Alternatives Analysis

BHP Proposed Grays Harbor Potash Export Facility Hoquiam, Washington 40600-HS-RPT-55047 Revision 2

17 June 2019

Submitted by

WSP USA 33301 Ninth Avenue South, Suite 300 Federal Way, Washington 98003-2600

WA17.0202.00

ALTERNATIVES ANALYSIS BHP PROPOSED GRAYS HARBOR POTASH EXPORT FACILITY

TABLE OF CONTENTS

SECTION PAGE

1.0 INTRODUCTION ...... 1 1.1 Proposed Facility Overview ...... 2 2.0 ALTERNATIVES ANALYSIS PROCESS ...... 4 2.1 Section 404(b)(1) Background ...... 4 2.2 Analysis Process ...... 4 3.0 PHASE 1 – NEED, PURPOSE, AND GEOGRAPHIC AREA...... 6 3.1 Step 1: Project Need ...... 6 3.2 Step 2: Basic Project Purpose and Water Dependency ...... 7 3.2.1 Purpose ...... 7 3.2.2 Water Dependency ...... 7 3.3 Step 3: Overall Project Purpose and Geographic Area Selection ...... 8 4.0 PHASE 2 - ALTERNATIVES IDENTIFICATION - STEP 4: POTENTIALLY PRACTICABLE CRITERIA IDENTIFICATION ...... 9 4.1.1 Availability ...... 9 4.1.2 Cost ...... 10 4.1.3 Existing Technology ...... 11 4.1.4 Logistics ...... 11 4.2 Criteria Summary ...... 12 4.3 Potentially Practicable Alternatives Identification ...... 13 5.0 PHASE 3 - PRACTICABILITY EVALUATION ...... 14 5.1 Alternative A: Port of Grays Harbor Terminal 3 ...... 14 5.1.1 Site Availability...... 15 5.1.2 Cost ...... 16 5.1.3 Existing Technology ...... 16 5.1.4 Logistics ...... 16 5.1.5 Conclusion ...... 16 5.2 Alternative A1: Grays Harbor Terminal 3 Alternative Layout ...... 16 5.2.1 Conclusion ...... 17 5.3 Alternative B: Port of Tacoma SSA/MVV Site...... 17 5.3.1 Site Availability...... 17 5.3.2 Cost ...... 18 5.3.3 Existing Technology ...... 18 5.3.4 Logistics ...... 18 5.3.5 Conclusion ...... 18 5.4 Alternative C: Port of Longview Barlow Point Site ...... 19 5.4.1 Site Availability...... 19 5.4.2 Cost ...... 19 5.4.3 Existing Technology ...... 20 5.4.4 Logistics ...... 20 5.4.5 Conclusion ...... 20

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5.5 Alternative D: Port of Longview Berth 2 Site ...... 20 5.5.1 Site Availability...... 20 5.5.2 Cost ...... 21 5.5.3 Existing Technology ...... 21 5.5.4 Logistics ...... 21 5.5.5 Conclusion ...... 21 5.6 Alternative E: Port of Vancouver, Washington Terminal 5...... 21 5.6.1 Site Availability...... 22 5.6.2 Cost ...... 22 5.6.3 Existing Technology ...... 22 5.6.4 Logistics ...... 22 5.6.5 Conclusion ...... 23 5.7 Alternative F: Fraser Surrey Docks, Vancouver, B.C...... 23 5.7.1 Site Availability...... 23 5.7.2 Cost ...... 23 5.7.3 Existing Technology ...... 24 5.7.4 Logistics ...... 24 5.7.5 Conclusion ...... 24 5.8 Alternative G: Kinder Morgan Terminals, Vancouver Wharves...... 24 5.8.1 Site Availability...... 24 5.8.2 Cost ...... 24 5.8.3 Existing Technology ...... 25 5.8.4 Logistics ...... 25 5.8.5 Conclusion ...... 25 5.9 Alternative H: No Federal Action Alternative ...... 25 5.10 Practicability Analysis Results Summary ...... 25 6.0 PHASE 4: ENVIRONMENTAL ANALYSIS ...... 27 6.1 Alternatives A and A1 Impacts Summary and Comparison ...... 27 6.2 Alternative A1 Environmental Analysis ...... 28 6.2.1 Existing Wetland and Aquatic Habitat Conditions ...... 29 6.2.2 Mitigation Sequencing ...... 33 6.2.3 Wetland and Buffer Impacts ...... 39 6.2.4 Aquatic Impacts ...... 41 6.2.5 Compensatory Mitigation Summary ...... 46 7.0 PHASE 5: LEDPA IDENTIFICATION ...... 49 8.0 BIBLIOGRAPHY ...... 50

LIST OF TABLES Table 1. Alternatives Analysis Framework for Compliance with 40 CFR 230.10 ...... 5 Table 2. Arable Land per Capita Forecast ...... 6 Table 3. Approximate Rail Distances ...... 9 Table 4. Example Export Vessel Class Characteristics ...... 12 Table 5. Practicability Criteria Summary ...... 13 Table 6. Alternatives Practicability Analysis Summary ...... 26 Table 7. Alternatives A and A1 Impacts Comparison ...... 27 Table 8. Alternative A1 - Wetland and Wetland Buffer Impacts ...... 41 Table 9. Aquatic Impacts ...... 42 Table 10. Aquatic Impacts by Tidal Zone ...... 42 Table 11. Wetland and Wetland Buffer Mitigation Summary ...... 47

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LIST OF APPENDICES Appendix A – Drawings Sheet 1 – Vicinity Map, Washington State Sites Sheet 2 – Vicinity Map, Canada Sites Sheet 3 – Alternative A – Grays Harbor Terminal 3 Sheet 4 – Alternative A1 – Grays Harbor Terminal 3 On-site Alternative Sheet 5 – Alternative B – Port of Tacoma SSA/MVV Site Sheet 6 – Alternative C – Port of Longview Barlow Point Sheet 7 – Alternative D – Port of Longview Berth 2 Sheet 8 – Alternative E – Port of Vancouver, WA Terminal 5 Sheet 9 – Alternative F – Fraser Surrey Docks, Vancouver, B.C. Sheet 10 – Alternative G – Kinder Morgan Terminals, Vancouver, B.C.

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1.0 INTRODUCTION BHP has been developing the Jansen Potash Project in Saskatchewan, Canada, a potential potash mine for export to overseas markets. The Jansen Project is now in the feasibility study phase and remains subject to approval from the Board of BHP to progress to execution (final construction). Mineshaft development, initial surface works, and studies for the mine are currently in progress.

The Jansen Project requires a reliable outbound logistics strategy with competitive development and operating costs. A key part of this strategy is to develop a marine terminal for export of potash transported by rail from the proposed Jansen mine to international markets via oceangoing vessels.

BHP is a world-leading resources company. BHP extracts and process minerals, oil, and gas primarily in Australia and North and South America and its products are sold worldwide. Decisions that BHP makes on the Jansen Project’s future will be value based and need to align with the company’s strict Capital Allocation Framework requirements.

BHP had previously selected a preferred Port option at the Port of Vancouver, Washington, in 2010. However, after four years of negotiations, BHP later concluded that the Vancouver, Washington, location was not commercially practicable because of the company’s inability to secure competitive rail access over the last mile of track to the facility. This location is discussed in greater detail in Section 5.4 below.

BHP then conducted an extensive evaluation of other potential terminal sites in North America, including those depicted in Sheets 1 through 10. BHP searched very broadly throughout North America during their initial review of potential sites. BHP started by looking at potential sites located within 2,250 rail miles from the Jansen Project as an initial filter. The search distance was narrowed to potential sites located within 1,400 miles of the mine because of further evaluation of the economic viability of sites and their associated distances from the mine. Shipping distance from the proposed sites to delivery ports (primarily in Asia) was an additional variable that narrowed the area of potentially practicable project sites. BHP decided to evaluate permitting and commercial availability at two potentially practicable alternative sites simultaneously. BHP selected the Port of Grays Harbor’s existing Terminal 3 site (Sheet 3 and 4) and a site near Vancouver, British Columbia known as the Fraser Surrey Docks site (Sheet 9). BHP began outreach to the public, regulatory agencies, and other stakeholders at both sites and began the process of developing permit applications at both locations. BHP does not own or lease either site. It is BHP’s goal, however, to successfully secure commercial access of one of the sites, and ultimately permit a marine terminal facility there.

BHP has determined that the Fraser Surrey Docks site is not commercially available at this time, and this is explained in more detail in this document. The Port of Grays Harbor Terminal 3 site is therefore the Least Environmentally Damaging Practicable Alternative available for siting the proposed potash export marine terminal.

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The project consists of redeveloping the Terminal 3 industrial site and portions of adjacent parcels for the unloading and storage of potash transported to the site via rail from the proposed Jansen mine in Saskatchewan, Canada, for shipment to international markets. The upland portion of the proposed project site would include rail unloading and product storage facilities, a conveyor system for transferring potash from the rail unloading area to the product storage facilities and to the shiploader, and administrative and maintenance buildings. The shiploader and new berth facility would be located directly west of the existing Terminal 3 dock located in Grays Harbor.

This report analyzes potential alternative sites and alternative configurations on the proposed Port of Grays Harbor site under the framework of the Clean Water Act (CWA) Section 404(b)(1) Alternatives Analysis.

1.1 PROPOSED FACILITY OVERVIEW BHP has developed an outbound logistics strategy that consists of transporting potash by rail from the proposed Jansen mine to a Pacific Coast marine terminal and transferring the potash from rail to oceangoing vessels for export. Although Jansen Stage 1 is expected to be 4.3-4.5 Mtpa, the export terminal site would need to be large enough to accommodate up to 8 million metric tonnes per annum (Mtpa) of potash produced at Jansen in Stage 2. It must also be capable of accommodating the continuous unloading of trains and loading of vessels at a rate of approximately 4,000 tons per hour based on operating philosophy and design throughput. The continuous unloading of cars allows for unloading without delay so that they can return to the mine. This is important because of the limited number of trains available, as well as the limited storage capacity available at the mine. Production at the mine cannot be stopped and started without significant impacts to efficiency and the cost of production.

The proposed project components on the upland portion of the potash export terminal site generally include a rail loop, railcar unloading facility, conveyor systems, dust collectors, a product storage building, administration and maintenance buildings, electrical rooms, stormwater ponds, and utility connections. Sheet 4 shows the proposed layout of the facilities on the Grays Harbor site.

The railcar unloading facility, conveyor system, and storage facility would be completely covered to prevent rainwater from contacting the potash. This is important as potash is water soluble. The railcars conveying the potash to the facility would also be enclosed.

The facility conveyance system is designed to support the 8 Mtpa throughput from the mine. The design configuration, specifically including the height and slope of the conveyors, is required to move material to the storage building allowing for maximum storage height in the building, from the storage building, and from the railcar unloading facility to the design height of the dual-quadrant shiploader so that the design vessels can be loaded with potash.

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The product storage building must be at least 141.5 feet high to accommodate the design storage volumes for the throughput from the mine at Stage 2 capacity and the associated conveyance equipment. The design storage volume is needed to insure that trains can continue to deliver product while ships are in transit or if a ship’s arrival is delayed. The adjacent Bowerman Field Airport and the Federal Aviation Administration (FAA)-regulated air space restricts the height of buildings at the Port of Grays Harbor site as discussed in more detail in Section 5.1. A single product storage building represents the most efficient design for the facility throughput and operations of the conveyance machinery required to move the product from the trains to the shiploader. Alternative arrangements that result in a shorter building height have been studied; however, because of the performance limitations of the machines that are able to place and reclaim material in a building with a lower height, the project throughput requirements would not be met without additional material- handling equipment and increasing the building size. Similarly, splitting the single building into two smaller buildings would result in a total building area larger than that of a single building, at substantially higher cost and increased environmental impacts, particularly to wetlands. A single building provides the most efficient storage configuration, equipment arrangement, and power consumption. A second building would require duplicating all related equipment, adding conveyors, increasing power consumption, and increasing capital expenditure.

The rail loop size and configuration were designed to efficiently accommodate an entire unit train during delivery of potash in order to minimize off-site traffic impacts from the trains. BHP is using unit trains because all of the product goes to a single destination and does not require inefficient stops at other facilities to offload cars with other commodities. In addition, rail freight benefits of maximizing unit train capacity and operations is critical to obtaining project economics to support viability and project sanction by BHP. The company’s planned unit trains will consist of 177 rail cars requiring a minimum of 8,500 feet of track to accommodate the entire train on site during unloading. The approximate 11-degree turning radius of the track was designed to accommodate the unit train on site, accommodate the unit trains turning parameters, and to allow the placement of the support structures (product storage building, conveyors, administration building, etc.) within the rail loop.

Required in-water facilities for the proposed project generally include a marine terminal and deepwater berth with a dual quadrant shiploader capable of servicing bulk material oceangoing vessels. The facility berth must have access to a navigable waterway with a minimum depth of 11.5 meters (38 feet) to accommodate current and future design vessels necessary to accommodate the throughput of 8 Mtpa. The berth was designed to minimize the overwater coverage while still optimizing operations to accommodate oceangoing vessels. The dual quadrant shiploader consists of two shiploaders at a single berth. It has the capacity to load most vessels within 24 hours, can load all holds without the need to move the vessel and offers equipment redundancy (i.e., if one goes down for maintenance, the facility can continue to operate with the operational shiploader). The shiploader and access trestles are relatively narrow structures, founded on relatively few piles so they do not result in a substantial benthic footprint (see Section 6.2.4, Table 9). The impacts associated with

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overwater shading from the proposed shiploader and trestle structure is relatively low compared to that which would be associated with a larger monolithic structure (e.g., Port of Grays Harbor Terminal 3 pier) that was constructed closer to the water, not allowing as much light to pass beneath it throughout the day.

2.0 ALTERNATIVES ANALYSIS PROCESS

2.1 SECTION 404(B)(1) BACKGROUND Section 404 of the CWA authorizes the U.S. Army Corps of Engineers (USACE) to issue permits for the discharge of dredged or fill materials into waters of the United States, including wetlands (33 U.S. Code 1344). Waters of the United States include coastal and inland waters, lakes, rivers, and streams, including adjacent wetlands and tributaries.

The Section 404(b)(1) Guidelines (Guidelines) (40 Code of Federal Regulations [CFR] 230) are the substantive environmental criteria the USACE uses to evaluate permit applications. The Guidelines prohibit discharges of dredged or fill material into waters of the United States if a practicable alternative to the proposed discharge exists that would have less adverse impacts on the aquatic ecosystem, including wetlands, as long as the alternative does not have other significant adverse environmental impacts (40 CFR 230[a]). The analysis process is shown schematically on Table 1, taken from the USACE Seattle District’s guidance document Alternatives Analysis Framework dated April 18, 20161.

The first part of the 404(b)(1) analysis consists of identification of the project purpose and need, the appropriate geographic area for the project, and the potential site alternatives. This information is then used to determine whether those alternatives are practicable. An alternative is considered practicable if the site is available and the project is capable of being implemented after considering geographic location, cost, existing technology, and logistics in light of overall project purpose (40 CFR 230.10[a][2]).

The identified practicable alternative(s) are then evaluated relative to project-specific criteria to identify the alternative that is the LEDPA (40 CFR Part 230.10[d]). The guidelines for project compliance with 40 CFR 230.10 are set forth in an alternatives analysis framework as discussed below.

2.2 ANALYSIS PROCESS This summary is organized in accordance with the process described in the USACE Alternatives Analysis Framework (April 20161), as shown on Table 1. The framework establishes five phases of evaluation to identify the LEDPA. The five phases include the following.

1 http://www.nws.usace.army.mil/Portals/27/docs/regulatory/Forms/Alternative%20Analysis%20 Framework%20NWS%20(4-18-16).pdf?ver=2016-06-07-111159-147.

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• Phase 1: Need, Purpose, and Geographic Area • Phase 2: Alternatives Identification • Phase 3: Practicability Evaluation • Phase 4: Environmental Analysis • Phase 5: LEDPA Identification

Table 1. Alternatives Analysis Framework for Compliance with 40 CFR 230.10

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3.0 PHASE 1 – NEED, PURPOSE, AND GEOGRAPHIC AREA

3.1 STEP 1: PROJECT NEED There is a growing demand for potash (potassium chloride) in international markets where economic and population growth are driving increased agricultural production and the need for potash fertilizer to improve agricultural yields and crop resiliency.

