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NOTICE This document is for the private information and benefit only of the client for whom it was prepared and for the particular purpose previously advised to Sandwell Engineering Inc. ["Sandwell"]. The contents of this document are not to be relied upon or used, in whole or in part, by or for the benefit of others without prior adaptation and specific written verification by Sandwell. Particular financial and other projections and analysis contained herein, to the extent they are based upon assumptions concerning future events and circumstances over which Sandwell has no control, are by their nature uncertain and are to be treated accordingly. Sandwell makes no warranties regarding such projections and analysis. Sandwell and its corporate affiliates and subsidiaries and their respective officers, directors, employees and agents assume no responsibility for reliance upon this document or any of its contents by any party other than Sandwell's client. Copyright to this document is wholly reserved to Sandwell. Prepared By: July 2005 N.R. Krpan, Technical Manager, Sandwell Engineering Inc. Prepared By: July 2005 S. Grindal, Environmental Co-ordinator, AXYS Reviewed By: July 2005 K. Rosenberg, Project Manager Western Canadian Coal Brule Mine Options Analysis Coal Handling & Transportation July 2005 142874

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Page 1: Western Canadian Coal Brule Mine - Amazon S3s3.amazonaws.com/zanran_storage/a100.gov.bc.ca/ContentPages/75366128.pdf · Western Canadian Coal, Brule Mine Page 2 Options Analysis –

NOTICE

This document is for the private information and benefit only of the client for whom it was prepared and for the particular purpose previously advised to Sandwell Engineering Inc. ["Sandwell"]. The contents of this document are not to be relied upon or used, in whole or in part, by or for the benefit of others without prior adaptation and specific written verification by Sandwell.

Particular financial and other projections and analysis contained herein, to the extent they are based upon assumptions concerning future events and circumstances over which Sandwell has no control, are by their nature uncertain and are to be treated accordingly. Sandwell makes no warranties regarding such projections and analysis.

Sandwell and its corporate affiliates and subsidiaries and their respective officers, directors, employees and agents assume no responsibility for reliance upon this document or any of its contents by any party other than Sandwell's client.

Copyright to this document is wholly reserved to Sandwell.

Prepared By: July 2005 N.R. Krpan, Technical Manager, Sandwell Engineering Inc.

Prepared By: July 2005 S. Grindal, Environmental Co-ordinator, AXYS

Reviewed By: July 2005 K. Rosenberg, Project Manager

Western Canadian Coal Brule Mine Options Analysis

Coal Handling & Transportation

July 2005 142874

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Western Canadian Coal, Brule Mine TOC - ii Options Analysis – Coal Handling & Transportation, Rev. 1, 142874, July 2005

Table of Contents

Western Canadian Coal Brule Mine

Options Analysis – Coal Handling & Transportation

July 2005

Page

EXECUTIVE SUMMARY 1

1 INTRODUCTION 8 1.1 Study Objectives 8 1.2 Terms of Reference for the Options Analysis Study 9 1.3 Project Description 10 1.4 Project History 10

2 SCREENING ANALYSIS 12 2.1 Methodology for Screening Potential Options 12

2.1.1 Transportation 12 2.1.2 Storage and Handling 12 2.1.3 Haul Route and Loadout Locations 12

2.2 Transportation 13 2.2.1 Railroad 13 2.2.2 Road and Trucks 14 2.2.3 Slurry Pipelines 15 2.2.4 Overland Conveyor Belts 16 2.2.5 Preliminary Evaluation of Transportation Systems 16 2.2.6 Conclusions from Preliminary Review of Transportation Alternatives 18

2.3 Storage and Handling 18 2.3.1 Open Stockpiles without Wind Fence 18 2.3.2 Open Stockpiles with Wind Fence Outside the Loadout Loop 19 2.3.3 Open Stockpiles with Wind Fence Inside the Loadout Loop 20 2.3.4 Covered Stockpiles– A-frame 20 2.3.5 Storage and Loadout using Two (2) Silos 21 2.3.6 Other Options 21 2.3.7 Summary 22

2.4 Haul Routes/Loadout Locations 22 2.4.1 Haul Routes/Loadout Locations Options Descriptions 22 2.4.2 Screening Assessment of Haul Routes/Loadouts Locations 26

3 DETAILED ANALYSIS 30 3.1 Methodology 30 3.2 Detailed Ranking Analysis of Transportation options 30

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3.2.1 Introduction 30 3.2.2 Selection Method 30 3.2.3 Road and Trucks 32 3.2.4 Slurry Pipelines 33 3.2.5 Overland Conveyor Belts 34 3.2.6 Option Selection Analysis and Preferred Option 34

3.3 Detailed Ranking Analysis of Storage and Handling Options 35 3.3.1 Introduction 35 3.3.2 Selection Method 35 3.3.3 Open Stockpiles without Wind Fence 37 3.3.4 Open Stockpiles with Wind Fence Outside Loadout 37 3.3.5 Covered Stockpiles – A-frame 38 3.3.6 Storage and Loadout using Two (2) Silos 38 3.3.7 Option Selection Analysis and Preferred Option 39

3.4 Detailed Ranking Analysis of Haul Routes / Loadout Locations 40 3.4.1 Introduction 40 3.4.2 Selection Method 41 3.4.3 Option F1 Brule to Falling Creek Area (south of CN tracks) 42 3.4.4 Option F3 Brule to Falling Creek Area (south of CN tracks) 42 3.4.5 Option H4 Brule to Hasler Flats (west of Hasler) 43 3.4.6 Option H3 Brule to Hasler Flats (west of Hasler) 43 3.4.7 Option W1 Brule to Willow Creek Flats 44 3.4.8 Option Selection Analysis and Preferred Option 44

3.5 Environmental Analysis 45 3.5.1 Introduction 45 3.5.2 Selection Method 45

3.6 Socio-Community and Land Use Analysis 69 3.6.1 Introduction 69 3.6.2 Selection Method 69

4 PREFERRED HAUL ROUTE/LOADOUT LOCATION 80 4.1 Engineering Analysis 80

4.1.1 Falling Creek (F1) Option 80 4.1.2 Hasler (H4) Option 81

4.2 Environmental Analysis 82 4.3 Socio-Community and Land Use Analysis 84

5 PROPOSED DEVELOPMENT PROGRAM 87 5.1 On-Going Field Investigations 87

5.1.1 Environmental 87 5.1.2 Socio-Community and Land Use 87

5.2 EA Application/Permitting Schedule 87 5.3 Overall Project Development Schedule 87

6 CONCLUSIONS / RECOMMENDATIONS A 6.1 Haul Route / Loadout Location A

6.1.1 Engineering A 6.1.2 Environmental A

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6.1.3 Socio-Community and Land Use B 6.2 Storage / Handling B

6.2.1 Engineering B 6.2.2 Environmental B 6.2.3 Socio-Community and Land Use B

6.3 Transportation B 6.3.1 Engineering C 6.3.2 Environmental C 6.3.3 Socio-Community and Land Use C

APPENDIX A – SITE MAPS D

APPENDIX B – ROAD MAPS E

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Western Canadian Coal, Brule Mine Page 1 Options Analysis – Coal Handling & Transportation, Rev. 1, 142874, July 2005

Executive Summary

INTRODUCTION

Western Canadian Coal (WCC) is conducting a feasibility study and an environmental impact assessment for the proposed Brule Mine in Northeast BC. A key element of this study is the identification and assessment of options for coal transportation from the mine gate to the point where it can be loaded on either the CN Chetwynd Main Line or the Tumbler Ridge Branch Line. and the storage and handling of the coal.

In early 2005, WCC defined and announced a preferred alternative for coal transportation. The selection was based on studies conducted between 2001 to 2004 to evaluate a range of alternatives for coal transportation. The preferred alternative was coal haul by off-highway trucks via a connector road from the Brule Mine joining up to the Hasler FSR and hauling to a loadout site in Hasler Flats.

At public and agency meetings in the first quarter of 2005, serious objections were raised with this site, and WCC was asked to re-examine alternatives, and to fully investigate options for a loadout away from Hasler Flats.

WCC has retained Sandwell Engineering Inc to lead the option analysis, and to document the assessment and analysis of economic and operational issues, and AXYS Inc to co-ordinate input from other study team members and to document the analysis of environmental and socio-community issues. Both consultants are already involved in feasibility studies for the project. The report assesses transportation, storage and handling options and finally haulage routes and loadout locations with the objective of selecting a system that is economically favourable, meets acceptable standards with respect to protection of the environment, and mitigates potential socio-economic impacts.

Other consultants retained by WCC whose services were engaged to assist in the production of this report are AllNorth for coal haul route and rail loop site assessments, Westmar for loadout design, Knight & Piesold for geotechnical components. RWDI for Air Quality issues, Keystone for Wildlife issues, and Reynier & Associates for land use and public consultation elements. Axys was directly responsible for socio-economic, vegetation and wildlife studies.

Key areas of assessment include:

• Methods of coal transportation

• Coal storage and handling options at the loadout

• Haul road routes and loadout locations

Site selection criteria include:

• Capital and operating costs, including constructability costs

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• Operational constraints, including expansion potential, system flexibility, system reliability and weather factors

• Environmental and socio-community impacts and mitigation options

TRANSPORTATION OPTIONS

Methods of coal transportation analyzed by WCC since 2001 included:

• Railroad

• Road and trucks

• Slurry pipelines

• Overland conveyor belts

• Rail spur from Sukunka Valley to Tumbler Ridge Branch Line

• Rail spur from Sukunka Valley to Chetwynd Main Line.

The high capital cost of establishing long overland conveyor belts for transporting the coal from the mine to the loadout makes this option unacceptable in comparison with available alternatives. This option would be attractive for a mine with a higher production rate and a longer project life.

The major disadvantage of a slurry pipeline system is the high capital cost. The installation of the pipeline and pumping system, plus requirements for a dewatering facility, settling ponds and coal dryer at the loadout location contributes to the cost disadvantage. A certain amount of coal degradation is possible during transit resulting in higher fines content in the final product – a disadvantage when drying and shipping the coal.

Early studies (Sukunka Rail Feasibility Study, July 28, 2004)), conducted by R. Morin of Earth Tech Canada Inc, investigated a rail spur from Sukunka Valley to Tumbler Ridge Branch Line and to the Chetwynd Main Line. These two rail spur options were screened out based on unacceptable capital costs. Environmental impacts of a new corridor are less favourable compared to use of largely existing roads.

From the environmental perspective, transporting coal using roads and trucks is preferred, as the abundance of roads in the area allows for a number of options for route location without the need for significant additional linear development. Most options considered would also require few new creek crossings. This limits potential effects on water quality and fisheries, as well as minimizing wildlife habitat fragmentation and loss. However, increased volume on certain roads may present increased traffic conflicts. Coal haul to the south to the Tumbler Branch Line was eliminated from detailed consideration for the long term coal haul due to long distance and associated cost. Road haul to Chetwynd and Hasler Flats was ruled out due to higher potential socio-community impacts than for other options. The use of the Falling Creek Connector road (largely a low volume traffic system) is expected to limit any potential traffic conflicts.

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Overall, the preferred transportation method involves trucking coal from the mine site to a designated coal loadout facility where the coal is loaded onto rail cars on the Chetwynd Main Line and shipped to Ridley Terminals.

STORAGE AND HANDLING OPTIONS

Coal storage and handling options at the loadout included investigations into:

• Open stockpiles

• Open stockpiles with wind fence (either inside or outside the rail loop)

• Covered stockpiles – A-frame

• Storage/loadout using silos

Engineering studies have concluded that open stockpiles and silos are the more practical approaches to establishing a cost effective operating system. Wind fences/screens with open stockpiles were considered for the Hasler site, but would add to the cost without providing an adequate compensating benefit since wind direction at this site is unpredictable and highly variable and the wind speeds can be very high. The cost of A-frame covered stockpiles is greater than the cost of silos without providing significant operating benefit.

From the environmental perspective, closed storage and handling options are preferred, as they will provide the greatest containment for potential fugitive dust and will limit visual impacts. However, if considered with site specific locations (e.g., buffering effects and wind control of tall or dense vegetation), alternative storage and handling options (e.g., stockpiles with adequate dust emission controls) could also achieve accepted standards established for the protection of the environment and human health.

An air quality screening assessment was conducted for the Hasler, Falling Creek, and Willow Flats locations by RWDI using best available regional meteorological data. Based on the limited available site specific wind data for the six Hasler locations (H1 to H6), and without further study, the conclusion was that wind screens/fences or covered stockpiles (either A-frame or silos) would be required at all Hasler locations. Screening level assessments indicated that open stockpiles were a potentially feasible option for the Willow Creek Flats and Falling Creek Flats sites.

Therefore, in this study, silos are considered appropriate for the short listed Hasler sites, and open stockpile storage is considered appropriate for the Willow Creek Flats and the two Falling Creek Flats location options with the choice dependent on proximity of residences i.e. silos where the loadout location is near a residential area and open storage when the loadout is a greater distance from a residential area.

A fundamental assumption that the options analysis study is based on is that coal storage in open stockpiles is appropriate if there is a sufficient distance between the stockpiles and the closest residence, and that storage in silos is necessary where the loadout is relatively close to residences, such that established standards for ambient air quality are likely to be frequently exceeded. This

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assumption is based on discussions between WCC and staff at the Ministry of Water, Land and Air Protection.

HAULAGE ROUTES AND LOADOUT LOCATIONS

A total of 14 options for combinations of haulage routes and rail loadout locations have been considered by WCC in a series of studies conducted since 2001. This includes additional options identified and evaluated in the Hasler Creek and Falling Creek Flats area subsequent to the public meeting in Chetwynd in March 2005. Work conducted at the various stages of options analysis is systematically summarized in this report for final decision making and for presentation to the public, First Nations, and regulatory agencies. Residents in the proposed Hasler and Falling Creek loadout areas were provided an opportunity to review information and provide input during the study.

In summarizing the studies to date, the engineering consultants’ approach was to first perform a screening level assessment of 14 options that have been studied since 2001. This was an engineering/technical evaluation of the options using grading factors for comparison of constructability issues and economic impacts on the overall coal project. The result was the elimination of those options that could not meet the required economic criteria for development of the project. Short listed options, two at the Falling Creek area (F1 and F3), one at Willow Creek (W1), and two at Hasler (H3 and H4) were subsequently subjected to more detailed engineering, environmental and socio-community analysis with the result that F1, W1 and H4 became the preferred options from an engineering perspective.

The F1 option is located in the Falling Creek area. Access to this loadout option from Highway 97 is via Willow Creek Forest Service Road (FSR) and Falling Creek Road, a distance of approximately 7 km. This loadout requires about 0.7 km of new road construction from Falling Creek Road for access to the site. Open stockpiles are proposed for this location as it is at some distance (6 km) from the nearest occupied residence (a house purchased by Pine Valley Coal / Falls Mountain Coal now providing accommodation for staff) and 7.5 km to the closest privately owned residence. The F1 and H4 options have about the same operating costs over the life of the project under the assumptions made for the study. F1, however, has lower capital costs and is therefore ranked ahead of H4 from a project economic point of view.

The W1 option is located at Willow Creek Flats; this loadout option is the site that is currently being used by Pine Valley Coal / Falls Mountain Coal for their coal loadout operation. Open stockpiles, as used by Pine Valley Coal, are proposed for this location. Preliminary discussions with the current tenure holders indicated a low probability that an agreement could be reached for co-development of the site. With this in mind, the level of effort expended in study of the site was minimal. However, recent indications are that co-development may be viable and this option is therefore being explored more thoroughly. This report however, does not include the results of the recent and ongoing study efforts.

The preferred Hasler loadout option, H4, is to the west of the community of Hasler. The nearest residence (a BC Rail tenanted house) is about 4.3 km away, and the Enersul plant is 3.6 km away. This loadout requires about 4.5 km of new road construction in the Hasler Flats area to provide access to the site from the Hasler FSR. Silos are proposed to prevent release of fugitive dust due

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to higher standards for air quality control required near populated areas. Because of its higher capital cost than F1, it is ranked behind F1 from a project economic point of view.

