short-term for grassland species, but would last longer for tree- and shrub-
dependent species. Concurrent reclamation would minimize these impacts. A diverse seed
mixture planted in a mosaic with a shrub-land phase would provide food, cover, and edge effect.
Other habitat enhancement practices include the restoration of diverse landforms, direct topsoil
replacement, and the construction of brush piles, snags, and rock piles. Therefore, under the
Proposed Action Alternative impacts to fish and wildlife species would be minor and short and
long-term.

Waterfowl and shorebird habitat on the Mine is minimal, and production of these species is very
limited. Mining would thus have a negligible effect on migrating and breeding waterfowl.
Sedimentation ponds created during mining would provide interim habitat for these fauna. No
delineated wetlands occur on the Mine so no wetlands mitigation would be required. No
fisheries habitat would be impacted within the Mine.

Under the Proposed Action Alternative, big game would be displaced from portions of the Mine
to adjacent ranges during mining. Mule deer would be most affected as the Mine contain good
quality habitat. White-tailed deer would not be affected, as they have not been observed on the
Mine. Big game displacement would be incremental, occurring over several years and allowing
for gradual changes in distribution patterns. Big game residing in the adjacent areas could be
impacted by increased competition with displaced animals. Noise, dust, and associated human
presence would cause some localized avoidance of foraging areas adjacent to mining activities.
On existing surface mines, however, big game have continued to occupy areas adjacent to and
within active mine operations, suggesting that some animals may become habituated to such
disturbances (Medcraft and Clark 1986; Phillips et al. 1986). Therefore potential indirect impacts
to fish and wildlife species would be long-term and minor.

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A hydrologic control plan is designed to prevent adverse impacts to the hydrologic balance
outside the permit area, thus maintaining the quantity and quality of surface waters and the
existing fish habitat downstream of the disturbance.

3.10.2.2 No Action Alternative

Under the No Action Alternative, PCCC would begin reclamation activities immediately.
Reclaimed land would become forest and fish and wildlife habitat. Medium-sized mammals
(such as coyotes, foxes, skunks, and raccoons) would quickly rebound on reclaimed areas, as
forage developed and small mammal prey species recolonized. These animals have a high
reproductive potential and tend to re-invade and adapt to reclaimed areas quickly. Big game
and avian species displaced during mining activities to adjacent lands would be expected to
return to the area once reclamation activities are complete and vegetation has returned.
Therefore potential indirect impacts to fish and wildlife species would be long-term and minor.
Similar to the Proposed Action Alternative displacement as a result of reclamation activities
under the No Action Alternative would be long-term and minor.

3.11 Land Use

3.11.1 Affected Environment

The pre-mining land use of the permit area was unmanaged forest for the upland area and fish
and wildlife habitat for the Mud Lake and Ginder Lake wetlands. Prior logging of the site was
predominantly used as a source of timbers in underground mining from the 1880s until the mid
1970s. There was no planned reforestation conducted during this time and re-vegetation
occurred naturally. A portion of the permit area was clear-cut in 1982 to allow mining (OSMRE
1985). The land use since 1986 has been mining with the continued associated use of wildlife
habitat in undisturbed areas with some forest land reestablished in the reclaimed area of the
mine. The permit area consists of entirely private land. The post-mining land use approved by
OSMRE in 2001 for the upland area is forestry and fish and wildlife habitat (PCCC 2011a). This
is consistent with the landowners request for a continuation of the pre-mining land use. The
landowners have determined it is compatible with a variety of longer-term uses as illustrated in
the PAP in Chapters II and IV specifically Appendices II-3 and IV-8 (PCCC 2011a).

At the time of the 1985 FEIS, the planned Tacoma pipeline was scheduled to be routed through
the John Henry No. 1 Mine. However, when the pipeline was constructed in 2002, it was routed
around Pit 1 adjacent to the Green River Gorge Road. The construction of the pipeline and
related negotiation between Black Diamond and the City of Tacoma provided additional water to
Black Diamond and has facilitated development within the City of Black Diamond.

When the 1985 FEIS was issued, a portion of the proposed Mine located within the city limits
was already zoned as Mineral Extraction/Forestry. However, 12 acres were zoned residential R
2400 and 36 acres zoned residential RM-9600. This required a rezone to Mineral
Extraction/Forestry to allow for the placement of Spoil Piles 3 North and 3 South. PCCCs

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Environmental Assessment John Henry No. 1 Mine
rezone application was approved March 20, 1986 after hearings before the City of Black
Diamonds planning commission and council. The mining extraction/forestry designation is
considered an interim zoning classification. The underlying zoning for the land within the city
limits has zoning codes [Residential (R4,) Medium Density Residential (MDR8), and Master
Planned Development (MPD)] (Black Diamond 2009b).

Washington State passed the GMA in 1991. The primary purpose of the Act was to establish
designated Urban Growth Areas in order to prevent urban sprawl and focus growth in areas
either that had existing infrastructure or which could more easily develop new infrastructure.
Another purpose was to protect critical areas and natural resource lands. Urban Growth Areas
established in Washington as a result of the Act included all areas within incorporated cities
including Black Diamond.

The City of Black Diamond, including the historic downtown, Morganville and various additional
properties, was incorporated in 1959. Currently, John Henry No. 1 Mine permit area extends
within the city limits. The City of Black Diamond completed its first Comprehensive Plan in 1980.
That plan proposed future annexation of lands to the northwest, east, and southwest to the City
of Black Diamond. Subsequent annexations in 1985 and 1994 added lands to the northwest and
southwest to the City of Black Diamond including Lake Sawyer. The portion of the John Henry
No. 1 Mine located in unincorporated King County was considered for annexation, but was not
approved.

The City of Black Diamond completed its first GMA Comprehensive Plan in 1996. That same
year, the City of Black Diamond negotiated a potential annexation area agreement with King
County and nearby property owners that was formalized as the Black Diamond Urban Growth
Area Agreement. Following execution of the Black Diamond Urban Growth Area Agreement,
the City of Black Diamond annexed an area around Lake Sawyer and the West Annexation
Area to the City of Black Diamond in 1998 and 2005.

In 2005, the City of Black Diamond adopted MPD Ordinances (Ordinance No. 05-779 and
Ordinance No. 05-796). These Ordinances establish the MPD zoning district and its standards
and MPD permit requirements for parcels or groups of parcels that are greater than 80 acres in
size. In 2009, the City of Black Diamond further updated several of its planning documents and
environmental policies and procedures, including its Comprehensive Plan (Black Diamond
2009a), MPD Ordinance (Black Diamond 2005), and Sensitive Areas Ordinance (Black
Diamond 2008). In 2010, the City of Black Diamond approved two MPDs; The Villages and
Lawson Hill (see Section 4.1.7, Land Use, for additional information).

The City of Black Diamonds Comprehensive Plan includes a vision for what the City of Black
Diamond would become by 2025, and emphasizes:

Historic heritage and natural setting

Small-town atmosphere
Balance of moderate growth and economic viability

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Environmental Assessment John Henry No. 1 Mine
 Economic base
Mix of residential types, sizes and densities, clustered to preserve maximum open space
Trails/bikeways/greenbelts connecting housing, shopping, employment, and parks and
recreation areas
Active citizen participation in an effective and open government
Adequate public services and environmental protection

3.11.2 Environmental Consequences

In May 2011, OSMRE solicited comments from the City of Black Diamond as a result of PCCCs
permit revision application to resume mining. The City of Black Diamond had no comments
regarding land use other than noting that, under the Proposed Action Alternative, PCCC would
be required to submit a grading plan application and obtain a grading permit for activities
associated with Spoil Piles 3 North and 3 South, as they are located within the city limits.

As explained in Section 1.1, Background Information, the land was rezoned to a Quarry/Mining
designation by King County prior to mining in 1985. The pre-mining land use was unmanaged
forest in the upland area and fish and wildlife habitat in the Mud Lake and Ginder Lake
wetlands. The 29.7 additional acres of disturbance under the Proposed Action Alternative would
not result in a change of zoning designation or land use designation. During reclamation this
newly disturbed area will be backfilled and graded to AOC. There is no historical use of the soil
for cropland and in 2015 OSMRE determined that the property contained no Prime Farmland.

3.11.2.1 Proposed Action Alternative

Under the Proposed Action Alternative, PCCC would be required to submit a grading plan
application and obtain a grading permit for activities associated with Spoil Piles 3 North and 3
South. Impacts would be minor and short-term. Reclaimed land under both the Proposed Action
Alternative and the No Action Alternative would be forest and fish and wildlife habitat. The
underlying land use within the permit area cannot change for 5 years after reclamation is
completed in accordance with SMCRA requirements. Land use impacts would be restricted to
the mine permit area and would not result in any indirect impacts.
3.11.2.2 No Action Alternative
Under the No Action Alternative, PCCC would begin reclamation activities immediately and
conform to the City of Black Diamond grading permit for Spoil Piles 3 North and 3 South.
Reclaimed land under both the Proposed and No Action Alternative would be forest and fish and
wildlife habitat. This underlying land use within the permit area cannot change for 5 years after
reclamation is completed in accordance with SMCRA requirements for liability under the bond
which is for the duration of mining and reclamation and coincident with the operators
responsibility under revegetation requirements. Land use impacts would be restricted to the
mine permit area and would not result in any indirect impacts.

3.12 Socioeconomics and Environmental Justice

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3.12.1 Socioeconomics
3.12.1.1 Affected Environment
The affected environment for Socioeconomics and Environmental Justice is comprised of the
City of Black Diamond and area surrounding the John Henry No.1 Mine including King County.
This affected area was identified because Black Diamond is the only urbanized area in the
immediate vicinity of the mine. It is expected that this area will supply the majority of employees
at John Henry No.1 Mine.
3.12.1.1.1 Population and Employment
The City of Black Diamond had an estimated population of 4,257 in 2014, representing a six
percent growth since 2000. The population is comprised of approximately equal numbers of
men and women, a median age of 35.7 years, and an average household size of 2.7 people.
King County, which includes the City of Black Diamond and the John Henry No. 1 Mine, had a
population of 2,008,997 in 2014, representing a 9.9 percent increase from 2000 (U.S. Census
Bureau 2000).

Black Diamond is considered a residential community with little industry and direct employment.
Most working-aged residents commute to jobs located in the Kent Valley or the Seattle area.
According to the City of Black Diamond unemployment is 3.3 percent (Black Diamond 2015a).
At its peak production in 1993, the mine employed 75 people and was an important employer in
the greater Black Diamond area.

Under the Proposed Action Alternative, PCCC and/or contractors expect to employ 30 full-time
staff during the six year mining period and 20 full-time staff during one year of reclamation.
Under the No Action Alternative, 20 full-time staff would be employed during two years of
reclamation.

3.12.1.1.2 Utilities
Electrical power at the John Henry No.1 Mine is provided by Puget Sound Energy through a
privately-owned high voltage power line. PCCC constructed a septic system in 1991. These and
other utilities are described:

PCCC receives power from Puget Sound Energy. The load is 800 to 1,000 kilovolt-
ampere (KVA).
An underground transmission line was built along the access road to the facilities area.
The transmission line is owned by PCCC and provides electricity to the office, shop, and
preparation plant.
Two ground-based step-down transformers were installed under Puget Sound Energy's
supervision at PCCCs expense. One 300 KVA transformer provides 480-volt electricity
to the preparation plant and the other 75 KVA transformer provides 480-volt electricity to
the office and shop facilities.
The John Henry No. 1 Mine uses a well as a source of potable water.
PCCC pumps make up water for the plant from Pit 2. PCCC can also supply water from
pond G or from Ginder Lake.

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Environmental Assessment John Henry No. 1 Mine
 PCCC constructed a sewage system in 1991. The system has an approximate 2,500
lineal foot drain field and a septic tank total capacity of approximately 4,500 gallons.

3.12.1.1.3 Public Services

King County and the City of Black Diamond have sufficient public services including a County
and City police force, specialized enforcement teams [hazardous materials, helicopter rescue,
marine rescue, and special weapons & tactics squad (SWAT)], regional and local fire and
emergency medical services (EMS), and several area hospitals [including two 24-hour
emergency care hospitals (St. Elizabeth Hospital and the Valley Medical Center)] (King County
2016).

Housing availability in and around the City of Black Diamond is sufficient to accommodate the
estimated workforce of 30 full time employees for a period of six years and one year of
reclamation under the Proposed Action Alternative. It is assumed that the majority of the
workforce will come from the local City or County and therefore will not require relocation.
3.12.1.1.4 Royalty and Tax Revenues
Like all coal mines in the U.S., PCCC paid the Federal Black Lung Excise Tax and into the
Abandoned Mine Land fund during previous mining operations and will continue to do so under
the Proposed Action Alternative. The coal is a privately-owned reserve and would not be subject
to paying royalties. Local tax contributions are expected to be small portion (less than 1 percent)
of total King County tax revenues. PCCC would be required to resume abandoned mine land
fees upon mining.
3.12.1.1.5 Property Values
Homeowners and landowners in those areas contiguous to the Mine in unincorporated King
County expressed concern over a decrease in property values attributable to the proximity of
the proposed mine development. Local realtors were contacted to determine if this was the
case. One realtor noted that a monthly analysis of home sales and listings in the Black Diamond
zip code area since January 2011 shows that, while there is monthly variability, the trend has
been from a buyers to sellers market with fewer homes on the market selling at higher prices.
In 2011, it was considered to be a buyers market with home prices ranging from $113 per
square foot to a maximum of $184 per square foot. Over the ensuing 17 months, prices per
square foot trended up and were over $200 per sq. ft. on two occasions (Johnston 2014).

Another realtor provided a background on values of property located adjacent to the mine (Beck
2014). In 1985, the mine opened and employment expanded rapidly. A few years later, several
residential developments were proposed and constructed in Black Diamond. The largest
development was the 129-lot Morgan Creek developed across the Black Diamond-Ravensdale
Road from the entrance to the mine. Another 72-lot development, Lawson Hills Estates was built
south of and directly adjacent to the John Henry No.1 Mine in 1992. The 30-lot Diamond Glen
development was built in 1990 a half mile west of the mine site. The 10-lot Sunny Lane was built
in 1993, one mile west of the mine site. One 5-acre rural residential development was platted in
1977 and completed in the early 1980s. This development, known as Diamond Acres, is
surrounded by the John Henry No. 1 Mine on three sides. Eleven lots were developed, but the

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Environmental Assessment John Henry No. 1 Mine
first home was not built until 1982, with the next seven homes built from 1985 to 1998. This
period also coincided with the most active period of surface coal mining at the John Henry No. 1
Mine. The realtor provided data that shows property values in these developments have
increased consistent with other regional property value changes.