The world population is growing while the availability of arable land is declining as shown on the graph below (Table 2). Rising food consumption, driven both by population growth and improving diets, is putting pressure on global agriculture to deliver higher yields. The simplest and most widespread solution is the use of fertilizers that can increase crop yield and provide higher quality food products with fewer defects and often at less cost. Potash is an essential part of the solution and global demand for potash has been growing at 1.5 million tons per year over the last 15 years. Much of that growth has been in Asia and South America while demand in North America has remained relatively flat.

Table 2. Arable Land per Capita Forecast

(Source: usanewsgroup.com/2017/12/06/potash-supply-to-exceed-demand-by-2020-report)

BHP is developing the Jansen Potash Project in Saskatchewan, Canada. The area of east-central Saskatchewan has the largest known potash reserves in the world, and the Jansen mine is planned to be one of the world’s largest potash mines.

BHP needs the ability to deliver potash produced from the Jansen mine to international markets in an economically competitive manner. The potash market remains competitive even as demand grows, which means buyers purchase potash from the seller capable of delivering it to the market at the lowest price (USA News Group, 6 December 2017).

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BHP needs to secure competitive rail service from the Jansen mine to a port location, develop a marine port terminal facility to store potash and transfer it into oceangoing vessels, and secure ship transportation from the port to international markets. The primary international markets for potash from the Jansen mine would be located in China, India, Southeast Asia and Brazil. The focus of the project is the development of the required marine port terminal facility.

The marine port terminal facility must be large enough to handle 8 Mtpa of potash. The terminal must have access to a deepwater navigational channel and be capable of accommodating Handymax and Kamsarmax vessels. The terminal must also be serviced by at least two Class I rail carriers either directly or via existing short line rail services that provide “last mile” access to the site in order to provide competitive rail transport and achieve the design throughput.

3.2 STEP 2: BASIC PROJECT PURPOSE AND WATER DEPENDENCY

3.2.1 Purpose The basic purpose of the proposed project is to provide storage and rail-to-vessel deepwater transfer facilities for bulk potash export to international markets. This project purpose requires rail off-loading equipment to unload rail cars bound from the Jansen mine, potash storage facilities, and a marine terminal for loading potash onto oceangoing vessels at berth.

BHP investigated existing terminal capacity with the help of logistics consultants and subject matter experts and concluded that contracting with existing terminals was not an option. Potash requires dedicated terminal facilities because of its corrosive nature, moisture sensitivity, and related handling requirements. Only 32 of the more than 8,000 dry-bulk commodity storage facilities and terminals in North America are designed to handle potash. Many of those are import-only facilities, lack sufficient connections to rail transportation, or are operated by BHP competitors. Focusing on those facilities capable of handling rail-to-vessel logistics and storage, it was concluded that those facilities lack sufficient capacity to serve the Jansen Project.

BHP also considered whether it could ship potash via multiple existing facilities or whether it could construct two or more smaller terminals to handle the desired volume of potash shipments. BHP concluded that the use of multiple terminals would be financially and operationally impracticable.

3.2.2 Water Dependency 40 CFR 230 Section 404(b)(1)(3) provides: “Where the activity associated with a discharge which is proposed for a special aquatic site (as defined in subpart E) [i.e., wetlands] that does not require access or proximity to or sighting within the special aquatic site in question to fulfill its basic purpose (i.e., is not "water dependent"), practicable alternatives that do not involve special aquatic sites are presumed to be available, unless clearly demonstrated otherwise. In addition, where a discharge is proposed for a special aquatic site, all practicable alternatives to the proposed discharge which do not involve a discharge into a special aquatic site are presumed to

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have less adverse impact on the aquatic ecosystem, unless clearly demonstrated otherwise.”

Developing the selected project site will involve filling of existing wetlands (special aquatic sites) as described further in this report. However, the filling of wetlands is not necessary to fulfill the basic project purpose. The project is, therefore, not “water dependent” as defined under the CWA. The following analysis demonstrates that, while locating the project within a special aquatic site is not needed to fulfill the basic project purpose, there are no other available, practicable sites that meet the project criteria and have less adverse environmental impacts.

3.3 STEP 3: OVERALL PROJECT PURPOSE AND GEOGRAPHIC AREA SELECTION BHP considers the geographical area of selection to include marine ports along the Pacific Coast located no more than 1,400 rail miles from the Jansen Project, along the Pacific Coast of North America. At this distance, rail freight comprises a significant portion of the operating cost. Transporting the product distances greater than 1,400 miles for export would erode project value and impact the Jansen Project’s viability. Additionally, longer distances of rail transport would increase the train greenhouse gas emissions associated with the project.

Rail transportation represents a significant portion of the projected cost associated with getting potash to market. Distance affects the cost of rail transportation in at least two ways. First, the rates charged by rail service providers use distance as a key input because the cost of providing service is driven by the distance traveled. Second, distance affects train transit times, which in turn determines the number of rail cars that BHP would need to purchase to get its product to the export terminal economically.

BHP searched very broadly during their initial review of potential sites. BHP started by initially looking at potential sites located within 2,250 rail miles from the Jansen Project as an initial filter. As the evaluation of the project progressed and the cost and service implications of longer rail distances better understood, it became clear that a terminal located within approximately 1,400 miles of the project (the Pacific Northwest) is required for the project to be economically viable. The average ocean freight vessel travel from the Pacific Northwest is also the most economical considering some of the primary markets (China, India and Southeast Asia) to which the potash will be delivered. A Pacific Northwest (including Vancouver B.C.) site would also be the least environmentally impactful from an emissions perspective since it would be the closest location in terms of both rail and marine travel.

The distances from the Jansen Project to various ports in the United States and Canada are shown on Table 3. Only some of the Pacific Northwest and British Columbia ports are within 1,400 rail miles of the Jansen Project.

Great Lakes ports located within 1,400 miles of the Jansen Project were ruled out for the following reasons. Ports in the Great Lakes cannot accommodate the design

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vessel sizes and low temperatures and adverse weather in winter months would impede terminal operations and shipping. Additionally, the distance of shipment by vessels via the St. Lawrence River and Seaway to the East Coast and then to the required international markets would be considerably greater and more expensive than using a Pacific Coast port, making the project financially unviable.

Additionally, longer vessel travel distances would increase vessel greenhouse gas emissions associated with the project.

Table 3. Approximate Rail Distances Port Location Approximate Distance Pacific Northwest Bellingham, WA Tacoma, WA

Hoquiam, WA 1,200 – 1,400 miles Kalama, WA Longview, WA Vancouver, WA Portland, OR British Columbia Prince Rupert, BC 1,200 - 1,300 miles Vancouver, BC California Bay Area Oakland, CA 1,800 miles San Francisco, CA Southern California Long Beach, CA 2,100 - 2,200 miles San Diego, CA Gulf Coast 2,000 - 2,200 miles Northeast Coast 1,900 - 2,400 miles Mid-Atlantic Coast 1,900 - 2,000 miles Southeast Coast 2,300 - 2,800 miles

4.0 PHASE 2 - ALTERNATIVES IDENTIFICATION - STEP 4: POTENTIALLY PRACTICABLE CRITERIA IDENTIFICATION 40 C.F.R. 230.3(l) defines “practicable” as meaning “available and capable of being done after taking into consideration cost, existing technology, and logistics in light of overall project purposes.”

The following identifies and defines the practicability criteria used to evaluate alternatives for this project.

4.1.1 Availability A site the applicant owns is considered available. Under 40 C.F.R. 230.10(2), a site that the applicant does not own could also be considered available if it could

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“reasonably” be obtained or used. For this analysis, the criteria for availability includes the following.

• The site is marketed for sale or lease, and the site owner is willing to sell the site to BHP or enter into a long-term lease with BHP on commercially reasonable terms. • There are no legal disputes or contractual issues that create significant uncertainty about the ability to purchase, lease, or use the site. • Existing laws—such as the Federal Aviation Administration’s (FAA) regulations—do not prohibit construction of the proposed project on the site.

4.1.2 Cost Determining the cost associated with developing and operating a marine terminal at any particular site requires detailed analysis, considering multiple factors. Any such analysis is highly confidential and proprietary.

After analyzing various factors that can have significant implications on the costs of construction and operations, BHP has determined that the availability of two Class I rail carriers providing competitive service to the site is an essential practicability criterion, based both on its cost and logistics implications.2

The cost of rail transportation is a significant factor in determining the economic viability of the project. For this reason, rail distance, and the associated cost, was the primary rationale for defining the geographic scope of the alternatives analysis.

Whether or not two Class I rail carriers provide service to a site also has a significant impact on rail transportation cost. Although it is understood intuitively that competition is necessary for optimal pricing, BHP retained rail specialists to support the evaluation of the likely impact of competition on rail transportation costs. Evaluation of likely rail tariffs indicated that the cost implications may be significantly greater when only one Class I rail carrier serves a location, compared to a competitive environment with two or more carriers. This cost differential renders sites with only one Class I rail carrier impracticable.

Although a site must be served by two Class I railroads to be practicable, the railroads need not necessarily operate their own lines all the way to a site. The carriers may serve the site indirectly through a short-line rail service that provides competitive access. The entire trip is covered in the tariff negotiated with the Class I carrier when a Class I carrier has contracted with a short-line carrier to connect the site to the main line. In some instances, two Class I carriers operate near a site, but only one provides last-mile service. In those situations, the carrier providing last-mile service has a

2 Because the need for two Class I rail carriers has both a logistical and cost basis, it was originally included in the category of “Logistics” criteria. At the request of EPA, this discussion has been moved to the “Cost” section.

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monopoly position and exposes BHP to the significant costs described above, making the site impracticable.

4.1.3 Existing Technology Existing technology generally applies to construction equipment, methods, and materials. This criterion is defined for this analysis as follows.

• Construction methods will use proven technology and readily available equipment. • Materials for construction of the facility are readily available and proven suitable for the intended purpose.

4.1.4 Logistics Logistics includes criteria related to the specific infrastructure needs of the project. Logistics criteria for this project are focused on site size and vessel needs as described below.

• Competitive Rail Access – Service Redundancy Two rail carriers provides redundancy that is critical for a business that depends upon timely shipments and deliveries. The Jansen mine would have limited capacity for storage, so rail shipments must occur on a timely basis to maintain throughput, as production cannot easily be slowed. Having two available rail carriers ensures that service will continue even if one carrier faces physical, economic, or other constraints or is simply unwilling to serve the project at any time. • Site Size and Configuration The Jansen mine is expected to produce 4.3-4.5 Mtpa in Stage 1, expanding to approximately 8 Mtpa in Stage 2. The terminal site must be large enough to accommodate this level of throughput and provide enough storage to maintain continuous operations at the mine and associated rail delivery whether there is a ship available for loading or not. As a result, the terminal must be capable of continuous unloading of trains and loading of vessels at a rate of approximately 4,000 tons per hour.

Potash will be transported from the Jansen mine to the terminal by unit trains. Unit trains are the most efficient rail transportation method because all of the product on a unit train goes to a single destination and does not require stops at other facilities to offload cars carrying other materials. BHP’s planned unit trains will consist of 177 covered hopper-type rail cars with three to five locomotives. The rail loop turns must be designed to meet rail regulatory and Class I rail carrier design requirements for safe rail operations. The site must include a rail loop that is at least 8,500 feet long to accommodate the entire unit train with these parameters within the site. Potential safety, security, noise, and traffic issues could be created if the entire train could not be accommodated on site, resulting in a portion of the train extending off site.

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The facility would require access across more than 100 acres to accommodate the rail loop as described above in addition to the other needed structures and infrastructure.

• Deepwater Navigation Channel Access The site must have access to a navigable waterway with a minimum vessel draft of 11.5 meters (38 feet). This requirement is based on the size of vessels that the customers’ receiving ports can currently accommodate and projections of the vessel sizes that will be required in the future.

Table 4 shows the classes of vessels that would be used, depending on depth of the navigation channel and tidal assist at the selected site. This table also demonstrates the efficiencies gained in the volume shipped and the loading times as the vessel size and draft increases with Supramax (with 38-foot laden draft) and Ultramax (with 44-foot laden draft) vessels providing the most per hour volume efficiency at berth. BHP has specified the larger vessel classes in their ship distribution because of present or future ship- type availability and potential freight cost advantages when ship supply now and in the future is considered. Vessels with draft greater than the minimum 38 feet could still be used if vessel departures are timed with the tides and vessels are not fully loaded.

Table 4. Example Export Vessel Class Characteristics Vessel Class Length (ft) Draft Fully Laden (ft) Potash Load Duration at Capacity (tons) Berth1 (h) Handysize 558 32 19,000 14 Handymax 617 38 33,250 19 Supramax 657 38 51,853 26 Ultramax 656 44 50,186 25 Kamsarmax 751 49 54,437 28 1 Includes time for mooring, loading, hatch changes, trimming, and unmooring. Does not include any delays (e.g., weather) at berth.

4.2 CRITERIA SUMMARY Table 5 summarizes the availability, cost, existing technology, and logistics criteria described above. All criteria must be met for an alternative to be considered practicable.

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Table 5. Practicability Criteria Summary The applicant is able to acquire or lease the site or has a terminals services agreement on commercially reasonable terms. There are no legal disputes or contractual issues that create significant uncertainty Availability about the ability to purchase, lease, or use the site. Existing laws, such as FAA regulations, do not prohibit construction of the proposed facility. Two or more Class I rail carriers can provide competitive service to the site directly Cost or indirectly via short line rail service. Construction methods will use proven technology and readily available equipment. Existing Technology Materials for construction of the facility are readily available and proven suitable for the intended purpose The site must provide access to over 100 acres and be configured to accommodate an 8,500-foot-long rail loop. The site must have access to a deepwater navigation channel with a minimum vessel draft of 38 feet (11.5 meters). Logistics The site must provide a level of service required to support the movement of export volumes without impacting the mine production though inefficient logistics (water, rail, terminal). Service redundancy provided by the availability of two or more rail carriers to maintain service when a single provider is physically unable to provide the service given terrain, climate, distance, etc.

4.3 POTENTIALLY PRACTICABLE ALTERNATIVES IDENTIFICATION BHP undertook an extensive investigation to identify sites that might satisfy the practicability criteria with the assistance of consultants at Westmar Project Advisors. The investigation considered numerous ports located in British Columbia and in the Pacific Northwest. The information in this analysis is based on an identification phase study completed from 2014 to 2016 in order to select terminal options that could gate into a Selection Phase Study for BHP.

The ports of Kalama, Washington; Portland, Oregon; Prince Rupert, British Columbia; and Seattle, Washington were not advertising any available terminal sites, and no available site could be identified.

Nine potential alternatives were identified in the geographic region (Sheets 1 and 2). This analysis evaluates those alternatives, as well as the No Federal Action Alternative. The alternatives evaluated include the following.

• Alternative A - Port of Grays Harbor Terminal 3 (Sheet 3) • Alternative A1 - Port of Grays Harbor Terminal 3, Alternative Configuration (Proposed Project, Sheet 4) • Alternative B - Port of Tacoma SSA Marine (SSA)/Marine View Ventures (MVV) (Sheet 5) • Alternative C - Port of Longview Barlow Point (Sheet 6) • Alternative D - Port of Longview Berth 2 (Sheet 7)

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• Alternative E - Port of Vancouver, Washington Terminal 5 (Sheet 8) • Alternative F - Fraser Surrey Docks, Vancouver B.C. (Sheet 9) • Alternative G – Kinder Morgan Terminals, Vancouver Wharves. (Sheet 10) • Alternative H - No Federal Action

5.0 PHASE 3 - PRACTICABILITY EVALUATION The nine potentially practicable alternatives included in the practicability evaluation are shown on Sheets 3 through 11.

Site conditions for the potentially practicable sites and the no action alternative are described below with respect to practicability criteria defined in Section 4.