Engineering

The following table compares the key engineering (technical and economic characteristics) of the preferred haulage routes and loadout options from an engineering perspective: F1 and H4.

* Because of early indications that WCC loadout could not be accommodated at this site, W1 was not evaluated further during engineering assessments for this study. However this site has been subjected to recent ongoing study efforts.

Option No.

Dist Km

Land Ownership

Relative Capital Costs

Relative Operating

Cost

Remarks

F1 Falling Creek

60.1 Crown Land 1.00 1.00 Based on storing coal in open stockpiles 6 km to closest residence 1st in project economics of available alternatives

W1 Willow Creek

65 Crown Land and land lease to Pine Valley

Coal/Falls Mountain Coal

* * Based on storing coal in open stockpiles 1.5 km to closest residence Favourable capital costs, but higher operating costs. Under further consideration.

H4 Hasler

49.7 Crown Land and BC Rail right of way

land

1.20 1.00 Based on storing coal in silos 4.3 km to closest residence 3.6 km to Enersul plant 2nd in project economics

Environmental

For the environmental and socio-community assessments of the loadout options, selection criteria were identified for each environmental discipline and for socio-community and land use issues, ratings were generated for each option, and an overall weighted rating and subsequent ranking was calculated.

Based on these rankings, the following options are rated the highest from an environmental perspective:

#1 – Option F1 and Option F3

#3 – Option F2

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Western Canadian Coal, Brule Mine Page 6 Options Analysis – Coal Handling & Transportation, Rev. 1, 142874, July 2005

#4 – Option W1

Wildlife habitat is generally moderate in the Falling Creek Flats area.

Socio-community and land use

Options in Falling Creek Flats and Willow Creek Flats area were preferred from a socio-community and land use perspective and included: Preferred – Options F1, F2, F3, W1, H5, H6

Preferred Option from Engineering, Environmental and Socio-community and land use Perspectives

Taking into account engineering, environmental and socio-community and land use considerations, the preferred haulage route and loadout option is F1.

* (W1 was not ranked during this study but has been subjected to recent ongoing study efforts).

Option No.

Dist Km

Land Ownership

Capital and Operating

Cost

Environmental Socio-community/land use

Remarks

F1 Falling Creek Flats

60.5 Crown Land Of the options assessed from an engineering

point of view, F1 was determined to have the most

favourable capital and

operating costs

Few sensitive receptors exist within 10km of the loadout site; forest cover provides protection from prevailing winds; no fish-bearing streams within loadout facility footprint; mostly low quality wildlife habitat; no previously recorded archaeological sites in direct conflict or close proximity

Proposed loadout is on Crown Land, 6 km to closest residences owned by Pine Valley Coal / Falls Mountain Coal and 7.5 km to next closest residences.

Based on storing coal in open stockpiles First in project economics of available alternatives

W1 Willow Creek Flats

65 Crown Land and land lease to

Pine Valley Coal/Falls Mountain

Coal

Capital and operating costs of Option W1

were not determined

Brownfield Site; existing loadout footprint No previously recorded archaeological sites in direct conflict or close proximity

Existing loadout is on Crown Land. Pine Valley Coal / Falls Mountain Coal have already purchased residences in the area. The next closest residences are 6 km away.

Based on storing coal in open stockpiles Favourable capital costs, but higher operating costs Under further consideration.

In general, higher ranked or preferred options from a socio-community and land use perspective are located in the Falling Creek area, because it is relatively distant from occupied residences. ,

CONCLUSION

Combining the three disciplines of Engineering, Environmental and Socio-Community and Land Use, this study concludes that the Falling Creek location identified as F1 has the most favourable characteristics for development as a loadout site, as there is a good prospect for resolution of all the engineering, environmental, socio-community and land tenure issues. The favourable economics of this site are based on open stockpiles without a wind fence.

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Willow Creek Flats (W1) would require further negotiations with the tenure holders at the site (Pine Valley Coal / Falls Mountain Coal), before it could be considered as a viable location. However, if an agreement can be reached with the tenure holders, this site has many favourable characteristics for co-development as a loadout site for both coal companies. The favourable economics of this site are based on open stockpiles without a wind fence, and the assumption that some of the infrastructure could potentially be shared

Should the approval process for both the Falling Creek sites (F1 and F3) and the Willow Flats site (W1) fail, WCC would propose the H4 site in Hasler Flats which has the most favourable characteristics of the 6 sites evaluated in the Hasler Flats area, from an Engineering, Environment and Socio-Community and Land Use standpoint. This site, if selected, would be developed using silos for storage of the coal.

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1 Introduction

Western Canadian Coal (WCC) is conducting a feasibility study and an environmental impact assessment for the Brule Mine in Northeast BC. Studies are targeted for completion by the end of July 2005.

WCC has retained the services of Sandwell Engineering Inc. (Sandwell) and AXYS to undertake the Brule Mine - Options Analysis for Coal Transportation, Storage and Handling (Options Analysis). Sandwell is also responsible for the Brule Mine Feasibility Study and AXYS is responsible for the Brule Mine wildlife, vegetation, cumulative effects, and socio-community Environmental Assessment (EA) Study components. For this Options Analysis Study and Report, AXYS is responsible for co-ordinating documentation of the environmental and socio-community issues and Sandwell is responsible for co-ordinating the economic and operational/engineering issues.

1.1 STUDY OBJECTIVES

A key element of WCC’s feasibility study and environmental impact assessment for the Brule Mine is the identification and assessment of options for coal handling and transportation from the mine gate to the point where it can be loaded on either the CN railway Chetwynd Main Line or the Tumbler Ridge Branch Line.

A key concern of WCC is that the Options Analysis addresses the concerns of residents of Hasler Flats. These include, but are not limited to, air quality, noise, health, potential impacts on agricultural land and traffic considerations. Other land users who have expressed concerns include property owners in the Willow Creek Flats and Falling Creek Flats areas, ranchers and farmers, trappers, a holder of a commercial recreation license, a guide/outfitter, Duke Energy (proximity to pipelines in Hasler Flats) and Enersul (impacts on Sulphur piles in Hasler Flats). Some sites would need to be rezoned and some would require removal of land from the ALR. Regulatory agencies have expressed a range of concerns, including air quality and health concerns related to loadout development at Hasler Flats, concern related to removal of land from the ALR, and a desire from a land use perspective to see shared use of a loadout(s) in the Pine Valley, as opposed to development of multiple load-outs.

The intent of this Options Analysis Study is to assess transportation options in four major areas with the objective of selecting a transportation system that is economically favourable, meets acceptable standards with respect to protection of the environment, and mitigates potential socio-community and land use impacts. The following four areas are considered:

• Methods of coal transportation

• Coal handling and storage options at the loadout

• Locations for the coal loadout facility

• Routes for coal transportation by road from the mine to the loadout facility.

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The latter two areas of study have been combined such that 14 combination of coal haul routes and loadout locations were considered.

This Options Analysis Report summarizes the site selection process for the purposes of the following:

• Fulfilling requirements for alternative analysis for EA submission

• Demonstrating the rationale for the preferred alternative(s)

• Demonstrating a feasible option for feasibility purposes.

1.2 TERMS OF REFERENCE FOR THE OPTIONS ANALYSIS STUDY

The Options Analysis Report will:

• Define conceptually all options considered

• Define the option selection parameters appropriate for this study and a simple accepted/standard methodology for option evaluation (e.g. multiple account evaluation); including criteria for threshold levels for option/site selection (e.g. acceptable dust fall levels, noise thresholds, etc), and identify valued ecosystem components and sensitive receptors

• Summarize very briefly the options eliminated by WCC at a screening level, and the rationale for the decision (i.e. not feasible due to engineering parameters/cost or unacceptable based on impact parameters/fatal flaw considerations).

• Summarize, as needed for option /impact evaluation:

─ Relevant aspects of preliminary engineering design for the remaining options (e.g. surveyed rail loops, loadout layouts, information on watercourse crossing requirements, etc.)

─ Relevant baseline environmental and socio-community information, taking into account information gleaned from public meetings, meetings with individuals and meetings with representatives from agencies, local government and industries.

• Summarize selection considerations using the agreed methodology

• Recommend one or more preferred options

• Define preliminary mitigation measures/alternatives for the preferred options.

The final option analysis report will incorporate input received from the residents of Hasler and Willow Creek Flats, who will be given an opportunity to review information, and to provide input. This will be accomplished through local meetings and presentations made by WCC and members of the Options Analysis Study Team.

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1.3 PROJECT DESCRIPTION

The project is located in the eastern foothills of the Rocky Mountains in northeastern British Columbia. The Brule Mine is on the Burnt River Property, which is part of WCC’s Brazion Group of coal properties. The Burnt River Property includes 6 Coal Licenses and one Coal Lease wholly owned and managed by WCC. The Brule coal deposit is at elevation 1000 to 1300 m on a shallow south-easterly sloping plateau, which is truncated to the east and west by the Sukunka River and Brazion Creek. It is adjacent to the recently approved Dillon Mine, but will mine different geologic structures in two separate pits (Brule and Blind). Road access is currently from Highway 29 between Chetwynd and Tumbler Ridge, then 16.6 km along the Sukunka Forest Service Road, 2.7 km on the Lower Burnt Road, and approximately 12.6 km on the Blind Creek Road to the Dillon minesite.

The Brule Mine will produce coal by open pit mining methods, and has potential to produce up to 2 million tonnes per year of PCI (pulverized coal injection) coal for sale in the export market. Detailed pit design and mine plans are currently being developed based on a recent geological model; environmental/engineering studies conducted to date; and on consideration of current and projected market conditions.

The main components of the Brule Mine at the minesite include the open pits, waste rock dumps, crushing facilities, heavy media wash plant, and mine site buildings such as truck maintenance shop, office/dry complex and warehouse. A new power line will be constructed to the minesite.

WCC has the option of hauling Brule coal to the Bullmoose loadout for the short term, and is in the process of examining the potential options for a new long term load-out facility at Hasler, Willow Creek Flats or Falling Creek Flats. From the load-out, the coal will be loaded into rail cars and hauled by CN Rail to Ridley Terminals at Prince Rupert, or if required, to the coal terminals in Vancouver.

Mine construction is scheduled to commence in mid 2006 and raw coal production and coal haul in fall 2006. Clean coal production is targeted for late 2007. Engineering and environmental work was initiated by WCC in 2002 and is ongoing. It is expected that the Application Report will be submitted to the Environmental Assessment Office in October 2005.

1.4 PROJECT HISTORY

Teck Corporation (Teck), the previous coal license holder, did extensive work on the property from 1975 through 1985. Cumulative exploration work totalled 227 drill holes, 3 adits and 2 bulk sample pits. Property resources were estimated to be in excess of 39 million tonnes, primarily in 3 main mineable seams - Seam 60, and the Upper and Lower seams (Teck 1983). Since acquiring the property, WCC has conducted further development work, including an extensive drill program on the Brule Mine site during 2004.

Teck undertook environmental studies at the site in the late 1970’s and early 1980’s as part of the mine approval process at that time. WCC initiated studies in 2002, many of which are ongoing. Data are being gathered to complement and confirm the earlier studies and provide information required for the environmental impact assessment. Much of the

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environmental information submitted for Dillon Mine permit applications is also relevant to the Brule Mine. Baseline report sections of the Dillon Mine Mines Act Permit Application (submitted June 17, 2004 and updated in August, 2004) present much of the known information for the Blind Creek drainage, in which most of the Brule Mine will be situated.

WCC and various consultants commenced feasibility studies on the project in 2004. Several different rates of production based on the then-known reserves were considered. Following further exploratory drilling in 2004 geological models were updated and a new mine plan developed for an open pit mine capable of producing up to 2 Mtpa of product coal. Detailed feasibility studies currently in progress are scheduled to be completed about July 2005.

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2 Screening Analysis

The intent of the Options Analysis is to assess the potential coal handling and transportation options available for meeting WCC’s transportation requirements for handling the annual Brule Mine coal production. The objective is to select a transportation system that is economically favourable, meets acceptable standards with respect to protection of the environment, and mitigates potential socio-community and land use impacts.

2.1 METHODOLOGY FOR SCREENING POTENTIAL OPTIONS

2.1.1 Transportation

Railroad, road/truck, slurry pipelines, and conveyor belt options were screened by developing a matrix chart to compare characteristics of each of the four modes of coal transportation considered for the Brule Project. Section 2.2.5 provides a detailed description of the systems and an acceptability ranking of very high, high, medium, and low for various elements of each transportation system.

2.1.2 Storage and Handling

The five options for storage and handling, open stockpiles, open stockpiles with wind fence either outside or inside the rail loop, covered stockpiles (A-Frame), and storage using 2 silos were screened by comparing physical and operational characteristics. The analysis in Section 2.3 resulted in the rejection of one option because of personnel safety issues leaving three options for detailed analysis in Section 3.3.

2.1.3 Haul Route and Loadout Locations

This section of the report presents the methodology and rationale for screening the options that were considered for the haul route and loadout locations. The overall objective is to reduce the “long list” of 14 loadout location options to a more manageable “short list” to be considered in more detail in Section 3.4, Detailed Ranking Analysis of Haul Routes/Loadout Locations.

The following subject areas are considered in this section of the report:

• Locations for the coal loadout facility;

• Routes for coal transportation by road from the mine to the loadout facility

Options were ranked based on the anticipated relative operating and capital costs, constructability (volume of cut/fill earthworks and number of bridges), status and availability of land holdings, restrictions to development of land due to zoning or inclusion in the ALR, and environmental (number of water crossings, proximity of facility to watercourses). These parameters were compared for each option by using the following simple ranking process:

• A - acceptable

• B - less favourable and with significant constraints

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• C - unacceptable

Two different road access routes from the mine to Hasler were investigated. The Hasler Connector Road, designated HR I, runs approximately 45.0 km north from the Brule Mine via the Talisman High Grade Road –Talisman Mink Highhat Road – Hasler Forest Service Road. The second route, designated the Hasler Connector Road HR II, runs approximately 61.5 km in a circuitous route in a north-easterly/westerly/north direction. The HR l road, shorter than HR II was selected as the connector for all the H l through H6 haul route and loadout options. Falling Creek options designated as F1 through F3 are connected via FR 1, the Falling Creek Connector Road which is approximately 60.1 km in length. Maps showing locations of the roads are included in the appendices.

The results of the ranking of options is shown in Table 2.4.2.

Since some of the options did not meet the minimum project objectives, they were eliminated very quickly; hence no analysis of the environmental and socio-community issues was needed at the initial screening level stage.

2.2 TRANSPORTATION

A range of alternatives for transporting coal from Brule Mine to existing railroads have been considered since 2001. Results of these analyses were documented during the screening analysis. The options included:

Railroad

Road/trucks

Slurry Pipelines

Overland Conveyor Belts

Relevant considerations which are specific to the Brule Mine are: (1) proposed annual production level, (2) length of mine life, and (3) extreme weather conditions. Brule Mine has a relatively low proposed annual production level of 2 Mtpa and a relatively short mine life of up to 15 years. Also extreme weather conditions in the area limit the use of some of the transportation options.

The following sections briefly describe the transportation alternatives and their suitability in the context of the Brule Mine.

2.2.1 Railroad

Rail transportation is by far the most common and widely used mode of transport for hauling coal over long distances. A railway system provides an efficient and reliable operation between the mine(s) and ship-loading terminal with low labour requirements and relatively low maintenance and operating costs. The inherent efficiency of rail transportation for moving bulk commodities is well recognized. The low rolling resistance of steel wheels on steel rails and the ability to string the cars close together to reduce wind resistance, result in high output

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per unit of input, e.g. high tonne-miles per unit of labour or fuel. However, high quality roadbed and track requirements and large fixed investment in locomotives and rolling stock make rail a very capital intensive mode. The gradients must be very low (generally less than 2 per cent and preferably not much over 1 per cent) due to the massive weight of trains. This means that adverse geographic conditions such as large bodies of water or steep grades can greatly affect the feasibility of rail transport. The high capital intensity and long-lived assets make rail appropriate for long-term, long distance, high volume movements of bulk commodities such as coal. The economic haul distance is generally between 100 to 2000 miles.