3.12.1.2 Environmental Consequences

Under the Proposed Action Alternative, the Mine would employ 30 full time people during mining
operations and 20 full time people during reclamation. Under the No Action Alternative, the mine
would employ 20 full time people during reclamation.

As reported by knowledgeable real estate professionals in the area, property values of nearby
properties have not been adversely impacted since the formal announcement of the mine
reopening in May 2011. Overall, the operation of the John Henry No. 1 Mine would have little
impact on the City of Black Diamond and its residents and very little socioeconomic impact in
general.

3.12.1.2.1 Proposed Action Alternative

Under the Proposed Action Alternative, PCCC and its contractors would employ an average of
about 30 people per day for six years during mining and 20 people per day during the one year
of reclamation. The average workweek is expected to consist of 5 working days. The mine
would be self-contained and would require no external utility services other than those
discussed previously. Between the low levels of unemployment in the community, the likely
impact to socioeconomics would be negligible, short-term and would be limited to the local area
in and around Black Diamond. Impacts to public services would be negligible because these
services are adequate for the estimated workforce of 30 full time employees during mining
operations and 20 full time employees during reclamation. It is not anticipated that the estimated
workforce would put a strain on any of these public services as they are likely to already be
residents of the area.

Indirect employment and increased revenue at local retailers and restaurants could result from
the Mine employees spending their salaries in and around the City of Black Diamond. Parts and
other various materials for the mine would most likely be purchased in nearby communities
outside of the City of Black Diamond due to its limited amount of commercial activity causing
beneficial indirect socioeconomic impacts in communities such as Maple Valley or Enumclaw.
Since all employees are only expected to work for the Mine for a maximum of seven years
(mining and reclamation), any indirect impacts would be negligible and short-term.

3.12.1.2.2 No Action Alternative

Under the No Action Alternative, PCCC and its contractors would employ an average of 20
people for two years for reclamation-only operations. No additional outside services would be
required under this alternative than what currently exists. The socioeconomic impacts would be
negligible, short-term, and limited to the local area in and around Black Diamond.

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Environmental Assessment John Henry No. 1 Mine
Indirect employment at local retailers and restaurants could result from the 20 reclamation
employees spending their salaries in and around the City of Black Diamond. Since, employees
are expected to come from the local area in and around the City of Black Diamond any indirect
impacts would be local. However, due to the small scale of full time employment these impacts
are expected to be negligible and short-term.

3.12.2 Environmental Justice

3.12.2.1 Affected Environment
Executive Order 12898 requires Federal agencies to identify and address disproportionately
high and adverse human health or environmental effects on minority and low-income
populations.

According to CEQ and U.S. EPA guidance established to assist Federal agencies, a minority
population is present in a project area if:

The minority population of the affected area exceeds 50%; or

The percentage of minority population in the affected area is meaningfully greater than
its population percentage in the general population.

According to 2010 Census data (U.S. Census Bureau 2010), there are few minority or low-
income populations documented in the general vicinity of the mine in the City of Black Diamond
compared to the population in the King County area (see Table 24).

Table 24. King County and City of Black Diamond Minority and Low-Income Populations
Income and Demographics King County City of Black Diamond
1
Income in the past 12 months below poverty level 35,930 34
Income in the past 12 months at or above poverty 443,034 1,161

level1
Male Population 1,002,198
1,999
Female Population 1,006,799
2,258
White 1,384,506 3,692
Black or African American 123,852 0
American Indian and Alaska Native 15,724 131
Asian 306,079 94
Native Hawaiian and Other Pacific Islander 15,323 0
Some Other Race 51,985 258
Two or More Races 111,528 82
Hispanic or Latino (any race) 184,318 279

1
households and individuals
Source: US Census Bureau 2010

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Environmental Assessment John Henry No. 1 Mine
3.12.2.2 Environmental Consequences
There would be no disproportionately high and adverse (direct or indirect) human health or
environmental effects on minority and low-income populations from the Proposed or No Action
Alternative. Impacts to human health and environmental resources are described in Sections
3.1 3.17 of this EA.
3.13 Transportation

3.13.1 Affected Environment

OSMRE determined that primary transportation impacts would be related to:

The capability of the Black-Diamond Ravensdale Road to carry the large coal trucks.

The capability of the existing traffic control and management system to handle additional
truck and car traffic at affected intersections.

The 2035 Washington State Long Range Transportation Plan does not outline any major
upgrades or projects for roadways utilized by the Proposed Action (Washington Department of
Transportation and Washington State Transportation Commission 2015). King County, through
a condition of PCCCs grading permit, put the burden of funding unusual road deterioration on
PCCC. PCCC would apply for a grading permit two years prior to the end of mining operations
and before reclamation activities.

The three roads impacted by truck traffic into and from the mine include (Parametrix 2009c), see
Figure 14:

SR 169/Maple Valley Black Diamond Road SE This roadway is classified as a

principal arterial that provides north-south travel. The number of lanes varies from two to
four, and the posted speed limit varies from 25 mph to 50 mph. SR 169 is classified by
WSDOT as an Urban-Principal Arterial (U1) and is a Highway of Statewide Significance
(HSS) which includes interstate highways (I) and other principal arterials that are needed
to connect major communities in the State of Washington. SR 169 is the only regional
north-south roadway that connects areas with high levels of employment and services.
As a result, a majority of commuters utilize SR 169 during some point of their trip.

SR 516 This roadway is classified as a principal arterial west of SR 169 and as a minor
arterial from SR 169 to Retreat Kanasket Road SE. The number of lanes varies from two
to five, and the posted speed limit varies from 30 mph to 45 mph. SR 516 is classified by
WSDOT as an Urban-Minor Arterial (U2) and is not a HSS route.

Black Diamond/Ravensdale Road This roadway is classified as a major collector that

provides north-south travel. One lane is provided for each direction of travel. The posted
speed limit of the Black Diamond-Ravensdale Road approaching the intersection of SR
169 is 45 mph.

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Environmental Assessment John Henry No. 1 Mine
 108
Environmental Assessment John Henry No. 1 Mine
Figure 14. Potential Roadways Impacted by Truck Traffic

The two intersections through which coal haul trucks must operate include the SR 169/Black
Diamond/Ravensdale Road Intersection and the SR 169/SR 516 Intersection (Parametrix
2009c). Conditions at these intersections are measured in terms of Level of Service (LOS). LOS
determinations are between letters A indicating free flowing traffic and F indicating that traffic

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Environmental Assessment John Henry No. 1 Mine
is highly congested with long delays (Transportation Research Board 2000). LOS
determinations are not considered relevant for non-peak hour conditions and therefore are only
used to analyze potential impacts during peak hour traffic. Washington Department of
Transportation standards indicate LOS D or greater is acceptable for urban highways and LOS
C or greater is acceptable for rural highways (WDOT 2010) see Table 25.

Table 25. Level of Service

LOS Delay (seconds per vehicle)
A 10
B >10-20
C >20-35
D >35-55
E >55-80
F >80

Source: Transportation Research Board 2000

SR 169/Black Diamond/Ravensdale Road Intersection This is an un-signalized four

way intersection. During a 2009 study, the AM peak hour the LOS was C or above the
standard. During the PM peak hour the LOS was F. This was primarily due to west
bound traffic (213 during that hour) on the Black Diamond - Ravensdale Road attempting
to turn left onto SR 169. This resulted in a 94.5 second delay per vehicle turning left
(Parametrix 2009c). This intersection has been proposed to the City of Black Diamond
for improvements in anticipation of future residential development (City of Black
Diamond 2016).

SR 169/SR 516 Intersection This is a fully signalized intersection located within the
City of Maple Valley. The intersection has five lanes in all directions and carries a LOS
category D according to the draft 2015 Maple Valley Comprehensive Plan update (Maple
Valley 2015). Average delay time during the peak PM hour is now 44 seconds. Peak PM
traffic volumes in 2014 through the intersection were about 1,750 vehicles per hour and
21,700 total vehicles per day in all directions traveling through the intersection.

There are several different factors to consider when analyzing potential impacts to
transportation. Those include the annual average daily traffic values (AADT), percent of AADT
that is comprised of trucks, peak hour traffic levels which for purposes of this analysis are
between the hours of 7 am 9 am and 4 pm 6 pm by request of King County, and LOS, see
Table 26 [King County Department of Permitting and Environmental Review (DPER) 2014].

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Environmental Assessment John Henry No. 1 Mine
Table 26. Existing Traffic Conditions
Roadway AADT (2016) Truck Traffic2 Peak Hour AADT
(AM/PM)3,4
SR 169/Maple Valley Black Diamond 23,540 2,354 15,066
Road SE1
SR 5161 25,169 2,517 16,108
Black Diamond-Ravensdale Road5 1,752 175 1,121
Intersections
SR 169/Black Diamond - Ravensdale 3,875 388 2,480
Road5
SR 169/SR 516 22,716 2,272 14,538

1
Average across all roadway sections.
2
Assumes 10% of all AADT is truck traffic actual percentages may vary.

3
Peak hour occurs between 7 am 9 am and 4 pm 6 pm on weekdays. Column shows total traffic during all 4 hours.

4
Assumes peak hour accounts for 16% of total daily traffic based on closest peak hour traffic recorder (SR901).

5
Calculated value based on PM peak hour traffic as 16% of daily traffic extrapolated to 2016 values assuming a 0.9% annual growth
rate.

Sources: Parametrix 2009c, WDOT 2014, WDOT 2016

Another factor considered when analyzing potential impacts to roadway traffic and safety is the
minimum sight distance required for stopping and entering an area roadway without disrupting
traffic. Sight distance measurements were not available from the direction of the Mine; however,
Transpo Group examined entering and stopping sight distances at the SR 169 and Black
Diamond Ravensdale Road intersection from the sand and gravel mine entrance. Entering
sight distance is defined as the distance necessary for a motorist to safely enter the traffic
stream without causing traffic on the major street to appreciably reduce its travel speed.
Stopping sight distance is defined as the distance necessary to enable a motorist to stop before
reaching a stationary object in its path. King County road standards require an entering sight
distance of 620 feet and stopping sight distance of 460 feet (King County 2007) at this
intersection in both directions. Transpo Group measured the distances at 500 feet and 360 feet
respectively in both directions thereby meeting the safety standard set by King County.

3.13.2 Environmental Consequences

For purposes of this EA, two transportation scenarios are analyzed for the Proposed Action
Alternative: Scenario 1 would result in approximately 10 trucks per day during non-barge
operations and Scenario 2 would result in 82 trucks over 36 hours to load barges for transport.
Current traffic levels on potential truck transport routes would see less than 5 percent change in
AADT. Coal haulage trucks would predominantly operate during off-peak hours while the
aggregate mining operations in the area used the road during normal business hours to a much
greater extent than PCCC.

3.13.2.1 Proposed Action Alternative

Under the Proposed Action Alternative, coal would be transported from the mine in trucks with
trailers that average 32 tons of coal per load. PCCCs expected peak annual production is
84,000 tons; coal haulage intensity would vary depending on PCCCs coal delivery schedules

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Environmental Assessment John Henry No. 1 Mine
and customer location. Coal would be hauled out at the average rate of about ten (9.9) truck
trips per day over seven days per week (Table 27).

The mine and plant operating hours are 6 a.m. until 10 p.m. based on King County operating
and trucking restrictions. It has not yet been determined if the mine will operate one or two shifts
per day but regardless, shift starting and stopping time will not coincide with the Peak hours at
the intersection of Black Diamond Ravensdale Road and SR 169. Vendor deliveries to the
mine will run 5-10 deliveries per working day and will be during normal working hours.

Employee traffic from 30 full time workers would account for 60 round trips per day arriving and
leaving at different points in the day depending on operating shift schedules. Even on the most
congested roadway (SR 169) at 23,540 vehicles per day (see Table 27) the addition of 60 trips
per day would only be a 0.3% increase.

The City of Black Diamond reviewed worst-case traffic impacts as discussed in this EA and the
conditions King County imposed in the grading permit. Given the King County grading permit
condition that prevents coal haulage during the peak traffic hours, Black Diamond determined it
was satisfied that the issue of truck traffic has been adequately addressed and requires no
further study (Black Diamond 2015b).

WDOT reviewed impacts to traffic on State Highways in the project area. WDOT analyzed a
worst-case scenario of 82 truck trips per day over a 20-hour period accessing State Highways
SR 169 and SR 516 as discussed in this EA. WDOT determined that the proposed project
would have insignificant traffic impacts to SR 169 and SR 516 over the proposed 6-year period
of coal haulage (WDOT 2016).

On December 24, 2014, King County Department of Permitting and Environmental Review
(DPER) issued a periodic review and decision regarding PCCCs grading permit. In that
decision, the County added three additional conditions to the grading permit to mitigate traffic
impacts. The periodic review analyzed average truck traffic of only 10 trucks per day, five days
per week (King County DPER 2014).

These include:

1. Once hauling begins, PCCC shall monitor the mine exit onto Black Diamond
Ravensdale Road for possible tracking of mud on area roadways. If it is determined that
tracking is a chronic problem during inclement weather, PCCC shall have 60 days to
provide a workable solution to prevent further tracking. All trucks leaving the site will be
covered.

2. Loaded trucks will be limited to exiting the site westbound onto the Black Diamond
Ravensdale Road.

3. No hauling can occur during peak traffic hours.

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Environmental Assessment John Henry No. 1 Mine
King County also noted that they were not aware of any capacity, safety or other impacts or
concerns that would result from using that portion of the Black Diamond Ravensdale Road
from the mine entrance to SR 169 at the haulage levels proposed. PCCC has informally agreed
with King County to expand the peak hour definition to 7-9 a.m. and 4-6 p.m. respectively. This
agreement will be formalized before PCCC begins hauling operations in accordance with King
County Grading Permit conditions (King County DPER 2014).

Subsequent to the issuance of the FEIS, PCCC constructed a wheel wash to clean trucks
leaving the mine site. Dirt is removed both by the action of the truck driving through the wash
and by the water sprays. Dirt would settle out in the wheel wash and not track onto the Black
Diamond Ravensdale Road. The effectiveness of this system would be monitored by PCCC
and King County and improved if necessary to keep mud and dirt off the county road.

Since King County has directed PCCC not to haul during peak traffic hours, short-term direct
traffic impacts would be negligible and short-term. Potential impacts to area intersections would
also be negligible and short-term due to the avoidance of travel during peak hour and low
increase in overall AADT values 0.3 4.5%, see Table 27.