5.1 ALTERNATIVE A: PORT OF GRAYS HARBOR TERMINAL 3 The existing Port of Grays Harbor Terminal 3 facility and adjacent parcels are located on the north shoreline of Grays Harbor in Hoquiam, Washington. The site is located on the southeast corner of State Route 109/West Emerson Avenue and Paulson Road in the city of Hoquiam, in Township 17 North, Section 10, and Range 9 West north of the Willamette Meridian. The site is adjacent to the Grays Harbor National Wildlife Refuge and approximately 2,000 feet east of Bowerman Field airport as shown on Sheets 1 and 3.

The site consists of multiple parcels3 owned by the Port of Grays Harbor, the City of Hoquiam, and private landowners, totaling approximately 200 acres.

The site was a historical tideflat that was filled during the early twentieth century with dredged material from the Chehalis River and Grays Harbor. The northeast corner of the site was developed and used as a machinery manufacturing facility for pulp and paper equipment from 1971 through 2001. The central and west areas of the site were historically used as a log yard and log export facility by Rayonier Grays Harbor from 1981 through 1999. The Port purchased the site from Rayonier in 1999.

The southeast upland portion of the site and the existing Terminal 3 dock are currently used by Willis Industries, a wood chip facility. The City parcel on the southwest upland corner of the site is occupied by the City’s former wastewater lagoon. The City is currently filling the lagoon with dredged material from the Chehalis River and Grays Harbor, landslide materials, and excess soil from other local projects. The northeast upland corner of the site (also known as the Emerson/Adams property) is occupied by a whiskey distillery. The remaining upland

3 The project site is located on portions of tax parcels (056401000102, 517100331005, 517100331007, 056401000101, 056401000102, 517101021001, 517101012001, 517101011001, 056401000600, 517101011004, 056401000501, 056401000801, 056401000400, 056401000301, 056401000201, 056401100204, 056401100202, 056401100100, 056401000302, and 056401100203) located in portions of Sections 3 and 10, Township 17 North, Range 10 West of the Willamette Meridian.

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areas within the site have been cleared of vegetation in the past and are unused or undeveloped.

Approximately 47 acres of wetlands, not including buffer areas, are present on the northern and eastern portion of the site.

The City’s zoning for the site is “Industrial,” the Comprehensive Plan designation is “Industrial District,” and Shoreline Master Program designation is “High Intensity.” The proposed uses are generally consistent with these designations. A variance for the height of some facilities would be required, but the project proposal is expected to satisfy City requirements for such a variance.

The preliminary conceptual layout used in this analysis is shown in Sheet 3.

The FAA-regulated approach and transitional surfaces for Bowerman Field airport’s runway are located directly above the proposed project site. Structure heights are subject to FAA-regulated airspace conditions. The approach surface ranges from approximately Elevation 60 feet to 120 feet mean sea level (MSL) and extends over the south and east portions of the site as shown on Sheet 3. The FAA transitional surface extends to the north and south of the approach surface and ranges from approximately Elevation 100 feet to 167 feet MSL and extends over the proposed facility berth and the north portion of the site as shown on Sheet 3. The FAA does not allow any penetrations of the runway approach or transitional surfaces except in very limited circumstances.

5.1.1 Site Availability BHP has negotiated acceptable lease terms for the required terminal lease and access, and expects to enter into an option to lease in the near term, subject to the appropriate approvals from all parties.

The zoning of the site is not expected to prevent development of the proposed terminal at the site4; however, the FAA airspace restriction associated with Bowerman Field airport prohibits this alternative’s layout of the product storage building in the center of the site oriented on a north/south axis. The storage building must be a minimum of 141.5 feet high to accommodate the conveyor system, other required equipment, and the volume of product storage needed based on the throughput from the mine when fully operational. The building would penetrate FAA- regulated approach surface (ranging from approximately Elevation 75 feet MSL to 85 feet MSL in that area) and portions of the FAA-regulated transition surface (ranging from approximately elevation 95 feet MSL to 167 feet MSL in that area) in the proposed layout of Alternative A.

4 A shoreline variance has been requested from the City of Hoquiam to accommodate the construction of the rail loop and the storage building on the north and northwest portions of the site.

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The configuration proposed in this alternative fails the legal restriction criterion because FAA airspace restrictions would not allow the proposed placement of the storage building.

5.1.2 Cost The site satisfies the rail service criteria described above. Two Class I railroads, BNSF Railway and the Union Pacific Railroad (UPRR), provide service to Centralia, Washington, located approximately 60 miles from the site. The Puget Sound and Pacific Railroad (PSAP) is the short line carrier that transports trains from both carriers to the Port of Grays Harbor. The PSAP traverses the northern boundary of the site and has competitive access to the site. An existing spur would be extended onto the project site.

5.1.3 Existing Technology Construction of a new ship-loading structure can be accommodated at the in-water portion of the site. The structure can be built with existing technology using typical pile-supported construction methods. Dredging approximately 110,000 cubic yards will be required to expand the existing berth (from Terminal 3 westward) to achieve the required berth depth. Construction of the facility would not require any unusual or unproven technology.

The site meets the existing technology criterion.

5.1.4 Logistics The approximately 250-acre site meets the minimum criterion of 100 acres and can accommodate the 8,500-foot rail loop.

The site meets the deep-water navigation criterion because it has access to the Grays Harbor Federal Navigation Channel, which accommodates a vessel draft of 38 feet.

The site meets the service redundancy by having dual rail carrier access.

5.1.5 Conclusion Alternative A is not practicable because it is not available because of FAA regulations that prohibit the proposed location of the storage building.

5.2 ALTERNATIVE A1: GRAYS HARBOR TERMINAL 3 ALTERNATIVE LAYOUT Alternative A1 (Sheet 4) utilizes the same site as Alternative A but has reconfigured the proposed facility. It would locate the product storage building in the northwest portion of the site, oriented approximately east/west so that the building height (minimum of 141.5 feet tall at the apex) would not exceed FAA height restrictions (Elevation 167 feet MSL) at this location.

The entrance into the site and the rail overpass would be located in the southeastern corner of the site under this alternative. The rail loop and railcar unloading system would be in the same locations as in Alternative A, but the arrangement of the conveyor system would be modified to accommodate the orientation of the storage

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building and minimize wetland impacts to the extent practicable. The location of the marine terminal and berth would be identical to that which is proposed in Alternative A. The configuration of the overwater conveyance was changed slightly by adding a wharf conveyance extending to the west side of the shiploader in order to shorten the shiploader towers to an elevation that meets the FAA transitional surface elevation requirements (below elevations ranging from approximately 100 feet to 140 feet MSL).

The configuration proposed in Alternative A1 would therefore satisfy the availability criteria. It would also satisfy all other criteria in the same manner as Alternative A.

5.2.1 Conclusion Alternative A1 satisfies all criteria and is considered a practicable alternative.

5.3 ALTERNATIVE B: PORT OF TACOMA SSA/MVV SITE Alternative B: Port of Tacoma SSA SSA/MVV site is located on the Blair-Hylebos Peninsula in the Port of Tacoma, Washington.5 The site is located within an industrial area on the shores of Commencement Bay in Puget Sound on the east side of the Blair Waterway (Sheet 5).

The site has historically been an active industrial area. The site consists of four parcels: one formerly owned by SSA (currently owned by DCT), one owned by the Port of Tacoma (Wypenn), and two (the Blair Backup and the Blair Waterway properties) held in trust for the Puyallup Tribe.

The City of Tacoma identifies eight wetlands across all four parcels on the project site totaling approximately 16.8 acres, not including buffer areas. Roughly 2,500 feet of drainages traverse the site.

The City of Tacoma’s zoning for the site is “Port Maritime and Industrial,” and the proposed uses are consistent with these designations.

5.3.1 Site Availability BHP investigated the ability to lease the site parcels and ultimately concluded that it was not available on commercially acceptable terms, because SSA entered into a selling process during the time BHP was completing its analysis on this property. The sale of this property to an entity not interested in a bulk terminal for potash 6 would preclude the development of the rail loop and potash storage building. It is now known that the parcel was sold to DCT Industrial who developed a 1.2-million- square-foot industrial facility on the subject property.

5 The Port of Tacoma SSA/MVV site is located on portions of Tax Parcels 5000350190 (Blair Backup - Tribe), 0321355005 (SSA), 5000350090 (Blair Waterway - Tribe), and 0321362056 (Wypenn).

6 DCT Blair Logistics Center MDNS. http://tacomapermits.org/wp-content/uploads/2013/06/LU16-0092-MDNS- Decision.pdf

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5.3.2 Cost The site satisfies the rail service criteria described above. Two Class I railroads, BNSF Railway and the Union Pacific Railroad (UPRR), provide service to Port of Tacoma interchange yards. The Tacoma Rail Railroad is the short line carrier that transports trains from both carriers into the Port of Tacoma. Tacoma Rail currently traverses the southern boundary of the site along Alexander Avenue and the northern boundary along Taylor Way. An existing spur would have to be extended onto the project site either through a grade separation on Alexander Avenue or Taylor Way. Alexander Avenue access to the site would require unit train traffic to pass through an existing container terminal (Pierce County Terminal), which would require an extensive grade separation to accommodate mobile equipment container transfers and container truck traffic across Alexander Avenue rail tracks. Currently, because the container terminal closes off these tracks during operations, access to the intermodal supplementary yard requires travelling across Alexander Avenue.

5.3.3 Existing Technology The site satisfies the technology criterion. Construction of a new shiploading structure can be accommodated at the in-water portion of the site. The structures can be built with existing technology using typical pile-supported construction methods. Dredging will be required to expand the existing berth to achieve the required berth depth. Construction of the facility or grade separations for rail access would not require any unusual or unproven technology.

5.3.4 Logistics This alternative does not meet the size and configuration criterion after the sale of the SSA parcel of land. The site configuration after DCT Industrial’s sale and development plan would not accommodate the required 8,500-foot-long rail loop. The facility layout, due to the MVV “X” shape parcel leftover7 after the removal of the SSA parcel, would require breaking the trains into sections for unloading, causing efficiency and safety concerns and adding operational complexity and risk for all operating parties involved including the Port of Tacoma rail and road networks.

The site meets the navigation criterion. The site is located on the east side of the Blair Waterway and has direct access to the Blair Waterway Navigation Channel, which accommodates a vessel draft of 51 feet. Dredging would be required to lengthen the berth along the east shoreline to accommodate the design vessel sizes.

This alternative meets the service redundancy requirement because it has dual rail access to the site.

5.3.5 Conclusion Alternative B: Port of Tacoma SSA/MVV is not considered practicable because it does not meet the availability and size and configuration criteria because of risks associated with securing lease/ownership and the sale of the SSA parcel to DCT

7 Note that Sheet 5 shows the proposed facility layout as it would be placed if all Alternative B parcels were available. Ensure formatting is justified

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Industrial, as that portion of land was required to support the overall rail and infrastructure layouts.

5.4 ALTERNATIVE C: PORT OF LONGVIEW BARLOW POINT SITE Alternative C: Port of Longview Barlow Point is located within an industrial corridor along the Columbia River in the southwestern portion of the city of Longview in Cowlitz County, Washington. The site consists of four parcels located on the north shoreline of the Columbia River (Sheet 6).8

The Port of Longview purchased the 275‐acre Barlow Point properties in October 2010 at a trustee sale. Terra Firma, Inc. previously owned the site, which was the site of Longview Motocross. Historical uses of the site generally consisted of agricultural activities, such as farming and grazing. Portions of the site were used as a motocross racetrack and sand drag strip in recent years. Since purchasing the land, the Port has contracted with a farmer to plant and harvest hay on approximately 80 acres of the site.

The Barlow Point site is located on an historic floodplain of the Columbia River. National Wetland Inventory (NWI) mapping for the Barlow Point site identifies portions of six wetland polygons on the Barlow Point site with five of these wetlands extending onto portions of the proposed site. According to the NWI map, approximately 45 acres of wetland overlap the site.

5.4.1 Site Availability The Barlow Point Site was not being marketed for sale or lease at the time BHP evaluated alternatives and decided to pursue the Port of Grays Harbor site. There was also active litigation concerning the ownership of the waterfront portion of the site. It would have been impossible for BHP to enter into a binding agreement to secure long-term use of the site without legal certainty regarding the legal owner of the site. The facility would require construction on and over the existing levee at the site. Alternative C does not satisfy the availability criterion based on this information.

5.4.2 Cost Two Class I rail carriers (BNSF and UPRR) provide main line service to Longview Junction near the site. The Longview Switching Company (which is owned 50/50 by BNSF and UPRR) has rights to provide service over a spur lined owned by BNSF called the Reynolds Lead. The Reynolds Lead runs into the Port of Longview but terminates before reaching the Barlow Point site. BNSF owns the right of way between the end of the Reynolds Lead and Barlow Point, so BNSF could decide to extend its track to the Barlow Point site. If it did so, BNSF would likely be the only Class I carrier able to provide last mile access to the site. Alternative C fails the competitive rail criterion based on these details.

8 The project site is located on portions of Tax Parcels 106990100, 106980100, 106970100, and 107090100.

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5.4.3 Existing Technology Construction of a site, rail, and shiploading structures can likely be accommodated at the site. The structures can be built with existing technology using typical pile- supported construction methods. Dredging would be required to construct the berth and to achieve the required berth depth. Construction of the facility would not require any unusual or unproven technology. This site meets the existing technology criterion.

5.4.4 Logistics This site satisfies the size criterion. It consists of approximately 275 acres, and its shape would accommodate the required rail loop.

The site meets the navigation criterion. The site is located on the north shoreline of the Columbia River and is adjacent to the Columbia River Federal Navigation Channel. There are no existing deep-draft berths at the site. Dredging would be required to provide adequate draft for the project.

This site does not provide the service redundancy of competitive rail access.

5.4.5 Conclusion This alternative is not practicable because the site was not available at the time of BHP’s evaluation and does not meet the competitive rail service criterion.

5.5 ALTERNATIVE D: PORT OF LONGVIEW BERTH 2 SITE The Alternative D: Port of Longview Berth 2 site is located within the Port of Longview’s Port Industrial Marine Property. The site is approximately 150 acres (Sheet 7) but consists of several parcels that are not contiguous and therefore does not meet size requirements. Existing facilities are interspersed within vacant parcels at the site. The site is bounded to the south by the Columbia River, to the west by Port Way, to the north by the Port’s lead track, and to the east by the Longview Export Grain Terminal.

The properties comprising the Port of Longview Berth 2 site have been purchased over the years by the Port of Longview beginning in 1929. The site is developed and does not contain wetlands. The site has historically been used for port and industrial activities. Current land use activities include warehousing, cargo transfer, cargo laydown, log storage, sawmills, grain elevators, and other similar activities. The project site has three developed berths along the Columbia River (Berths 1, 2, and 4).

The City’s zoning for the site is “Heavy Industrial” and the County’s designation is “Heavy Manufacturing.” The proposed uses are consistent with these designations.

5.5.1 Site Availability The Alternative D site consists of brownfield private and Port-owned land. For purposes of this analysis, it is assumed to be available for sale or lease.

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The Port is currently leasing the dock portion of the site to International Raw Materials (IRM). The initial lease term expires in 2022; however, there are extension options available to the current tenant.

5.5.2 Cost The cost of this alternative is expected to be comparable to Alternatives A1, B, and E.

This alternative meets the rail service criterion. Both BNSF and UPRR serve Berth 2 at the Port of Longview via an Industrial Rail Corridor. Both BNSF and UPRR deliver traffic to Longview Switching Company at Longview Junction, and LSC switches UPRR and BNSF trains into the Port of Longview via the Reynolds Lead. The Industrial Rail Corridor then diverges from the Reynold Lead and continues on to Berth 2.

5.5.3 Existing Technology This alternative meets the technology requirements. Construction of the facility would not require any unusual or unproven technology.

5.5.4 Logistics This alternative does not meet the size and configuration criterion. Although the combination of parcels provides sufficient total acreage, the site configuration would not accommodate the required 8,500-foot-long rail loop. The facility layout would be scattered across several parcels because other operations are blocking access; this would require conveyors to cross over these operations, and breaking the trains into sections for unloading would cause efficiency and safety concerns and add operational complexity and risk for all operating parties involved.