A railway system can utilize diesel-electric or totally electric motive power with bottom or rotary dump cars, and has excellent potential for higher throughput with minimal increases in capital and operating costs. However, the high initial capital cost does not favour the use of rail for a relatively low volume coal throughput such as the up to 2 million tonne per year coal production scenarios of this study. In coal transportation studies, cursory reviews of electric locomotives have been conducted, but in all cases, the higher initial capital over diesel electric locomotives made electrified railway less favourable than diesel.

It was assumed for the purpose of this study that existing rail infrastructure would be used to transport Brule Mine coal to the port.

The option of developing a rail spur into the Sukunka Valley to loadout coal from the Brule Mine (and from a potential Sukunka Mine) was considered in 2004. Based on high capitals costs, and the relatively small volumes of coal, this option was rejected without additional evaluation in this study.

2.2.2 Road and Trucks

A truck and roadway system provides more flexible operations for short distance coal haulage (less than 100 km); with relatively lower initial capital costs than a railway. Road transport technology, with its higher rolling resistance and smaller vehicle size, is inherently less technically efficient than rail. The primary advantages of road transport in general are operational flexibility and lower capital outlays for the roadbed. In the study area, the existence of a number of resource roads which can be connected to provide an appropriate haul routes, further lowers capital costs. Gradient and curves are much less of a problem for trucks compared to railways, with grades of up to 10% being acceptable, depending on the type of truck selected.

The various truck sizes and configurations available for this type of operation range from single unit dump trucks to tractor-trailer units, and tractor-trailer units with an additional trailer (configured as a "B-train"). Most of these combinations are available with either end, side or bottom dump capabilities. “Highway trucks”, which are permitted to travel on highways, are smaller vehicles with a maximum gross vehicle weight of 63,500 kg, while “off highway trucks” have a higher capacity which is limited by the load capacity of the haul roads and bridges over which they are travelling and on the specifications of the truck type. For evaluation in this study, it is assumed the use of side dump 50 tonne B train configuration haulers with 2 haulage units which haul 100 tonnes per trip. Larger off-highway trucks with capacities up to 250 tonnes are available, but these are normally used for shorter hauls within a mining operation.

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The relatively small shipment size and high running costs make trucking most suitable for lower volumes of coal (less than 4 million tonnes per year) and short hauls (maximum economic distance in the order of 100 miles but shorter distances much more favourable and more typical).

2.2.3 Slurry Pipelines

Slurry pipelines, which are operated similarly to oil pipelines, can transport coal suspended in water or some other liquid. Slurry pipelines have several potential advantages which include:

• Efficient movement of crushed coal over a variety of terrains with acceptable grades up to and exceeding 20% depending on the type of mobile equipment used for construction maintenance of the pipeline.

• Narrower right-of-way requirements than railways and roads with overall less land requirement

• Much less labour to operate (about 1/8), and about half as much steel and other supplies when calculated over a 30-year period than those of a railway of comparable capacity

• A large proportion of the costs (in the order of 70%) involved in slurry pipelining are invested in the initial construction of the line, pumping and dewatering stations. Because operational costs are low, the total costs of moving coal during the life of the line do not increase in proportion to general inflationary increases while a major portion of railway costs are operational costs and would increase with inflation.

Slurry pipelines also have a number of important limitations such as:

• High capital outlays with little or no adaptability to changes in demand make slurry pipelines suitable only where there is virtual certainty of large volume movements for a long project life.

• Limited capability to increase the throughput capacity without addition of a new pipeline.

• A long distance slurry pipeline has only one source and one destination, and because each application is unique a pipeline cannot be used interchangeably with other materials.

Slurry pipelines bring some potential environmental management challenges because of the amount of water required for operation. Water requirements are substantial (about one tonne of water for each tonne of coal). This is of special concern in areas where water supplies are scarce. There is also the problem of preventing water pollution at the end of the pipeline where the coal is separated from the water (potentially resolved by expensive recirculation). Water pollution could also arise from infrequent discharges along the route. This would arise if a section of pipe has to be emptied to clear blockages or to repair the pipe or pumps.

The cold northern climate also poses major problems to slurry pipeline construction and operation. A year-round pipeline system would have to be insulated and/or heated to prevent

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freezing. Currently no long distance commercial slurry pipeline exists in areas where freezing is a problem.

There are a number of long distance slurry pipelines transporting coal. Two have been constructed in the U.S.

2.2.4 Overland Conveyor Belts

Overland conveyor belts have been used to transport a wide variety of commodities, including coal, over distances varying in length from a few metres to hundreds of kilometres. An overland conveyor system usually consists of several single flight conveyors. The length of each flight is normally limited by the maximum tension rating of the belt. New developments such as nylon belting, steel cord belting and cable belting have increased belt tension ratings to permit increases in the length, in some cases, up to 16 kilometres.

The key to the success of a belt conveyor installation over other transport systems is its low operating and maintenance costs. Over time, this economy of operation and the conveyor's ability to deliver a reliable and steady flow of material, results in a low cost per tonne.

A belt conveyor system, however, requires high initial capital outlays. In order to reduce capital costs and maximize the benefit of the reduced operating costs it is desirable to select a minimum conveyor size which will be operated virtually continuously and at its rated capacity. It may be possible to increase throughput on an existing system by increasing the speed of the belt.

There are concerns with using belt conveyors in an extremely cold climate. Bearings, drives and other mechanical equipment must be designed to withstand extreme temperatures, and must be kept well lubricated with low temperature lubricants. Ice may build up unevenly on the belt and idlers, causing belt run-off and eventual spillage. Horsepower requirements are normally greater for cold weather operations due to increased friction resistance.

2.2.5 Preliminary Evaluation of Transportation Systems

The transportation alternatives evaluated in this section are all proven systems for the transport of commodities in a variety of applications, and all have inherent advantages and disadvantages.

A matrix chart was developed to compare the characteristics of each of the four alternative transportation modes considered for application in this study. Table 2.2-5 summarizes the major features of each mode.

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Table 2.2-5 Comparison of Overland Transportation Systems

TRANSPORTATION ALTERNATIVE

ITEM Railroad Road/Trucks Slurry Pipelines Overland Conveyor Belts

Initial Capital Costs Very High Medium High High

Maintenance Costs Low Medium/High Low Low

Operating Costs Medium High Low Low

Labour Requirements Low High Low Low

Earthworks High High Medium Medium

Right-of-Way Requirements High Medium High High

Weather Factor Low/Medium Medium Medium Low/Medium

Expansion Potential Excellent Good Low Good

System Reliability Excellent Good Excellent Excellent

Terrain Restrictions Maximum adverse grade of 1.5%

Maximum adverse grade of 10% Similar to oil pipelines Maximum adverse

grade of 27%

Route - direct, indirect Indirect Indirect Direct Direct

Environmental Impact - typical Medium/High Medium High High

Public Access Along Right-of-Way Limited Easy Limited Limited

Backhaul Potential Excellent Good None None

Haul Distance Economics 100 to 2000 miles up to 100 miles up to 1000 miles up to 150 miles

Volume Throughput Requirements (annual) 1.0 to 20.0 million tons up to 4 million tons 1.0 to 5.0 million tons 1.0 to 20.0 million tons

Other Similar Applications Several rail systems in North America

Mostly for short distance hauls A few up to 270 miles Mostly for short distance

hauls

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2.2.6 Conclusions from Preliminary Review of Transportation Alternatives

Based on a preliminary review of the mine to loadout transportation alternatives and the projected annual throughput of up to 2 million tonnes of coal, the road/trucks, belt conveyor and slurry pipeline alternatives warranted further consideration. The railway alternative was dropped in 2004 because it has very high initial capital costs and would be more suited for a much higher production scenario.

The road/trucks system alternative has medium initial capital, good expansion potential and good system reliability and appears to be ideally suited for the 2.0 million tonnes per annum scenario for a travel distance up to 100 miles, with favourable economics compared to other options.

The belt conveyor alternative is considered only for short distance applications because of the high initial capital cost. However, because of the high initial capital cost, this alternative must handle a high volume throughput to offset this cost. Also, it is a single source/single destination type of application with limited potential for carrying other types of materials at any one time.

The slurry pipeline is an interesting concept of transportation and is proven technology. However, the main concern is the amount of water required to transport the coal and the inherent problems such as source of water, water disposal at the destination, and potential freeze-up of system should there be any shutdown in flow. This alternative is also a single source/single destination type of application, similar to the belt conveyor alternative.

The transportation alternatives that are carried forward to the detailed analysis include road/trucks, conveyor belts and slurry pipelines.

2.3 STORAGE AND HANDLING

This section summarizes the initial evaluation and screening of the alternatives for storage and handling of coal. The April 2005 report prepared by Westmar Consultants Inc. reviewed five options for the storage and handling of coal at the Hasler Flats location. The five options include:

• Open stockpiles without wind fence

• Open stockpiles with wind fence outside loadout loop

• Open stockpiles with wind fence inside loadout loop

• Covered stockpiles – A-frame

• Storage/loadout using silos

The following are brief descriptions and key engineering/technical features of the options, together with critical issues that would eliminate any option from further evaluation.

2.3.1 Open Stockpiles without Wind Fence

The arrangement for this option consists of:

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• A truck dump with 100-tonne capacity hopper to receive coal

• An apron feeder to feed coal from the receiving hopper to a belt conveyor

• A belt conveyor to transport coal from truck dump to the stockyard

• An open storage area

• A stacker/reclaimer to stack and reclaim coal to and from the stockpile

• A belt conveyor transporting reclaimed coal from stockpile to the railcar loadout bin

• A loadout bin used to load coal into railcars

The key engineering and technical features of this option include:

• Feed rate of 550 t/h from truck dump to storage

• Stockpile capacity of up to 25,000 tonnes

• Reclaim rate to railcar loadout of 3,000 t/h

• Loading of 125 railcars in five (5) hours.

This option uses proven technology for the storage and handling of coal. There does not appear to be any critical issue that would eliminate this option from a detailed analysis.

2.3.2 Open Stockpiles with Wind Fence outside the Loadout Loop

The arrangement for this option consists of:

• A truck dump with 100-tonne capacity hopper to receive coal

• An apron feeder to feed coal from the receiving hopper to a belt conveyor

• A belt conveyor to transport coal from truck dump to the stockyard

• An open storage area

• A stacker/reclaimer to stack and reclaim coal to and from the stockpile

• A wind fence for dust reduction

• A belt conveyor transporting reclaimed coal from stockpile to the railcar loadout bin

• A loadout bin used to load coal into railcars

The key engineering and technical features of this option include:

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• Feed rate of 550 t/h from truck dump to storage

• Stockpile capacity of up to 25,000 tonnes

• Reclaim rate to railcar loadout of 3,000 t/h

• Loading of 125 railcars in five (5) hours

This option uses proven technology for the storage and handling of coal. There does not appear to be any critical issue that would eliminate this option from a detailed analysis.

2.3.3 Open Stockpiles with Wind Fence inside the Loadout Loop

This arrangement for this option is very similar to the open stockpile with wind fence outside the rail loop option described above in 2.3.2. It has the same engineering and technical features. The only exception is that the stockpile is located inside the rail loop.

Westmar indicated that because of the stockpile being located inside the rail loop, a personnel overpass and additional conveyor lengths are required.

Westmar did not study this option further in their study because

• It is very similar to the open stockpile with wind fence outside rail loop option

• Because the stockpiles would be placed inside the loadout loop rather than on the outside on the side that is furthest away from residences/Enersul plant, this option causes the stockpiles to be closer to properties they could negatively impact

• Potential access and personnel safety issues when train-loading operations are in progress

This option was not advanced for further detailed analysis and was eliminated from the study because of the negative safety issues.

2.3.4 Covered Stockpiles– A-frame

The arrangement for this option consists of:

• A truck dump with 100-tonne capacity hopper to receive coal

• An apron feeder to feed coal from the receiving hopper to a belt conveyor

• A belt conveyor to transport product to the stockyard

• Storage of coal inside an A-frame building

• An overhead tripper conveyor system mounted along the apex of building to place coal onto stockpile

• A portal reclaimer to reclaim coal from the stockpile and place coal onto a belt conveyor

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• A belt conveyor to transport reclaimed coal from stockpile to the railcar loadout bin

• A loadout bin used to load coal into railcars

The key engineering and technical features of this option include:

• Feed rate of 550 t/h from truck dump to storage

• Covered storage capacity of 25,000 tonnes

• Reclaim rate to railcar loadout of 3,000 t/h

• Loading of 125 railcars in five (5) hours

This option uses proven technology for the storage and handling of coal. There does not appear to be any critical issue that would eliminate this option from a detailed analysis.

2.3.5 Storage and Loadout using Two (2) Silos

The arrangement for this option consists of:

• A truck dump with 100-tonne capacity hopper to receive coal

• An apron feeder to feed coal from the hopper to a belt conveyor

• A belt conveyor to transport product from truck dump to two (2) concrete silos

• Two (2) concrete silos constructed over the loadout rail track

The key engineering and technical features include:

• Feed rate from truck dump to silos is 550 t/h

• Storage capacity of up to 25,000 tonnes

• Loadout rate of 3,000 t/h or higher directly from silos

• Loading of 125 railcars in five (5) hours

This option uses proven technology for the storage and handling of coal. There are no critical issues that would eliminate this option from the detailed analysis.

2.3.6 Other Options

There are other options for the open stockpiles, but only in terms of equipment type and configuration. Conceptually, these other options would not be substantially different from the open stockpile options described in Sections 2.3.1, 2.3.2 and 2.3.3.

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There are also other options involving enclosure of the stockpiles. These involve different types of enclosed storage facilities, such as concrete dome, Eurosilos, and arches. However, they would not be substantially different, in terms of concept, from the covered storage described in Sections 2.3.4 and 2.3.5.

2.3.7 Summary

The “Open Stockpiles with the Wind Fence inside the Rail Loop” option was eliminated from the list of five options, leaving four options for further evaluation in the detailed analysis. The four options selected for detailed analysis are:

• Open stockpiles without wind fence

• Open stockpiles with wind fence outside the loadout loop

• Covered stockpiles using A-frame building

• Storage and loadout using two (2) silos

2.4 HAUL ROUTES/LOADOUT LOCATIONS

At the start of the screening process fourteen (14) options were considered for the haul routes and coal loadout locations. All of the options are listed and briefly described below.

2.4.1 Haul Routes/Loadout Locations Options Descriptions

Option 1. Brule to Chetwynd using CN Rail yard loadout The coal haul route from the Brule Mine to Chetwynd would be about 55 km via the Blind Creek Road, Lower Burnt Road, Sukunka Forest Service Road, Highway 29 north to Chetwynd, then via 48th Street to the CN Rail Yard. The likely haul trucks would be truck trailer combination with a capacity for 110 tonnes. The on-highway portion of the truck haul would result in a greater number of trucks than for off-highway haul options. This would mean increased traffic on the Sukunka Forest Service Road and Highway 29 from the junction with the Sukunka Forest Service Road to Chetwynd. Each truck will have a smaller payload than off-highway trucks. The truck haul must pass close to a residential subdivision with high residential densities. Proximity to residences would likely require covered storage, and traffic management and safety would be significant issues. The CN Rail loadout is currently constructed and operational. Dominant land tenure for this proposed new loadout site is private (owned by BC Rail); however, there is insufficient room to accommodate the proposed WCC facility within the boundary of BC Rail’s property. High capital and operating costs, as well as challenges with land acquisition and operational constraints make this option unattractive compared with the Falling Creek Flats and Hasler options.

Option 2. Brule to Wolverine Valley using Bullmoose loadout The on-highway truck haul of 93.6 km (smaller trucks, longer distances) will result in a greater number of trucks on the road. Each truck will have a smaller payload than off-highway trucks. The Bullmoose owned loadout is currently constructed and operational. There is no long term commitment from Bullmoose Operating Corporation to WCC to

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provide the railway loadout (WCC has a 2.5 year lease for the loadout, potentially renewable for 2.5 years. High operating costs due to coal haul distance and small payload make this option uncompetitive with the Falling Creek Flats and Hasler options.