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Table 27. Proposed Action Traffic Conditions
# of # of
# of % Truck Peak Hour
Baseline Mining Delivery
Employee Total Traffic for for Total
Roadway AADT Truck Vehicles % change
Trips per AADT Total AADT
(2016) Trips per Trips per
day AADT2 (AM/PM)3,4
Day6 Day
SR 169/Maple Valley Black
23,540 19.8 60 20 23,640 0.42% 2,364 15,129
Diamond Road SE1
SR 5161 25,169 19.8 60 20 25,269 0.39% 2,527 16,172
Black Diamond-Ravensdale
1,752 19.8 60 20 1,852 5.39% 185 1,185
Road 5

Intersections

SR 169/Black Diamond -
3,875 19.8 60 20 3,975 0.42% 2363.98 15,129
Ravensdale Road 5
SR 169/SR 516 22,716 19.8 60 20 22,816 0.42% 2,282 14,602
1
Average across all roadway sections.
2
Assumes 10% of all AADT is truck traffic actual percentages may vary.
3
Peak hour occurs between 7 am 9 am and 4 pm 6 pm on weekdays. Column shows total traffic during all 4 hours.
4
Assumes peak hour accounts for 16% of total daily traffic based on closest peak hour traffic recorder (SR901).
5
Calculated value based on PM peak hour traffic as 16% of daily traffic extrapolated to 2016 values assuming a 0.9% annual growth rate.
6
19.8 truck trips per day equals 1 loaded truck and 1 unloaded truck for the average of 9.9 trucks per day
Sources: Parametrix 2009c, WDOT 2014, WDOT 2016

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Environmental Assessment John Henry No. 1 Mine
3.13.2.1.1 Barge Transport
Hourly truck traffic intensity depends on various factors. For example, barge loading could occur
in Tacoma, Seattle or possibly at other barge loading sites in Puget Sound where coal stockpile
capacity and barge loading rate would determine peak trucking conditions. PCCC has not yet
selected a proposed barge loading site or sites but it is assumed that all suitable barge sites
would be accessible by the proposed trucking routes. That will depend on market conditions
when production begins. It is assumed that trucks would directly discharge onto conveyors
which load onto barges or into trucks which directly dump on the barge. The worst-case
condition is when 4,000-ton barges would be loaded over a minimum of 36 hours. This scenario
results in truck traffic of four truck trips per hour or 82 truck trips over a 20.5-hour day. As shown
in Table 27, area roadways have enough capacity to accommodate the increase of 82 truck
trips per day for barge loading. However, the King County permit periodic review did not analyze
this level of traffic. The additional truck trips associated with barge loading will likely need to go
through a separate review process and possible King County permit modification.

With 84,000 tons per year production and 4,000 tons per barge, 21 barges per year, or about
one every two weeks, are required if all production is barged. The haul route would be
southwest along the Black Diamond Ravensdale Road to SR 169 then north to the
intersection of SR 169 and SR 516. For coal delivery to Seattle customers or a Seattle barge
loading site, the trucks would continue north on SR 169 to I-405 and then on I-405 to I-5. For
coal delivery to customers or a barge loading site located in Tacoma or further south, the trucks
would turn west on SR 516 and proceed to SR 18 and then onto I-5 into Tacoma. Exact trucking
routes for barge offloading at the Port of Richmond in British Columbia to the cement plant in
Delta, BC are unknown but would be expected to experience the same level of traffic on area
roadways (82 truck trips per day). However, the distance between the port and offload site is
much shorter (approximately 1 mile) than the original loading from the Mine to the port.

According to the U.S. Army Corps of Engineers, Waterborne Commerce Statistics Center, the
Port of Seattle handled 99,499 vessel trips and the Port of Tacoma handled 39,482 vessel trips,
of foreign and domestic cargo, in 2014 (USACE 2016). The barges used to transport coal would
be subject to the vessel traffic service regulations established under the Ports and Waterways
Safety Act and managed by the U.S. Coast Guard while traveling in Puget Sound (USCG 2015).
Since the route from Port of Tacoma or Port of Seattle to the Port of Richmond in British
Columbia is heavily traveled daily, the addition of 21 barges traveling through the Puget Sound
Waterways and loading and unloading at port facilities would be negligible and short-term.

3.13.2.1.2 Emergency Services

Emergency service vehicles response time delays can result from several factors including
potential traffic congestion. Under the Proposed Action Alternative, daily increases to roadway
traffic would be minimal and would avoid travel during peak hour conditions where emergency
services would experience the most delay due to traffic congestion. Therefore, potential impacts
to emergency service vehicles would be negligible and short-term.

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3.13.2.2 No Action Alternative
Under the No Action Alternative, coal would not leave the mine site. Approximately 20 people
will be employed during the two years of reclamation and will travel to the site in the morning
and leave in the late afternoon or evening. Normal operating hours are 6 am until 10 pm.
Employee and vendor traffic into and out from the mine will likely be outside peak hours at the
intersection of Black Diamond Ravensdale Road and SR 169 due to shift schedules
accommodating potential mine operation hours of 7 am 10 pm. Shift one would need to arrive
before 7 am and would leave in mid-afternoon with second shift starting mid-afternoon and
leaving in the late evening. Impacts to traffic associated with reclamation would be negligible,
short-term, and local. Under the No Action Alternative, coal would not leave the mine site and
therefore would not result in any barge traffic or delays to emergency services. Indirect impacts
would be negligible and short-term.

3.14 Recreation

3.14.1 Affected Environment

There are no parks or recreational facilities located within one mile of the Mine. The City of
Black Diamond maintains a three-acre park in the middle of the city adjacent to the Black
Diamond elementary school. This school is located approximately 5,300 feet from the current
disturbed area of Pit 2, and just over 4,000 feet from Pit 2 at its closest approach under the
Proposed Action Alternative, which would be estimated to occur in 2017 2018. The
elementary school is currently undergoing renovations and will reopen in fall 2017 (Enumclaw
School District 2016). The school is approximately 2,000 feet from the John Henry No. 1 Mine
Revision Permit boundary (King County 2016). The school and the park provide space for little
league baseball and soccer practice and games and has basketball courts, tennis courts, and a
new skateboard arena.

Lake No. 12 located east of the permit boundary is a recreational and residential lake.
Recreational uses include fishing and swimming. Lake Sawyer is located over a mile west of the
western permit boundary and is also a residential and recreational lake. In addition to fishing
Lake Sawyer supports a variety of water sports during the summer including water skiing and
wake boarding.

3.14.2 Environmental Consequences

The mine property was privately owned land and was not used for recreational purposes before
mining began in 1986. The approved post-mining land use does not include recreational uses.
There have been no direct adverse environmental impacts observed from the mines historic
operation on either Lake No. 12 or Lake Sawyer recreational activities. As described in Section
3.15, Visual Resources, any potential visual impacts to recreational users has been diminished
by the vegetation barrier along the Green River Gorge Road.

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Environmental Assessment John Henry No. 1 Mine
3.14.2.1 Proposed Action Alternative
There are no parks or recreational facilities located within one mile of the Mine therefore there
would be no direct impacts from the Proposed Action Alternative. There are no parks or
recreational facilities located within one mile of the Mine therefore there would be no indirect
impacts from the Proposed Action Alternative.

3.14.2.2 No Action Alternative

There are no parks or recreational facilities located within one mile of the Mine therefore there
would be no direct impacts from the No Action Alternative. There are no parks or recreational
facilities located within one mile of the Mine therefore there would be no indirect impacts from
the No Action Alternative.

3.15 Noise and Vibration

3.15.1 Affected Environment

King County Noise Ordinance No. 3139 and the Washington Administrative Code, Chapter 173
60, require that the basic permissible sound level during daytime hours of operation be less than
57 dBA at the receiving rural residences in unincorporated King County (including those
residences around Lake No. 12 and the Diamond Ridge Acres subdivision) and less than 60
dBA for the offsite residential properties in Black Diamond. Prior to mining, PCCC
commissioned a Noise Mitigation Study (Towne, Richards and Chartiere, Inc. 1983). This study
is included as Appendix III-4 of the PAP (PCCC 2011a). Noise mitigation berms including Spoil
Pile 1, the berm along the east edge of the mine site, Spoil Pile 2 and Spoil Pile 3 South were
constructed and were effective at mitigating noise impacts on surrounding residents as no noise
complaints were filed with King County that would have potentially required additional
monitoring. Spoil Pile 1 primarily served to attenuate noise from coal processing activities. In
addition, the coal processing plant was enclosed to minimize noise.

A source of potential noise and vibration impacts would be from blasting the rock overburden
prior to haulage and backfilling. All blasts are designed by a licensed blaster to ensure that they
are conducted in a controlled manner and achieve compliance with all regulations. Blast holes
are drilled in a fixed pattern to a depth of 25 feet below ground surface. The blast holes are
loaded with explosives and detonated in a controlled manner and sequence to minimize
vibration and fly rock. Blasting would occur only during daylight hours and the proposed
schedule would be published every 12 months in a local newspaper. As a condition of its King
County Grading Permit, PCCC would only be allowed to blast between the hours of 10 am and
4 pm (King County DPER 2014). Noise levels associated with mining activities and ground
vibrations from blasting attenuate with distance. They are expected to be perceptible, but not
significant, outside the proposed mining area. PCCC is responsible for maintaining records of all
blasts.

OSMRE concluded in the 1985 FEIS that based upon the blasting procedures outlined in the
PAP, blasting operations would not produce ground vibrations in excess of 0.3 inch per second

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Environmental Assessment John Henry No. 1 Mine
(maximum peak particle velocity) at the closest structure not owned and/or occupied by the
operator. Vibrations of this magnitude would not cause damage to structures but would be
perceptible to humans and animals (OSMRE 1985). Vibration impacts related to blasting under
the Proposed Action Alternative would follow the same procedures analyzed in the 1985 FEIS
and therefore vibration impacts would be similar in nature.

3.15.2 Environmental Consequences

To mitigate noise impacts, King County set defined hours for mining operations that run 6 am
until 10 pm on weekdays. In accordance with King Countys rezone ordinance, this restriction
does not apply to truck traffic in and out of the mine (King County 1985). Vibration from blasting
under the Proposed Action Alternative would be controlled as required in the regulations (30
CFR 816.61-68). PCCCs approved blasting plan can be found in Section 3.3.2 of the PAP.

Potentially negative impacts from blasting are controlled in a number of ways. Spoil Piles 3
North and 3 South and the berm along the eastern edge of the mine site act to reduce the
impact of noise from blasting on the local community. Blasting operations are done in
compliance with the Federal performance standards at 30 CFR 816.61 through 816.68.
Condition 9006 of the King County Grading Permit limits blasting to the hours between 10:00
am until 4:00 pm.

During the first three years of mining under the Proposed Action Alternative the minimum
distance to the nearest non-mine structure is 1,005 feet. As the mine advances to the west it
would terminate 530 feet from the nearest structure located on SE 310th Street. There is also a
small-scale residential community located across the street from the mine entrance/exit. The
Black Diamond elementary school is located approximately 5,300 feet from the current location
of Pit 2, and just over 4,000 feet from Pit 2 at its closest approach under the Proposed Action
Alternative, which would be estimated to occur in 2017 2018.

3.15.2.1 Proposed Action Alternative

Noise levels would increase in the vicinity of residents off of SE 310th Street from mining
operations and increased traffic at the mine entrance/exit at the residential development across
the street. Construction equipment used during mining operation would not exceed standards
set in the King County Code 12.86.520 for operation of heavy equipment and King County Code
21A.22 for mineral extraction. Under the truck transport scenario, increased transportation noise
would be negligible because the additional traffic would only result in a less than 5 percent
increase on area roadways and any truck noise associated with entering or exiting the mine
would be short-term and last only a few minutes 3 to 4 times per day. Under the barge transport
scenario, there would be 82 trucks entering/exiting the mine within a 36 hour period resulting in
increased noise levels for the residential development across the street. Trucks used to
transport coal would conform to King County Code 12.86.200 and King County grading permit
standards and not exceed the maximum permissible sound levels under WAC 173-62-030.
Those standards state for all motor vehicles over 10,000 pounds the maximum sound level
(dBA) for 45 mph or less is 86 dBA, over 45 mph is 90 dBA and stationary is 86 dBA. Although
the number of trucks is greater than the 10 trucks per day, 82 trucks within a 36-hour period are
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Environmental Assessment John Henry No. 1 Mine
still less than 15 percent increase to AADT levels on area roadways. Noise impacts related to
barge transport would be considered minor and short-term.

Noise impacts to the Black Diamond elementary school are expected to be negligible and short-
term due to its distance from mining operations (approximately 1 mile) and potential coal hauling
routes. Any increase in noise levels would be dissipated by natural topographic and manmade
features before reaching the school.

As discussed in the King County grading permit, DPER utilizes noise sampling equipment
periodically during inspections and if its determined that an exceedance of the standards may
be occurring it can require the permittee to provide a supplemental noise study with proposed
mitigations to address the issue (King County DPER 2014). It should also be noted that King
County recently amended its Noise Ordinance to shift the enforcement focus for neighborhood
noise from solely technical decibel limits to public disturbance provisions. A public disturbance
is any sound that unreasonably disturbs or interferes with the peace, comfort or repose of a
person or persons.

Reclamation activities take place away from most surrounding residential areas. The exceptions
are the reduction in volume and size of Spoil Pile 1 near Lake No. 12, Spoil Pile 3 South near
Lawson Hills Estates and Spoil Pile 3N near one residence along SE 310th Street. This activity
uses the same equipment as used elsewhere, namely articulated trucks and excavators in the
case of the Proposed Action Alternative. In each instance, as layers of the spoil piles are
removed to achieve AOC, the outer edge of the pile would be mined last. This allows most
overburden removal activities to take place behind that outer edge which creates an effective
temporary noise mitigation berm. This does not mitigate noise when the outer edge of the layer
is removed but it does mitigate it during much of the spoil pile removal activities. As only the
upper levels of the spoil piles are removed to achieve AOC, this activity occurs 100-200 feet
farther from local residences as when the spoil piles were constructed.

Noise would also occur as trees are removed on the spoil piles. All reclamation activities related
to reduction in size of the spoil piles would occur during limited hours in accordance with the
King County grading permit. Under King County Code 12.86.500, sounds originating from forest
harvesting and silviculture are exempt any time from King County noise restrictions in a rural,
commercial or industrial district in King County. Such sounds are also exempt during the
daytime for all other districts (KCC 12.86). Trees would likely be removed with mechanized
equipment. The noise impacts associated with tree removal are expected to be similar to
impacts from mining and reclamation equipment as logging uses similar equipment powered by
similar engines. In the case of timber removal direct impacts would be extremely short-term
(less than one month) and minor.