This alternative meets the deepwater navigation channel access criterion. The site is located on the Columbia River and is adjacent to the Federal Navigation Channel. The Port of Longview maintains the existing deep-draft berths. Berth 2 is used for agriproducts, chemicals, and minerals. It is 850 feet in length and can accommodate a vessel draft of 43 feet.

This site meets the service redundancy requirement because it has competitive rail access to the site.

5.5.5 Conclusion This alternative is not considered practicable because it does not meet the size and configuration criterion.

5.6 ALTERNATIVE E: PORT OF VANCOUVER, WASHINGTON TERMINAL 5 Alternative E: Port of Vancouver Terminal 5 site is located at 5701 Northwest Lower River Road in the city of Vancouver, Washington. The site is located approximately 3 miles (4.8 km) northwest of downtown Vancouver, Washington, and is composed of submerged, tidal, nearshore, and upland lands (Sheet 8).

The site is located along a 2,300-foot-long section of shoreline owned by Port of Vancouver on the north bank of the Columbia River across from Hayden Island,

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centered at approximately River Mile 103.3. The site has been in heavy industrial use since the 1940s. The site was historically used for aluminum smelting, as well as for the fabrication and outdoor storage of aluminum ingots. The aluminum facilities have been removed with the exception of the dock and crane that was used to offload raw materials. It is currently developed with a rail loop and is used for laydown and material storage.

The Port of Vancouver, for the BHP potash development, permitted this site and worked to achieve an acceptable commercial outcome for the proposed project between 2010 and 2014. At that time, the site was used for storage of large windmill components.

The Port of Vancouver has a Port Management Agreement with the Washington State Department of Natural Resources (DNR) for the submerged aquatic lands at the site. All of the shoreline is within the jurisdiction of the City of Vancouver under the City‘s Shoreline Management Master Program. There are no wetlands on the upland portion of the site. The designation for this area is Urban High Intensity, and the area is zoned as Heavy Industrial.

5.6.1 Site Availability Alternative E met the site availability criterion at the time it was evaluated.

Alternative E site consisted of Port of Vancouver-owned land at the time of consideration (2010 to 2014) and was available for lease during that period. The zoning and Shoreline Management Master Program allowed for the proposed use.

5.6.2 Cost The cost of this alternative is expected to be less than other alternatives because of the extent of existing rail infrastructure and presence of adequate water depth for the new berth (i.e., no dredging would be required), though a new dock would be required.

This alternative does not meet the rail access criterion because it does not having competitive rail service to the site.

5.6.3 Existing Technology This alternative meets the technology criterion. Construction of the facility would not require any unusual or unproven technology.

5.6.4 Logistics This alternative meets the size and configuration criterion. The site can accommodate the required 8,500-foot-long unit train with the existing rail loop at the site.

This alternative meets the deepwater navigation channel-access criterion. The site is located on the Columbia River and is adjacent to the Federal Navigation Channel. the Port of Vancouver maintains the existing deep-draft berths. The existing berth at Terminal 5 is approximately 450 feet in length and has access to the USACE deep- draft Columbia River channel, maintained at a draft of 43 feet. A new dock would be required, but additional dredging would not be needed.

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This alternative does not meet the rail access criterion. Only one Class I carrier, BNSF, provides service to the site. Commercial negotiations to achieve competitive rail service to the site progressed for four years at which point BHP concluded that an agreement would not be achieved. This alternative does not provide service redundancy required due to not having competitive rail access at the site.

5.6.5 Conclusion Alternative E is not practicable because it does not meet the competitive rail service criterion.

5.7 ALTERNATIVE F: FRASER SURREY DOCKS, VANCOUVER, B.C. Alternative F: Fraser Surrey Docks (FSD) is an active port terminal with 156 acres of yard area and seven berths located at 11060 Elevator Road in Surrey, BC, opposite the northern end of Annacis Island and adjacent to the South Westminster Heights residential neighborhood (Sheet 9). The FSD site is located in an industrial area adjacent to Highway 17 (South Fraser Perimeter Road) and is located entirely on federal lands within the jurisdiction of the Vancouver Fraser Port Authority (VFPA). Under the Canada Marine Act, SC 1998, c. 10, the VFPA is responsible for the administration, management, and control of land and water within its jurisdiction.

Situated on the south shore of the Fraser River’s Main Arm, the site has been an industrial port facility since the early 1930s. Land use west of Highway 17 is designated as industrial, and east of the highway is designated for residential, institutional, and park use. There are no identified wetlands on the site. A parcel of this site has been designated by Environment and Climate Change Canada as critical habitat for the streambank lupine, a species at risk.

5.7.1 Site Availability The FSD site is not commercially available to BHP at this time. FSD was identified by BHP as a potential terminal location in 2015. At that time, BHP began a detailed study of the commercial, permitting, construction, and operational aspects of this site. Through this study, BHP explored commercial arrangements and began the permitting process with the VFPA. Despite considerable efforts, it has not been possible to secure the site on terms that support the sanction of the Jansen project. While likelihood of success is considered to be low, BHP will continue exploring opportunities for commercial access at FSD for as long as the Jansen project execution schedule will allow. FSD cannot be considered a practicable alternative available to BHP in the absence of such commercial access arrangements. Further details are confidential and subject to binding non-disclosure agreements.

5.7.2 Cost The cost of constructing a facility at this location is expected to be comparable to the other sites considered.

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The site satisfies the rail criterion as FSD is accessed directly by Canadian National (CN) and via regulated interswitching9 by Canadian Pacific (CP).

5.7.3 Existing Technology This alternative meets the technology criterion. Construction of the facility would not require any unusual or unproven technology.

5.7.4 Logistics The site satisfies the size and configuration criterion as the facilities and rail loop can be configured to fit on the 156-acre site.

The site satisfies the deep-water navigation channel criterion. The Fraser River Channel can accommodate a vessel draft of approximately 38 feet based on the ability to transit the channel on at least one high tide cycle per day, the resulting limitations on operations makes the site less desirable but still feasible. The shorter rail distance to this site offsets the reduced guaranteed vessel draft in project economics.

This site meets the service redundancy requirement because it has competitive rail access.

5.7.5 Conclusion Alternative F is not practicable because it is does not meet the availability criteria.

5.8 ALTERNATIVE G: KINDER MORGAN TERMINALS, VANCOUVER WHARVES. Alternative G: Kinder Morgan Terminals, Vancouver Wharves is a 125-acre bulk marine terminal located east of the Lions Gate Bridge on the north shore of Burrard Inlet in Greater Vancouver’s Port Metro Vancouver (Sheet 11). The facility has been in operation since 1959 and consists of four vessel berths and rail infrastructure, dry bulk and liquid storage, and material handling systems. Kinder Morgan Canada Terminals has a long-term lease on the property. There are no identified wetlands on the site.

5.8.1 Site Availability This site is leased from British Columbia Railway Company and operated by Kinder Morgan; however, it is unclear whether BHP could gain access to the facility on commercially reasonable terms. At the time of the study, KMVW was unable to offer the capacity to handle more than 2.5 Mtpa of potash for BHP, which did not support the Jansen project.

5.8.2 Cost The cost of constructing a facility at this location is expected to be comparable to the other sites considered.

9 Regulated interswitching requires a railway that has sole access to a shipper’s facility to deliver traffic from that facility to an interchange with a second railway that is within 30 km, at a rate determined by the Canadian Transportation Agency

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The site satisfies the rail criterion, with CN and CP providing competitive rail service via regulated interswitching.

5.8.3 Existing Technology Construction is possible with existing technology.

5.8.4 Logistics This site currently has a small loop track designed for unloading of 110 rail cars. Kinder Morgan has the ability to add an additional track within the site that will allow for the 177-railcar unit train. Therefore, this site satisfies the size and configuration criterion.

The site satisfies the deep-water navigational channel criterion. The channel is at least 42.6 feet (13 meters) deep.

At the time of the study only 2.5 Mtpa of potash handling capacity was available to BHP, which does not meet the throughput needs of the proposed BHP project.

This site satisfies the service redundancy criteria because it has competitive rail service to the site.

5.8.5 Conclusion Alternative G was deemed not practicable. It failed the logistics size/configuration criterion because the terminal did not have enough available capacity to accommodate start up or full operational throughput of the proposed potash export facility.

5.9 ALTERNATIVE H: NO FEDERAL ACTION ALTERNATIVE Alternative H is the No Federal Action Alternative; there is no site to evaluate relative to the project-specific practicability criteria. The No Action Alternative does not meet the project need and purpose and is considered not practicable.

5.10 PRACTICABILITY ANALYSIS RESULTS SUMMARY The practicability analysis results determined that only Alternative A1 at the Port of Grays Harbor is considered a practicable alternative for the proposed facility. Alternative A1 is, therefore, the LEDPA. Table 6 provides a summary of the practicability analysis results.

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Table 6. Alternatives Practicability Analysis Summary Alternative A Port Alternative A1 Port Alternative B Port Alternative E Alternative G Alternative C Port of Alternative D Port Alternative F Screening of Grays of Grays Harbor of Tacoma Port of Vancouver Kinder Morgan, Longview Barlow Point of Longview Berth 2 Fraser Surrey Docks Criteria Harbor Terminal 3 Terminal 3 SSA/MVV Terminal 5 Vancouver Wharves Meets Availability Does Not Meet Criteria Does Not Meet Criteria Does Not Meet Criterion Criterion BHP identified risk BHP identified unacceptable Availability/ Does not meet Other Meets Criterion associated with risk associated with securing Meets Criterion Meets Criterion The site is not available Does Not Meet Criterion Zoning/Other Restrictions criterion securing lease/ lease/ownership agreements to based on BHP’s Restrictions because of height ownership agreements waterfront negotiations with the restrictions current owner. Does Not Meet Criterion because only BNSF Does Not Meet Meets Criterion Meets Criterion Cost: Rail Service Meets Criterion Meets Criterion Meets Criterion has access to the right-of-way Meets Criterion Criterion; only BNSF to extend rail service to the site has access to the site Existing Meets Criterion Meets Criterion Meets Criterion Meets Criterion Meets Criterion Meets Criterion Meets Criterion Meets Criterion Technology Logistics: Dual Does Not Meet Meets Criterion Meets Criterion Meets Criterion Does Not Meet Criterion Meets Criterion Meets Criterion Meets Criterion Rail Access Criterion Logistics: Site Does Not Meet Does Not Meet Does Not Meet Criterion Size and Meets Criterion Meets Criterion Criterion because of Meets Criterion Criterion because of Meets Criterion Meets Criterion because of the lack of capacity Configuration site configuration site configuration for project purpose and need. Logistics: Deepwater Meets Criterion Meets Criterion Meets Criterion Meets Criterion Meets Criterion Meets Criterion Meets Criterion Meets Criterion Navigation Channel Access Green indicates highly desired qualities present. Red indicates that sites provide inadequate features (e.g., lacking competitive rail or sufficient contiguous space for unit train length of rail) or have restrictions that make the alternative not practicable.

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6.0 PHASE 4: ENVIRONMENTAL ANALYSIS Phase 4 of the Alternatives Analysis is to (1) compare impacts to waters of the United States across all practicable alternatives and (2) determine if the practicable alternatives cause other significant effects.

The practicability analysis identified Alternative A1, Grays Harbor Terminal 3 On- site Alternative (Sheet 4) as the only practicable alternative. The facility site layout was originally designed to avoid wetland impacts as much as possible by placing the storage warehouse in a more central location at the site as noted previously. This original layout (Alternative A, Sheet 3) was designed before the extent of the FAA- restricted airspace at the site was fully understood. The layout was required to change to the Alternative A1 layout (Sheet 4) when the extent of the FAA restrictions (including those associated with visual and instrument-aided air navigation) were fully understood. Alternative A1 represents the best and only layout for the Terminal 3 site based on operational constraints and site restrictions (e.g., FAA airspace) and minimizes environmental impacts to the extent practicable. This section provides a comparison of the impacts associated with the two on-site alternatives (Alternatives A and A1, Sheets 3 and 4, respectively), to document the relative difference in impacts between the two alternatives as previously requested by the agencies. The environmental analysis below also addresses mitigation sequencing and describes the proposed mitigation for the environmental impacts associated with Alternative A1 (Sheet 4).

6.1 ALTERNATIVES A AND A1 IMPACTS SUMMARY AND COMPARISON Table 7 below provides a comparison of the impacts to wetlands and aquatic habitats, as well as to associated buffers, from both the initial site layout (Alternative A) and the proposed project revised alternative site layout (Alternative A1, Sheet 4).

Table 7. Alternatives A and A1 Impacts Comparison Wetland Impacts Aquatic Impacts Wetland Shoreline Alternative Benthic Overwater Dredging Direct Indirect Temporary Buffer Buffer Impacts Coverage Alternative 7.09 17.59 0.00 acre 4.39 acres 1.06 acres 2,502 sf 48,114 sf 110,000 A acres acres (solid) cubic yards 4,279 sf 7.49 acres (Initial Site (grated) Layout) Alternative 18.32 20.74 0.00 acre* 12.27 acres 2.68 acres 2,502 sf 48,114 sf 110,000 A1 acres* acres (solid) cubic yards 4,279 sf 7.49 acres (Proposed (grated) Project: Revised Alternative) *Excludes 0.20 acres of direct impact and 23.96 acres of temporary wetland impact that would occur as part of off-site compensatory mitigation construction.

The initial layout of the site at the Port of Grays Harbor Terminal 3 site (Alternative A, Sheet 3) would have resulted in approximately 11.23 acres less of a permanent direct wetland impact than the revised alternative layout (Alternative A1, proposed project, Sheet 4). The original layout of the storage building in the central

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developed portion of the site would have reduced the direct impacts to the wetlands in the northern portion of the site. The location and orientation of the building on the site also allowed the conveyors to be sited in a location that would have resulted in less direct wetland impact.

Alternatives A and A1 would result in comparable amounts of indirect wetland impact, though the Alternative A initial layout would have resulted in approximately 3.15 acres less of an indirect impact that the revised Alternative A1 layout (proposed project). The majority of the indirect wetland impacts are the result of the rail loop and the unloading facility, and these features are similar in size and configuration under both the Alternatives A and A1 layouts.

Neither alternative would result in temporary wetland impacts to construct the facility or associated infrastructure at the site. As described in the mitigation plan for the project (BergerABAM 2018b), the construction of the compensatory wetland mitigation under Alternative A1 would result in approximately 23.96 acres of temporary wetland impacts, which would be fully offset upon completion of the proposed improvements at the site.

Alternative A would have resulted in approximately 4.39 acres of wetland buffer impacts, compared to approximately 12.27 acres of wetland buffer impact associated with Alternative A1. This difference is largely the result of the location of the storage building. The initial layout in Alternative A would have avoided areas of wetland buffer in the northern portion of the site but the FAA height restrictions (as noted in Section 5.1.1) required that the product storage building be moved to the north portion of the site for Alternative A1 (proposed project, Sheet 4). These wetland areas could not be avoided in the Alternative A1 layout (proposed project, Sheet 4).

Alternatives A and A1 would both use the same shiploader and berth design and configuration. Impacts associated with the shiploader and berth would be equivalent under both alternatives.

As described previously, the initial layout of the site depicted in Alternative A was developed to avoid and minimize impacts to wetlands and aquatic habitats to the extent practicable. The Alternative A (Sheet 3) site layout was determined to be impracticable because of the FAA height restrictions, and the Alternative A1 layout (Sheet 4) was subsequently developed as the least environmentally damaging practicable alternative layout of the project at the site.

6.2 ALTERNATIVE A1 ENVIRONMENTAL ANALYSIS This section describes the environmental impacts associated with Alternative A1 (proposed project, Sheet 4) in detail, including the baseline condition of the wetlands and aquatic resources at the project site, the mitigation sequencing process that was implemented to avoid and minimize impacts, and the compensatory mitigation that has been proposed to offset the unavoidable impacts from the project.