Option 3. Brule to Wolverine Valley using Wolverine mine loadout The on-highway truck haul of 110 km will result in a greater number of trucks on the road (smaller trucks, longer distances). Each truck will have a smaller payload than off-highway trucks. The WCC-owned Wolverine loadout is currently under construction and could be operational for Brule Mine start up. Land tenure is Crown land under a License of Occupation to WCC which will be converted into a 30-year lease. High operating costs due to coal haul distance and small payload make this option uncompetitive with the Falling Creek Flats and Hasler options.

Option 4. Brule to Sukunka Valley using Sukunka loadout This option was evaluated in 2004 in relation to a scenario where WCC would develop the Brule Mine and another mine in the Chamberlin Creek area further up the Sukunka Valley. The proposal involves a coal haul to an as-yet unbuilt loadout in the upper Sukunka Valley to service the two mines. The distance to the Sukunka Valley loadout would have been about 70 km. The potential loadout site is in a remote location and requires construction of a rail extension from the Sukunka mainline up the valley. Previous study information provided to WCC indicates that high costs make this option uncompetitive with the Falling Creek and Hasler options. The new rail spur was judged uneconomic under a scenario where two mines would be developed, and could not be supported by the Brule Mine alone.

Option F1. Brule to Falling Creek Area (south of CN tracks) The F1 loadout option is located in the Falling Creek Flats area approximately 55 km west of Chetwynd. Existing access to the proposed loadout from Highway 97 is approximately 7 km on the Willow Creek FSR and then the Falling Creek Road. The total haul distance from the Brule Mine is 60.1 km via a new Falling Creek Connector Road - FR-1. The loadout access requires approximately 700m of new road construction. The Falling Creek Connector Road requires an additional 4.5 km of new road construction (vs. the Hasler Connector route), plus upgrades to existing roads. The rail loadout access road does not transect any known water courses. The coal would be stored in open stock piles. The site is treed. WCC has commissioned modelling of wind sheltering effect of trees and consequent reduction in fugitive emissions with a view to leaving screens of trees on site. The closest occupied residences are 6 km from the site (residences purchased by Pine Valley Coal / Falls Mountain Coal and currently housing company staff). The next closest occupied privately owned residences are 7.5 km from the site. The constructability appears to be good and operability of the loadout configuration appears good. Land tenure is Crown land contiguous with privately owned lands. The privately owned lands are not currently resided on but rather have presently-unoccupied summer cabins.

Option F2. Brule to Falling Creek Area (north of CN tracks) The F2 loadout option is located in the Falling Creek Flats area approximately 54 km west of Chetwynd. Existing access to the proposed loadout from Highway 97 is approximately 6 km on the Willow Creek FSR and then the Falling Creek Road. The total haul distance from the Brule Mine is 62 km via the Falling Creek Connector Road. The loadout access requires approximately 1,700m of new road construction and a level crossing of the railway line. The Falling Creek Connector Road requires an additional 4.5 km of new road construction (vs.

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the Hasler Connector route), plus upgrades to existing roads. The loadout rail access road does not transect any known water courses. The coal would be stored in open stock piles. The privately-owned land is former ranch land, 600 acres in size. It is not currently resided on but rather has presently-unoccupied summer cabins. The closest occupied residences are 4.5 km from the site (residences purchased by Falls Mountain Coal / Pine Valley Coal and currently housing company staff). The next closest privately owned occupied residences are 6 km from the site. The constructability appears to be good and operability of the siding loadout configuration appears good. The loadout track and facility would be located on private land. The land is within the ALR.

Option F3 Brule to Falling Creek Area (also south of CN tracks and west of F1) The F3 loadout option is located in the Falling Creek area approximately 56 km west of Chetwynd. Access to the proposed loadout from Highway 97 is approximately 8 km on the Willow Creek FSR and the Falling Creek Road. The total haul distance from the Brule Mine is 61.5 km via the Falling Creek Connector Road. The loadout access road requires approximately 1,000m of upgrade to the access road and a 45m bridge across Beaudette Creek. The coal would be stored in open stock piles. The closest residences are 7 km from the site (residences purchased by Falls Mountain Coal / Pine Valley Coal and currently housing company staff). The next closest privately owned, occupied residences are 8.5 km from the site. The constructability appears to be good and operability of the siding loadout configuration appears good. Land tenure is on crown land. The site is not in the ALR.

Option W1 Brule to Falling Creek Area (Pine Valley / Falls Mountain Loadout) The W1 loadout option is located in the Willow Creek Flats area approximately 50 km west of Chetwynd. Access from Highway 97 to the proposed loadout is approximately 2km on the Willow Forest Service Road. The total haul distance from the Brule Mine is 65.0 km via the Willow Flats Connector Road WR-I. The Willow Flats Connector Road requires the same 4.5 km of new road construction and upgrades to existing roads as does the Falling Creek Connector, with additional upgrades required to 1,000m of the Willow Flats road. This loadout option utilizes the existing rail infrastructure developed by Falls Mountain Coal (also known as Pine Valley Coal) in 2004. The coal will be stored in open stock piles consistent with the current practice on the site. The closest residences are 1.5 km from the site, being residences that were purchased by Falls Mountain Coal and now house company employees. The next closest privately-owned and occupied residences are 6 km from the loadout site. The loadout is currently constructed and operational. Discussions in 2004 indicated that the site may not be able to accommodate shared loading of the coal between the two companies. . Land tenure is Crown land with a land lease held by Falls Mountain Coal.

Option H1 Brule to Hasler Flats (southwest of Hasler)

The H1 loadout option is located to the southwest of the community of Hasler approximately 800 meters west of Enersul’s sulphur plant. The total haul distance from the Brule mine is 46.5 km via the Hasler Connector Road HR-I and a new 1.2 km access road from the Hasler Forest Service Road. The loadout rail access road does not transect any known water courses. The coal would be stored in silos located approximately 2.0 km from the closest residence. Initial investigations show the constructability of option H1 to be good. Operability of the loadout configuration appears good. Land tenure for both the loadout access road and the loadout site is a mixture of Crown and private ownership. All the land for the loadout

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and access is within the ALR. Silos are assumed for all Hasler options. Mitigation measures to prevent contamination of sulphur piles by coal may be required.

Option H2 Brule to Hasler Flats (southeast of Hasler) The H2 loadout option is located to the south of the community of Hasler approximately 1.8 km east of Enersul’s sulphur plant. The total haul distance from the Brule Mine is 46.3 km via the Hasler Connector Road and a new loadout access road. The loadout requires approximately 1.0 km of road upgrade to the Duke Energy access road. Approximately 1km of new track is required crossing the Hasler Forest Service Road and the Hasler Creek. The loadout rail access requires a new bridge over Hasler Creek. The coal would be stored in silos located approximately 1.4 km from the closest resident. Issues affecting constructability are the rail bridge and the level crossing at the Hasler Forest Service Road. Due to gradients on to the main line, the loadout would be operable with some difficulty. Land tenure is private ownership (Duke Energy and a rancher) for the area of the loadout and the loadout access road crosses Crown land. All the land for the loadout and access is within the ALR.

Option H3 Brule to Hasler Flats (west of Hasler) The H3 loadout option is located to the west of the community of Hasler approximately 2 km from Enersul’s sulphur plant. The total haul distance from the Brule Mine is 47.6 km via the Hasler Connector Road. The loadout requires approximately 2.4 km of new access road construction crossing two small tributaries of the Pine River. The coal would be stored in silos located approximately 3.0 km from the closest resident. A constructability issue is the large amount of excavation required to meet grade requirements. Due to gradients on to the main line, the loadout will be operable with some difficulty. Land tenure is a mixture of Crown and private ownership and is partly within the ALR.

Option H4 Brule to Hasler Flats (west of Hasler) The H4 loadout option is located to the west of the community of Hasler approximately 3.6 km from Enersul. The total haul distance from the Brule Mine is 49.7 km via the Hasler Connector Road. The loadout requires approximately 4.5 km of new access road construction along the base of the Valley bottom. The rail loadout is within 50 m of the Pine River at four locations and there are four potential stream crossings for this option. The coal would be stored in silos located approximately 4.3 km from the closest residence. The constructability of the siding is assumed to be good as it parallels the existing main line. Land tenure is a mixture of Crown and private ownership. The land is partly within the ALR.

Option H5 Brule to Hasler Valley (south of Hasler) The H5 loadout option is located up the Hasler Creek valley directly south of the community of Hasler approximately 3.7 km from Enersul. The total haul distance from the Brule Mine is 45.0 km via the Hasler Connector Road. A portion of the Hasler Forest Service Road requires re-alignment due to the rail siding. A vehicle overpass is required over the loading track and a rail bridge is required over Little Johnsen creek. The coal would be stored in silos located approximately 4 km from the closest resident. The constructability is difficult due to the quantity of cut and fill required for the railway grade. There may be significant issues related to train operations and safety as the current grade is 1.65%. Land tenure is a mixture of Crown and private ownership. The land is not within the ALR.

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Option H6 Brule to Hasler Valley (south of Hasler) The H6 loadout option is located directly south of the community of Hasler approximately 4.2 km from Enersul. The total haul distance from the Brule Mine is 43.0 km via the Hasler Connector Road. A portion of the Hasler Forest Service Road requires re-alignment due to the rail siding. A rail bridge is required over Little Johnsen creek. The coal would be stored in silos located approximately 4.5 km from the closest resident. The constructability is difficult due to the quantity of material required to construct the railway grade and to potential slope stability issues. There may be significant issues related to train operations and safety as the current grade is 1.92%. Land tenure is a mixture of Crown and private ownership. The land is not within the ALR.

2.4.2 Screening Assessment of Haul Routes/Loadouts Locations

A matrix chart for comparative screening analysis of the options is shown in Table 2.4.2. Logic and weighting factors were used to rank the options and to select those that are worthy of detailed analysis. For the screening level assessment the key elements of each option are ranked as being: A – acceptable, B – less favourable with significant constraints, C – unacceptable.

The screening analysis of the 14 options produced the following results:

Option Comments 1 – 4 Removed from further consideration because of high capital and/or operating

costs and/or private ownership of existing facilities without long term certainty of tenure.

F2 Removed from further consideration because of relatively high operating costs. The loadout site would be placed north of the rail tracks and a level crossing installed to transport the coal to the loadout facility. The land is in the Agricultural Land Reserve (ALR) and removal from the ALR is not a certainty.

H1 and H2 Removed from further consideration because the proposed location is on private land. H1 is on land that Enersul has an option to acquire from BC Rail. Enersul is not in favour of a rail loadout being so close to its operation and as a result BC Rail will not sell the land to WCC. Similarly H2 is partly on lands owned by Duke Energy. WCC has been informed by Duke Energy that they are not willing to sell to WCC for a rail loadout development.

H5 – H6 Removed from further consideration because of high capital cost due to steep grades and other constructability and operational issues.

The short listed options that are forwarded for detailed analysis in Section 3.2 are bolded in Table 2.4.2. They include the following:

F1 Located in the Falling Creek area 60.1 km from the Brule Mine

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F3 Located in the Falling Creek area 61.5 km from the Brule Mine

H3 Located in the Hasler Flats area west of Hasler 47.6 km from the Brule Mine

H4 Located in the Hasler Flats area west of Hasler 49.7 km from the Brule Mine

W1 Located in the Willow Creek Flats area 65 km from the Brule Mine

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Table 2.4.2 Relative Screening - Haul Routes/Loadout Locations

Option Optg Cost

Cut &

Fill

Bridges &

Culverts Land Cap

Cost Main Project Impacts

1 C A A C A Limited space at site. Traffic close to residential area. On-highway truck haul will result in a greater number of trucks with smaller payloads than off-highway trucks. The CN Rail loadout is currently constructed and operational. Land is owned by BC Rail. Ruled out due to socio-community factors. Unacceptable option.

2 C A A C A

On-highway truck haul of 93.6 km will result in a greater number of trucks with a smaller payload. The Bullmoose owned loadout is currently constructed and operational. Land is owned by Teck. No long term commitment from Bullmoose to provide the railway loadout. Option ruled out due to high operating costs and lack of long term use.

3 C A A A A On-highway truck haul of 110 km will result in a greater number of trucks on the road with a smaller payload than off-highway trucks. The Wolverine-owned and operated loadout is currently being constructed and will be operational in 2006. The long on-highway haul causing high operating costs makes this option unacceptable.

4 C A A A C The coal haul to the proposed loadout in the upper Sukunka Valley is 70 km. The as yet un-built loadout would be in a remote location and require the construction of a rail spur. Unacceptable option.

F1 A B A A A 700m of new road required. The coal will be stored open stock piles, nearest residence 6.0 km away. Crown land. Requires application for a land lease and rezoning.

F2 B A A B A 1,700m of new road required and a level crossing of the railway line. Nearest residence 4.5 km. Coal would be stored in open stock piles. Land is privately owned but not does not have full time residences on it. Located in ALR. Owner has reportedly been approached to sell land to other coal companies.

F3 B A B A A 1,000m of access road upgrade and a 45m bridge across Beaudette Creek. The constructability appears to be good and operability of the siding loadout configuration appears good. Nearest residence 7 km. Coal stored in open stock piles. No wind protection. Crown land. Requires application for a land lease and rezoning.

W1 B A A B A Utilizes the existing rail infrastructure developed by Falls Mountain Coal. Requires 1,000m of upgrade to the access road. The site may not be able to handle the increase in volume of coal. The loadout is currently constructed and operational. Nearest residence 2 km. Coal stored in open stock piles. Crown land with lease to Falls Mountain Coal. Land has been rezoned from A-2 to M-2.

H1 A A A C B Coal stored in silos. Nearest residence 2 km. Enersul has rights to a portion of the proposed loadout lands and has rejected WCC’s offer to purchase lands. Remaining portion of loadout lands are owned by rancher. Both loadout land and access to loadout land are in the ALR.

H2 A A B C B New rail bridge required. Some difficulties due to railway gradient. Coal stored in silos. Loadout land owned by private rancher and by Duke Energy. Duke Energy has rejected WCC’s offer to purchase. Also requires

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Option Optg Cost

Cut &

Fill

Bridges &

Culverts Land Cap

Cost Main Project Impacts

negotiation with Duke Energy re access road. Open field, limited wind protection. Nearest residence is 1.4 km. Both loadout land and access to loadout land are in the ALR.

H3 A C B B C 2.4 km of new road. Some difficulties due to railway gradient. Coal stored in silos. Large cut/fill volume. Nearest residence is 3.0 km. Both loadout land and access to loadout land are in the ALR. 2.2 km from Enersul plant/ Proximity to the Pine River is an issue.

H4 A C C B B 4.5 km of new road. The loadout is within 50 m of the Pine River at four locations. Has 4 stream crossings). Nearest residence 4.3 km. Coal stored in silos. Location is 3.6 km from Enersul plant Loadout land and access to loadout land are partially in the ALR.

H5 A C B B C A vehicle overpass is required over the loading track and a rail bridge is required over Little Johnston creek. Issues related to train operations and safety as the current grade is 1.65%. Coal stored in silos Nearest residence 4 km.

H6 A C B B C Re-alignment of part of Hasler FRS. A rail bridge is required over Little Johnston creek. Coal stored in silos 4.5 km from closest residence. Slope stability issues with railway construction and operational/safety issues due to 1.92% grade.

• A - acceptable

• B - less favourable and with significant constraints

• C - unacceptable

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3 Detailed Analysis

3.1 METHODOLOGY

This section describes the approach for comparative analysis in areas of engineering/technical, environmental and socio-community characteristics for the options remaining after the initial engineering screening assessment in Section 2. The engineering aspects are reviewed in more detail concerning constructability/operational issues. A ranking system has been used to undertake a relative comparison of costs and impact on overall project economics.

Similar to the approach for engineering, a ranking system was developed for environmental and socio-community issues. The ranking system was used to the compare the potential effects and relative importance of various aspects of the environment and socio-community.