Blasting would occur in a controlled manner that limits vibration. Blasts would be controlled and
monitored as required by OSMRE regulations at 30 CFR 816.67. Specific permit stipulations
required under the Proposed Action Alternative as described in the PAP (PCCC 2011a) include:

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Environmental Assessment John Henry No. 1 Mine
 Blasting operations would be limited to occur between the hours of 10 am and 4 pm;
The blasting schedule would be published in a local newspaper once each year;
Pre-blast surveys would be conducted if requested by property owners;
Blasters would be required to be certified by OSMRE;
Blast designs would be required to be submitted to and approved by OSMRE if blasting
within 1,000 feet of a structure were to occur;
An audible blast warning and all-clear signals, covering a range of mile from the
proposed blast location, would be provided;
Air blast limits set by 30 CFR 816.67(b) would be adhered to;
Vibration limits set by 30 CFR 816.67(d) would be adhered to;
Guards would be posted on adjacent public road to restrict traffic during blasts;
Nearby properties would be periodically monitored to ensure compliance with Federal air
and vibration blast standards.

Direct impacts from mining operation, coal transport, and reclamation noise and blasting are
expected to be minor and short-term, mostly confined within the mine site but could be local at
times. PCCC must comply with both King County and Federal regulations related to noise and
blasting. OSMRE periodically monitors potential noise and vibration impacts to ensure
compliance with OSRME regulations. Noise and vibration impacts would be restricted to the
mine permit area and would not result in any indirect impacts.

3.15.2.2 No Action Alternative

Reclamation activities under the No Action Alternative would take place away from most
surrounding residential areas, with exception of Spoil Pile 1 near Lake No. 12 and Spoil Pile 3
South near Lawson Hills Estates. In each of those instances, most overburden removal
activities would take place behind a temporary berm that would be reduced in size as the height
of the spoil pile is reduced. Noise impacts would be further avoided by the operating hour
restrictions (7:00 am 10:00 pm) imposed by the King County and Black Diamond rezone
ordinances and grading permits. Since the haul road is located in the middle of the mine area,
noise impacts at the permit boundary or closest residence would likely be less than what would
be expected to occur under the Proposed Action Alternative. Under the No Action Alternative,
noise levels would be periodically monitored as required by King County as discussed above
and, noise mitigation efforts would be implemented if required to meet King County regulations.
Blasting is not required and there would be no vibration impacts under the No Action Alternative.
Noise impacts would be local, short-term, and minor because PCCC must comply with King
County noise regulations. Noise and vibration impacts would be restricted to the mine permit
area and would not result in any indirect impacts.

3.16 Visual Resources

3.16.1 Affected Environment
As a condition of the 1985 King County rezone ordinance (King County, 1985), PCCC was
required to construct a wooden fence along the Green River Gorge Road. In 2003, subsequent
to the construction of the Tacoma Pipeline along the Green River Gorge Road, King County
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Environmental Assessment John Henry No. 1 Mine
allowed PCCC to remove the wooden fence and replace it with a vegetation barrier. Based on
visual resource standards established in the BLMs Visual Resource Inventory Manual the visual
resources in the Mine would most likely be considered a Class III or Class IV with moderate to
least value (BLM 1986).

3.16.2 Environmental Consequences

The vegetation barrier along the Green River Gorge Road has developed since it was planted in
2003. It is currently an effective visual barrier that separates the mine from the Green River
Gorge Road. Douglas fir trees were planted on approximately eight foot centers along the
relatively steep slope as required by King County. The success rate in 2008, after five years,
was about 90 percent and the trees are now 8 to 12 feet high. This success rate has not
changed since 2008 and the trees continue to grow. In addition, natural volunteer vegetation of
deciduous trees, including alder and maple, has populated the corridor and these supplement
the Douglas fir plantings. Visual impacts to residences surrounding the mine were minimized
once the spoil piles and noise mitigation berm were constructed from 1986 1992.
3.16.2.1 Proposed Action Alternative
Proposed mining and ongoing reclamation activities would be visible from surrounding
residential properties. The height of Spoil Pile 1 and Spoil Pile 3 South would be reduced and
some visual connection with external properties may occur. This would be controlled by
sequencing spoil removal such that loading operations would take place behind a berm. These
effects, if they occur, would constitute a direct, minor, and short-term impact and would be
confined within or adjacent to the permit boundary. Visual impacts would be restricted to the
mine site and therefore no indirect impacts would occur.
3.16.2.2 No Action Alternative
The No Action Alternative would have the same visual impacts as the Proposed Action
Alternative during reclamation. No additional impacts are foreseeable. The direct impacts would
be minor and short-term and confined within or adjacent to the permit boundary. Visual impacts
would be restricted to the mine site and therefore no indirect impacts would occur.

3.17 Cultural Resources

3.17.1 Affected Environment

An archeological survey of the mine site was conducted in 1983 by Dr. Brian G. Holmes
(Holmes 1983). No prehistoric sites were located but evidence of past underground mining was
noted. No additional cultural resources have been encountered since mining began in 1986.
The Washington State Office of Archeology and Historic Preservation has concluded that the
mine would have no effect on known cultural resources included in or eligible for inclusion in the
National Register of Historic Places (Washington Office of Archeology and Historic Preservation
1984).

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Environmental Assessment John Henry No. 1 Mine
3.17.2 Environmental Consequences
Due to the absence of cultural resources, there would be no impacts or need for mitigation
under either the Proposed Action Alternative or the No Action Alternative. Should unreported
cultural resources be discovered during future mine operation under either the Proposed Action
or the No Action Alternative, such discovery would be reported and work would cease in the
area until the discovery can be evaluated by a qualified archeologist.

3.17.2.1 Proposed Action Alternative

There are no direct impacts on cultural resources from the Proposed Action Alternative. There
are no indirect impacts on cultural resources from the Proposed Action Alternative.

3.17.2.2 No Action Alternative

There are no impacts on cultural resources from the No Action Alternative. There are no
impacts on cultural resources from the No Action Alternative.

3.18 Human Health and Safety

3.18.1 Affected Environment
The affected environment for public health and safety includes the mine operations and
individuals who could be exposed to dust, noise, heat stress, and chemicals from PCCCs
mining and reclamation activities. Many activities conducted during mining operations carry
inherent health and safety risks. Typical risks encountered include exposure to dust, noise, heat
stress, and chemicals, as well as the opportunity for accidents due to working directly with or in
proximity to large equipment. Procedures used during operation and maintenance activities
associated with the project, such as blasting or construction, also pose health and safety risks.
However, the establishment of appropriate policies and procedures, and the monitoring of those
procedures to verify that they are properly observed, helps to reduce the risk involved. The
Federal Mine Safety and Health Act (MSHA) of 1977 regulates mine employee health and
safety associated with PCCCs operations. During mining and reclamation, permits will be
required along with safety inspections to minimize the frequency of accidents and maximize
worker safety. PCCCs MSHA mine identification number is 45 02967. MSHA inspectors
normally complete a full inspection every six months but can inspect as frequently as they deem
necessary to ensure compliance with the regulations. Inspections do not take place when the
mine is idle for extended periods of time.

This section brings forward pertinent information from the other affected environments and
examines potential impacts associated with the Proposed and No Action Alternative from a
human health and safety perspective.

PCCC utilizes a number of different mechanisms to ensure that public health and safety is
adequately maintained throughout the mines operations. These existing measures are
described below.

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Environmental Assessment John Henry No. 1 Mine
3.18.1.1 Dust and Debris
Dust and debris on roads is reduced by the use of a wheel washing facility prior to trucks exiting
the mine area.
3.18.1.2 Site Access
No Trespassing signs are posted around the property to warn the public of the dangers within
the mine site. When staff is not present on the mine site, all access gates are locked.

3.18.2 Environmental Consequences

Health and safety at John Henry No.1 Mine is managed by establishing appropriate policies and
procedures and monitoring those procedures to verify that they are properly observed and
executed. PCCCs safety and health standards include requirements for ground support
systems, coal piles, electrical systems, combustible fluid storage, shops, equipment
specifications and maintenance, explosives storage and handling, dust control, monitoring and
reporting requirements, alarm systems, worker personal safety equipment, and restrictions for
public access. To comply with MSHA standards, all mining and reclamation operations will
require the necessary MSHA mine permit, an MSHA-approved miner-training plan, and escape
and evacuation plan since work carried out in the presence of heavy equipment and machinery
inherently bears a degree of risk. It is acknowledged that air quality is also a health and safety
consideration which is considered in terms of NAAQS under Air Quality Section E.1.7. NAAQS
are determined based on the USEPAs assessment of health-protective air quality levels. In
addition, transportation at and near the mine site also poses risk for workers as well as the
public.
3.18.2.1 Proposed Action Alternative
Under the Proposed Action Alternative the current health and safety practices, described above,
PCCC would continue to implement a health and safety program to protect employees and the
public. PCCCs health and safety requirements would comply with current health and safety
requirements in its standard operating procedures, and compliance with mandated safety rules
will continue to be required. Safety risks would be present, including exposure to dust, noise,
heat stress, and chemicals. The opportunity for accidents due to working directly with or in
proximity to large equipment will also continue.
3.18.2.1.1 Climate Change
While there will be impacts on human health from global climate change, assessing specific
impacts from either the Proposed or No Action Alternative would be speculative and not
discernible.
3.18.2.1.2 Air Quality
The State of Washington implements the Federal NAAQS, and develops air quality attainment
and maintenance plans, in order to keep Washington in compliance with the NAAQS standards.
NAAQS are determined based on the USEPAs assessment of health-protective air quality
levels. The Puget Sound airshed has been in compliance with the annual PM2.5 standard since
the EPA promulgated it in 1997 (PSCAA 2014). The Black Diamond area is in compliance with
the Federal air quality standards for these pollutants (PSCAA 2014). Mining at the historic
maximum rate of 350,000 tons per year showed negligible impacts on local or regional air
quality. Negligible impacts are defined as human health and safety will not be affected, or the

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Environmental Assessment John Henry No. 1 Mine
effects will not be measurable or perceptible using standard scientific tests. Under the Proposed
Action Alternative, mining at the proposed rate of 130,000 tons per year would have even lower
impacts. PCCC is not required to implement an air quality monitoring program, but does
maintain a dust control program.

As noted in Section 3.5, Air Quality, in an effort to prevent off site impacts and to protect worker
health and safety, all active roads within the mine site are watered as necessary during dry or
dusty conditions. The temporary spoil piles were covered with topsoil, seeded, and revegetated.
Coal waste is mixed with overburden in the backfill area and not stored separately. Coal
stockpiles are watered as necessary, but this is not frequent due to relatively damp weather
conditions. As topsoil is spread it is immediately reseeded and with favorable growing
conditions, vegetation establishes quickly. This has proven an effective means of controlling
fugitive dust emissions. No thermal dryers are used, but the preparation plant feed hopper and
the crushers at the coal preparation plant are equipped with water spray devices to minimize
dust. The blast hole drill also uses water to minimize dust from the drilling operations. Disturbed
acreage is kept to a minimum, and is topsoiled and seeded as soon as possible to eliminate
possible sources of dust.

BACT is applied where required at the coal processing plant. Application of BACT helps PCCC
to attain limits for coal processing and conveying equipment (including breakers and crushers),
coal storage systems, transfer and loading systems, open storage piles (of processed coal and
refuse), and associated equipment. PCCCs plant operating and maintenance plan targets no
visible emissions from coal processing and conveying equipment. Specifically:

The enclosed crusher with water sprays is BACT;

If the material was dry, fully enclosed conveyors would be BACT, in this case given the
wetness of handled product conveyor covers are BACT;
Enclosed coal preparation plant is BACT.

Impacts on air quality from the Proposed Action Alternative are generally confined within the
permit area but potentially could be local. The impacts are short-term and negligible due, in part,
to the fact that prevailing winds in the dry summer months are from the North and Northwest
and the land use to the South and Southeast is forest with no residences.

Federal regulations, enforced by MSHA, require worker dust monitoring to protect worker
health. PCCC must comply with these regulations.
3.18.2.1.3 Water Resources
As is demonstrated in the CHIA, the Proposed Action Alternative would have little impact on
water resources outside the permit area. The City of Black Diamond obtains its water from two
external sources that are not impacted by mine activities. There are no known future water
users that may be impacted. Water discharges are strictly regulated by WDOE through the
NPDES Permit. Water is sampled and tested on a regular basis to make sure it meets
appropriate standards to protect public health. Ground water impacts would be minor due to
some noticeable drawdown on one off-site well (Reichert well) that is monitored in accordance

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Environmental Assessment John Henry No. 1 Mine
with OSMRE and WDOE regulations, see Section 3.4.2, Groundwater. Impacts on public health
and safety would be negligible and short-term. There were no reported adverse impacts on
downstream water users while the mine operated at full production and none are expected at
the lower production levels predicted under the Proposed Action Alternative.
3.18.2.1.4 Transportation
Coal trucks leaving the mine enter onto the Black Diamond Ravensdale Road which is a
county Tier 2 road. Tier 2 roads provide generally reliable access, are heavily travelled, provide
access to smaller geographical areas, and serve as alternatives to Tier 1 roads. Tier 2 roads
receive a lower level of storm and snow response, receive maintenance to keep them in good
condition and, in general, preservation efforts would be more reactive and prioritized based on
level of risk and availability of funding. DPER have determined that it is not aware of any safety
impacts or concerns that would result from the level of traffic expected under the Proposed
Action Alternative (King County DPER 2014).

Under the Proposed Action Alternative, indirect impacts related to the transport of coal including
potential impacts to emergency service response times on area roadways, as described in
Section 3.13.2.1.2.2, Emergency Services, would occur resulting in minor and short-term
impacts to human health and safety. The projected delay in emergency service response times
on transportation routes used for hauling coal from the John Henry No. 1 Mine are uncertain
due to the different transportation methods and routes that could be used, see Section 3.13,
Transportation.

3.18.2.1.5 Vegetation and Wildlife

There is no evidence that there would be any adverse impacts on food sources including fish
under the Proposed Action Alternative. There is no commercial farming in the general area.
Water quality is strictly monitored by WDOE through the NPDES permit and there is no
evidence that water quality in the upper Green River basin has had any adverse impact on
Puget Sound Chinook or Puget Sound Steelhead runs.
3.18.2.1.6 Noise and Vibration
King County noise limits are set to prevent detrimental health impacts. Under the Proposed
Action and No Action Alternatives, PCCC must comply with those regulations. Blasting
operations would occur. Residents would be offered pre-blast survey and would continue to be
notified and warned of blasting operations, and notification of the blasting schedule will continue
to be posted and advertised. Blasts will continue to be monitored for air blast and ground
vibration. PCCC mines blasting records will continue to be monitored by OSMRE on a monthly
to quarterly basis. Vibration performance standards under SMCRA were established to prevent
adverse impacts to protected structures, detrimental health impacts to citizens and mine
employees and are monitored for each blast. MSHA has strict noise limits to protect mine
worker safety and health that the operator must comply with.