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A mitigation sequencing process has been applied throughout the design of the project, consistent with federal, state, and local regulatory guidance. This mitigation sequencing process consists of a sequence of steps that begins with avoiding impacts to the extent practicable, minimizing and/or rectifying unavoidable impacts, and finally compensating to offset unavoidable impacts. The project has been designed to avoid and minimize impacts to aquatic resources and other sensitive habitat features to the greatest extent practicable.

While impacts to wetlands and other aquatic resources have been avoided and minimized to the extent practicable, the project will result in unavoidable impacts. These impacts are described in detail below.

6.2.1 Existing Wetland and Aquatic Habitat Conditions Wetlands Wetlands provide a variety of important water quality and hydrologic functions. Wetlands can also provide a significant wildlife habitat function for a variety of aquatic, terrestrial, and avian species. The size and condition of the wetland, its hydrologic regime, species composition, and its position on the landscape and surrounding land uses (among other factors) influence the degree to which a given wetland provides these functions.

Most of the project site consisted of open water, tidally influenced mudflats, and the estuarine habitats of Grays Harbor prior to development. The project site has been filled over the course of the last 75 years to create the upland waterfront that is present today. The fill placed at the site over the last several decades has significantly altered the hydrology at the site, nearly eliminating tidal influence and hydrologic connectivity between the wetlands on site and the bay. These activities also resulted in a significant reduction in the quantity and quality of wetland habitats in the vicinity. However, the project site supports wetland habitats, including forested, emergent/scrub-shrub, and estuarine wetlands. These wetlands provide forage, cover, breeding and rearing, and migratory habitat for a variety of species, including fish, birds, small mammals, deer, coyote, and various amphibians.

A wetland delineation was completed at the site in June 2018 (BergerABAM 2018a). The results of this wetland delineation identified the presence of three wetlands at the project site. These wetlands are briefly described below, and a more detailed discussion of wetlands at the site can be found in the wetland delineation report (BergerABAM 2018a).

Wetland A Wetland A is an approximately 61.90-acre, palustrine forested wetland that covers the western portion of the study area. Approximately 37.20 acres of Wetland A is located on the study area, and approximately 24.70 acres extend off the study area to the east. Vegetative species identified within Wetland A include red alder, Indian plum, impatiens, bracken fern, soft rush, water parsley, slough sedge, and giant cattail, among others. Himalayan blackberry is also prevalent throughout this wetland.

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Wetland A has been extensively modified over the course of the past 50 years, through placement of fill material, ditching, and construction of upland berms. While the area in which Wetland A is located was once in the historic tideflats of Grays Harbor, the existing wetland has formed on top of dredged sands and other fill material.

Rated using the depressional Hydrogeomorphic classification, Wetland A received a score of 19 points under the Ecology Wetland Rating System for Western Washington – Revised (Hruby 2014) resulting in a Category III rating.

Wetland B Wetland B is an approximately 4.89-acre, palustrine emergent and palustrine scrub- shrub wetland that is located in the northwest corner of the study area. Wetland B is a remnant area that has developed upon fill material and which appears to be maintained by a combination of areas of high groundwater and slowly permeable soils.

The central portion of the wetland is composed of depressional areas that pond and drain to a network of ditches around the periphery of the wetland. Wetland B is adjacent to and hydrologically associated with Wetland C (described below) but is hydrologically distinct from Wetland C in that it is not tidally influenced.

Vegetative species in Wetland B include a variety of native emergent, shrub, and tree species. Reed canarygrass is well established throughout much of the emergent portions of the wetland, particularly in the ditches and along the periphery. Himalayan blackberry is well established near the interior upland/wetland boundary, as well as along the margins. Several stands of Japanese knotweed are present in the northeastern portion of the wetland.

Wetland B received a score of 19 points under the rating system and is considered a Category III wetland.

Wetland C Wetland C is an approximately 0.39-acre wetland located in the northwestern corner of the study site. This wetland consists of two ditches that converge at a culvert near the intersection of Paulson Road and West Emerson Avenue. The culvert connects Wetland C to the Refuge to the west. Wetland C’s hydrology is tidally influenced because of this hydrologic connection to the mudflats and salt marsh to the west. Vegetation is dominated by reed canarygrass, though cattail and willow were also noted during the site investigation. Wetland C received a Category II rating based on special characteristics as an estuarine wetland.

Overall, these wetlands provide variable levels of hydrologic, water quality, and habitat functions. The forested wetland and portions of the emergent wetland exhibit structural complexity and diversity. However, reed canarygrass dominate significant portions of the emergent and estuarine wetlands, and thus lack structural diversity.

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These less diverse portions of the wetland primarily provide water quality functions with limited habitat functions.

Wetland Ditches The study area consists of an area that was originally tideflats of Grays Harbor. The entire study area was initially filled over 50 years ago to develop industrial waterfront sites. Initial fill placement consisted of sandy material dredged from Grays Harbor, while subsequent fill included angular rock fill used to develop the upland portions of the site, and a variety of mixed soils likely imported to the site from off-site locations. The Terminal 3 site was developed for log storage in the 1970s and additional fill material was placed to establish the conditions of the site that are present today.

Former and current operators at the site have established and maintained several National Pollutant Discharge Elimination System (NPDES) stormwater discharge permits10, which are required for facilities that discharge stormwater to surface waterbodies or municipal storm sewer systems. Over the course of the past 30 years, a network of ditches and treatment facilities have been excavated into the filled uplands at the site for the purpose of treating and/or conveying stormwater in association with these NPDES permits. The Port and the current operator of the site continue to maintain these ditches for the purposes of stormwater treatment, conveyance, and drainage, along with the existing roads, fences, and railroad spur on the property. The Port will continue to maintain these in the future in the absence of other development at the site.

A total of approximately 4.65 acres of wetland ditch features were identified at the site. These ditches exhibit wetland characteristics (soils, vegetation, and hydrology), and are similar in nature and structure, and provide similar levels of function. When ditches are excavated back to their original configuration, as allowed by regulation, their functions as wetlands is largely removed or diminished.

Aquatic Habitats The delineation of aquatic habitat zones presented in the application materials has been refined consistent with habitat descriptions established by WDFW (2008) and as further described in the Marine and Estuarine Habitat Classification System for Washington State (Dethier 1990).

Intertidal Habitats The bathymetry, tidal regime, and benthic substrate of the nearshore at the project site are such that there is little functional difference in habitat function aside from the two tidal regimes that are described. There is a narrow band of riprapped shoreline that spans the MHHW elevation (+8.47 feet NAVD88), but most of this riprap is above MHHW. This zone provides limited ecological function.

The entire intertidal nearshore from the base of the riprapped shoreline, just below the MHHW elevation, to the ELLW elevation at the site (-4.38 feet NAVD88) is a

10 NPDES Stormwater Permits WAR000130, WAR000131, and WAR000132, which were terminated in 2014, and WAR011407, which is the current permit held by the tenant currently operating on the southern portion of the site.

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uniform, shallowly sloping sandy tidal flat. The Washington State Coastal Atlas Map identifies this shoreline as a patchy salt marsh fringe (Ecology 2017). The habitat type is consistent with the “Estuarine Intertidal Sand: Open” habitat type described in Dethier (1990). The estuarine designation is based upon the salinity regime at the project site, which is uniformly mesohaline (salinity between 5 and 18 percent) due to freshwater inputs from the Hoquiam and Chehalis Rivers (Sandell et al. 2014). The “open” designation is based on the shoreline, which receives both wind waves and currents.

Most of the intertidal habitat at the project site is unvegetated with the exception of sporadic macroalgae, such as leafy green sea lettuce (Ulva lactuca) and rockweed (Fucus distichus). The eastern portion of the shoreline intertidal zone has small patches of established salt marsh vegetation, primarily seaside arrowgrass (Triglochin maritima) and pickleweed (Salicornia virginica). Substrate in the intertidal zone at the project site consists predominantly of sands with lesser amounts of silt and sparse clays and gravels. This substrate composition is uniform throughout the intertidal zone.

Intertidal habitats at the project site provide habitat for a variety of fish, shellfish, crustaceans, benthic invertebrates, shorebirds, and other wildlife that use the project site and are critical elements of both primary production and the benthic/detrital food web of the estuary.

Intertidal habitat also occurs in the northwestern corner of the site, associated with the tidal channel that comprises Wetland C. This channel is hydraulically connected to the tidal waters of Grays Harbor to the west of the project site via a culvert under Paulson Road. The portion of intertidal habitat that is present on the site is limited to the channel itself and its associated banks. The channel is deeply incised, and the upper terraces adjacent to the channel are not subject to tidal inundation. Vegetation in and adjacent to the channel consists primarily of reed canarygrass. There is extensive intertidal salt marsh and mudflat habitat associated with the Refuge located to the west of the project site.

Subtidal Habitats The subtidal aquatic habitats waterward of the ELLW elevation at the site transition rapidly to the deep-water portions of the existing Grays Harbor Navigation Channel and the berth associated with the existing Terminal 3 dock. The natural bathymetry of the project site drops off steeply to depths of -30 to -36 feet (NAVD88) below ELLW elevation. Dethier (1990) differentiates subtidal habitats as either shallow or deep, depending on relative water depth. Shallow subtidal habitats are those that are approximately 49 feet or less below MLLW. All subtidal habitats at the project site are shallower than 49 feet. These areas provide a uniform ecological function and, as such, are described as a single habitat type for purposes of assessing habitat function, impacts, and compensatory mitigation.

The USACE regularly dredges the navigation channel and turning basin to maintain a bottom depth of -36 feet MLLW at the site and is currently deepening the channel to

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the fully authorized depth of -38 feet MLLW. Multiple species of fish and other aquatic organisms use deep-water habitats for migration, movement, and foraging. These deep-water habitats are generally less sensitive to effects of development (e.g., dredging and overwater coverage) than shallower water habitats.

6.2.2 Mitigation Sequencing All of the regulatory requirements applicable to the project require a sequence of steps that begins with avoiding impacts to the extent practicable, minimizing and/or rectifying unavoidable impacts, and finally compensating to offset those impacts that are unavoidable. The mitigation sequencing process that was implemented for the project is described below.

Impact Avoidance Measures The layout of the upland portion of the facility has undergone several iterative modifications in an effort to avoid impacts to waters of the State/U.S. and to regulated species and habitats where possible, and to accommodate design requirements and site constraints. As noted previously, the layout and configuration of the rail loop is dictated by the track curvature limits (11 degrees) needed to accommodate unit trains and placement of structures within the rail loop and the length of the unit train (8,500 feet) that will be used at the site. It is not possible to avoid all wetland impacts and still achieve the project purpose at the Terminal 3 site.

Similarly, the location of the storage building, north portion of the site, and other structures at the site are dictated in part by FAA approach and transitional regulated air navigation surface requirements for the approach to Bowerman Field airport as shown on Sheets 3 and 4. The height of the building has been shortened to the extent possible (a minimum height of 141.5 feet at its peak as shown on Sheet 4) and still enable the building to accommodate the conveyance and full design storage capacity. Alternative arrangements that would result in a lower building have been studied; however, because of the performance limitations of the machines that are able to place and reclaim material in a lower building, the project throughput requirements would not be met without adding additional material-handling equipment and significantly increasing the cost and building size. Similarly, splitting the single building into two smaller buildings would decrease the storage efficiency, resulting in a total building area larger than that of a single building, at substantially higher cost. A second building would also require duplicating all related equipment, adding additional conveyors, increasing power consumption, and increasing capital expenditure. As a result, a single building provides the only practicable storage configuration.

The project design has avoided and minimized impacts to wetlands, buffers, shoreline buffers, aquatic habitats, and other environmentally sensitive habitats to the extent practicable, while still accommodating the necessary features to meet the project purpose and need. The administration and maintenance buildings, associated parking areas, and the vehicular site access infrastructure have been located in developed portions of the site and would not result in impacts to wetlands, aquatic resources, and

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associated buffers. The railcar unloading facility is located in an area where fill has previously been placed, which further minimizes wetland impacts in that location.

The overall hydrographic patterns and movement of surface and groundwater through the site will also be maintained to the extent practicable. The project will be required to treat stormwater to meet state water-quality standards, and water that is outfalling from the site will, therefore, be of similar or improved quality from the water that is currently outfalling from the site. The project will direct stormwater to treatment facilities, four detention and/or treatment-only ponds (near the storage building, rail car unloading facility, administrative building, and maintenance building). Treated stormwater will then be routed to existing points of outfall along the Grays Harbor shoreline and in the northwest corner of the site. The conceptual stormwater design and associated treatment were designed as specified in Ecology’s 2014 stormwater manual (Amec Foster Wheeler, July 2018). No new stormwater outfalls will be constructed.

The stormwater facilities at the railcar unloading facility have been designed at a location west of the proposed unloading facility improvements. This location was selected so that existing drainage patterns could be preserved to the largest extent possible. Based on site reconnaissance, this area presently drains to the west, and this pond location would allow treated stormwater runoff to continue to drain to the west and north, as in the existing condition. In the proposed location, stormwater runoff could be collected, treated, detained, and dispersed at the natural discharge location without requiring pumping of stormwater.

The layout of the site was also designed so that noisier equipment (e.g., unloading facility) is sited on the opposite side of the facility from the Refuge, and the parking and administration and maintenance buildings are all located on the southeast corner of the site near the site's main entrance, minimizing cross-site traffic and potential associated interactions with wildlife. The unit trains on site will travel at very slow speeds (less than 6 mph), which will minimize both train-related noise and will also reduce the potential for any wildlife interactions.

The size and configuration of the marine terminal structures have also been kept to the minimum necessary to support their needed functions. No fill is planned as part of the ship terminal construction. Shiploading systems will be designed for loading vessels with capacities of 20,000 to 82,000 dead-weight tonnage. Larger vessels may not be fully loaded to accommodate berth and channel water depths. The average shiploading rate is estimated to be approximately 4,000 tons per hour. The dual quadrant shiploader is the most efficient shiploader design for operational efficiency, capacity, and redundancy for unplanned or planned maintenance. Additionally, all vessel holds can be filled without moving the ship when both quadrant shiploaders are operating. The range of vessels from Handymax to Kamsarmax was chosen in the berth and shiploader design to support best rate access and ensure availability of ships across a range of vessels to meet market supply and demand. The terminal has been designed such that the shiploader and berth are sited in deep water, which minimizes the potential for effects to aquatic habitats, including minimizing the required

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dredging volume. This will also place the berth as close to the federal navigation channel as possible to minimize wake and prop wash impacts to shallower habitat when a ship is leaving or entering the berth area. Structures in and over deeper water habitats have less impact to function than those in shallow water areas, because they have less effect on primary productivity, and deeper water habitats are of less critical importance to sensitive species. Ship berthing and maneuvering activities will also occur in deep water, reducing impacts to habitat from vessel operations, such as scour from propellers and thrusters. Overwater walkways will be grated to further minimize shading. Additionally, the shiploader is composed of relatively narrow trestles supported between small, pile-supported platforms with relatively few piles overall. Since the shiploader and access trestles are relatively narrow structures, they do not result in a substantial benthic footprint, and the impacts associated with overwater shading are relatively low compared to those be associated with a monolithic structure.

New piles for the marine terminal will be installed primarily with a vibratory hammer, to minimize noise-related impacts to aquatic species. A bubble curtain or other similarly effective noise attenuation device will be employed during all impact pile proofing or installation.

Minimization Measures and Best Management Practices The proposed project has adopted a list of impact minimization measures and best management practices (BMPs) to reduce, eliminate, or minimize the effects of the project to listed species or habitat. The minimization measures and BMPs listed below will be used for construction and operation of the proposed project. • In-water work will be conducted only during the approved in-water work window for marine waters of Grays Harbor - Tidal Reference Area 16 and as previously coordinated with the Quinault Indian Tribe and the Port of Grays Harbor, as follows. − 16 July to 14 February (midnight). − Impact pile driving will only occur between 1 October and 14 February (midnight) to protect eulachon and green sturgeon. − No nighttime dredging will occur between 1 October and 30 November.

• Project construction will be completed in compliance with Washington State Water Quality Standards (WAC 173-201A), including − Petroleum products, fresh cement, lime, concrete, chemicals, or other toxic or deleterious materials will not be allowed to enter surface waters or onto land where there is a potential for reentry into surface waters. − Fuel hoses, oil drums, oil or fuel transfer valves, fittings, etc., will be checked regularly for leaks, and materials will be maintained and stored properly to prevent spills.