3.2 DETAILED RANKING ANALYSIS OF TRANSPORTATION OPTIONS

3.2.1 Introduction

In the Screening Analysis, four transportation alternatives were discussed. The railroad alternative was discarded from further evaluation because of the very high initial capital cost for a greenfield railroad and the relatively lower annual throughput to justify the high cost.

The three remaining options include:

• Road and trucks

• Slurry pipelines

• Overland conveyor belts

In this section, the three remaining alternatives are evaluated in greater detail to arrive at one preferred option.

3.2.2 Selection Method

The strategy at this point in the study is to reduce the number of options under review to a preferred option. To narrow the number of options examined, consideration is given to the following aspects of each option:

• Initial capital costs

• Annual operating and maintenance costs

• Expansion potential

• System flexibility

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• Weather factor

• System reliability

• Environmental and Socio-community impact

Each of the aspects are entered into a decision matrix and given weights based on their level of importance. The options are then ranked according these aspects. The option that is best for each category receives 10 points, while the others are given lower points in increments of (2), based on their relative merits.

The points are then multiplied by the respective weight to arrive a score for each aspect. The scores are totalled to arrive at a total score for each alternative. The alternative that has the highest score is the preferred alternative.

Initial capital Costs This aspect is given a 20% weight. The initial capital cost for each option is compared and ranked from lowest to highest. The alternative with the lowest cost received a 10, while successively more expensive options received lower scores in increments of 2, based on their relative costs.

Annual Operating and Maintenance Costs This aspect is given a 15% weight. The annual operating and maintenance costs are compared and ranked according to their estimated costs from lowest to highest. The alternative with the lowest costs received a 10.

Expansion Potential This aspect is given a 5% weight. Expansion potential is the ability to handle increased throughput to the system. The alternative with the greatest expansion potential received a 10.

System Flexibility This aspect is given a 5% weight. System flexibility is the ability to handle different grades of coal in the system at any given time. The alternative with the greatest flexibility received a 10.

Expansion and flexibility are combined for a total weight of 10% for overall system flexibility. The alternative with the greatest expansion potential and greatest flexibility received a 10.

Weather Factor This aspect is given a 10% weight. Weather factor is the ability of the alternative to operate year round with little or no effect from adverse weather. The alternative that is least affected by weather received a 10.

System Reliability This aspect is given a 10% weight. The reliability of an option is a measure of an option’s likelihood of breakdown and is based on the following:

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• Type of equipment in use (proven equipment ranks higher)

• Operational redundancy

• Equipment utilization (excessive utilization ranks lower)

• Maintenance required (equipment requiring more maintenance ranks lower)

Again, in this section, the options are ranked in best to worst order.

Environmental and Socio-community Impact Because of its importance to this project, this aspect is given a 35% weight. The environmental impact of an option is the amount of potential adverse effect expected to be imposed on the route’s surroundings as a result of the operations and is based on the following (actual impacts could be highly variable, depending on final routing):

• Fugitive dust generation

• Noise emission

• Other impact to public along route – traffic, hazards, etc

• Stream crossings and effects on water quality and fisheries

• Wildlife habitat fragmentation (through increased access development)

• Habitat loss for wildlife and fisheries

3.2.3 Road and Trucks

Pros and Cons: The advantages of this alternative include:

• Lowest initial capital cost – assuming existing road(s) are used

• Greatest expansion potential – add more trucks

• Can receive coal from more than one source, if required

• System fairly reliable – if one truck breaks down, system does not shut down

• Use of existing access features, so no or limited wildlife habitat fragmentation effects

The disadvantages of this alternative include:

• Highest annual operating and maintenance costs

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• During operations high environmental impact – generation of dust and noise; high traffic volume; offset by reduced clearing and loss of habitat, to extent that existing roads can be used; overall makes this medium environmental impact

• Some routes have fish-bearing stream crossings

• Operation can be affected by severe winter weather

3.2.4 Slurry Pipelines

Pros and Cons: The advantages of this alternative include:

• Low annual operating and maintenance costs

• Relatively low operational environmental impact along route, if wildlife crossings are provided except that route would be constructed through virgin forest and land resulting in high environmental impact

• System can be highly automated

The disadvantages of this alternative include:

• High initial capital cost

• Limited potential for expansion – system designed for certain annual throughput

• Single source and Single destination

• Operation can be affected by adverse weather - freezing

• Require year-round water supply

• Can handle only single grade of coal

• Need to manage discharge, or recycle water, to avoid water pollution at end of pipeline, where coal is separated from water.

• Need for coal dryer at loadout, with emissions issues

• Environmental negative, potential need for stream crossings in fish bearing areas

• New corridor, with potential wildlife habitat loss and fragmentation effects

• System reliability proven only in a temperate climate

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3.2.5 Overland Conveyor Belts

Pros and Cons: The advantages of this alternative include:

• Low annual operating and maintenance costs

• Some potential for expansion

• Operation can be highly automated

• Operation not severely affected by adverse weather

• Good system reliability

The disadvantages of this alternative include:

• Very high initial capital cost

• Single source and single destination

• Can only handle single grade of coal

• Environmental negative constructed through virgin forest and land resulting in high negative environmental impact, potential need for stream crossings of fish-bearing creeks

• Potential wildlife habitat loss and fragmentation effects

3.2.6 Option Selection Analysis and Preferred Option

The following Table 3.2.6 summarizes the selection analysis.

Table 3.2.6 Transportation Method - Option Selection Analysis

Road and Trucks Slurry Pipelines Overland Conveyor Belts

Selection Criteria Weight Points Score Points Score Points Score

Initial Capital Cost 20% 10 2.0 8 1.6 6 1.2

Annual O & M Costs 15% 8 1.2 10 1.5 10 1.5

System Flexibility 10% 10 1.0 8 0.8 10 1.0

Weather Factor 10% 8 0.8 8 0.8 10 1.0

System Reliability 10% 10 1.0 8 0.8 10 1.0

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Environmental Impact 15% 10 1.5 6 0.9 8 1.2

Socio-community and land use 20% 10 2.0 8 1.6 6 1.2

Total 100% 9.5 8.0 8.1

Rank 1 3 2

Based on the selection analysis, the road and truck alternative is ranked first. The other two options are ranked close together and although operating costs are favourable the high capital costs make the alternatives unattractive. The two rejected options also have a less favourable environmental rating, particularly for the construction phase and in case of the slurry pipeline also for the operating phase.

3.3 DETAILED RANKING ANALYSIS OF STORAGE & HANDLING OPTIONS

3.3.1 Introduction

In the Screening Analysis, five storage and handling options are discussed. One option (open stockpiles with wind fence inside rail loop) was discarded from further evaluation. The open stockpiles with wind fence inside the rail loop posed safety issues that made it significantly less attractive than the other four options, with no offsetting advantages.

The four remaining options include:

• Open stockpiles without wind fence

• Open stockpiles with wind fence outside loadout loop

• Covered stockpiles – A-frame

• Storage and loadout using two (2) silos

In this section, the four remaining options are evaluated in greater detail in order to identify the preferred option.

3.3.2 Selection Method

To narrow the number of options examined, consideration is given to the following aspects of each option:

• Capital costs

• Annual operating and maintenance costs

• Reliability

• Environmental impact

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• Socio-community and Land Use impact

Each of the aspects are entered into a decision matrix and given weights based on their level of importance. The options are ranked according these aspects. The option that is best for each category receives 10 points, while the others are given lower points in increments of (2), based on their relative merits.

The points are then multiplied by the respective weight to arrive at a score for each aspect.

Capital Costs This aspect is given a 25% weight. The capital cost for each option is compared and ranked from lowest to highest. The option with the lowest cost receives a 10, while successively more expensive options receive lower scores in increments of 2, based on their relative costs.

Annual Operating and Maintenance Costs This aspect is given a 20% weight. The annual operating and maintenance costs are compared and ranked according to their estimated costs from lowest to highest. The option with the lowest cost receives a 10.

Reliability This aspect is given a 20% weight. The reliability of an option is a measure of an option’s likelihood of breakdown and is based on the following:

Type of equipment in use (proven equipment ranks higher)

• Operational redundancy

• Equipment utilization (excessive utilization ranks lower)

• Maintenance required (equipment requiring more maintenance ranks lower)

Again, in this section, the options are ranked in best to worst order.

Environmental Impact This aspect is given a 15% weight. The environmental impact of an option is the amount of adverse effect expected to be imposed on the loadouts surroundings as a result of the operations and is based on the following:

• Fugitive dust emission (covered and enclosed options ranked higher)

• Noise emission (covered and enclosed options ranked higher)

• Visibility of coal to general public (options with coal not visible ranked higher).

For purposes of the analysis, the rating table assumes an “environmentally sensitive” site.

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Socio-Community and Land Use Impact This aspect is given a 20% weight. The socio-community and land use impact of an option is based on the following:

• Fugitive dust emission (covered and enclosed options ranked higher)

• Noise emission (covered and enclosed options ranked higher)

• Visibility of coal to general public (options with coal not visible ranked higher)

• Distance from residences

• Land ownership / tenure

• Regulatory restrictions on land.

For purposes of the analysis, the rating table assumes a “sensitive” site from a socio-community perspective. That is, that there are residences or other sensitive land uses near the site.

3.3.3 Open Stockpiles without Wind Fence

Pros and Cons: The advantages of this option include:

• Lowest capital cost – 1.0 for comparative purpose

• Storage capacity can be expanded by lengthening the stockpile

• If located in forested area can avoid added cost of wind fence

The disadvantages of this option include:

• High annual operating and maintenance costs – 1.43 times lowest O & M costs option

• Coal stockpile is exposed to weather – wind, rain, etc.

• Less acceptable from environmental impact viewpoint, potential fugitive dust

• Coal stockpile is highly visible to the general public in the area

• Need high reclaim and loadout rates to load 125 railcar in five (5) hours

3.3.4 Open Stockpiles with Wind Fence Outside Loadout

Pros and Cons: The advantages of this option include:

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• Capital cost will be marginally higher than no fence option but can be considered as 1.0 for comparative purposes

• Storage capacity can be expanded by lengthening the stockpile

The disadvantages of this option include:

• High annual operating and maintenance costs – 1.43 times lowest O & M costs option

• Coal stockpile is exposed to weather – wind, rain, etc.

• Less acceptable from environmental impact viewpoint, potential fugitive dust

• Coal stockpile is highly visible to the general public in the area

• Need high reclaim and loadout rates to load 125 railcar in five (5) hours

3.3.5 Covered Stockpiles – A-frame

Pros and Cons: The advantages of this option include:

• Coal stockpile is protected from environment

• More acceptable from environmental impact viewpoint, less chance of fugitive dust

• Coal stockpile is much less visible to the general public in the area than open storage

• Stacking and reclaiming operations can be automated

The disadvantages of this option include:

• Highest capital cost – 1.55 times cost of the lowest capital cost option

• Highest annual operating and maintenance costs – 1.54 times lowest O & M costs option

• More equipment than other options

• Difficult to increase storage capacity, if needed

• Need high reclaim and loadout rates to load 125 railcar in five (5) hours

3.3.6 Storage and Loadout using Two (2) Silos

Pros and Cons: The advantages of this option include:

• Lowest annual operating and maintenance costs – 1.0 for comparative purpose

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• Coal storage is protected from environment

• More acceptable from environmental impact viewpoint, less chance of fugitive dust

• Coal is not visible to the general public in the area

• Less equipment than other options - stacking or reclaiming systems are not required – coal is transported directly from truck dump to silos, resulting in much less handling and potential dust generation

• Higher loadout rate is possible, if required, by increasing rate of feeders below silos

• Operation can be highly automated

The disadvantages of this option include:

• High capital cost but lower than covered stockpile option – 1.28 times cost of lowest capital cost option

• Can only handle two grades of coal with two silos

• Cannot expand storage capacity without adding more silo(s)

3.3.7 Option Selection Analysis and Preferred Option

The following Table 3.3.7 summarizes the selection analysis.

Table 3.3.7 Storage Alternatives - Option Selection Analysis

Open Stockpiles

without Wind Fence

Open Stockpiles with Wind

Fence

Covered Stockpiles

A-frame

Storage & Loadout with 2

Silos

Selection Criteria

Weight Points Score Points Score Points Score Points Score

Capital Cost 25% 10 2.5 10 2.5 6 1.5 8 2.0

Annual O & M Costs

20% 10 2.0 8 1.6 8 1.6 10 2.0

Reliability 20% 10 2.0 10 2.0 8 1.6 10 2.0

Environmental Impact

15% 6 0.9 8 1.2 10 1.5 10 1.5

Socio-Community and Land Use Impact

20% 6 1.2 8 1.6 10 2.0 10 2.0

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Total 100% 8.6 8.9 8.2 9.5

Rank 3 2 4 1

Based on the selection analysis assuming a “sensitive site from a socio-economic perspective”, the Storage and Loadout with 2 Silos option is ranked first, with the Open Stockpile with Wind Fence option ranked second. If WCC selects a loadout site where socio-community effects are a dominant concern, then the preferred option is the Storage and Loadout using 2 Silos. If location of the loadout is at some distance from populated areas, then covered or screened storage is not necessary, and open storage is the preferred alternative.

Marginally higher capital costs for a wind fence and annual upkeep costs result in this versus the without fence option being at a disadvantage with respect to costs. A loadout in a forested area such as F1 would be afforded natural wind protection without need for a wind fence and therefore environmental impact and socio-community and land use impact would be the same as for the wind fence option. The no wind fence option at F1 would therefore rank higher than the wind fence option on the basis of lower costs.

3.4 DETAILED RANKING ANALYSIS OF HAUL ROUTES / LOADOUT LOCATIONS

3.4.1 Introduction

The initial screening of the 14 alternatives and selection of 4 for detailed analysis are described in Section 2.4. The four options that were selected for the detailed ranking analysis are Options F1, F3, H3 and H4. The objective in this section is to reduce the number of options to two for detailed study in the next section of this report.

In the Screening Analysis, fourteen options for haul routes/loadout locations were discussed and screened. In view of the number of potential options available, the initial relative screening assessment reduced the number of practical options for consideration to the following five options:

• Option F1 Brule to Falling Creek Area (south of CN tracks)

• Option H3 Brule to Hasler Flats (west of Hasler)

• Option F3 Brule to Falling Creek Area (east of CN tracks)

• Option H4 Brule to Hasler Flats (west of Hasler)

Option W1 Brule to Willow Creek Flats Area (Pine Valley Coal Loadout site)

In this section, the remaining options are evaluated in greater detail to arrive at two preferred options.

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3.4.2 Selection Method

The strategy at this point in the study is to reduce the first four options under review to two preferred options. To narrow the number of options examined, consideration is given to the following aspects of each option:

• Capital costs

• Annual operating and maintenance costs

• Constructability

• Reliability

Each of the aspects are entered into a decision matrix and given weights based on their level of importance. The options are ranked according to these aspects. The option that is best for each category receives 10 points, while the others are given lower points in increments of (2), based on their relative merits.

The points are then multiplied by the respective weight to arrive a score for each aspect.

Capital Costs This aspect is given a 25% weight. It is assumed that the individual capital costs have been estimated to the same degree of accuracy. The capital cost for each option is compared and ranked from lowest to highest. The option with the lowest cost received a 10, while successively more expensive options received lower scores in increments of 2, based on their relative costs.

Annual Operating Cost for Truck Haul Because of its importance to this project, this aspect is given a 45% weight. In view of the fact that the estimated cost of each truck route is relative to the distance of the truck haul, as well as the driveability (grades and curves), this aspect is very cost sensitive. This aspect has a higher ranking than capital costs since annual operating costs are significantly higher than the initial capital costs and tend to increase over the life of the mine. The annual operating and maintenance costs for trucking up to 2.5 million tonnes per year of coal are compared and ranked according to their estimated costs from lowest to highest. The option with the lowest cost received a score of 10 points.