3.18.2.2 No Action Alternative

Under the No Action Alternative mining activities will not resume and public health and safety
risks related to coal-production operations and blasting would not occur. During the reclamation

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Environmental Assessment John Henry No. 1 Mine
period, PCCC would continue to comply with all applicable federal, county, and state rules and
regulations regarding health and safety and handling and disposal of hazardous materials and
wastes. Safety procedures regarding on site truck traffic will continue to be followed throughout
the duration of reclamation activities, although fewer vehicles will be required for these activities.
Impacts resulting from cessation of mining activities on public health and safety in terms of job-
related accidents would be negligible and short-term. Under the No Action Alternative, coal
would not leave the mine site and therefore would not result in any indirect transportation of coal
resulting in no impacts to human health or safety.

3.19 Short Term Uses and Long Term Productivity

The NEPA regulations at 40 CFR 1502.16 require a discussion of the relationship between
short-term uses of mans environment and the maintenance and enhancement of long-term
productivity.

3.19.1 Local Area

In the long term, following reclamation under either alternative, the land surface would be
topographically lower and, although the reclaimed surface would resemble original contours, it
would lack some of the original diversity of geometric form.

Soils and vegetation have been disturbed and the associated wildlife habitat that the John
Henry No. 1 Mine previously provided before mining operations began has been lost in the short
term, during mining and reclamation. Soils would be replaced and vegetation would be restored,
as required by the mining plan.

There would be loss and displacement of wildlife in the short term but, based on monitoring of
previously reclaimed lands on other coal mines within the U.S., it is anticipated that the
reclaimed lands would provide habitat that would support a diversity of wildlife species similar to
pre-mining conditions over the long term.

Mining operations and associated activities would degrade the air quality and visual resources
of the area on a short-term basis. Following coal removal, removal of surface facilities, and
completion of reclamation, there would be no long-term impact on air quality. The long-term
impact on visual resources would be minor.

The short-term economy of the region would be enhanced as a result of the Proposed Action
Alternative. Mining at the John Henry No. 1 Mine would last up to six years with one year of
reclamation activities under the Proposed Action Alternative.

3.19.2 Greenhouse Gas Emissions

GHGs have been raised as a concern due to the greenhouse effect. The greenhouse effect is a
theory that certain gases in the atmosphere impede the release of radiation from the earth,
trapping heat in the atmosphere like glass over a greenhouse. GHGs currently include carbon
dioxide (CO2), methane (CH4), water vapor, ozone, and nitrous oxide (NO2). If the coal in the
John Henry No. 1 Mine is mined, additional GHGs would be released into the atmosphere. A

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Environmental Assessment John Henry No. 1 Mine
discussion of emissions and by-products that are generated by burning coal to produce
electricity is included in Chapter 3, Section 3.5.2 of the EA. Under the Proposed Action
Alternative, mining and continuous reclamation activities would result in 71,690 MT CO2e/y and
reclamation activities would result in 3,137 tons of CO2e MT CO2e/y (see Table 8, Summary of
Direct and Indirect CO2e Emissions Proposed Action Alternative).

3.20 Irreversible or Irretrievable Commitments of Resources

The major commitment of resources would be the mining and consumption of 737,000 short
tons of minable coal reserves under the Proposed Action. It is estimated that <1 percent of the
energy produced would be required to mine the coal, and this energy would also be irretrievably
lost.

The characteristics of topsoil would likely be irreversibly changed. Soil formation processes,
although continuing, would be irreversibly altered during mining-related activities. Newly formed
soil material would be unlike that in the natural landscape.

Direct and indirect wildlife deaths caused by mining operations or associated activity would be
an irreversible loss.

Loss of life may conceivably occur due to the mining operations and vehicular traffic. According
to the MSHA the John Henry No. 1 Mine did not have any fatal or reported injuries for
contractors or mine employees from 2014 - 2017 (MSHA 2016). Any injury or loss of life would
be an irretrievable commitment of human resources.

There are no known historic and prehistoric sites on the mine areas. However, disturbance of
any encountered historic and prehistoric sites on the mine areas would be mitigated to the
maximum extent possible. However, accidental destruction of presently unknown archeological
or paleontological values would be irreversible and irretrievable.

3.21 Summary of Impacts to the Affected Environment Under the Proposed Action
Alternative

A summary of the anticipated impacts to the Affected Environment under the Proposed Action
Alternative is provided in Table 28.

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Environmental Assessment John Henry No. 1 Mine
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Environmental Assessment John Henry No. 1 Mine
Table 28. Impact Assessment Summary for the Proposed Action Alternative
Impact Designation and Assessment Permit Stipulations,
Design Features, and
Resource Assessment Approach Short- Intensity Definition
Direct or Best Management
or Long- Intensity
Indirect1 Practices
Term
A change in slope or
Evaluation of Final Mine elevation that will be
Contemporaneous
Topography and Required Spoil detectable and long-term but
Topography Direct Long Minor reclamation;
Movement Associated with will resemble the AOC of
reclamation to AOC.
each Alternative undisturbed landforms within
the permit area.
Changes that will not result in
a loss of scientific and
Evaluation of the Mining Plan
educational values for Contemporaneous
Geology and Coal Extraction Associated Direct Long Moderate
geologic and paleontological reclamation.
with each Alternative
resources or potential mineral
resource development.
Changes in water
quality at NPDES outfalls that
sometimes (0-33%) exceed
applicable water quality
standards. Contemporaneous
reclamation;
Changes in yearly maintenance of
Minor and average flow from NPDES
Evaluation of Historic Data; sedimentation
Water Resources Direct and Negligible discharges which have a
Water Quality Modeling of Short structures, proper
and Hydrology Indirect (groundwater measurable effect on
Phosphate handling of spoil,
quantity) downstream watersheds. topsoil, and coal
Changes in water processing waste
quality that occasionally (0% materials.
33%) exceed applicable
water quality standards and
are attributable to mining.
Mining related
drawdown which can be
quantified at water supply
wells outside the permit area.
Use high efficiency
Causing no discernible
equipment.
impact on global climate or
Evaluation of Greenhouse Gas Direct and
Climate Short Negligible Washington States ability to
Emissions Indirect
achieve GHG emission
reductions by 2020.

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Environmental Assessment John Henry No. 1 Mine
 Impact Designation and Assessment Permit Stipulations,
Design Features, and
Resource Assessment Approach Short- Intensity Definition
Direct or Best Management
or Long- Intensity
Indirect1 Practices
Term
Maintaining PM10 and PM2.5 Watering mine roads for
levels below PSCAA dust suppression;
Evaluation of criteria pollutants Direct and modeled levels and opacity cleaning trucks leaving
Air Quality Short Negligible
and HAPs relative to standards Indirect levels on the coal preparation the permit area.
and handling facilities at less Existing controls at coal
than 10%. combustion facilities.
Soils will not be affected by
Use of 4 feet of topsoil
erosion and the effects on
Evaluation of the Proposed or suitable material as a
Soils Direct Long Moderate soil productivity will be below
Mining and Reclamation Plans plant growth medium
the levels of detection with no
for reclamation.
long-term effects.
Direct effects on vegetation
Minor = community structure and
Direct composition that will be
Evaluation of T&E Plant limited to areas disturbed by Timely seeding and
Direct and
Vegetation Species and the Mining and Long mining and reclamation with revegetation of
Indirect
Reclamation Plans no changes in the plant disturbed areas.
Negligible =
community structure or
Indirect
composition elsewhere in the
permit area.
Direct effects on wetlands
removal that would be limited
to areas disturbed by mining Minimizing the amount
Evaluation of Potential and reclamation with no of disturbed area;
Wetlands Direct Long Minor
Wetlands changes in the plant preservation of Mud
community structure or Lake Wetlands.
composition elsewhere in the
permit area.
Minor = Effects on wildlife species
Minimizing the amount
Wildlife could be detectable and long-
Evaluation of T&E Species and Direct and Short of disturbed area;
Fish & Wildlife Negligible = and short-term. The effects
other Wildlife Indirect and Long preservation of Mud
Birds and will be limited to local
Lake Wetlands.
Fish changes to the population.
Reestablishment of
Evaluation of Pre and Post There will be no changes to
Land Use Direct Short Minor land uses that existed
Mining Land Uses existing or future land use.
prior to mining.

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Environmental Assessment John Henry No. 1 Mine
 Impact Designation and Assessment Permit Stipulations,
Design Features, and
Resource Assessment Approach Short- Intensity Definition
Direct or Best Management
or Long- Intensity
Indirect1 Practices
Term
Effects on the
socioeconomic
environment will not be
Evaluation of Potential Mine distinguishable from
Direct and Hire local employees and
Socioeconomics Employment and Environmental Short Negligible changes that were
Indirect contractors.
Justice occurring from other social
and economic activities
within the surrounding
communities.
There will be no discernible
Use of wheel washers
Evaluation of Potential Coal Direct and changes to existing traffic
Transportation Short Negligible prior to trucks exiting the
Truck and Other Traffic Indirect patterns at key
mine site.
intersections.
Recreational activities will
not be affected or changes
Evaluation of the Proposed No recreation sites exist
in use and/or experience
Recreation Actions Effects on Recreation None None None within 1-mile of the permit
will be below or at the level
in the Area boundary.
of detection by the
recreational user.
Noise levels will be
detectable from current
levels but will not exceed Use of noise mitigation
Noise and Evaluation of Previous Noise
Direct Short Minor King County noise berms, following the
Vibration and Vibration Complaints
standards. Vibrations performance standards 30
associated with blasting CFR 816.
would occur but would not
exceed regulatory limits.
Change to the visual
appearance of the site will
generally be noticeable but Sequencing spoil
Evaluation of the Mining and
Visual Resources Direct Short Minor subtle. It will usually be movement, utilizing berms
Reclamation Plans
subordinate, but will be and other barriers.
noticed by viewers without
being pointed out.
No prehistoric sites are
Cultural
Archaeological Survey None None None No impacts. known to exist at the
Resources
Mine.

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Environmental Assessment John Henry No. 1 Mine
 Impact Designation and Assessment Permit Stipulations,
Design Features, and
Resource Assessment Approach Short- Intensity Definition
Direct or Best Management
or Long- Intensity
Indirect1 Practices
Term
Human health and safety Mandated safety rules
Evaluation of Public Health and will not be affected, or the and standard operating
Human Health and Safety related to air quality, Direct or effects will not be procedures for blasting.
Short Negligible
Safety water resources, transportation Indirect measurable or perceptible See air quality, water
and noise and vibration using standard scientific resources, transportation
tests. and noise and vibration.

1
Where indirect impacts arent designated in the Table the resource area analysis determined that impacts associated with the Proposed Action would only occur within the mine
permit boundary and therefore would not result in indirect impacts.

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Environmental Assessment John Henry No. 1 Mine
4.0 CUMULATIVE IMPACTS
Cumulative impacts are those environmental impacts that could result from the implementation
of the Proposed Action Alternative or the No Action Alternative, when added to the impacts from
all other past, present, and reasonably foreseeable activities, regardless of who is conducting
such activities. Figure 15 shows approximate locations for all past, current, and future projects
analyzed in Section 4.1.

The scope of the cumulative impacts analysis is limited to those resources where the proposed
action could have an additive impact in combination with other past, present, and reasonably
foreseeable and similar future actions. Resource areas that would not result in an incremental
impact to those identified in the direct and indirect impacts sections were not analyzed in
cumulative impacts including: geology/paleontology, cultural resources, soils, topography,
vegetation, noise and vibration, recreation, and human health and safety.

All GHG emissions contribute to cumulative climate change on a global scale. However, it is not
scientifically possible to determine the impact that would result on the global climate conditions
from the emissions from this specific proposed action or in total from the emissions of other
actions. The variables involved in such an analysis would make this determination conjectural
and not within the rule of reason. Therefore, it would be inconsistent with the NEPA to require
the preparation of an EIS for every Federal action that may cause GHG emissions regardless of
the magnitude of those emissions 40 CFR 1502.22(b). For this reason, past projects and other
projects that may or may not be approved by OSMRE do not include GHG emissions in the
cumulative effects analysis.

For the hydrologic and wildlife resource areas, the geographic scope is focused upon the
expanded watershed area through Lake Sawyer and into Covington Creek. Due to the
discontinuous nature of groundwater occurrence in the John Henry No. 1 Mine permit area there
would not be any anticipated cumulative impacts from past, present, or future projects therefore
only potential cumulative impacts associated with surface water is carried forward for analysis
(OSMRE 2014).

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Environmental Assessment John Henry No. 1 Mine
Figure 15. Cumulative Impacts Study Area

Based on the analysis presented in Chapter 3, Affected Environment and Environmental

Consequences, the Proposed Action Alternative would affect the following resources and could
contribute to an incremental cumulative impact:

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Environmental Assessment John Henry No. 1 Mine
 Surface Water
Air Quality
Vegetation
Wetlands and Riparian Zones
Fish and Wildlife
Special Status Species
Land Use
Socioeconomics
Transportation
Visual
Recreation

Past Actions. The primary existing (past) disturbances within the geographic area includes
mining within the permit area from 1986 until 1999 and residential development within Black
Diamond, including residential development around Lake Sawyer. Lake Sawyer was annexed
into Black Diamond in 1998. The Morgan Kame sand and gravel operation is located in Black
Diamond about a half mile west of the western permit boundary encompassing 220 acres. That
operation, at its peak, produced over 400,000 tons per year, but is now operating at a reduced
production level of less than 100,000 tons per year. The Cadman Black Diamond 293 acre sand
and gravel mining and concrete manufacturing operation is located to the south of the John
Henry No. 1 Mine along SE Green Valley Road. The Reserve Silica sand and gravel operation
is located to the north of the John Henry No. 1 Mine along Black Diamond Ravensdale Road
and is approximately 47 acres in size.

Present Actions. Present actions are focused on coal mining, sand and gravel mining, and
residential development.

Reasonably Foreseeable Future Actions. Two large-scale residential developments within

Black Diamond, the Villages and Lawson Hills MPDs, have the potential to contribute to
cumulative impacts. Lawson Hills MPD is in closest proximity to the mine permit area and abuts
it in places along the south and southeast borders. Initial land clearing for the first phase of this
development of the Lawson Hills has not yet begun. Water lines and required traffic
improvements have not yet been constructed. Initial housing development is expected in 2017
with 89 dwelling units. The developer expects to construct 83 dwelling units per year thereafter
(Nelson 2014). Under the Proposed Action Alternative, PCCC is expected to complete mining in
2024. By 2024, approximately all units will have been constructed and occupied in the MPDs.
Under the No Action Alternative, reclamation will be completed when the first houses are
constructed. Ultimately, in the two MPDs, the developer expects to construct 6,050 dwelling
units over 1,567 acres that includes 783 acres of open space while adding over 11,000 people
to Black Diamond (Parametrix 2009a).