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• A spill prevention, control, and countermeasures (SPCC) plan will be prepared by the contractor and used during all in-water demolition and construction operations. A copy of the plan will be maintained at the work site. − The SPCC plan will outline BMPs, responsive actions in the event of a spill or release, and notification and reporting procedures. The plan will also outline management elements, such as personnel responsibilities, project site security, site inspections, and training. − The SPCC plan will outline the measures to prevent the release or spread of hazardous materials found on site and encountered during construction but not identified in contract documents, including any hazardous materials that are stored, used, or generated on the construction site during construction activities. These items include, but are not limited to, gasoline, diesel fuel, oils, and chemicals. − Applicable spill response equipment and material designated in the SPCC plan will be maintained at the job site. • The Port of Grays Harbor (Port) is consulting with the Washington State Department of Ecology’s Toxics program (Toxics) with regards to the contaminated soil and groundwater encountered at the Terminal 3 project site and the proposed IDD#1 mitigation site. Coordination is ongoing and the Port as summarized below. − Terminal 3 Project Site o Contaminated soil encountered during construction excavation at the Terminal 3 site will be covered and stockpiled on site to prevent rainwater, wind, animals and the environment from coming into contact with contaminated soil.

o Dewatering water at the site will be captured and treated during construction dewatering. − IDD#1 Mitigation Site o The Port is in ongoing coordination with the Ecology Toxics Cleanup Program regarding the contaminated soil and groundwater encountered at the proposed mitigation site.

Best Management Practices In-, Over-, and Near-Water BMPs Typical construction BMPs for working in, over, and near water will be applied, including activities such as the following.

• Checking equipment for leaks and other problems that could result in the discharge of petroleum-based products or other material into waters of Grays Harbor. • Corrective actions will be taken in the event of any discharge of oil, fuel, or chemicals into the water, including

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− Containment and cleanup efforts will begin immediately upon discovery of the spill and will be completed in an expeditious manner, in accordance with all local, state, and federal regulations. Cleanup will include proper disposal of any spilled material and used cleanup material. − The cause of the spill will be ascertained and appropriate actions taken to prevent further incidents or environmental damage. − Spills will be reported to Ecology Spill Response Office at 1-800-645-7911 and Southwest Regional Office 360/407-6300. • Work barges will not be allowed to ground out. • Excess or waste materials will not be disposed of or abandoned waterward of ordinary high water or allowed to enter waters of the state. Waste materials will be disposed of in an appropriate manner consistent with applicable local, state, and federal regulations. • Demolition and construction materials will not be stored where wave action or upland runoff can cause materials to enter surface waters. • Oil-absorbent materials will be present on site for use in the event of a spill or if any oil product is observed in the water.

Pile Removal BMPs Pile removal BMPs will be applied, including the following.

• While creosote-treated piles are being removed, a containment boom will surround the work area to contain and collect any floating debris and sheen. Any debris will be retrieved and disposed of properly. • The piles will be dislodged with a vibratory hammer when possible and will not be intentionally broken by twisting or bending. • The piles will be removed in a single, slow, and continuous motion in order to minimize sediment disturbance and turbidity in the water column. • If a pile breaks above or below the mudline, it will be cut or pushed in the sediment consistent with agency-approved BMPs. • Removed piles, stubs, and associated sediments (if any) will be contained on a barge. If piles are placed directly on the barge and not in a container, the storage area will consist of a row of hay or straw bales, filter fabric, or similar material placed around the perimeter of the barge. • The contractor will dispose of all creosote-treated material, pile stubs, and associated sediments (if any) into a landfill approved to accept those types of materials.

Pile-Installation BMPs Pile-installation BMPs to be applied will include the following.

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• A vibratory hammer will be used to drive steel piles to the extent possible to minimize noise levels. • A bubble curtain or other similarly effective noise attenuation device will be employed during all impact pile proofing or installation. • Pile installation will be conducted during the approved Washington Department of Fish and Wildlife (WDFW) in-water work window for Tidal Reference Area 10 (16 July to 14 February, midnight). This period was established to minimize impacts to aquatic species. All in-water work will be completed within the work window when Environmental Site Assessment-listed species are least likely to be present. Overwater Concrete Placement Minimization and BMPs On-site concrete placement will follow appropriate BMPs, including the following.

• Wet concrete will not come into contact with surface waters. • Forms for any concrete structure will be constructed to prevent leaching of wet concrete. • Concrete process water will not be allowed to enter the bay. Any process water/contact water will be routed to a contained area for treatment and will be disposed of at an upland location.

Dredging BMPs Dredging activities will follow appropriate BMPs, including the following.

• Construction activities will be conducted in compliance with Surface Water Quality Standards for Washington (WAC 1730201A), or other conditions as specified in the Water Quality Certificate (WQC). • Appropriate BMPs will be employed to minimize sediment loss and turbidity generation during hydraulic dredging. BMPs may include, but are not limited to, the following. − No stockpiling of dredged material below MHHW, − Maintaining suction head of hydraulic dredge at the mudline to the extent practicable, − Using a buffer plate or other means to reduce flow discharge of the hydraulic dredge at the placement area, and/or − Other conditions as specified in the WQC. • Enhanced BMPs may also be implemented during mechanical dredging and may include, but are not limited to, the following. − Smooth closure of the bucket when at the bottom, − Slowing the velocity (i.e., cycle time) of the ascending loaded clamshell bucket through the water column,

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− Pausing the dredge bucket near the bottom while descending and near the waterline while ascending, and/or − Placing filter material over the barge scuppers to clear return water. • If sediment is placed on a barge for delivery to the placement area, no spill of sediment from the barge will be allowed. The barge will be managed such that the dredged sediment load does not exceed the capacity of the barge. The load will be placed in the barge to maintain an even keel and avoid listing.

Dredge Material Placement BMPs Placement of dredge materials will follow appropriate BMPs, including the following.

• Dredging is expected to be conducted using hydraulic (pipeline) or mechanical (clamshell bucket) and disposed at the nearest DNR-managed Point Chehalis or South Jetty disposal sites if characterization finds the material suitable for in- water placement.11 • Visual water quality monitoring and, if necessary, follow-up measurements will be conducted during dredging in accordance with a project-specific water quality monitoring plan and associated permit conditions. • Sediment that is dredged by hydraulic dredge and placed in water by hydraulic pipeline will be discharged at the mudline to the extent practicable to minimize turbidity in the water column. • Sediment placement will occur using methods that minimize sediment loss and turbidity to the maximum extent possible. • The placement activities will be visually monitored to ensure placed sediment is contained inside of the specified boundaries.

Operation BMPs (Project Site) • The site will have a facility-specific SPCC plan and spill kits throughout the site to prevent, minimize, and respond to spills that may result from day-to-day operations at the site. • The facility includes a fueling station that will be constructed on a concrete pad within secondary containment appropriate to the size of the station.

6.2.3 Wetland and Buffer Impacts

Permanent Direct Wetland Impacts The project will result in unavoidable permanent direct impacts (fill) to on-site wetlands and wetland ditches though wetland impacts have been avoided and minimized to the extent practicable (as discussed above). These include impacts associated with the construction of portions of the rail loop, railcar unloading facility, product storage building, conveyors, and stormwater treatment and conveyance

11 The proposed dredged material has been characterized and received a suitability determination from the Dredged Material Management Office dated 19 February 2019 finding all of the proposed material suitable for in-water placement based on the characterization results.

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facilities. The project will result in a total of 15.49 acres of direct permanent impacts to wetlands, which includes approximately 0.20 acre of wetland impact at the IDD#1 site, which will occur as a result of compensatory mitigation activities. The project will also result in 2.83 acres of impacts to ditches on site. This represents a net total of 18.32 acres of permanent direct impact to wetlands and ditches.

Permanent Indirect Wetland Impacts The project will also result in indirect impacts to wetlands, which will result from further fragmentation of the existing wetland network at the site and the associated reduction in buffer for those wetland areas that have been avoided by the project. While indirect wetland impacts will not result in a net loss of wetland acreage, they have the potential to reduce wetland function. The project will result in a total of 20.01 acres of permanent indirect impacts to wetlands at the project site, and an additional 0.73 acre of indirect impact to ditches on site. This represents a net total of 20.74 acres of permanent indirect impact to wetlands and ditches.

Temporary Wetland Impacts The project will also result in 23.96 acres of direct temporary wetland impacts, associated with the construction of the compensatory mitigation site. Portions of the existing wetlands on the IDD#1 site will be graded and recontoured to establish the finished grades within the mitigation site. Existing vegetation, both native and invasive, will be removed during this process, and soils will be temporarily disturbed. These areas will be planted with native vegetation consistent with the mitigation plan, and will be restored to a more highly functioning wetland condition. The minor temporary loss of wetland function will be offset by these proposed enhancements.

Wetland Buffer Impacts The City’s Shoreline Master Program (SMP) (Appendix 2 Section 2.03.02) establishes protective buffers for all regulated activities conducted adjacent to regulated wetlands. Base buffer widths are established based on the total point score from the wetland rating form, and the intensity of the proposed land use. Because the proposed project represents a high-intensity land use, Wetlands A, B, and C all have a 150-foot base buffer width. Ditches are exempt from regulation as wetlands under the SMP, and as such they do not have a regulatory buffer.

Base buffer widths only apply to functioning buffers. Section 2.03.02.B of Appendix 2 of the SMP clarifies that protective buffers do not include those areas functionally and effectively disconnected from the wetland, such as by a road or other structures. Most of the upland portion of the project site is a developed industrial site consisting of paved and/or compacted fill surfaces and/or roadways. Therefore, the functional portion of the buffers extend only from the wetland boundary to the toe of the existing fill or development that establishes the upland portion of site. The project will impact approximately 12.27 acres of existing wetland buffer at the project site. Table 8 summarizes the wetland and wetland buffer impacts that would occur from the project.

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Table 8. Alternative A1 - Wetland and Wetland Buffer Impacts Impact Type Identifier Wetland Rating Impact (acres) Wetland A III 13.09 Wetland B III 2.08 Permanent/Direct (Wetlands) Wetland C II 0.12 IDD#1-A III 0.20 Wetland Subtotal 15.49 Permanent/Direct (Ditches) Ditches NA 2.83 Permanent Direct Impact Totals 18.32 Wetland A III 18.27 Wetland B III 1.70 Permanent/Indirect Wetlands) Wetland C II 0.04 Wetland Subtotal 20.01 Permanent/Indirect (Ditches) Ditches NA 0.73 Permanent Indirect Impact Totals 20.74 Temporary Wetland Impacts 23.96 Wetland Buffer Impacts 12.27

Shoreline Buffer Impacts The City’s SMP also establishes protective buffers along shorelines to retain areas of native vegetation and to allow habitat connectivity. The buffer for Type S waters of the state (including Grays Harbor) are established in Table 4-1 of the revised SMP, which establishes buffers by shoreline environmental designation and the water dependency of a proposed land use.

A functional shoreline buffer is present in the northwestern corner of the site, adjacent to the tidal portion of Wetland C. This buffer extends into the site to the south and east a maximum distance of 150 feet. Impacts to approximately 2.68 acres of shoreline buffer will result from the construction of rail improvements.

6.2.4 Aquatic Impacts Impacts to aquatic habitats will occur from the construction of the new dock and shiploader (overwater coverage and benthic impacts associated with new piling), and from the dredging required to accommodate the new berth. There is no fill placement associated with the project in-water work. Tables 9 and 10 below provide a full accounting of all the aquatic impacts associated with the project. The impacts are discussed in detail in the sections below.

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Table 9. Aquatic Impacts Area of Overwater Number of Piles Coverage (sf) Benthic Terminal Component Dimensions (ft) Impact 48-inch 24-inch Solid Grated (sf) Steel Steel Permanent Mooring Dolphins (4) W: 21.32’ L: 32.80’ 2,799 -- 24 - 302 Berthing Dolphins (2) W: 22.96’ L: 26.24’ 1,206 -- 16 - 201 Quadrant Supports (14) W: 5.24’ L: 13.12’ 975 -- 28 - 352 Transfer Tower Platform (1) W: 57.41’ L: 50.85’ 2,920 -- 9 - 113 Support Platforms (10) W: 26.24’ L: 32.80’ 6,889 -- 48 - 604 Service Platform (1) W: 41.01’ L: 62.33’ 2,556 -- 12 - 151 1 at: 29.52’ x 42.65’ Pivot Supports (2) 3,584 -- 12 - 151 1 at: 39.37’ x 59.05’ Access Support Platform (1) W:32.80’ L: 39.37’ 1,292 -- 6 - 75 Variable Access Trestle Spans (14) W: 14.75’ to 16.00’ 25,893 -- 4 - 50 L: 97.17’ to 133.92’ Variable Walkways (20) W: 3.25 to 4.92 -- 4,279 - - - L: 28.24’ to 142.71’ Contingency Piles (40) N/A -- -- 40 - 503 Total Permanent 48,114 4,279 199 0 2,502 Temporary Total Temporary -- -- - 48 151

Table 10. Aquatic Impacts by Tidal Zone Area of Overwater Piles Dredging Coverage (sf) Habitat Zone # 48- # 24-inch Benthic Dredge Prism Solid Grated inch Steel Impact (sf) (sf) Steel Permanent Intertidal (above ELLW) 35,360 0 81 0 1,020 18,770 Subtidal (below ELLW) 12,754 4,279 118 0 1,482 0 Total Permanent 48,114 4,279 199 0 2,502 18,770 Temporary Intertidal (above ELLW) 0 0 0 * * 0 Subtidal (below ELLW) 0 0 0 * * 307,494 Total Temporary 0 0 0 48 151 307,494 * Specific locations of temporary piles are not known.

Overwater Shading The project will result in a total of approximately 48,114 square feet of new solid overwater coverage associated with the construction of the new shiploader. The shiploader has been designed such that the structure is located in deepwater habitats as much as is practicable to minimize impacts to intertidal habitats where the effects

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of overwater shading can be more pronounced. Approximately 35,360 square feet (0.81 acre) of the new solid overwater coverage will be located over intertidal habitats at the project site.

The primary effects to aquatic habitat function associated with shading from overwater structures are the potential for (1) effects to aquatic vegetation and reduced primary productivity and (2) reduced habitat suitability for aquatic species, particularly juvenile salmonids (Nightingale and Simenstad 2001a).

Reduced sunlight penetration to benthic surfaces can reduce photosynthetic activity and lead to reduced habitat suitability for aquatic vegetation. The bulk of primary productivity in Grays Harbor is generated in intertidal habitats in areas where eelgrass and benthic algae are abundant (Thom 1981). The potential for impacts to eelgrass beds is of particular concern in estuarine habitats in Washington State. Eelgrass beds, where present, provide important nearshore habitat in estuarine environments. As described previously, intertidal habitat at the project site is largely unvegetated with the exception of sporadic macroalgae. Eelgrass surveys conducted at the site in May 2017 and February 2018 did not document the presence of any eelgrass beds (RSS 2018). However, eelgrass is dynamic and can expand, contract, disappear and recolonize based on numerous factors. Previous studies conducted at the project site have identified isolated shoots of Japanese eelgrass (Zostera japonica) within the project area, primarily limited to nearshore areas with less than 2 percent coverage (HDR 2014). There is a low potential that eelgrass or kelp beds would be present during the growing season based on the results of the preliminary surveys, the high current, low-light transmission, and storm exposure at this site.

Overwater shading also affects aquatic habitat suitability for fish, in particular for migrating and rearing juvenile salmonids. Juvenile salmonids rely on nearshore habitats during migration and rearing, and nearshore shading can affect patterns of movement, and can also provide habitat for predatory fish species.

A number of factors can reduce the potential effects to aquatic habitat function that could otherwise occur associated with overwater shading. These include the height of the structure, the orientation of the structure, the density of the piling, and the piling material and reflectivity (Nightingale and Simenstad 2001a).