Constructability This aspect is given a combined 20% weight for (a) the anticipated amount of cut and fill volumes and (b) for known bridge structures. The estimated volume of cut and fill for site preparation and road/rail access is different for each option. A balanced cut and fill is much preferred to a situation where material has to be hauled into the site or removed from the site. A site with minimal cut and fill is preferred over one requiring large volumes as these are subject to a certain degree of risk that the volumes could exceed the estimate.

Likewise, an option with one or more bridges or large culverts is at risk to cost escalation if geotechnical or environmental conditions are not as anticipated.

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In this section, the options are ranked in order of best to worst.

Reliability This aspect is given a 10% weight. The reliability of an option is a measure of an option’s likelihood of not performing to plan. Since all options include a truck haul, it is assumed that each route is just as likely as another to experience a delay or temporary loss of service due to extreme driving conditions. For this reason, this risk assessment weighs the risk of delay or loss of service related to railway access to and from the loadouts. In this case, the grade of the railway roadbed plays an important role in train safety and cycle times at the loadout. Options are ranked from best to worst.

3.4.3 Option F1 Brule to Falling Creek Area (south of CN tracks)

Pros and Cons: The advantages of this option include:

• Use of open stockpiles

• Lowest capital cost

• Requires only 700m of new access road construction

• No bridge crossings required

• Constructability appears to be easy as relatively level area with good access

• No operational difficulties expected

• Land is owned by Crown

The disadvantages of this option include:

• Higher annual operating cost based on a truck route of 60.5 km.

3.4.4 Option F3 Brule to Falling Creek Area (south of CN tracks)

Pros and Cons: The advantages of this option include:

• Use of open stockpiles

• Low capital cost (similar to F1)

• Requires only 1,000m of new access road construction

• Constructability appears to be easy as relatively level area with good access

• No operational difficulties expected

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• Facility would be on Crown land

The disadvantages of this option include:

• Highest annual operating cost based on a truck route of 61.5 km.

• 45m bridge required across Beaudette Creek

3.4.5 Option H4 Brule to Hasler Flats (west of Hasler)

Pros and Cons: The advantages of this option include:

• Lower annual operating cost based on a truck route of 49.7 km

• Highest capital cost

• Coal is stored in silos

• No operational difficulties expected

• Constructability appears to be good

The disadvantages of this option include:

• Requires 4.5 km of new access road construction

• Facility would be on land classified as crown and private

• There are 4 stream crossings

3.4.6 Option H3 Brule to Hasler Flats (west of Hasler)

Pros and Cons:

The advantages of this option include:

• Lowest annual operating cost based on a truck route of 47.6 km

• Coal is stored in silos

The disadvantages of this option include:

• Highest capital cost

• Requires 2.4 km of new access road construction

• Constructability appears to be difficult in order to meet railway grade requirements

• Some operational difficulties due to adverse grade

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Some potential operational difficulties due to adverse grade presents risk to achieving anticipated annual operating cost and reduce reliability. Corrective measures would involve increase in capital cost. Not quantifiable at this level of analysis but justifiable to eliminate this option from the short list, leaving:

F1 – Brule to Falling Creek Area (south of CN tracks) – based on use of open stockpiles

H4 – Brule to Hasler Flats (west of Hasler) – based on use of silos

F3 – Brule to Falling Creek Flats (south of CN tracks) – based on use of open stockpiles.

3.4.7 Option W1 Brule to Willow Creek Flats

The W1 option located at Willow Creek Flats; this loadout option is the site that is currently being used by Pine Valley Coal / Falls Mountain Coal for their coal loadout operation. Open stockpiles, as used by Pine Valley Coal, were proposed for this location. Preliminary discussions with the current tenure holders had indicated a low probability that an agreement could be reached for the co-development of the site. With this in mind, the level of effort expended in study of the site was minimal. However, recent indications late in this study are that co-development may be viable and this option is therefore being explored more thoroughly. It is not included in this report because no acceptable scenario has yet been defined.

3.4.8 Option Selection Analysis and Preferred Option

The following Table 3.4.8 summarizes the results of the engineering selection analysis on options F1, F3, and H4.

Table 3.4.8 Detailed Option Selection Analysis- Haul Route and Loadout Options - Economic and Constructability Aspects

Option F1 Option F3 Option H4

Selection Criteria

Weight Point Score Point Score Point Score

Capital Cost 25% 10 2.5 8 2.0 6 1.5

Annual Operating Cost 45% 8 3.6 6 2.7 10 4.5

Constructability Cut/Fill Volume 10% 8 0.8 10 1.0 8 0.8

Constructability of Bridges 10% 10 1.0 6 0.6 6 0.6

Reliability 10% 10 1.0 10 1.0 10 1.0

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Total 100% 8.9 7.3 8.4

Rank 1 3 2

3.5 ENVIRONMENTAL ANALYSIS

3.5.1 Introduction

General environmental assessments were integrated into the option analysis for selection of 1) coal transportation methods, and 2) coal storage and handling at the loadout. These analyses are tabulated and discussed in preceding sections.

This more detailed environmental option comparison was conducted to assist in the selection of the preferred loadout site amongst the Hasler, Falling Creek, and Willow Creek options.

For the detailed environmental analysis, the study considered the four options that were selected for the detailed ranking and engineering analysis (Options F1, F3, H3 and H4), as well as the other options in the Hasler and Falling Creek areas (for a total of 10 options). This includes haul route/loadout options in the Hasler area (H1-H6) as well as those in the Falling Creek area (F1-F3, W1). The four other options were not considered in detail as they were eliminated from consideration early in the study.

In this section, a detailed ranking analysis for environmental issues was conducted for the 10 haul routes/loadout options (described above). The relevant disciplines included:

• Air quality • Water quality • Fisheries • Terrain • Wildlife • Archaeology and Historical Resources The following describes the selection method and rating system for the options.

3.5.2 Selection Method

The detailed assessment was conducted using the following steps:

• For each discipline, 3-6 criteria were identified (Table 3.5.1). This information was provided by discipline experts.

• For each criteria, a rationale and basis for rating options were described (Table 3.5.1).

• Each discipline was then ranked for each option using the above criteria (Tables 3.5.2a-f). A three class rating system was used (low, moderate, high), based on the

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potential for adverse effects on the resource or discipline. Additional details on the pros and cons of each option were also provided to support each rating.

• The relative importance of each discipline was then determined, using a percent value (10-25% for each discipline). This information was used to calculate the overall rating for each option (Table 4.2.1).

• A final ranking was determined for each option (1-10) (Table 4.2.1).

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Table 3.5.1 Criteria and Rationale for Loadout Options for Environmental Disciplines

Discipline Criteria Rationale and Basis for Rating

1) Proximity to Sensitive Receptors (i.e. residences, other industry, streambeds, etc.)

• If residences are with 10km of the loadout site then the potential for human health impacts from fugitive dust must be assessed.

• Deposition of fugitive dust to rivers is an environmental concern. • Deposition of coal dust to neighbouring industry is of concern (i.e. Enersul

concerned with contamination of their sulphur piles by coal dust). 2) Stockpile Enclosed? • If the coal stockpile at the loadout is enclosed then the potential for fugitive coal

dust impacts is greatly reduced (wind erosion from the coal stockpile is the major concern in terms of emissions and air quality).

• If the coal stockpile is not enclosed and there are nearby residences then ambient monitoring of PM10 and PM2.5 may be required for one year prior to submitting the EA.

3) Number of Sensitive Receptors Within 10km of Loadout

• The greater the number of sensitive receptors the higher the potential for dust impacts.

4) Stockpile Location Relative to Predominant Wind Direction

• Higher potential for dust impacts if sensitive receptors are located downwind of the loadout site.

5) Stockpile Location Relative to Terrain/Surface Features

• Lower potential for dust impacts if the loadout is ‘shielded’ from the predominant wind by high terrain or forested areas.

• Lower potential for dust impacts if the smaller cross-section of the loadout coal stockpile is perpendicular to predominant wind direction.

Air Quality

6) Distance and Location of Haul in Relation to Sensitive Receptors

• The longer the haul route the higher potential for dust impacts. • The closer the sensitive receptors, the greater the potential for dust impacts.

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Discipline Criteria Rationale and Basis for Rating

1) Chronic toxicity with respect to selenium, other metals, and sulphate and nitrate

• Receiver flow: lower impact in Pine River (high flow) in comparison to tributaries (lower flow).

• Lentic versus lotic receiving water environment (potentially greater impact for selenium bioaccumulation and food-chain transfer in lentic habitat)

• Fish utilization of receiver • Waterbird use of receiver

2) Exceedence of water quality objectives (aquatic life and drinking water criteria)

• Receiver flow: lower impact in Pine River (high flow) in comparison to tributaries (lower flow).

• Fish utilization of receiver • Waterbird use of receiver

Water Quality

3) Exceedence of sediment quality objectives

• Receiver flow: lower impact in Pine River (high flow) in comparison to tributaries (lower flow).

• Substrate type of receiving environment: gravel and cobbles (less potential for impact) in comparison to silts and clays (greater potential for accumulation of fine-grained sediments and metal accumulation)

1) Direct effects on fish habitat

• Proximity of loadout to Pine River (short-term construction effects, long-term coal dust and sediment effects)

• Proximity of loadout to fish-bearing streams (bridge construction issues, surface drainage management)

2) Fish Passage Issues • Access road upgrades at existing fish-bearing stream crossings • New crossings of fish-bearing streams

Fish

3) Long-term downstream siltation effects

• Proximity of loadout to fish-bearing streams • Access road stream crossings (upgrades and new construction)

1) Geohazards • Landslide potential • Slope stability • Liquefaction

2) Foundations shallow/deep

• Foundation types/ depth • Bearing capacity/ settlement • Liquefaction

Terrain

3) Flood potential 200 yr • Flooding

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Discipline Criteria Rationale and Basis for Rating

1) Habitat Availability • Modeled habitat quality - based on mapped wildlife habitat ratings for key species, where available

• Existing land use - e.g., agriculture = low value; undisturbed forest = higher quality

• Proximity to disturbance features - e.g., transportation corridors, industrial facilities, communities; the closer to these, the lower the habitat quality

• Proximity to riparian habitat/movement corridors - i.e., generally higher quality wildlife habitat closer to riparian areas

• Sensory disturbance – buffering effects of vegetation and proximity to high quality habitat

2) Disruption to Movement Patterns

• Landscape fragmentation (e.g., increased road density = lower rating) • Traffic volume (e.g., higher road use) - limiting daily or seasonal wildlife travel

Wildlife

3) Mortality Risk • Road kills – increased traffic volume • Hunting or poaching – increased access • Health concerns – exposure to contaminants

Archaeology & Historical Resources

Archaeology Definition: Archaeological sites contain the physical remains of past human activity. Sites may include both artefacts and features (e.g. stone tools, hearths). Archaeological site types may include campsites, quarries, burials, middens, caches, hearths or historic structures. Archaeological sites are protected under the British Columbia Heritage Conservation Act if they pre-date 1846,

• Proximity to previously recorded archaeological sites (site file searches to be conducted using R.A.A.D (Remote Access to Archaeological Data) and H.R.I.A. (Heritage Resource Inventory Application) • Proximity to terrain features used as indictors of moderate to very high archaeological potential (e.g. knolls, eskers, terraces or benches near rivers and streams , well drained features in otherwise saturated terrain)

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Discipline Criteria Rationale and Basis for Rating

contain human remains, aviation history or shipwreck remains. Some post-1846 sites may also be protected on a site-specific basis if historic significance is demonstrated and accepted by the British Columbia Ministry of Sustainable Resource Management, Archaeological Planning and Assessment Section. Traditional Land Use (Heritage & Sacred Sites) Definition: Traditional land use sites may be protected under the British Columbia Heritage Conservation Act as archaeological sites if they pre-date 1846, contain human remains, aviation history or shipwreck remains. Many historic period traditional land use sites, although often of significance to aboriginal communities, fall short of this legislation.

• Proximity to previously recorded archaeological sites (site file searches to be conducted using R.A.A.D (Remote Access to Archaeological Data) and H.R.I.A. (Heritage Resource Inventory Application) • Proximity to terrain features used as indictors of moderate to very high archaeological potential (e.g. knolls, eskers, terraces or benches near rivers and streams, well drained features in otherwise saturated terrain) • Incorporation of general knowledge of the development area and local region in relation to aboriginal traditional and current land use

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Discipline Criteria Rationale and Basis for Rating

Heritage sites (e.g. post 1846 pack trails, cabins, historic campsites or food processing sites) and sacred or ceremonial sites may be of importance within the context of First Nations Treaty Rights and/or Aboriginal Rights or Title. Site-specific TLUS information is considered proprietary to participating aboriginal communities. Traditional Land Use (Environmental Sites) Definition: Traditional Land Use Sites may include sensitive or important environmental areas or animal habitat areas (e.g.. ungulate calving areas, moose licks, bear dens, berry picking or medicinal plant collecting areas) These sites may be of importance within the context of First Nations

• Proximity to terrain features used as indictors of preferred animal habitat (e.g. proximity to rivers and streams, areas lacking previous industrial disturbances) • Proximity to terrain features used as indictors for selected plants and vegetation (e.g.. well drained sandy soils on open terrain may support blueberries) • Incorporation of general knowledge of the development area and local region in relation to aboriginal traditional and current land use

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Discipline Criteria Rationale and Basis for Rating

Treaty Rights and/or Aboriginal Rights or Title. Site-specific TLUS information is considered proprietary to participating aboriginal communities.

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Table 3.5.2a Ratings for Loadout Options for Air Quality

Comments Option

Pros Cons Rating*

H-1** • Coal stockpile to be enclosed in silo • Forest cover provides protection

from prevailing winds

• Loadout very close to sensitive receptors (2km to nearest residence, 800m to Enersul Plant, 700m to Pine River)

• A number of sensitive receptors exist within 10km of the loadout site

• Sensitive receptors are frequently downwind from loadout area • Coal haul route close to Hasler community compared to option

H-6

2

H-2 • Coal stockpile to be enclosed in silo • Most sensitive receptors are

infrequently downwind of loadout area

• Loadout very close to sensitive receptors (1.4km to nearest residence, 1.8km to Enersul Plant, 200m to Hasler Creek, 1.2km to Pine River)

• A number of sensitive receptors exist within 10km of the loadout site

• Loadout area is located on an open grazing field (no wind protection)

• Coal rail and road haul route requires crossing of Hasler Creek (increased potential for dust deposition to the creek)

• Coal rail and road haul route close to Hasler community compared to option H-6

2

H-3** • Coal stockpile to be enclosed in silo • Forest cover provides protection

from prevailing winds

• Loadout close to sensitive receptors (3km to nearest residence, 2.2km to Enersul Plant, 250m to Pine River)

• A number of sensitive receptors exist within 10km of the loadout site

• Sensitive receptors are frequently downwind from loadout area • Coal haul route close to Hasler community compared to option

H-6 • Coal rail and road haul route requires crossing of two small

tributaries to the Pine River (increased potential for dust deposition)

2

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Comments Option

Pros Cons Rating*

H-4** • Coal stockpile to be enclosed in silo • Forest cover provides protection

from prevailing winds

• Loadout close to sensitive receptors (4.3km to nearest residence, 3.6km to Enersul Plant, <50m to Pine River)

• Rail line <50m to Pine River in 4 locations • A number of sensitive receptors exist within 10km of the loadout

site • Sensitive receptors are frequently downwind from loadout area • Coal haul route close to Hasler community compared to option

H-6 • Coal road haul route requires crossing of four tributaries to the

Pine River (increased potential for dust deposition) • Loadout location very close to Pine River (high potential for dust

deposition to river)

2

H-5 • Coal stockpile to be enclosed in silo • Forest cover provides protection

from prevailing winds • A coal road haul route close to the

Hasler community is not required • Terrain provides protection from

higher wind speeds in predominant wind direction

• Loadout very close to sensitive receptors (4km to nearest residence, 3.7km to Enersul Plant, 50m to Hasler Creek)

• A number of sensitive receptors exist within 10km of the loadout site

• Valley is narrow which could result in wind channelling of dust emissions up the valley in the direction of the Hasler community particularly at night under stable conditions