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Environmental Assessment John Henry No. 1 Mine
Another small scale residential development is the Reserve at Woodlands which would be a
residential community consisting of 77 dwelling units over 394 acres located to the southwest of
the John Henry No. 1 Mine. The developer is Oakpointe which is also one of the development
partners for the Lawson Hills and Villages developments. Based on a County agreement with
the developers of the Reserve at Woodlands, a regional stormwater facility would be
constructed within the Reserve at Woodlands. The Reserve at Woodlands would not begin
construction until after Lawson Hills and Villages developments have commenced (King County
2011). For the cumulative impact analysis the Villages, Lawson Hills, and Reserve at
Woodlands developments are analyzed together due to their similar construction impacts and
close proximity to one another (Stiles 2015).

In 2015, Maple Valley, which includes the City of Black Diamond, updated its Comprehensive
Plan in conformance with the requirements of the Washington State GMA (RCW 36.70A). The
Comprehensive Plan Update covers a period of 20 years and focuses on transportation, parks
and recreation, public services and utilities, capital facilities, environmental quality, and
economic development. The Plan outlines several proposed projects to continue to meet the
needs of the growing population which are described below under the relevant resource (Maple
Valley 2015).

Actions Eliminated from Further Study. Two coal export terminals proposed in Washington
State were eliminated from further study: the Gateway Pacific Terminal in Cherry Point,
Washington, and the Millennium Bulk Terminal in Longview, Washington. The Gateway Pacific
Terminal EIS process was terminated on May 9, 2016 by the U.S. Army Corps of Engineers due
to a determination of potential adverse impact on the Lummi Indian Nations treaty fishing rights
(WDOE 2016b). The Millennium Bulk Terminal released the Draft EIS on April 29, 2016 for
public comment; however, due to high transportation costs and a low annual production it is not
reasonably foreseeable that PCCC coal would be shipped out of this terminal (WDOE 2016c).
For purposes of indirect impacts associated with air quality the Millennium Bulk Terminal is
located outside of the indirect impact study area in Cowlitz County therefore causing no regional
cumulative air quality impacts.

As described in Section 1.6, Proposed Action Alternative, PCCC has a contract in place for 60%
of their annual coal production (50,400 tons per year) at the Lehigh Cement Plant in British
Columbia and has previous consumers from past mining that could resume purchases once
operations begin. If all existing contracts and previous customers did not purchase the coal, it is
unlikely this coal would be exported to other customers because of low annual production rates
and high transportation costs.

The Keta Creek Fish Hatchery is located approximately 7 miles southwest of the Proposed
Action study area in Auburn, WA on Crisp Creek, a tributary of the Green River. It is owned and
operated by the Muckleshoot Indian Tribe and the hatchery stock is Green River Fall Chinook.
Potential impacts to the fish hatchery were not analyzed because as stated in Section 3.3,

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Environmental Assessment John Henry No. 1 Mine
Water Resources, there would be negligible impacts to the Green River and therefore no
impacts to any tributaries (NOAA 2009).
4.1 Cumulative Impact Assessment

A cumulative impact assessment was conducted for the resource areas previously described in
Chapter 3, Affected Environment and Environmental Consequences.

4.1.1 Surface Water

4.1.1.1 Historic John Henry No. 1 mining
As stated in Section 3.3.1, Surface Water, phosphorus and TSS levels have dropped since
mining ceased in 1999. During previous mining operations PCCC did not exceed its NPDES
standards for the aforementioned water quality parameters. Its anticipated that phosphorus
loading would increase from the Proposed Action Alternative, but not likely to the levels
observed during the pre-1999 period of mining.

4.1.1.2 Historic Residential Development around Lake Sawyer

Potential sources of cumulative impacts to surface water associated with urban growth include:
septic sewer systems, lawn fertilizers, and release of sediments during seasonal turnovers,
other urban development, and native environment sources (aquatic plants and air). Cumulative
phosphorus impacts from these sources and other urban development are not anticipated to
change significantly now or in the near future and are assessed in the Lake Sawyer
Management Plan and other reports produced by King County, WDOE and various agencies
(King County SWM, 2000).

As a city with a population less than 100,000, all stormwater-related activities are regulated
under the Black Diamonds Western Washington NPDES Phase II Permit (Phase II Permit).
Among other requirements, the Phase II Permit requires the City of Black Diamond to have
programs that directly address operation and maintenance of existing stormwater collection,
treatment, and discharge systems; pollution prevention from sites of development,
redevelopment, commercial, industrial, residential, and municipal activities; and an Illicit
Discharge Detection and Elimination program to identify, isolate, and terminate illicit discharges
to the City of Black Diamonds storm sewer. Therefore, any historic development that has
occurred within the City of Black Diamond has been done in accordance with NPDES permitting
standards and not resulted in a cumulative impact.

4.1.1.3 Sand and Gravel Mining

There are sand and gravel mining operations around the Black Diamond area which ultimately
drain into Lake Sawyer. The Morgan Kame Sand Gravel Mine is located approximately a mile
west of the permit boundary along Rock Creek just before it empties into Lake Sawyer. The
sand and gravel mine represents a potential mining-related contribution of phosphorus to Lake
Sawyer and other surface water in the area. This operation is managed through a Sand and
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Environmental Assessment John Henry No. 1 Mine
Gravel General NPDES Permit issued by WDOE which applies to it and other similar operations
throughout the State. Since there is no data on phosphorus concentrations and flow related to
discharge from the nearby sand and gravel operation, it is difficult to ascertain numerically how
it could contribute to a cumulative impact to Lake Sawyer. However, turbidity is limited to a daily
maximum of 50 nephelometric turbidity units (NTU) and total suspended solids is limited to a
quarterly average of 25 mg/L which should reduce phosphorous loading to Lake Sawyer.

The Reserve Silica sand and gravel operation discharges into the Lake Sawyer watershed and
falls under a Sand and Gravel General NPDES permit with the same specified limits on turbidity
and total suspended solids as other operations in the watershed.

For site disturbances of more than 1 acre, or for sites smaller than 1 acre which are part of a
larger common plan of development, a Construction Stormwater General NPDES Permit must
be obtained from WDOE. The Construction Stormwater General Permit details specific actions
the permittee must implement to prevent and mitigate water quality impacts due to construction
activities. These would help limit cumulative impacts, which are expected to be negligible to
minor and short term. Therefore, any constructed sand and gravel mining operations in the area
are regulated under an NPDES permit reducing any potential cumulative impact.

4.1.1.4 Villages, Lawson Hills, and Reserve at Woodlands Residential Developments

The Villages is part of a proposed MPD for the Black Diamond area covering 1,190 acres, part
of which lies within the Lake Sawyer watershed. Predicted total phosphorus concentrations in
discharges from the Villages development to Rock Creek and Jones Lake are 0.038 mg/L and
0.053 mg/L, respectively (A.C. Kindig & Co, 2008). The Villages is currently in early phases of
development, and the 150 acres currently disturbed is covered under WDOEs Construction
Stormwater General NPDES Permit which sets specific limits to turbidity, which should
decrease total phosphorus loading to Lake Sawyer. This NPDES permit is a general permit
issued to numerous construction operations throughout the State of Washington. Specifically, it
sets numerical limits for certain 303(d) listed waters (turbidity, fine sediment, or phosphorus)
and specifies a numerical effluent limit of 25 NTUs, or alternatively no more than 5 NTUs over
background turbidity when the background turbidity is 50 NTUs or less, or no more than a 10%
increase in turbidity when the background turbidity is more than 50 NTUs. Because Lake
Sawyer is 303(d) listed for phosphorus impairment, these standards apply here and should be
effective in limiting phosphorus contributions from construction operations in this watershed.

The entirety of the 376 acre proposed Lawson Hills development lies within the Lake Sawyer
watershed and mostly abuts the southern end of the John Henry No. 1 Mine permit boundary
(A.C. Kindig & Co, 2008). Estimated post-treatment total phosphorus discharges from the
Lawson Hills development varies between 0.036 and 0.051 mg/L depending on the
subwatershed, with combined discharges to Rock Creek averaging 0.045mg/L.

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Environmental Assessment John Henry No. 1 Mine
The Reserve at Woodlands is assumed to have impacts similar to those presented for the
Villages and Lawson Hills, but at a smaller scale due to the reduced number of dwelling units to
be constructed (77 dwelling units for the Reserve at Woodlands versus 6,050 dwelling units for
the Villages and Lawson Hills). Lawson Hills and the Reserve at Woodlands have yet to be
constructed but are planned for the near future.

The MPDs would preserve natural hydrologic functions to a degree by designating certain lands
within the developments as Open Space. Designated open space for the Lawson Hills MPD
includes the area between Spoil Piles 3N and 3S and State Highway 169. Mining operations at
John Henry No. 1 Mine are projected to be completed by 2024 when it is estimated that all
dwellings within the MPD would be constructed and occupied.

In developing baseline data for the two MPD FEISs, grab samples of water were taken during
storm and baseflow events between December 2006 and April 2007. This measured an average
phosphorus concentration of .021 mg/L (Parametrix 2009a). This undeveloped state compares
to an average discharge from the John Henry No. 1 mine of less than 0.024 mg/L over the past
15 years at Discharge Point 002 and 0.025 mg/L at Discharge Point 001 which is expected to
continue under the Proposed Action Alternative.

4.1.1.5 Maple Valley Comprehensive Plan

The Maple Valley Comprehensive Plan includes measures to promote water conservation,
protect the quality and quantity of public groundwater, mitigate discharges that pollute state
waters, and protect water quality (Maple Valley 2015). The Proposed Action and No Action
Alternative would adhere to all NPDES and SMCRA permit requirements thereby meeting all
proposed water conservation efforts outlined by the Comprehensive Plan. Therefore, cumulative
impacts associated with other projects and the Proposed Action is expected to be negligible and
short term.

4.1.1.6 Other
Other potential cumulative impacts exist in the Lake Sawyer watershed from abandoned mines
in the area. There are no anticipated impacts to other resources analyzed in cumulative impacts
associated with the abandoned mine lands and Jones Lake therefore these are only analyzed in
this section. The Lawson Hill Mine, located to the south of the John Henry No. 1 Mine, has a
small permanent discharge from the main adit, which drains into Jones Lake and then into Rock
Creek and Lake Sawyer. Although this location has higher specific conductivity than typical
surface water of the area, total phosphorus only averaged 0.009 mg/L at this location based on
data provided in the Lawson Hills MPD Water Quality Technical Report.

Jones Lake, located to the southeast of Lake Sawyer, is also a potential source of total
phosphorus loading from re-suspension of phosphorus-laden sediment and other materials
which have accumulated in the lake. Data collected by King County from April through October
2003 indicated that total phosphorus levels in the lake varied from 0.017 0.086 mg/L (A.C.
Kindig & Co, 2008).
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Environmental Assessment John Henry No. 1 Mine
4.1.1.7 Summary
In summary, a water quality report and associated model drafted by King County Surface Water
Management was released in 2000 which specified how much phosphorus can discharge into
Lake Sawyer and still maintain the target steady state concentration of 16 g/L. The
assumptions from this model were utilized by OSMRE in the CHIA to approximate the impact of
the John Henry No. 1 Mine on phosphorus loading in the watershed. Yearly average
phosphorus loading rates were derived from the water monitoring data for discharges 001 and
002 and compared to in-lake yearly average phosphorus concentrations at 1 meter. Figure 16,
based on the total phosphorus loading model from the CHIA, illustrates the yearly average
phosphorus concentration in Lake Sawyer, marked by the red line, and the hypothetical
concentration, without any discharge from the John Henry No. 1 Mine NPDES points, marked
by the green line.

Figure 16. Phosphorus Loading TMDL Model

TotalPhosphorusConcentrationinLakeSawyer
0.025

Actual
Concentration
0.02

Model
Concentration
0.015
mg/L

Theoretical
0.01 Concentration
(NoJohnHenry
Loading)

0.005

0
1993 1998 2003 2008 2013
Year

140
Environmental Assessment John Henry No. 1 Mine
The primary conclusion drawn from the phosphorus-loading model is that a high natural
variability associated with the phosphorus levels in Lake Sawyer exists. The total loading
percentage from the mine operation has tended to be higher when the mine was active, and a
lower rate of loading can be observed in the years from 2000 to 2015. Sufficient data was not
available to calculate internal phosphorus loading from the lake itself and cumulative loading
rates from other operations within the watershed.

The cumulative impact of phosphorus loading in Rock Creek is difficult to quantify specifically
given the lack of loading data from all contributing operations and urban/suburban areas.
However, given the water resource protection measures in place for each operation reviewed
the long-term cumulative impacts on phosphorus levels in Lake Sawyer would be minor. In this
case minor is defined as changes in water quality at Rock Creek where it enters Lake Sawyer
that sometimes (0-33%) exceed background levels for total phosphorus. The potential increases
in phosphorus expected from urban development through the MPDs must be mitigated in
accordance with their MPD Agreements with the City of Black Diamond. Ultimately phosphorus
loading in excess of permit standards will require the MPD developer to install phosphorus
treatment facilities. As noted above, by the time the mining ceases operations in 2024, all
residential units would be constructed and occupied at Lawson Hills MPD. Due to the MPD
agreements with the City of Black Diamond, this makes it unlikely that there will be any
cumulative impacts from the mine and the MPDs as reflected in water quality of Rock Creek as
it enters Lake Sawyer.

It was a conclusion of the CHIA that phosphorus loading into the Lake Sawyer increases slightly
during time periods in which the John Henry No. 1 Mine is active. However, the differences in
phosphorus loading between the No Action and Proposed Action Alternatives would be
negligible given that the proposed action alternative adds 29.7 acres of total new disturbance.
There would be a minor and long-term cumulative impact to phosphorus loading whether that
activity consists of reclamation-only or mining and reclamation given that the amount of
reclamation work remaining to be conducted at the mine is much greater than the proposed new
disturbance.