Increased dock height diminishes the intensity of shading by providing a greater distance for light to diffuse and refract around the dock surface. The deck of the shiploader structure will be located at approximate Elevation +22 feet (NAVD88) and the height of conveyance over water will range from approximately +26 feet (NAVD88) to approximately +83 feet (NAVD88). A north-south dock orientation has also been shown to increase underwater light availability by allowing varying shadow periods as the sun moves across the sky (Nightingale and Simenstad 2001a). A 3-D Overwater Shading Model has been prepared for the project (BergerABAM 2018c), and the results of the model show that the shading created from the proposed structure is constantly moving, extends outside of the footprint of the structure (e.g., not directly below the structure at or near sunrise and sunset), and the shape and intensity

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of the shading is not a solid dark area but a more diffuse irregular shape at various times of day (e.g., at or near sunrise and sunset). This reduces the extent of the functional impact of the shading.

An open-pile structure also reduces the effect to aquatic habitat function (Nightingale and Simenstad 2001a). Large numbers of densely spaced piling (e.g., adjacent Terminal 3 pier) increase the shade cast by piling on the underwater environment, whereas open structures allow for more light penetration. Piling material (i.e., concrete, wood, or steel) also affects underwater light transmission as concrete and steel piling refract more light than light-absorbing wood piles (Nightingale and Simenstad 2001a). The shiploader that uses a minimal number of steel piling (as opposed to a more densely spaced arrangement of smaller diameter concrete or timber piles) minimizes the extent of the functional impact to aquatic habitat impacts.

The project also will result in approximately 4,279 square feet of new, grated overwater coverage associated with walkways to the proposed mooring dolphins. However, the grating and the position of these walkways over subtidal areas will not result in impacts to primary productivity or other aquatic habitat function, and no compensatory mitigation is required or proposed for these grated elements.

Benthic Habitat Loss from Piling Approximately 199 48-inch steel piles will be placed for the proposed shiploader and trestle structure as summarized in Table 3 above. The total includes a contingency of approximately 40 piles to accommodate the potential need for additional piles as the structural design is finalized. This will represent a total of approximately 2,502 square feet of new permanent benthic habitat impact associated with new pile footprints. Of the total, 81 new piles representing approximately 1,020 square feet of benthic habitat impact will be located within intertidal habitats at the project site.

The pile footprints will represent a loss of physical benthic substrate for species that rely on aquatic habitats at the project site, both intertidal and subtidal. The extent of the impact to aquatic habitat function is tempered by the levels of aquatic habitat function that current site habitats provide. Aquatic habitat function at the project site has been modified from its natural condition by the degree of human alteration of the system. The intertidal sandflats that were once closely associated with an extensive salt marsh at the project site are now isolated from adjacent riparian and upland habitats by historic fill placement that occurred to develop the upland areas currently present at the site.

Construction may also require up to 48 temporary piles. Temporary piles will consist of 24-inch-diameter open-ended steel pipe piles, driven solely with a vibratory pile driver. Temporary piles may be installed for the mooring of a work barge during the construction and as pile installation templates. The temporary piles will be removed after construction of the relevant feature is completed and, because of their transient nature, any impacts to aquatic habitat will be short-lived in nature. The localized, short-term nature of the impacts associated with temporary pile installation and

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removal will result in no net loss of aquatic habitat function. No compensatory mitigation is required or proposed for temporary piles.

Benthic Habitat Modification from Dredging The project will result in modification of benthic habitat as a result of initial dredging of the expanded berth.

Approximately 110,000 cubic yards of material will be dredged from an area approximately 7.49 acres in size to provide sufficient draft for vessels. The proposed berth will be approximately 4.72 acres in size. Most of this activity would be conducted outside of intertidal areas, and the majority of the dredge prism would be located in areas already deeper than 30 feet. However, dredging would convert an area approximately 18,770 square feet (0.43 acre) in size from an intertidal condition to a shallow subtidal condition, which would represent a modification of habitat condition.

The primary impacts associated with dredging in estuarine waters are those temporary effects associated with construction, including the potential for entrainment, temporarily increased turbidity, direct injury, and disturbance associated with construction noise (Nightingale and Simenstad 2001b). Long-term effects of dredging include the potential for effects associated with disposal of contaminated materials and changes in habitat characteristics, such as a conversion from intertidal to subtidal habitats (Nightingale and Simenstad 2001b).

Conversion of approximately 18,770 square feet (0.43 acre) of intertidal habitat to subtidal habitat will represent a permanent conversion from one habitat type to another. It has the potential to affect primary productivity by reducing the degree of light transmission to the benthic substrate. This has the potential to affect the specific plant and animal assemblages that can occur in that location and reduces the ability of that area to provide habitat for species that rely on intertidal conditions. This habitat conversion represents an impact to intertidal habitat function but does not represent a complete loss of habitat. The maximum extent of deepening within the intertidal portion of the dredge prism would be 4 feet. Subtidal habitats will continue to provide aquatic habitat function at the project site, comparable to those provided by existing subtidal habitats at the site.

Dredging and material placement activities in subtidal habitats have the potential to result in short-term, temporary impacts to benthic organisms and their habitat, but these temporary impacts are not expected to result in permanent effects to aquatic habitat function. The potential for and extent of any temporary effects to aquatic habitat function will be offset by the implementation of operational BMPs during construction. While subtidal benthic substrates will be disturbed during construction, they are expected to recolonize rapidly, and the temporary disturbance to subtidal habitats will result in no net loss of aquatic habitat function.

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6.2.5 Compensatory Mitigation Summary The project will affect wetlands and associated buffers (through direct impacts from fill placement associated with construction of the upland portions of the facility) and aquatic habitats (by increasing the quantity of overwater shading and benthic habitat impacts from new piles). In addition to impact avoidance and minimization, the project incorporates a comprehensive compensatory mitigation project to be constructed on the IDD#1 site, an approximately 45-acre site of former tidelands at the mouth of the Hoquiam River.

Specific actions to be conducted include excavating tidal channels, restoring a tidal hydrologic regime to the site, and creating and rehabilitating wetlands into high quality salt marsh habitats. In addition, the compensatory mitigation includes the removal of existing piles and a derelict overwater structure at an offsite location in the inner Grays Harbor, near the mouth of the Chehalis River.

A conceptual mitigation plan has been prepared and submitted as part of the permit application package for the project (BergerABAM 2018b). These compensatory mitigation actions are summarized below.

Wetland and Wetland Buffer Mitigation Table 11 documents the quantity of mitigation proposed for the unavoidable wetland and wetland buffer impacts associated with the project.

The size and quantity of the proposed wetland and wetland buffer mitigation have been established based on extensive discussion and coordination between agency staff from the USACE, Ecology, WDFW, and the City, conducted in 2017 and 2018.

Ecology has established guidelines for mitigation ratios in Wetland Mitigation in Washington State Part 1: Agency Policies and Guidance (Ecology 2006). However, this guidance allows for reduced ratios in instances where the proposed mitigation actions will provide functions and values that are significantly greater than the wetland being affected. The mitigation site provides a unique opportunity to conduct a high-quality restoration project within inner Grays Harbor in an area where nearshore estuarine salt marsh habitats have been largely eliminated. Whereas wetland impacts are primarily to moderate quality Category III wetlands, the proposed compensatory mitigation is expected to create a large contiguous area of high-quality Category II estuarine wetland. The net result will be a compensatory mitigation site that results in a net increase in water quality, hydrologic, and wildlife habitat function, which justifies the proposed mitigation ratios.

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Table 11. Wetland and Wetland Buffer Mitigation Summary Mitigation Mitigation Ratio Total Impact Wetland Category Impact Quantity Mitigation Type Mitigation (acres) Ecology Proposed Proposed Guidance (acres) Wetland 4.31 ac.* 4:1 2:1 8.62 Rehabilitation Wet A III 13.09 Wetland Perm./ 8.78 ac.* 2:1 1:1 8.78 8.78 acres Direct Creation wetland (Wetlands) Wet B III 2.08 Wetland Rehabilitation 4:1 2:1 4.16 creation; Wet C II 0.12 Wetland Rehabilitation 4:1 2:1 0.24

IDD#1-A III 0.20 Wetland Rehabilitation 4:1 2:1 0.40 23.70 acres Totals 15.49 22.20 wetland Wet A III 18.27 Wetland Rehabilitation N/A 0.5:1 9.14 rehabilitation* Perm./ * Indirect Wet B III 1.70 Wetland Rehabilitation N/A 0.5:1 0.85 (Wetlands) Wet C II 0.04 Wetland Rehabilitation N/A 0.5:1 0.02 Totals 20.01 10.25 Perm./ Wetland Direct N/A 2.83 Ditches N/A Self- (Ditches) minimum 1:1 area replacement in on-site drainage network mitigating Perm./ Wetland Indirect N/A 0.73 Ditches (Ditches) Totals 3.56 Existing wetlands at mitigation site temporarily disturbed during N/A Self- Temporary Wetland Impacts 23.96 construction. mitigating 5.24 acres Enhanced Wetland Buffer enhanced Wetland Buffer Impacts 12.27 Creation 1:1 0.43:1 5.24 wetland (110 ft buffer) buffer creation Wetland and Wetland Buffer Mitigation Summary 8.78 acres wetland creation; 23.70 acres wetland rehabilitation**; 5.24 acres enhanced wetland buffer creation * = quantity of impact (in acres) that is mitigated for by each mitigation type. ** = only 23.67 acres of rehabilitation are required at the proposed ratios, but 23.70 acres would be created at the mitigation site.

Created wetland areas will be graded to elevations that provide appropriate wetland hydrologic conditions, and will be planted and seeded with a suite of native emergent species to create and rehabilitate a natural mosaic of low and high salt marsh habitats at the site. Enhanced buffer areas will be planted with native tree and shrub species to provide natural functional buffering for the site.

The proposed wetland creation and rehabilitation, and enhanced wetland buffer creation will improve both terrestrial and aquatic habitat, water quality, and hydrologic functions in a sensitive estuarine habitat at the mouth of the Hoquiam River. The proposed native plantings will provide a biologically productive habitat that will be a source of insect and invertebrate fauna, leaf litter, detritus, and woody debris to the associated aquatic system. The establishment of native vegetation will improve habitat suitability for native birds and other terrestrial species that rely on these habitats. The net gain in wetland acreage at the mitigation site will increase

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water quality and hydrologic function, particularly in areas where currently impervious surfaces are converted to wetlands.

The wetland creation and enhanced wetland buffer creation will provide direct in- kind mitigation for wetland and wetland buffer impacts associated with the proposed project.

Tidal Channel Habitat Creation and Enhancement The mitigation project includes the creation of approximately 5,941 linear feet and approximately 0.94 acre of new fish-accessible tidal channels12 at the site. These new tidal channels will provide a network of low-energy side-channel habitat within a mosaic of newly restored high and low salt marsh habitats.

The tidal channels will be excavated to a final elevation such that they remain inundated throughout the typical range of flows and tidal conditions throughout the year, and such that they will not create pockets of standing water during low flow conditions. A hydrologic assessment is currently being conducted, and the results of this assessment will be used to establish the final surface elevations at the mitigation site.

It is anticipated that the tidal channel will be largely unvegetated, as it will be regularly inundated throughout the majority of a typical tidal cycle. Over time, some desirable aquatic macroalgae species and other aquatic vegetation will likely become established. Adjacent low salt marsh will be both seeded and planted with plugs of desirable emergent salt marsh species.

Nine large woody debris (LWD) structures will be installed throughout the newly created intertidal habitats at the site. LWD structures are a restoration and mitigation component that helps build high-quality fish habitat, develops scour pools, and provides complex cover. These large wood structures will increase habitat complexity and overhead cover with interstitial spaces that will allow juvenile and adult salmonids and other native species to evade predation by mammals, birds, and fish. The structures will provide refuge and foraging opportunities for juvenile salmonids.

Each structure will be composed of large-diameter untreated logs, logs with rootwads attached, and small wood debris. Logs generally will have a minimum diameter of 20 inches and be 20 feet long. They will be anchored as needed to minimize movement.

The proposed tidal channel creation will provide both in-kind mitigation (for shoreline buffer impacts) as well as out-of-kind habitat enhancements to nearshore aquatic habitat (for impacts to aquatic habitats from new overwater structure and permanent benthic habitat impacts).

12Tidal channel acreage is in addition to, and separate from, the wetland creation and rehabilitation acreages reported in Table 11.

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Pile and Overwater Structure Removal In addition to the proposed on-site compensatory mitigation, the applicant will remove approximately 1,368 piles from nearshore waters of Grays Harbor in the vicinity of the Port of Grays Harbor’s Terminal 4 near the mouth of the Chehalis River. These piles are estimated to range between 12 and 14 inches in diameter at the mudline. The applicant will also remove a derelict concrete overwater structure that is associated with one of the groups of piles.

The piles result in the direct loss of benthic habitat and serve to reduce the quality of the habitat in the area. The piles serve as habitat for non-native species, including fish and bird species that prey on native salmonids and potentially represent a source of pollutants from chemicals used for treatment.

Removal of these piles will restore approximately 1,464 square feet of benthic habitat within an area approximately 4.35 acres in size. In addition, removal of the structure will restore an area of approximately 2,147 square feet of nearshore habitats. Pile and structure removal will provide both in-kind mitigation for benthic habitat and overwater coverage impacts associated with the new terminal, as well as out-of-kind habitat mitigation in the form of water quality improvements.

7.0 PHASE 5: LEDPA IDENTIFICATION This alternatives analysis was developed in accordance with the CWA Section 404 (b)(1) guidelines. The analysis presented above demonstrates that Alternative A1 (Sheet 4) is the only practicable alternative. The analysis presented in Section 6.2.2 above describes the mitigation sequencing process that was undertaken to avoid and minimize impacts to wetlands and aquatic habitats, and documents that the project does not present significant environmental impacts. Alternative A1 is, therefore, documented to be the LEDPA for the project.

The unavoidable environmental impacts will be mitigated as described in Section 6.2.5. A conceptual mitigation plan has been prepared and submitted as part of the permit application package. The mitigation has been designed to meet the regulatory requirements of the agencies with jurisdiction, and to result in no net loss of ecological function. Additional agency coordination regarding project mitigation is ongoing and a revised mitigation plan will be submitted at the conclusion of that coordination.

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8.0 BIBLIOGRAPHY Amec Foster Wheeler. 2018. Conceptual Stormwater Management Plan, Jansen Outbound Logistics, Amec Foster Wheeler. Revised July 2018. BergerABAM. 2018a. Wetland and Waterbody Delineation and Assessment. Proposed Grays Harbor Potash Export Facility. Hoquiam, Washington. BergerABAM. 2018b. Conceptual Mitigation Plan. Proposed Grays Harbor Potash Export Facility. Hoquiam, Washington. BergerABAM. 2018c. Summary of 3-D Overwater Shading Modeling. BHP Proposed Grays Harbor Potash Export Facility, A17.0202.00. April 2018. Dethier, M.N. 1990. A Marine and Estuarine Habitat Classification System for Washington State. Washington Natural Heritage Program. Dept. Natural Resources. 56 pp. Olympia, Wash. Available at: https://www.dnr.wa.gov/publications/amp_nh_marine_class.pdf. HDR. 2014. Grays Harbor Rail Terminal LLC. Intertidal Technical Report. March 2014. Hruby, T. 2014. Washington State Wetland Rating System for Western Washington – Revised. Washington State Department of Ecology Publication-Draft Publication. Nightingale, B. and C.A. Simenstad. 2001a. Overwater Structures: Marine Issues. White Paper. Dated May 9, 2001. Seattle, WA. Available at: https://wdfw.wa.gov/publications/00051/wdfw00051.pdf. Nightingale, B. and C.A. Simenstad. 2001b. Dredging Activities: Marine Issues. White Paper. Dated July 13, 2001. Seattle, WA. Available at: https://wdfw.wa.gov/publications/00055/wdfw00055.pdf. Research Support Services, Inc. February 2018. Sea All eelgrass and macroalgae video survey of the BHP Grays Harbor site. Thom, R.M. 1981. Primary productivity and organic carbon input to Grays Harbor Estuary, Washington. Grays Harbor and Chehalis River Improvements to Navigation Environmental Studies. U.S. Army Corps of Engineers. 71 pp. Seattle, Wash. USA News Group, 6 December 2017. “Potash Supply to Exceed Demand by 2020.” http://usanewsgroup.com/2017/12/06/potash-supply-to-exceed-demand-by- 2020-report/. Washington State Department of Ecology. 2017. Washington State Coastal Atlas Map. Accessed 9 June 2017 at https://fortress.wa.gov/ecy/coastalatlas/tools/Map.aspx. Washington State Department of Ecology. 2006. Wetland Mitigation in Washington State – Part 1 Agency Policies and Guidance and Part 2: Developing Mitigation Plans (Version 1). Ecology Publication #06-06-011a. Dated March 2006.