• Coal rail haul route requires crossing of Little Johnson Creek (increased potential for dust deposition to the creek)

• Loadout location very close to Hasler Creek (high potential for dust deposition to creek)

2

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Comments Option

Pros Cons Rating*

H-6 • Coal stockpile to be enclosed in silo • Forest cover provides protection

from prevailing winds • A coal road haul route close to the

Hasler community is not required • Removed from key sensitive

receptors (>3km to nearest residence, >3.0km to Enersul Plant)

• A number of sensitive receptors exist within 10km of the loadout site

• Loadout is close to Hasler Creek (300m) compared to other options

• Valley is narrow which could result in wind channelling of dust emissions up the valley in the direction of the Hasler community particularly at night under stable conditions

• Coal rail haul route requires crossing of Little Johnson Creek (increased potential for dust deposition to the creek)

• Loadout location and coal road haul route are close to Hasler Creek and Little Johnson Creek (high potential for dust deposition to creeks)

1

F-1 • Few sensitive receptors exist within 10km of the loadout site

• Loadout site is removed from key sensitive receptors (7km to nearest residence)

• Coal road haul route is removed from key sensitive receptors

• Forest cover provides protection from prevailing winds

• Coal stockpile not enclosed • Loadout is close to Pine River (400m), Beaudette Creek

(300m), and Falling Creek (500m) • Falling Creek is frequently downwind from loadout area • Haul distance is further than Hasler Loadout options therefore

increased generation of crustal dust and vehicle emissions

1

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Comments Option

Pros Cons Rating*

F-2 • Few sensitive receptors exist within 10km of the loadout site

• Loadout site is removed from key sensitive receptors (6.5km to nearest residence)

• Coal road haul route is removed from key sensitive receptors

• Stockpile has small cross-sectional area perpendicular to predominant wind direction

• Coal stockpile not enclosed • Two proposed loadout areas and stockpiles • Loadout is close to Pine River (300m), and Falling Creek

(300m) compared to other options • Pine River is frequently downwind from loadout area • Haul distance is further than Hasler Loadout options therefore

increased generation of crustal dust and vehicle emissions • Loadout area is located on an open grazing pasture (less wind

protection) • Greater potential for cumulative impacts from Pine Valley Coal

than for options W-1 or W-3

1

F-3 • Few sensitive receptors exist within 10km of the loadout site

• Loadout site is removed from key sensitive receptors (7.5km to nearest residence)

• Coal road haul route is removed from key sensitive receptors

• Stockpile has small cross-sectional area perpendicular to predominant wind direction

• Coal stockpile not enclosed • Loadout is close to Pine River (650m), and Beaudette Creek

(300m) • Beaudette Creek is frequently downwind from loadout area • Haul distance is further than Hasler Loadout options therefore

increased generation of crustal dust and vehicle emissions • Loadout area is located on a reforested area (less wind

protection) • Access to loadout requires a bridge for truck traffic over

Beaudette Creek (increased potential for dust deposition to creek)

1

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Comments Option

Pros Cons Rating*

W1 • Brownfield Site • Coal stockpile not enclosed • Loadout is very close to sensitive receptors (2km to nearest

residence, 450m to Pine River, and 50m to Willow Creek) • Residences are frequently downwind from loadout area • Haul distance is further than Hasler Loadout options therefore

increased generation of crustal dust and vehicle emissions • Loadout area is located on the existing Pine Valley Coal plant

site. The potential for cumulative impacts will be high in an area already observing dustfall exceedences.

3

* Potential for adverse effect on resource or discipline (1=low, 2=moderate; 3=high)

** Screening-level dispersion modeling was conducted on these loadout options. The modeling included fugitive coal dust emissions from wind erosion of coal stockpiles. Since the modeling did not account for enclosed coal stockpiles, the results are no longer valid.

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Table 3.5.2b Ratings for Loadout Options for Water Quality

Comments Option

Pros Cons Rating*

H-1 • Loadout/access do not transect any known water courses

• Configuration may allow for direct surface water discharges to Pine River (high flow, low impact)

• Potential for selenium loadings to fish and/or waterbird habitat in either lentic habitat, or lotic habitats in smaller tributaries of Pine River. Lentic habitat located <1 km from rail loop (oxbow visible on map north of loadout).

1

H-2 • No apparent streams in vicinity of rail loop

• Potential for elevated TSS levels associated with Hasler Creek crossings

• Potential for selenium loadings to fish and/or waterbird habitat in either lentic habitat, or lotic habitats in smaller tributaries of Pine River.

• Configuration does not allow for direct surface water discharges to Pine River (high flow, low impact)

1-2

H-3 • Proximity to Pine River (<50 m) may allow for direct surface water discharges to Pine River (high flow, low impact)

• Potential for selenium loadings to fish and/or waterbird habitat in either lentic habitat, or lotic habitats in smaller tributaries of Pine River.

1

H-4 • Proximity to Pine River (<50 m) may allow for direct surface water discharges to Pine River (high flow, low impact)

• Potential for elevated TSS levels associated with crossings of several fish-bearing streams (seven potential stream crossings).

• Potential for selenium loadings to fish and/or waterbird habitat in either lentic habitat, or lotic habitats in smaller tributaries of Pine River.

1

H-5 • none • Potential for elevated TSS levels associated with road re-alignments and rail line.

• Potential for selenium loadings to fish and/or waterbird habitat in either lentic habitat, or lotic habitats in Johnson Creek and/or Hasler Creek.

1-2

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Comments Option

Pros Cons Rating*

H-6 • none • Potential for elevated TSS levels associated with road re-alignments and rail line.

• Potential for selenium loadings to fish and/or waterbird habitat in either lentic habitat, or lotic habitats in Johnson Creek and/or Hasler Creek.

1-2

F-1 • Access road does not transect any known water courses

• Configuration may allow for direct surface water discharges and seepages to Pine River (high flow, low impact)

• Potential for selenium loadings to fish and/or waterbird habitat in lentic and/or lotic habitats in Beaudette and Falling Creek drainages.

• Proposed loadout appears to consume tributary of Pine River

1

F-2 • Configuration may allow for direct surface water discharges and seepages to Pine River (high flow, low impact)

• Access road appears to cross tributary of Falling Creek • Loadout and rail loop appear to consume tributary of Pine River • Potential for selenium loadings to fish and/or waterbird habitat in

either lentic habitat, or lotic habitats in Falling Creek and small tributaries of Pine River.

1

F-3 • Configuration may allow for direct surface water discharges and seepages to Pine River (high flow, low impact)

• Loadout requires upgrade and a 45 m bridge across Beaudette Creek: potential for added suspended loads to Beaudette Creek.

• Potential for selenium loadings to fish and/or waterbird habitat in either lentic habitat, or lotic habitats in Beaudette Ck. and smaller tributaries of Pine River.

1

W1 • Configuration (< 200 m to Pine River) may to allow for direct surface water discharges and seepages to Pine River (high flow, low impact)

• Proximity to Pine Valley Coal

• Loadout requires upgrade and a 45 m bridge across Beaudette Creek: potential for added suspended loads to Beaudette Creek.

• Potential for selenium loadings to fish and/or waterbird habitat in either lentic habitat, or lotic habitats in Willow Ck. and smaller tributaries of Pine River.

1-2

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*Potential for adverse effect on resource or discipline (1=low, 2=moderate; 3=high). Ratings are speculative, and represent best-guessed estimates. Ratings will be highly dependent on conditions which have not yet been assessed, including: 1) surface water routing; 2) fish utilization; 3) waterbird use; 4) flow conditions in receiver; 5) presence/absence of lentic habitat; and 6) substrate type. Those options with the potential for direct discharge of surface drainages to Pine River received a lower rating (rating=1) in comparison to those options for which direct discharge is likely not possible (rating=1-2).

Table 3.5.2c Ratings for Loadout Options for Fisheries

Comments Option

Pros Cons Rating*

H-1 • no fish-bearing streams within rail loop/loadout footprint

• no surface drainage courses between loadout and Pine River

• haul route requires upgrading of potentially fish-bearing stream crossings on Hasler FSR

1

H-2 • no fish-bearing streams within rail loop/loadout footprint

• no surface drainage courses between loadout and Pine River

• haul route requires upgrading of potentially fish-bearing stream crossings on Hasler FSR

• close proximity to lower Hasler Creek • requires bridge construction over lower Hasler Creek

2

H-3 • no fish-bearing streams within rail loop/loadout footprint

• haul route requires upgrading of potentially fish-bearing stream crossings on Hasler FSR

• close proximity to Pine River • open exposure to Pine River • requires more intensive surface drainage management to

prevent sedimentation into Pine River • requires re-routing of Iverline Creek

3

H-4 • minimum new disturbance (rail siding along existing CN mainline

• no fish-bearing stream crossings on siding

• close proximity to Pine River mainstem • open exposure to Pine River mainstem

2

H-5 • proximity to Pine River mainstem • major disturbance in close proximity to lower Hasler Creek and Little Johnson Creek

• haul route requires upgrading of potentially fish-bearing stream

3

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Comments Option

Pros Cons Rating*

crossings • on Hasler FSR • requires rail bridge construction over Little Johnson Creek

H-6 • proximity to Pine River mainstem • major disturbance in close proximity to lower Hasler Creek and Little Johnson Creek

• haul route requires upgrading of potentially fish-bearing stream crossings

• on Hasler FSR • requires rail bridge construction over Little Johnson Creek

3

F-1 • no fish-bearing streams within loadout facility footprint

• no stream crossings required at loadout

• almost all stream crossings on haul route (Falling Creek Road) are non fish-bearing.

• close proximity to lower Falling Creek 1

F-2 • no fish-bearing streams within rail loop footprint

• existing bridge at Falling Creek crossing

• almost all stream crossings on haul route (Falling Creek Road) are non fish-bearing except lower Falling Creek mainstem.

• close proximity to lower Falling Creek • open exposure to Pine River • south loadout area option conflicts with stream channel along

south side of tracks

2

F-3 • no fish-bearing streams within rail loop/loadout footprint

• no surface drainage courses between loadout and Pine River

• almost all stream crossings on haul

• requires construction of bridge over lower Beaudette Creek

1

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Comments Option

Pros Cons Rating*

route (Falling Creek Road) are non fish-bearing except lower Beaudette Creek mainstem.

W1 • existing loadout footprint • existing rail siding • almost all stream crossings on haul

route (Falling Creek Road) are non fish-bearing except lower Falling and Willow Creek mainstems.

• close proximity to lower Willow Creek mainstem • requires construction of new bridge over lower Willow Creek

1

Table 3.5.2d Ratings for Loadout Options for Terrain –

Comments Option

Pros Cons Rating*

H-1 • Alluvial plain could have liquefaction potential. However, the loadout is designed such that this will not be an issue.

• Deep foundations requirement for silo structures

3

H-2 • Flat, open • Favourable foundation conditions

likely

1

H-3 • Same as H1 3 H-4 • Same as H1 3 H-5 • Foundations on cut rock excavation • Cut slope stability 2 H-6 • Situated above flood plain • Steep valley walls; potential instability 2 F-1 • Open stockpiles will require shallow

foundations • Alluvial plain – potential liquefaction. However, the loadout is

designed such that this will not be an issue. 1

F-2 • Open stockpiles will require shallow • Alluvial plain – potential liquefaction. However, the loadout is 1

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Comments Option

Pros Cons Rating*

foundations designed such that this will not be an issue. F-3 • Open stockpiles will require shallow

foundations • Alluvial plain – potential liquefaction. However, the loadout is

designed such that this will not be an issue. 1

W • Open stockpiles will require shallow foundations

• Alluvial plain – potential liquefaction. However, the loadout is designed such that this will not be an issue.

1

* Potential for adverse effect on resource or discipline (1=low, 2=moderate; 3=high)

Table 3.5.2e Ratings for Loadout Options for Wildlife.

Comments Option

Pros Cons Rating*

H-1 • close to existing disturbance • low to moderate habitat quality

• intercepts some patches of moderate quality habitat

2

H-2 • Occurs on existing modified and disturbed habitat (used as grazing for bison)

• Most development not close to riparian areas

• Some disturbance to riparian habitat at lower Hasler Creek 1

H-3 • Some disturbance occurs along existing linear features

• intercepts patches of moderate and high quality habitat • close proximity to riparian area

3

H-4 • most disturbance occurs along existing linear features

• close proximity to riparian area • intercepts some patches of moderate and high quality habitat

2

H-5 • most disturbance occurs along existing linear features

• intercepts some patches of moderate quality habitat 2

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Comments Option

Pros Cons Rating*

H-6 • parallels some existing linear features

• intercepts patches of moderate and high quality habitat • close proximity to riparian area • increases fragmentation effects • most extensive disturbance of 6 options

3

F-1 • mostly low quality habitat • intercepts some patches of moderate quality habitat 1 F-2 • Occurs on existing modified and

disturbed habitat (grazing pasture) • n/a 1

F-3 • Occurs on existing modified and disturbed habitat (previously harvested cutblock, with pine regeneration – 3m)

• Low quality habitat

• n/a 1

W • disturbance occurs along existing linear features

• Occurs on existing modified and disturbed habitat (plant site for Pine Valley Coal)

• n/a 1

• Potential for adverse effect on resource or discipline (1=low, 2=moderate; 3=high)

Table 3.5.2f Ratings for Loadout Options for Heritage Resources.

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Comments OPTION

Pros Cons

Rating*

H-1 • No previously recorded archaeological sites in direct conflict or close proximity to option H-1.

• Private land will not require a TLUS.

• Option H-1 is located within 200m of the Pine River.

• Forest cover is indicative of well-drained terrain.

• Crown land will require TLUS.

• Riparian habitat indicates increased wildlife activity (TLUS).

3

H-2 • No previously recorded archaeological sites in direct conflict or close proximity to option H-2.

• Private land will not require a TLUS.

• Option H-2 is located within 200m of Hasler Creek.

• Upgrading bridge at Hasler Creek.

• Open grazing field is indicative of well-drained terrain.

3

H-3 • No previously recorded archaeological sites in direct conflict or close proximity to option H-3.

• Private land will not require a TLUS.

• Option H-3 is located within 50m of the Pine River and within close proximity to the oxbow of the Pine River.

• Loadout and road access will impact several drainages.

• Forest cover is indicative of well-drained terrain.

• Crown land will require TLUS.

• Riparian habitat indicates increased wildlife activity (TLUS).

3

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H-4 • No previously recorded archaeological sites in direct conflict or close proximity to option H-4.

• Private land will not require a TLUS.

• Option H-4 is located less than 50m from the Pine River.

• Road access will impact several drainages.

• Forest cover is indicative of well-drained terrain.

• Crown land will require TLUS.

• Riparian habitat indicates increased wildlife activity (TLUS).

3

H-5 • No previously recorded archaeological sites in direct conflict or close proximity to option H-5.

• Development area may transect steeply sloped terrain.

• Private land will not require a TLUS.

• Option H-5 is located within 200m of Hasler Creek and transects Little Johnson Creek.

• Forest cover is indicative of well-drained terrain.

• Crown land will require TLUS.

• Riparian habitat indicates increased wildlife activity (TLUS).

2

H-6 • No previously recorded archaeological sites in direct conflict or close proximity to option H-6.

• Development area may transect steeply sloped terrain.

• Private land will not require a TLUS.

• Option H-6 is located within 200m of Hasler Creek and transects Little Johnson Creek.

• Forest cover is indicative of well-drained terrain.

• Crown land will require TLUS.

• Riparian habitat indicates increased wildlife activity (TLUS).

2

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F-1 • No previously recorded archaeological sites in direct conflict or close proximity to option F-1.

• Option F-1 is located within 200m of the Pine River and Falling Creek, and within 500m of Beaudette Creek.

• Loadout is on level terrain. • Forest cover is indicative

of well-drained terrain. • Crown land will require

TLUS. • Riparian habitat indicates

increased wildlife activity (TLUS).

3

F-2 • No previously recorded archaeological sites in direct conflict or close proximity to option F-2.