4.1.2 Air Quality

4.1.2.1 Historic John Henry No. 1 mining
Any previous mining of the John Henry No. 1 Mine would not result in cumulative air quality
emissions since mining activities ceased in 1999. Air quality impacts associated with the
Proposed Action Alternative is described in Section 3.5, Air Quality.
4.1.2.2 Historic Residential Development around Lake Sawyer
Since construction of these residences is complete there would be no construction emissions
released and cumulative impacts would be limited to vehicle emissions from new residents.
Cumulative impacts of these vehicles and the truck traffic under the Proposed Action Alternative

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Environmental Assessment John Henry No. 1 Mine
would not result in a significant increase in area traffic and the residential traffic currently
occurring was considered as part of the air quality analysis baseline using WDOE 2011
emission inventory data which covers the time when historical residential development would
have occurred (see Section 3.5, Air Quality).
4.1.2.3 Sand and Gravel Mining
Air quality emissions related to sand and gravel mining would be restricted to the immediate
area in and around the Morgan Kame sand and gravel mine and would primarily be associated
with mining equipment and fugitive dust from mining, transportation, and storage. Cumulative
impacts would be negligible and short-term because the Morgan Kame mine was operational
during the last inventory data from WDOE in 2011 and therefore included as part of the air
quality analysis baseline used to determine that direct and indirect impacts would be negligible.
4.1.2.4 Villages, Lawson Hills, and Reserve at Woodlands Residential Developments
The proposed MPD projects and the center of Black Diamond are both located to the south and
west of the mining area. Air emissions were not quantified in the MPD proposals and sufficient
data to perform these calculations was also not provided (such as hours of operation,
equipment type, etc) (City of Black Diamond 2011). However, it can be inferred that the effects
of emissions from MPD activities in conjunction with those under the Proposed Action
Alternative would be temporary and at any given time would occur only where operations are
occurring. The effects of the emissions on ambient air quality would vary with time due to the
operational schedule, mobility of emission sources, type of equipment in use, and local
meteorological conditions; therefore, they are not anticipated to lead to pollutant concentrations
that would violate the NAAQS or impair regional air quality conditions and would be considered
negligible and short-term. Indirect cumulative impacts from coal transportation and increased
residential traffic would be considered moderate and short-term due to the increase of
potentially 6,050 additional vehicles (assuming 1 vehicle per residential unit constructed);
however, once mining operations cease by 2024 there would no longer be any impacts from
coal transportation traffic.
4.1.2.5 Maple Valley Comprehensive Plan
Components of the Maple Valley Comprehensive Plan that would result in air quality emissions
would include construction of roadway improvements along SR 169, additional utility services,
upgraded community facilities, and various improvements and upgrades to area parks. These
projects are expected to be small-scale construction operations (i.e. only utilizing 1 or 2 pieces
of diesel or electric equipment) and short-term in duration (i.e. less than 3 months) therefore any
emissions would be negligible.
4.1.2.6 Summary
In summary, cumulative impacts for air emissions would be minor and primarily be associated
with the future development of the MPDs.

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4.1.3 Fish and Wildlife
4.1.3.1 Historic John Henry No. 1 mining
Impacts of previous mining operations from 1986 1999 were analyzed in Section 3.10, Fish
and Wildlife, Table 23.
4.1.3.2 Historic Residential Development around Lake Sawyer
Residential development around Lake Sawyer would have removed wildlife habitat and moved
area species into adjacent lands. Since development around Lake Sawyer did not pick up until
after mining operation had already begun it is presumed that species migrated into lands further
from both Lake Sawyer and the Mine.
4.1.3.3 Sand and Gravel Mining
Table 23 presents wildlife data from the Morgan Kame sand and gravel mine. Other area mining
operations would have removed wildlife habitat and forced species to migrate into adjacent
lands with suitable habitats. It is presumed that species migrated into lands further from both
sand and gravel mining operations and the John Henry No. 1 Mine.
4.1.3.4 Villages, Lawson Hills, and Reserve at Woodlands Residential Developments
Impacts on fish and wildlife have potential to be cumulative as land is cleared for the MPDs over
the next fifteen years. The MPDs would mitigate these impacts by maintaining open space
corridors that connect with surrounding undeveloped rural lands including the mine site
(Parametrix 2009a). As noted in Section 3.7, Vegetation, under the Proposed Action Alternative,
PCCC would disturb an additional 29.7 acres of land. The site would be planted with Douglas fir
as part of reclamation activities. PCCC has also planted 123 acres of Douglas fir and maintains
162 acres of mixed deciduous forest within the permit area. This has provided extensive
additional wildlife habitat. Given the 15-year time frame for MPD development and 5.5-year
mine life the cumulative impacts would be negligible and could be positive as the mine site
provides an area for elk, black bear, and black tailed deer to migrate into as the MPDs are
developed. Under the No Action Alternative no additional wildlife habitat is disturbed although
temporary habitat on the spoil piles will be removed and replaced as part of the reclamation
plan. The land is reclaimed to forest and fish and wildlife habitat over one year under the
Proposed Action Alternative and two years under the No Action Alternative. No negative
cumulative impacts are expected.
4.1.3.5 Maple Valley Comprehensive Plan
The Maple Valley Comprehensive Plan includes a section on Plants and Animals under the
Environmental Quality element. The section outlines several mitigation measures for future
urbanization such as residential and commercial design standards, vegetative protection
requirements, land use, and zoning restrictions, critical area regulations, incentives for open
space and stream corridor preservation and revegetation projects, and public education and
involvement programs (Maple Valley 2015). Two designated wildlife corridors have been
established and are maintained by the city of Maple Valley.
4.1.3.6 Summary
In summary, potential cumulative impacts to fish and wildlife would be minor and short-term.
Impacts associated with increased development such as the MPDs resulting in loss of habitat
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Environmental Assessment John Henry No. 1 Mine
would be minor and short-term since the Mine would be reclaimed after six years under the
Proposed Action Alternative providing suitable habitat once vegetation is re-established.

4.1.4 Vegetation
4.1.4.1 Historic John Henry No. 1 mining
Impacts of previous mining operations from 1986 1999 were analyzed in Section 3.8,
Vegetation.

4.1.4.2 Historic Residential Development around Lake Sawyer

Residential development around Lake Sawyer would have removed vegetation through
disturbance. Continued urbanization would include a process of habitat alteration that changes
the characteristics of the plant communities and the habitat for wildlife.

4.1.4.3 Sand and Gravel Mining

Other area mining operations would have removed wildlife habitat through vegetation. Slopes
would be reforested and the valley floor would be revegetated with grasses.

4.1.4.4 Villages, Lawson Hills, and Reserve at Woodlands Residential Developments

Additional mining under the Proposed Action Alternative would impact vegetation within the
permit boundary. Mining under the Proposed Action Alternative would add to the past and
present actions, and reasonably foreseeable future actions within the SMCRA permit boundary.
This would result in minor contributions to cumulative impacts due to the removal of forested
areas for mining and the eventual return to reclaimed forest habitat. As noted in Section 3.7,
Vegetation, under the Proposed Action Alternative, PCCC would disturb an additional 29.7
acres of land. The site would be planted with Douglas fir as part of the reclamation activities.
PCCC has also planted 123 acres of Douglas fir and maintains 162 acres of mixed deciduous
forest within the permit area. Under the No Action Alternative no additional vegetation would be
disturbed; although, temporary vegetation on the spoil piles would be removed and replaced as
part of the reclamation plan. No negative cumulative impacts are expected.

4.1.4.5 Maple Valley Comprehensive Plan

The Maple Valley Comprehensive Plan includes a section on Plants under the Environmental
Quality element. The section outlines several mitigation measures for future urbanization such
as residential and commercial design standards, vegetative protection requirements, land use,
and zoning restrictions, critical area regulations, incentives for open space and stream corridor
preservation and revegetation projects, and public education and involvement programs (Maple
Valley 2015). Ground-disturbance type projects require consultation with the City in order to
reduce the cumulative impacts on natural resources.

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4.1.4.6 Summary
In summary, potential cumulative impacts to vegetation resources would be minor and short-
term. The overall contribution to cumulative impacts to vegetation under the Proposed Action
Alternative would be minor due to the localized effects and the improved productivity on mined
lands that become reclaimed. Impacts associated with increased development such as the
MPDs resulting in loss of forested areas would be minor and short-term since the Mine would be
reclaimed after seven years under the Proposed Action Alternative providing suitable forest
habitat once vegetation is complete.

4.1.5 Wetlands and Riparian Zones

4.1.5.1 Historic John Henry No. 1 mining
Impacts of previous mining operations from 1986 1999 were analyzed in Section 3.9,
Wetlands and Riparian Zones.
4.1.5.2 Historic Residential Development around Lake Sawyer
Habitat potentially affected is consistent with the definition of EFH and is protected by federal
law against significant adverse effects.
4.1.5.3 Sand and Gravel Mining
Habitat potentially affected is consistent with the definition of EFH and is protected by federal
law against significant adverse effects. The only species with EFH habitat designation within the
project area is Coho salmon and no direct impact to any fish-bearing creek is expected. The
Morgan Kame gravel mine included riparian and wetland management buffers meeting current
City of Black Diamond Sensitive Areas Ordinance requirements. City requirements include:
a 225-foot buffer measured from the ordinary high water mark of Rock Creek as required by
BDMC 19.10.325.C; a 225-foot buffer measured from the edge of the Frog Lake wetland
complex as required by BDMC 19.10.230.B; the existing wider buffers would be enhanced
through planting of the additional area beyond the current buffer; the expansion area wider
buffers would be set aside for permanent protection (Black Diamond 2009c).

4.1.5.4 Villages, Lawson Hills, and Reserve at Woodlands Residential Developments

The residential developments would be constructed in clusters to minimize impacts to
environmentally sensitive areas including wetlands. Also, the proposed stormwater control
systems would maintain wetland recharge for wetlands located on the property in order to
protect wetland hydrology and function, therefore reducing any cumulative impacts (Parametrix
2009a).
4.1.5.5 Maple Valley Comprehensive Plan
Both the Cedar and Green Rivers, and their tributaries, contain Chinook, Coho, and Sockeye
Salmon. The NMFS has listed several of these species as threatened or endangered under the
Endangered Species Act. Lake Wilderness is managed for trout. Large and small mouth bass
are also found in Lake Lucerne and Pipe Lake (Maple Valley 2015). Mitigation measures such
as: residential and commercial design standards, vegetative protection requirements, land use,
and zoning restrictions, critical area regulations, incentives for open space and stream corridor
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Environmental Assessment John Henry No. 1 Mine
preservation and revegetation projects, and public education and involvement programs are
implemented by City of Maple Valley.
4.1.5.6 Summary
Wetlands would be disturbed by mining and reclamation activities that eliminate non-
jurisdictional wetlands in either the long-term (life of the project) or the short-term (temporary, up
to seven years). The primary cumulative impacts to wetlands would be from elimination of 2.58
acres of wetlands as a result of the continued mining of coal at the John Henry No. 1 mine.
However, these wetlands would be reclaimed to lowland forest and there would be no
cumulative impacts to other streams and riparian zones within the permit boundary.

4.1.6 Special Status Species

4.1.6.1 Historic John Henry No. 1 mining
Impacts of previous mining operations from 1986 1999 were analyzed in Section 3.10.1.5,
Special Status Species.
4.1.6.2 Historic Residential Development around Lake Sawyer
Residential development around Lake Sawyer would have removed wildlife habitat and moved
area species into adjacent lands. Since development around Lake Sawyer did not pick up until
after mining operation had already begun it is presumed that species migrated into lands further
from both Lake Sawyer and the Mine. Lake Sawyer is considered aquatic priority habitat and
continues to have regular concentrations of waterfowl and/or raptors, including the American
white pelican and Bald eagle. Previous residential development around Lake Sawyer has
historically occurred in approved zoning areas for residential or industrial development, and
therefore would not result in reduced critical habitat special status species.
4.1.6.3 Sand and Gravel Mining
Table 23 presents wildlife data from the Morgan Kame sand and gravel mine. Other area mining
operations would have removed wildlife habitat and forced species to migrate into adjacent
lands with suitable habitats. It is presumed that species migrated into lands further from both
sand and gravel mining operations and the John Henry No. 1 Mine.
4.1.6.4 Villages, Lawson Hills, and Reserve at Woodlands Residential Developments
Impacts on fish and wildlife have potential to be cumulative as land is cleared for the MPDs over
the next fifteen years. The MPDs would mitigate these impacts by maintaining open space
corridors that connect with surrounding undeveloped rural lands including the mine site
(Parametrix 2009a). As noted in Section 3.7, Vegetation, under the Proposed Action Alternative,
PCCC would disturb an additional 29.7 acres of land. The site would be planted with Douglas fir
as part of reclamation activities. This has provided extensive additional wildlife habitat. Given
the 15-year time frame for MPD development and seven year duration of the Proposed Action
Alternative, the cumulative impacts would be negligible and could be positive as the mine site
provides an area for elk, black bear and black tailed deer to migrate into as the MPDs are
developed. Under the No Action Alternative no additional wildlife habitat is disturbed although
temporary habitat on the spoil piles will be removed and replaced as part of the reclamation

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Environmental Assessment John Henry No. 1 Mine
plan. The land is reclaimed to forest and fish and wildlife habitat under the Proposed Action
Alternative and two years under the No Action Alternative. No negative cumulative impacts are
expected.
4.1.6.5 Maple Valley Comprehensive Plan
Both the Cedar and Green Rivers, and their tributaries, contain Chinook, Coho, and Sockeye
Salmon. The NMFS has listed several of these species as threatened or endangered under the
Endangered Species Act. Mitigation measures for future vegetative protection requirements,
land use and zoning restrictions, critical area regulations, incentives for open space and stream
corridor preservation, and revegetation projects have been implemented by the City (Maple
Valley 2015).
4.1.6.6 Summary
In summary, potential cumulative impacts to special status species would be minor and short-
term. Impacts associated with increased development such as the MPDs resulting in loss of
habitat would be minor and short-term since the Mine would be reclaimed after seven years
under the Proposed Action Alternative providing suitable habitat once vegetation is re
established. The determination for bull trout would remain the same as analyzed in 2001 - not
likely to adversely affect. Since 2001, the bald eagle has been de-listed and therefore is no
longer subject to an ESA section 7 analysis. There would be minimal cumulative effects for the
Whitebark pine, North American wolverine, Marble-murrelet, Oregon spotted frog, Yellow-billed
cuckoo, or the Streaked-horned lark. A determination of may affect, not likely to adversely
affect for the Puget Sound Chinook salmon, and designated critical habitat has been made by
OSMRE. OSMRE is currently waiting for concurrence from NMFS.

4.1.7 Land Use

4.1.7.1 Historic John Henry No. 1 mining
Before mining began at the John Henry No. 1 Mine the area was designated as unmanaged
forest for the upland area and fish and wildlife habitat for the Mud Lake and Ginder Lake
wetlands (OSMRE 1985). The land use since 1986 has been mining with the continued
associated use of wildlife habitat in undisturbed areas with some forest land reestablished in the
reclaimed area of the mine. The Proposed Action and No Action Alternatives would reclaim the
land to forest and fish and wildlife habitat.
4.1.7.2 Historic Residential Development around Lake Sawyer
Land use changes associated with the previous residential development around Lake Sawyer,
occurred in approved zoning areas for residential or industrial development, and therefore would
not result in reduced open space or removal of critical habitat.
4.1.7.3 Sand and Gravel Mining
Sand and gravel mining in the area has disturbed approximately 560 acres, primarily coniferous
forest. Similar to the John Henry No. 1 Mine the mining areas will be reclaimed to be consistent
with a forestry and uncategorized, cleared land use designation upon completion.