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APPENDIX A DRAWINGS

Seattle

Port of Tacoma SSA/MVV Site jk Tacoma

Olympia Hoquiamjk

Grays Harbor Site

Eatonville S

Centralia Raymond

Morton

Ilwaco

Cathlamet Port of Longview Barlow Point Site jk jkKelso Port of Longview Berth 2 Site

S

Vancouver Terminal 5 Site jk 0 6.5 13 19.5 26 Vancouver I Miles

PURPOSE:PURPOSE: Construct Construct a a bulk bulk potash potash export/outbound export/outbound Figure 1: Vicinity Map USACE REERENCE Reference No:NO NWSNWS - 2017 - 715 logistics facility. Sheet : icinit ap logistics facility. PROJECT: Proposed Grays Harbor Potash Export IN:IN: HoquiamHoquiam Washinton State Sites PROECT:Facility Proposed ras Harbor Potash Export acilit COUNTYCOUNTY OF: Grays Grays Harbor Harbor Alternatives Analysis LATITUE: STATE: WA ALTERNATIVES ANALYSIS LATITUDE: 46° 58' 42" APPLICANT:STATE: WA BHP Billiton Canada Inc. LONITUE:LONGITUDE: -123° 54' 44" ADJACENTAPPLICANT: PROPERTYBHP Billiton OWNERS:Canada Inc. USA, City of ATU:DATUM: NAStatePlaneWashinton NAD_1983_StatePlane_Washington Hoquiam,Hoquiam, Port Port of of Grays Grays Harbor, Harbor, Adams Adams Street Street Hoquiam Hoquiam LLC,LLC, Emerson Street Hoquiam LLCLLC SheetFigure 1 o of 80 April A 2018 Path: Q:\Vancouver\2017\A17.0202\00\GIS\02_MXD\Alternatives Analysis\Fig1_VicinityMap.mxd

SA

Kinder Morgan Terminals, Vancouver Wharves

Fraser Surrey Docks

Port of Metro Vancouver, Site 5

Service Layer Credits: Sources: Esri, HERE, Garmin, Intermap, increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri Japan, METI, Esri China (Hong Kong), (c) OpenStreetMap contributors, and the GIS User 01 2 4 6 Community National Geographic, Esri, Garmin, HERE, UNEP-WCMC, USGS, NASA, ESA, METI, ¨ Miles

PURPOSE: Construct a bulk potash export/outbound USACE REERENCE NO NWS PURPOSE: Construct a bulk potash export/outbound SheetSheet 1: : Vicinity icinit Map ap USACE Reference No:NWS-2017-715 logisticslogistics facility.facility. IN: Hoquiam BiologicalCanada Evaluation Sites PROECT:PROJECT: Proposed Proposed ras Grays Harbor Harbor Potash Potash Export Exportacilit IN: Hoquiam Facility COUNTYCOUNTY OF: OF: Grays Grays Harbor Harbor LATITUE: ALTERNATIVES ANALYSIS LATITUDE: 46° 58' 42" STATE:STATE: WA WA LONITUE: APPLICANT: BHP Billiton Canada Inc. LONGITUDE: -123° 54' 44" APPLICANT:ADJACENT BHP PROPERTY Billiton Canada OWNERS: Inc. USA, City of ATU:DATUM: NAStatePlaneWashinton NAD_1983_StatePlane_Washington Hoquiam,Hoquiam, Port of GraysGrays Harbor, AdamsAdams StreetStreet HoquiamHoquiam LLC,LLC, Emerson Emerson Street Street Hoquiam Hoquiam LLC LLC SheetSheet 1 o of 180 October A 2018

Path: Q:\Vancouver\2017\A17.0202\00\GIS\02_MXD\Alternatives Analysis\Fig2_Vicinity Canada.mxd Legend Hoquiam Project Site Proposed Site Plan Wetlands Delineated (BergerABAM 2018) FAA Regulated Surfaces Precision Runway Approach Center Line 50: 1 Runway Approach Surface

F.A.R.F.A.R. 77 TRANSITIONAL 77 TRANSITIONAL SURFACE SURFACE 7:1 SLOPE7:1 SLOPE FAR 77 7:1 Transition Surface 167.0'

AINTENANCE UILIN

STORWATER PON 167.0'

AINISTRATION UILIN

RAILCAR UNLOAIN ACILIT

F.A.R. 77 PRECISION RUNWAY F.A.R. 77 PRECISION RUNWAY 140.0'

RAIL APPROACH SURFACE 50:1130.0' SLOPE

CONEORS 120.0'

110.0'

100.0'

90.0'

80.0'

70.0'

60.0'

50.0'

40.0' 30.0'

Bowerman Airport Runway 8/24 Approach Surface

125.0' SHIP LOAER 150.0'

167.0'

0250 500 1,000 Feet F.A.R. 7F7.A.R. TRANSITIONAL 77 TRANSITIONAL SURFACE SURFACE 7:1 SLOPE 7:1 SLOPE I PURPOSE: Construct a bulk potash export/outbound Seet : Alternatie A Grays USACE REERENCE NO NWS logistics facility. IN: Hoquiam Harbor Terminal PROECT: Proposed ras Harbor Potash Export acilit COUNTY OF: Grays Harbor ALTERNATIVES ANALYSIS LATITUE: STATE: WA LONITUE: APPLICANT: BHP Billiton Canada Inc. ATU: NAStatePlaneWashinton Hoquiam, Port of Grays Harbor, Adams Street Hoquiam LLC, Emerson Street Hoquiam LLC Sheet o 0 A Legend Hoquiam Project Site Proposed Site Plan Proposed Storage Building 141.5' Height; Elevation 152.5 MSL Wetlands Delineated (BergerABAM 2018) Note: Top of warehouse elevation assumes FAA Regulated Surfaces finish floor elevation of 11' MSL Precision Runway Approach Center Line 50: 1 Runway Approach Surface FAR 77 7:1 Transition Surface

WAW USEA U SE

STORWATER PONS

RAIL

RAILCAR UNLOAIN ACILIT AINISTRATION UILIN AINTENANCE UILIN CONEORS

UEL PA F.A.R. 77 PRECISION RUNWAY APPROACH SURFACE 50:1 SLOPE

AINISTRATION UILIN

Bowerman Airport Runway 8/24 OERPASS Approach Surface

SHIP LOAER

0250 500 1,000 I Feet F.A.R. 77 TRANSITIONAL SURFACE 7:1 SLOPE

PURPOSE: Construct Construct a abulk bulk potash potash export/outbound export/outbound Figure 2: Alternative A USACEUSACE REERENCE Reference NO No: NWSNWS - 2017 - 715 logistics facility. Seet : Alternatie A Grays logistics facility. Harbor GraysTerminal Harbor Onsite Terminal Alternatie 3 PROJECT: Proposed Grays Harbor Potash Export IN: Hoquiam PROECT:Facility Proposed ras Harbor Potash Export acilit COUNTY OF: OF: Grays Grays Harbor Harbor Alternatives Analysis LATITUE: STATE: WA ALTERNATIVES ANALYSIS LATITUDE: 46° 58' 42" STATE:APPLICANT: WA BHP Billiton Canada Inc. LONITUE:LONGITUDE: -123° 54' 44" APPLICANT:ADJACENT PROPERTYBHP Billiton Canada OWNERS: Inc. USA, City of ATU:DATUM: NAStatePlaneWashinton NAD_1983_StatePlane_Washington Hoquiam, Port ofof GraysGrays Harbor,Harbor, AdamsAdams StreetStreet Hoquiam Hoquiam LLC, Emerson Emerson Street Street Hoquiam Hoquiam LLC SheetFigure 2o of 80 AprilA 2018 Path: Q:\Vancouver\2017\A17.0202\00\GIS\02_MXD\Alternatives Analysis\Fig4_AlternativeA1.mxd PURPOSE: Construct a bulk potash export/outbound Seet : Alternatie B Port of USACE REERENCE NO NWS logistics facility. IN: Hoquiam Tacoma SSA/ Site PROECT: Proposed ras Harbor Potash Export acilit COUNTY OF: Grays Harbor ALTERNATIVES ANALYSIS LATITUE: STATE: WA LONITUE: APPLICANT: BHP Billiton Canada Inc. ATU: NAStatePlaneWashinton Hoquiam, Port of Grays Harbor, Adams Street Hoquiam LLC, Emerson Street Hoquiam LLC Sheet o 0 A PURPOSE: Construct a bulk potash export/outbound Seet : Alternatie C USACE REERENCE NO NWS logistics facility. IN: Hoquiam Port of Longie Barlo Point PROECT: Proposed ras Harbor Potash Export acilit COUNTY OF: Grays Harbor ALTERNATIVES ANALYSIS LATITUE: STATE: WA LONITUE: APPLICANT: BHP Billiton Canada Inc. ATU: NAStatePlaneWashinton Hoquiam, Port of Grays Harbor, Adams Street Hoquiam LLC, Emerson Street Hoquiam LLC Sheet o 10 A Port of Longview Berth 2 Berth Port Longview of D Figure 6: Alternative Port of Longview Berth 2 Berth Port Longview of D Figure 6: Alternative Legend Sheet 6 of 7 of

CONEOR UNLOAIN ACILI RAIL CAR Legend

Sheet PURPOSE: Construct a bulk potash export/outbound Seet : Alternatie USACE REERENCE NO NWS logistics facility. IN: Hoquiam Port of Longie Bert PROECT: Proposed ras Harbor Potash Export acilit 6 COUNTY OF: Grays Harbor LATITUE: of 7 of ALTERNATIVES ANALYSIS STATE: WA LONITUE: APPLICANT: BHP Billiton Canada Inc. ATU: NAStatePlaneWashinton Hoquiam, Port of Grays Harbor, Adams Street Hoquiam LLC, Emerson Street Hoquiam LLC Sheet o 10 A PURPOSE: Construct a bulk potash export/outbound Seet : Alternatie USACE REERENCE NO NWS logistics facility. IN: Hoquiam Port of ancouer, A Terminal PROECT: Proposed ras Harbor Potash Export acilit COUNTY OF: Grays Harbor ALTERNATIVES ANALYSIS LATITUE: STATE: WA LONITUE: APPLICANT: BHP Billiton Canada Inc. ATU: NAStatePlaneWashinton Hoquiam, Port of Grays Harbor, Adams Street Hoquiam LLC, Emerson Street Hoquiam LLC Sheet o 10 A Port of Longview Berth 2 Berth Port Longview of D Figure 6: Alternative FOOT ADMINISTRATION EXISTING FRASER SURREY BUILDING AND PARKING DOCKS 12,000 SQUARE SHED 4 Legend 11 DEG 25'00" (R153.221m) CURVE NOTIONAL INTERNAL OVERPASS SHED 1 Sheet 6 of 7 of LEGEND: LAYDOWN AREA NOTIONAL INTERNAL OVERPASS PROPOSED ROADS NEW BHP INFRASTRUCTURE TO BE RELOCATED DIESEL SHOP SHED 2 11 DEG (R159.000m) CURVE DEMOLISHED BUILDING TO BE PARTIALLY NOTE: GROUND COORDINATE SYSTEM OVERALL SITE - PLAN

SHED 5 8m NOTES: .EMPLOYEE PARKING IS AT EXISTING FRASER SURREY DOCK 1. .TERMINAL SURFACE IS FLAT AND PAVED. ROADWAYS PEDESTRIAN 3. .2 OPERATOR PARKING STALLS AT EACH ELECTRICAL ROOM. 2. LEVEL CROSSING SCALE 1:2000 TERMINAL GUIDELINES AND NOT IN CONFLICT WITH OPERATIONS. WIDTH OF ROADWAY 8m. WALKWAYS ARE PAINTED ON PAVED SURFACE WITH NO CURBS. MIN. ADMINISTRATION BUILDING. OPERATOR PARKING WITHIN SITE AS PER FRASER RIVER (160,000 t) 412920A-BLD-00002

POTASH STORAGE BUILDING

STACKING CONVEYOR CONVEYOR CONVEYOR STACKING STACKING STACKING

412110A-CV-00003 412110A-CV-00003 412110A-CV-00003

RECLAIM CONVEYOR RECLAIM

413210A-CV-00004 413210A-CV-00004 413210A-CV-00004

8m REALIGNMENT ROBSON ROAD 11 DEG (R159.000m) LAYDOWN AREA CONSTRUCTION PORTAL RECLAIMER 413110A-RSC-00001 413110A-RSC-00001 CURVE EXISTING RAILS

180m 414150A-CV-00007 BERTH 9 CONVEYOR WHARF BAG HOUSE DUST COLLECTOR KAMSARMAX 82,000 DWT OUTFEED CONVEYOR TRANSFER TOWER 2 TRANSFER TOWER 3 411450A-BLD-00004 414110A-BLD-00005 411460A-DC-00003 414120A-CV-00005 414310A-SLS-00001 2 PARKING STALLS 2 - 3m x 7m TYP. SHIPLOADER 140m 11 DEG (R159.000m) CURVE 411440A-CV-00002 SUBSTATION / ELECTRIC ROOM 1 418320A-BLD-00007 STORAGE FEED BAG HOUSE DUST COLLECTOR 411330A-DC-00001 CONVEYOR RAILCAR UNLOADING FACILITY STRUCTURE PEDESTRIAN OVERPASS - PART OF SHED 6 100 TRANSFER TOWER 1 SCALE = 1:2000 HANDY SIZE 20,000 DWT 411430A-BLD-00003 2 - 3m x 7m TYP. 2 PARKING STALLS RAIL CAR UNLOADING STATION 411910A-BLD-00001 FOR SEISMIC UPGRADE REFER TO DWG. 40600-MA-DWG-00141

0 8m ELECTRICAL ROOM 3 414820A-BLD-00009

8m LEVEL RAIL CROSSING LEVEL RAIL CROSSING OUTLOADING CONVEYOR OFF SPEC STORAGE 414130A-CV-00006 413910A-BLD-00010 TRANSFER TOWER 4 414140A-BLD-00006 PIT CONVEYOR 411420A-CV-00001 ELECTRICAL ROOM 2 2 - 3m x 7m TYP. 2 PARKING STALLS 411820A-BLD-00008 BAG HOUSE DUST COLLECTOR 414160A-DC-00002 BERTH 10 100m

PURPOSE: Construct a bulk potash export/outbound Seet : Alternatie F Fraser USACE REERENCE NO NWS logistics facility. IN: Hoquiam Surrey ocs, ancouer, B.C. PROECT: Proposed ras Harbor Potash Export acilit COUNTY OF: Grays Harbor ALTERNATIVES ANALYSIS LATITUE: STATE: WA LONITUE: APPLICANT: BHP Billiton Canada Inc. ATU: NAStatePlaneWashinton Hoquiam, Port of Grays Harbor, Adams Street Hoquiam LLC, Emerson Street Hoquiam LLC Sheet o 0 A Legend

Figure 6: Alternative D

Port of Longview Berth 2 PURPOSE: Construct a bulk potash export/outboundSheet 6 of 7 USACE REERENCE NO NWS logistics facility. Seet 0: Alternatie G inder IN: Hoquiam organ Terminals, ancouer B.C. PROECT: Proposed ras Harbor Potash Export acilit COUNTY OF: Grays Harbor ALTERNATIVES ANALYSIS LATITUE: STATE: WA LONITUE: APPLICANT: BHP Billiton Canada Inc. ATU: NAStatePlaneWashinton Hoquiam, Port of Grays Harbor, Adams Street Hoquiam LLC, Emerson Street Hoquiam LLC Sheet 0 o 0 A