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Environmental Assessment John Henry No. 1 Mine
4.1.7.4 Villages, Lawson Hills, and Reserve at Woodlands Residential Developments
The proposed residential development for the Villages and Lawson Hills would convert 783
acres of open space to residential development when all 6,050 dwelling units are built. At a total
of 1,158 acres, each dwelling unit would be built on approximately 0.25 acres. The open space
to residential acreage ratio is approximately 1:2. So for every 2 acres of disturbed land one of
those is an open space acre. This means that by 2024, of the 1,158 acres disturbed
approximately 579 of those acres would be converted from open space to residential property.
The Reserve at Woodlands is already zoned for residential development and therefore would
not result in a loss of open space. Reclaimed land under both the Proposed Action Alternative
and the No Action Alternative would be forest and fish and wildlife habitat. This positive impact
would provide additional open space in proximity to the MPDs thereby replacing some fish and
wildlife habitat lost due to residential construction. Also, as part of the MPDs proposal
development agreements were established with the City and outline fish and wildlife buffers and
open space boundaries to help maintain existing and future parks and open spaces.
4.1.7.5 Maple Valley Comprehensive Plan
The Maple Valley Comprehensive Plan describes several small scale upgrades to area parks
including the Lake Wilderness Park near the City of Maple Valley. The Plan also describes one
new park facility to be named Summit Park located west of Maple Valley Black Diamond Road
SE (SR 169), south of Kent-Kangley Road, and north of SE 276th Street. This park falls outside
of City limits; therefore, it would not convert any existing land designations surrounding the
mine. However, residents of Black Diamond could use its facilities and benefit from having it
close by. The Plan goes on to describe the King County incentives to preserve open space on
private property such as tax reductions and the Community Stewardship Grants (Maple Valley
2015).
4.1.7.6 Summary
In summary, land use changes associated with the John Henry No. 1 Mine occurred in
approved zoning areas for residential or industrial development and therefore would not result in
reduced open space or removal of critical habitat. The greatest land use impacts would result
from the proposed residential developments; however, these would be phased developments
and by the time the Proposed Action and No Action Alternatives the mine itself would be
reclaimed into forest and fish and wildlife habitat therefore, cumulative impacts related to land
use are minor and long-term.

4.1.8 Socioeconomics and Environmental Justice

4.1.8.1 Historic John Henry No. 1 mining
Since previous mine operations ceased in 1999 the John Henry No. 1 Mine no longer provides
area employment until the Proposed Action Alternative or No Action Alternative is approved.
4.1.8.2 Historic Residential Development around Lake Sawyer
Since these homes have already been constructed there would be no construction related jobs.
The increase in area population from occupancy of these households would contribute to the

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Environmental Assessment John Henry No. 1 Mine
City of Black Diamond and King County taxes; however, those increases would be considered
minor.
4.1.8.3 Sand and Gravel Mining
The Morgan Kame sand and gravel mine employees between 12 24 people at any given time
and varies based on the current production level (Black Diamond 2009c). The workforce for the
Cadman Black Diamond and the Reserve Silica sand and gravel operation is unknown but
conservatively assumed to be similar to that of the Morgan Kame Mine. There are no
anticipated changes to employment at the sand and gravel mines operating in the area and
therefore no cumulative impacts.
4.1.8.4 Villages, Lawson Hills, and Reserve at Woodlands Residential Developments
The population within the City of Black Diamond is expected to show more rapid growth over the
next 25 years as the two MPDs are completed. The socioeconomic and environmental impacts
for the Villages and Lawson Hills MPD are calculated and discussed in separate EISs
(Parametrix 2009a and 2009b). Construction employment associated with building over 6,050
new residential units and substantial new commercial units in Black Diamond over the next 15
years dwarfs the projected 30 employees needed under the Proposed Action Alternative over
six years for mining operations and 20 employees for one year for reclamation and 20
employees over two years for reclamation under the No Action Alternative (Parametrix 2009a).
No discernible cumulative impacts are expected except for the positive short-term impact of
local employment.
4.1.8.5 Maple Valley Comprehensive Plan
Minor construction projects outlined in the Maple Valley Comprehensive Plan would add short-
term, temporary employment to area residents. The majority of economic development
described in the Plan related to the development of the MPDs within the City of Black Diamond
as described in Section 4.1.6.4, Villages, Lawson Hills, and Reserve at Woodlands Residential
Developments. One project that would improve the City of Black Diamonds existing utilities is
for the installation of a new high-pressure natural gas supply main in the south end of Maple
Valley near Auburn-Black Diamond Road and 224th Avenue SE to accommodate future growth
associated with the proposed MPDs thereby reducing any strain on utilities to existing residents
(Maple Valley 2015).

4.1.8.6 Summary
In summary, there would be no disproportionately high and adverse impacts on minority and
low-income populations as described in Section 3.11.2, Environmental Justice, therefore there
would be no cumulative impacts. Cumulative impacts to socioeconomic resources would be
negligible and short-term due to the seven-year duration of the Proposed Action Alternative and
two years of reclamation under the No Action Alternative.

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Environmental Assessment John Henry No. 1 Mine
4.1.9 Transportation
4.1.9.1 Historic John Henry No. 1 mining
Previous mining at the John Henry No. 1 Mine has ceased and therefore there would not be any
associated truck traffic from vendors, employees, or coal transport.
4.1.9.2 Historic Residential Development around Lake Sawyer
Residential development around Lake Sawyer would have resulted in an increase in vehicle
traffic however this increase in traffic was included as part of the baseline traffic analyzed along
with the Proposed Action Alternative in Section 3.12, Transportation.
4.1.9.3 Sand and Gravel Mining
Truck trips from the Morgan Kame sand and gravel mine have historically ranged and are
expected to continue to range from between 120 to 340 truck trips per day during the
construction season from April through October (Black Diamond 2009c). The daily truck trips for
the Cadman Black Diamond and the Reserve Silica sand and gravel operation is unknown but
conservatively assumed to be similar to that of the Morgan Kame Mine (for a total of
approximately 360 to 1,020 trucks per day from all sand and gravel operations) (Black Diamond
2009c). The cumulative impact of adding an average of ten (9.9) additional trucks to the traffic
(or even 82 truck trips per day under the most adverse barge loading conditions) from the John
Henry No. 1 Mine would be minor. This is especially the case because King County prohibits
truck traffic from the mine site during peak traffic hours.
4.1.9.4 Villages, Lawson Hills, and Reserve at Woodlands Residential Developments
The two MPDs would eventually add significant additional traffic that will be mitigated through
traffic improvements to maintain required LOS at major intersections (Parametrix 2009c).
According to the City of Black Diamonds 6-year Transportation Improvement Plan,
improvements would include a new arterial roadway, road extensions, and intersection
improvements including Ravensdale/SR 169, as well as safety upgrades and maintenance (City
of Black Diamond 2016). By the time the mining ceases operations in 2024, it is expected that
all units would be constructed and occupied. The cumulative traffic with the MPDs impacts will
be moderate and short-term due to the planned mitigation measures committed to by the MPD
Agreements with the City of Black Diamond and the short duration of the Proposed Action
Alternative.
4.1.9.5 Maple Valley Comprehensive Plan
The Maple Valley Comprehensive Plan outlines three potentially funded roadway improvement
projects on roads that would be used to haul coal from the John Henry No. 1 Mine. The Plan
states that along SR 516 from 160th Avenue SE to 164th Avenue SE turn lanes would be added
and traffic signals modified to accommodate growing traffic levels. Along SR 169 between 222th
and 244th and Witte and SE 240th the roadway would be widened beginning in 2017 and
ending in 2019. These planned improvements would allow for the City of Black Diamond to
accommodate future traffic growth scenarios associated with the coal hauling, sand and gravel
mine operations, and MPD developments (Maple Valley 2015).

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Environmental Assessment John Henry No. 1 Mine
4.1.9.6 Summary
In summary, there would be minor, short-term cumulative impacts from area projects and the
Proposed Action and No Action Alternatives. Incremental traffic increases would be projected to
be minor with a maximum of 368 (MPD new residences and Proposed Action Alternative
employment) vehicles added to area roadways. Potential roadway improvements could assist
with these growing numbers on SR 516 and 169. Traffic increases under the No Action
Alternative would be less than 360 vehicles per day. It is expected that current roadways within
King County would be equipped to handle this increase.

4.1.10 Visual
4.1.10.1 Historic John Henry No. 1 mining
Previous land clearing and grading associated with activities at the John Henry No. 1 Mine
occurred between 1986 and 1999. This area as well as the 29.7 acres of disturbance
encompass the mine permit boundary and would result in a minor visual cumulative impact
similar to that described in Section 3.15, Visual Resources, for the Proposed Action Alternative.
This area would be reclaimed land under both the Proposed Action Alternative and the No
Action Alternative.
4.1.10.2 Historic Residential Development around Lake Sawyer
Previous land clearing and construction of new structures associated with the development of
new residences around Lake Sawyer are completed and resulted in a change to the visual
landscape. The increase in residences around Lake Sawyer would result in an increase in those
impacted by changes to visual resources under the Proposed Action Alternative and were taken
into account in Section 3.15, Visual Resources.
4.1.10.3 Sand and Gravel Mining
The sand and gravel mining encompasses 560 acres of land disturbance and mining activities.
There are no additional mining activities or expansions planned therefore visual impacts related
to sand and gravel mining would remain the same and not result in cumulative impacts.
4.1.10.4 Villages, Lawson Hills, and Reserve at Woodlands Residential Developments
Reclaimed land under both the Proposed Action Alternative and the No Action Alternative would
be forest and fish and wildlife habitat. This positive impact would provide additional open space
and improve aesthetics of the community in proximity to the MPDs thereby replacing some fish
and wildlife habitat lost due to residential construction.
4.1.10.5 Maple Valley Comprehensive Plan
Components of the Maple Valley Comprehensive Plan would result in temporary and minor
impacts to visual resources from small-scale construction and improvement projects (Maple
Valley 2015). Most of the potential visual impacts would occur outside of the city limits and
therefore not cause a cumulative effect with the Proposed Action Alternative.

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Environmental Assessment John Henry No. 1 Mine
4.1.10.6 Summary
In summary, no cumulative impacts are expected except for a short period while Spoil Pile 3S is
reclaimed under the Proposed Action and No Action Alternatives. Those impacts would be
minor and short-term. This is because the change to the visual appearance of the site during
mining and reclamation activities will generally be noticeable but subtle. Potential visual impacts
would usually be subordinate, but may be noticed by viewers without being pointed out.

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Environmental Assessment John Henry No. 1 Mine
5.0 PERSONS / AGENCIES CONTACTED

5.1 OSMRE Western Region Interdisciplinary Review

Flynn Dickinson, Hydrologist
Paul Clark, Hydrologist
Jeremy Spangler, Civil Engineer
Jacob Mulinix, Soil Scientist
Matthew Hulbert, Civil Engineer
Alex Birchfield, Senior Ecologist
Glenn Waugh, Sr. Regulatory Program Specialist
Edward Vasquez, Senior Ecologist
Logan Sholar, Natural Resource Specialist
Gretchen Pinkham, Natural Resource Specialist
David Costain, Environmental Protection Specialist

5.2 Pacific Coast Coal Company

David Morris, General Manager
Mike Conaboy, Environmental Coordinator
William Kombol, Manager, Palmer Coking Coal Company

5.3 Interagency Consultation

U.S. Department of Labor, Mine Safety and Health Administration
U.S. Fish and Wildlife Service
U.S. Army Corps of Engineers
Washington Department of Ecology
City of Black Diamond
King County Department of Development and Environmental Services
Washington Department of Archeology and Historic Preservation
Washington Department of Natural Resources, Division of Geology and Earth Sciences
Washington Department of Fish and Wildlife

5.4 Tribal Contacts

Muckleshoot Indian Tribe
Confederated Tribes of the Warm Springs Reservation of Oregon
Puyallup Tribe of the Puyallup Reservation
Snoqualmie Indian Tribe
Stillaguamish Tribe of Indians of Washington
Confederated Tribes and Bands of the Yakama Nation
Suquamish Indian Tribe of the Port Madison Reservation

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Environmental Assessment John Henry No. 1 Mine
6.0 REFERENCES

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Argonne National Laboratory. 2013a. Updates to Transportation Parameters in GREET.

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_____. 2013b. Updates to Vehicle Operation Emission Factors in GREET. Available:

https://greet.es.anl.gov/publication-vehicles-13. Accessed: December 1, 2016.

Aubry, K.B., Raley, Catherine M. 2002. The Pileated Woodpecker as a Habitat Modifier in the
Pacific Northwest. In: Proceedings of the symposium on the ecology and management
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Southwest Research Station - Gen. Tech. Rep. PSW-GTR-181. 2002. Pp. 257-274.

Aubry, K. B., K.S. McKelvey, and J.P. Copeland. 2007. Distribution and broadscale
habitatrelations of the wolverine in the contiguous United States. Journal of Wildlife
Management 71:2147-2158.

Aubry, K. B., J. Rohrer, C. M. Raley, S. Fitkin. 2016. Wolverine distribution and ecology in the
North Cascades ecosystems Final progress report (February 9, 2016). U. S. Forest
Service, Pacific Northwest Research Station, Olympia, WA 98512.

Beck, S. 2014. Black Diamond Property Values and the John Henry Mine. Prepared for Pacific
Coast Coal Company. John L. Scott Real Estate. July 2014.

Bergdahl, J.C. 1997. Endemic Sphagnum bog beetles from the Puget Sound Region: Kings
Land and Snoqualmie Bogs, King Co., Washington. Unpublished report for Northwest
Biodiversity Center.

Black Diamond. 1995. City of Black Diamond Comprehensive Plan Appendices. August 1995.

_____. 2005. City of Black Diamond Master Plan Development Ordinance No. 05-779.

_____. 2008. City of Black Diamond Sensitive Areas Ordinance No. 08-875.

_____. 2009a. City of Black Diamond Comprehensive Plan.

_____. 2009b. City of Black Diamond Zoning Code, Chapter 18.04.

Available:http://www.ci.blackdiamond.wa.us/Depts/CommDev/planning/2009%20Zoning
%20Code.pdf). Accessed March 8, 2015.

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_____. 2009c. Draft Environmental Impact Statement Morgan Kame Terrace Mine Expansion,
SEPA Project File Under Grading and Clearing Permit Number: L06CG257. November
20, 2009.

_____. 2011. Master Plan Development Agreements, The Villages and Lawson Hills Master
Planned Developments. Available:
http://www.ci.blackdiamond.wa.us/Depts/CommDev/mpd_page.html. Accessed: April 24,
2017.

_____. 2015a. City of Black Diamond Economic Development web page. Available:
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