• Private land will not require a TLUS.

• Option F-2 is located within 200m of the Pine River and Falling Creek.

• Loadout is on level terrain. • Open grazing field is

indicative of well-drained terrain.

• Crown land will require TLUS.

• Riparian habitat indicates increased wildlife activity (TLUS).

3

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F-3 • No previously recorded archaeological sites in direct conflict or close proximity to option F-3.

• Option F-3 is located within 200m of the Pine River and Beaudette Creek.

• Loadout is on level terrain. • Reforested pine is

indicative of well-drained soils.

• Crown land will require TLUS.

• Riparian habitat indicates increased wildlife activity (TLUS).

3

W1 • No previously recorded archaeological sites in direct conflict or close proximity to option W-1.

• Previously assessed during Pine Valley Coal Willow Flats Mine AIA and TLUS.

• No further heritage resource work recommended.

• N/A 1

* Potential for adverse effect on resource or discipline (1 = low, 2 = moderate, 3 = high)

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3.6 SOCIO-COMMUNITY AND LAND USE ANALYSIS

3.6.1 Introduction

A detailed ranking analysis for socio-community and land use issues was conducted for the 10 haul routes/loadout options (described above).The following describes the selection method and rating system for the options.

3.6.2 Selection Method

The detailed assessment was conducted using the following steps:

• For each discipline, 3 to 5 criteria were identified (Tables 3.6.3 and 3.6.4). This information was provided by discipline experts.

• For each criteria, a rationale and basis for rating options were described.

• Each discipline was then ranked for each option using the above criteria (Tables 3.6.5 and 3.6.6). A four class rating system was used (low, moderate, high, and not feasible), based on the potential for adverse effects on the resource or discipline. Additional details on the pros and cons of each option were also provided to support each rating.

• The relative importance of each discipline was then determined, using a percent value. This information was used to calculate the overall rating for each option (Table 4.3.1).

• A final ranking was determined for each option (1-10) (Table 4.3.2).

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• Table 3.6.3 Criteria and Rationale for Loadout Options for Land Use Issues

Discipline Criteria Rationale and Basis for Rating

1) Property ownership of underlying land for rail loop and loadout.

• Rail loop and loadout situated on privately owned property where property owner does not wish to sell

• Rail loop and loadout situated on Crown land – tenure granted to another entity.

2) Proximity of rail loop and loadout to residential land uses

• Coal dust and its potential effect on (1) residential property values (2) health of humans and (3) cost to clean up.

• Noise of rail loop and loadout. • Lights at night. • Increased traffic on FSR and connecting roads during life of project – safety of

non industrial users (i.e. snow mobilers, etc.). • Increased traffic through residential community during construction period. • Increased traffic through residential community during shift change at the rail

loop and loadout. 3) Proximity of rail loop and loadout to agricultural land uses

• Coal dust and its potential effect on (1) agricultural property values (2) health of livestock (3) crops (4) price for crops.

4) Effect on land tenure other than fee simple ownership

• Guide outfitting • Trapping • PNG tenures • Mineral tenures • Commercial recreational uses • Forestry tenures

Land Use

5) Agricultural Land Reserve

• Uncertainty attached to applying to the Agricultural Land Commission for land to be taken out of the Agricultural Land Reserve.

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• Table 3.6.4 Criteria and Rationale for Loadout Options for Socio-community Issues

Discipline Criteria Rationale and Basis for Rating

1) Effects on vitality of local communities – Social vitality

• Noise associated with load out activities including 1) train noises, 2) coal handling related noises and 3) truck noises

• Disruption of day to day activities by traffic to load out • Traffic related dangers including 1) increased traffic through community during

construction and, 2) increased traffic through community during operations, particularly during shift change

• Human health effects resulting from proximity to load out • Coal Dust and increased road dust and its potential effect on 1) Health of

Humans 2) costs of clean up and 3) health of livestock • Visual quality including 1) lights at night and 2) visibility during the day

2) Effects on vitality of local communities – Economic vitality

• Change in property values including Coal Dust effects on 1) general property values and 2) agricultural property values

• Change in ability to earn a living including 1) Coal Dust effects on prices for agricultural products, 2) Increased opportunities for work associated with the load out including load out construction, load out operations, trucking and other mine activities

Socio-community

3) Effects on well traveled transportation corridors

• Interference with existing traffic including 1) increased truck traffic and 2) increased traffic during construction and operations (particularly during shift changes)

• Traffic related dangers associated with 1) increased truck traffic interacting with local traffic, 2) increased truck traffic interacting with pedestrians and 3) heavy equipment affecting the stability and safety of local roads

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Table 3.6.5 Ratings for Loadout Options for Land Use Issues

Comments Option

Pros Cons Rating*

H-1 • Near industrially used lands – Enersul, Duke Energy and BC Rail / CN Rail.

• Privately owned land (rancher, and BCR Properties with option to purchase by Enersul) – Enersul not willing to sell to WCC.

• Enersul has raised the issue of negative effects due to proximity to Enersul’s sulphur piles.

• Rail loop and loadout also on Crown Land with grazing lease to rancher.

• Property in the Agricultural Land Reserve. • Community of Hasler Flats has raised the

issue of negative effects due to proximity to the community – dust, lighting and noise.

• Increased traffic both construction traffic and coal haul traffic.

Potential issues with trap lines.

4

H-2 • Near industrially used lands – Enersul, Duke Energy and BC Rail / CN Rail.

• Owner of ranch lands was willing to negotiate sale of lands to WCC.

• Site is south-east of Enersul plant and therefore downwind of plant.

• Privately owned land (Duke Energy and rancher) – Duke not willing to sell to WCC.

• Property in the Agricultural Land Reserve. • Community of Hasler Flats has raised the

issue of negative effects due to proximity to the community – dust, lighting and noise.

• Enersul has raised the issue of negative effects due to proximity to Enersul’s sulphur piles – albeit south and west of the piles.

• Increased traffic.

4

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Comments Option

Pros Cons Rating*

• Potential issues with trap lines. H-3 • Crown Land

• Near industrially used lands – Enersul, Duke Energy and BC Rail / CN Rail.

• Greater distance from community of Hasler Flats and Enersul’s plant than H1.

• Property partly in the Agricultural Land Reserve.

• Community of Hasler Flats has raised the issue of negative effects due to proximity to the community – dust, lighting and noise.

• Enersul has raised the issue of negative effects due to proximity to Enersul’s sulphur piles.

• Increased traffic. • Potential issues with trap lines.

3

H-4 • Crown Land. • Greater distance from community of

Hasler Flats and Enersul’s plant than H1, H2 and H3.

• Property partly in the Agricultural Land Reserve.

• Proximity of rail siding to agricultural land use. Privately owned grazing lands between the river and the highway.

• Community of Hasler Flats has raised the issue of negative effects due to proximity to the community – dust, lighting and noise.

• Enersul has raised the issue of negative effects due to proximity to Enersul’s sulphur piles.

• Increased traffic. • Potential issues with trap lines.

3

H-5 • Crown land • Avoid truck haul into Hasler Flats

community • Rail loading activities and their

potential negative effects are further

• Increased traffic on lower portion of Hasler FSR.

• Potential issues with trap lines.

2

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Comments Option

Pros Cons Rating*

away from Hasler Flats community than H1, H2, H3 and H4.

H-6 • Crown land • Avoid truck haul into Hasler Flats

community • Rail loading activities and their

potential negative effects are further away from Hasler Flats community than H1, H2, H3 and H4.

• Increased traffic on lower portion of Hasler FSR.

• Potential issues with trap lines.

2

F-1 • Crown land • Location is some considerable

distance away from residential community

• Pine Valley Coal / Falls Mountain Coal has purchased all residential lots (with full time occupation) within 7.5 km radius of F1.

• WCC’s loadout would be located in the same general vicinity as Falls Mountain Coal’s loadout – keeping coal facilities in one area and limiting further disturbance

• Site is not suitable for agricultural use

• Nearest occupied, residential properties are approximately 6 km from loadout site – two properties were purchased by Pine Valley Coal/Falls Mountain Coal. Next privately owned, occupied residence

• Location is adjacent to privately owned, but unoccupied, 600 acre parcel of ranch land in the ALR.

• Potential issues with trap lines • Two non-exclusive Commercial

Recreational tenures on Crown Land – buffer zone along river, and expansion of Heli skiing operation.

• Access to loadout site along Falling Creek Road which passes through coal licenses held by entities other than WCC.

1

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Comments Option

Pros Cons Rating*

is approx. 7.5 km from loadout site. • Site is approximately 3.5 km and

east (downwind) from land used for chainsaw carving business

F-2 • Location is away from residential

community. • Pine Valley Coal / Falls Mountain

Coal has purchased all residential lots (with full time occupation) within 6.5 km radius of F2.

• Privately owned 600 acre parcel of land – owner has been approached with offer to purchase by another coal company.

• Nearest occupied, residential properties are approximately 4.5 km from loadout site – two properties were purchased by Pine Valley Coal/Falls Mountain Coal. Next privately owned, occupied residence is approx. 6 km from loadout site.

• Site is approximately 4.5 km and east (downwind) from land used for chainsaw carving business

• Property is within the ALR. • Potential issues with trap lines in the area.

3

F-3 • Crown land • Location is away from residential

community. • Pine Valley Coal / Falls Mountain

Coal has purchased all residential lots (with full time occupation) within 8.5 km radius of F3.

• Location is close to privately owned, but unoccupied, 600 acre parcel of ranch land in the ALR.

• Site will have to be rezoned. • Requirement for tenure under the Land Act. • Potential issues with trap lines. • Location overlaps Coal License tenure held

by Luscar Ltd. and Elk Valley Coal. • Two non-exclusive Commercial

Recreational tenure on Crown Land – buffer zone along river, and expansion of

1

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Comments Option

Pros Cons Rating*

Heli skiing operation. • Nearest occupied, residential properties are

approximately 7 km from loadout site – two properties were purchased by Pine Valley Coal/Falls Mountain Coal. Next privately owned, occupied residence is approx. 8.5 km from loadout site.

• Site is approximately 2.5 km and east (downwind) from land used for chainsaw carving business

• Access to loadout site along Falling Creek Road which passes through coal licenses held by entities other than WCC.

W-1 • Crown land • Location is away from residential

community. • Pine Valley Coal / Falls Mountain

Coal has purchased all residential lots (with full time occupation) within 3 km radius of W1.

• Existing industrial site potential to limit further disturbance

• Potential issues with trap lines. • Requires negotiation with tenure holder –

Pine Valley Coal / Falls Mountain Coal • Nearest occupied, residential properties are

approximately 1.5 km from loadout site – two properties were purchase by Pine Valley Coal/Falls Mountain Coal. Next privately owned, occupied residence is approx. 3 km from loadout site.

• Access to loadout site along Falling Creek Road which passes through coal licenses held by entities other than WCC.

1

• Potential for adverse effect on resource or discipline (1=low, 2=moderate; 3=high, 4=not feasible)

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Table 3.6.6 Ratings for Loadout Options for Socio-community Issues

Comments Option

Pros (with reference to criteria by number) Cons (with reference to criteria by number)

Rating*

H-1 1. Within/near to industrial area 2. Employment opportunities near community

1. Relatively close to Hasler Flats with resulting potential effects of: noise; disruption of day to day traffic; traffic related dangers; human health effects; coal and traffic dust; and, visual quality

2. Relatively close to Hasler Flats with resulting potential effects of: reduction of property values; reduction in viability of agriculture

3. Relatively close to Hasler Flats with resulting potential effects of: interference with existing traffic; and, traffic related dangers

3

H-2 1. Within/near to industrial area 2. Employment opportunities near community

1. Relatively close to Hasler Flats with resulting potential effects of: noise; disruption of day to day traffic; traffic related dangers; human health effects; coal and traffic dust; and, visual quality

2. Relatively close to Hasler Flats with resulting potential effects of: reduction of property values; reduction in viability of agriculture

3. Relatively close to Hasler Flats with resulting potential effects of: interference with existing traffic; and, traffic related dangers

3

H-3 1. Within/near to industrial area 2. Employment opportunities near community

1. 2. and 3. Further from Hasler Flats with the consequent moderate reduction of negative effects.

2

H-4 1. Within/near to industrial area 2. Employment opportunities near community

1. 2. and 3. Further from Hasler Flats with the consequent moderate reduction of negative effects.

2

H-5 1. Up Hasler Valley from Community 2. Employment opportunities near community

1. 2. and 3. Much further from Hasler Flats with the consequent virtual elimination of negative effects.

1

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Comments Option

Pros (with reference to criteria by number) Cons (with reference to criteria by number)

Rating*

H-6 1. Up Hasler Valley from Community 2. Employment opportunities near community

1. 2. and 3. Much further from Hasler Flats with the consequent virtual elimination of negative effects.

1

F-1 1. Distant from communities (6 km to nearest dwelling owned by Falls Mountain Coal / Pine Valley Coal and 7.5 km to next closest residences) • Within/near to industrial area • Not near a well traveled road • Near an existing loadout

2. Employment opportunities near community

1. 2. and 3. Distant from local residences and communities with the consequent virtual elimination of negative effects.

2. Further for local people to commute

1

F-2 1. Distant from communities (5 km to nearest dwelling owned by Falls Mountain Coal / Pine Valley Coal and 6.5 km to next closest residences)) • Within/near to industrial area • Not near a well traveled road • Near an existing loadout

2. Employment opportunities near community

1. 2. and 3. Distant from local residences and communities with the consequent virtual elimination of negative effects.

2. Further for local people to commute

1

F-3 1. Distant from communities (7 km to nearest dwelling owned by Falls Mountain Coal / Pine Valley Coal and 8.5 km to next closest residences)) • Within/near to industrial area • Not near a well traveled road • Near an existing loadout

2. Employment opportunities near community

2. 2. and 3. Distant from local residences and communities with the consequent virtual elimination of negative effects.

2. Further for local people to commute

1

W-1 Distant from communities (1.5 km to nearest dwelling owned by Falls Mountain Coal / Pine Valley Coal and 3 km to next closest

2. 2. and 3. Distant from local residences and communities with the consequent virtual elimination of negative effects.

1

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Comments Option

Pros (with reference to criteria by number) Cons (with reference to criteria by number)

Rating*

residences)Within/near to industrial area • Not near a well traveled road • Near an existing loadout

2. Employment opportunities near community

2. Further for local people to commute

* Potential for adverse effect on resource or discipline (1=low, 2=moderate; 3=high)

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4 Preferred Haul Route/Loadout Location

In summary, F1 is the only option that ranks as number 1 in all 3 categories, engineering, environment and socio-community and land use as described in the following sub-sections. However, tenure has not been established for F1, nor has WCC’s application for the site to be rezoned been approved by the Peace River Regional District. If tenure is not granted to WCC (a land lease under the Land Act), or if there are other reasons why the Falling Creek location is ruled out then WCC may have to consider the site with the least impacts in the Hasler Flats area, namely H4.

4.1 ENGINEERING

F1 has lower capital costs (about 20 % lower) than the H4 option, based on preliminary costing assumptions. The total operating costs over the life of the project are approximately the same for both options. From an engineering and project economic standpoint the F1 option is preferred to the H4 option. Table 4.1.1. is a summary of the engineering rankings for the short listed options

4.1.1 Falling Creek (F1) Option

Key characteristics:

Location: Located in the Falling Creek area. The closest point of contact to an occupied residence is about 6 km.

Haulage: Distance is 60.5 km via the Falling Creek Connector Road; approximately 0.7 km of new road must be constructed for access

Environment: The rail loadout access road and loadout facilities do not transect any known water courses. The rail line is within 200 m of Pine River at the northern end. Paralleling the loadout to the east is Falling Creek within 200 m and Beaudette Creek to the west within 500 m. The loadout is situated in the alluvial plain of the Falling and Beaudette Creeks. The area is densely forested with spruce, pine and aspen as the predominant species. Average tree height is about 22 m.

WCC has commissioned modelling of wind sheltering effect of trees and consequent reduction in fugitive emissions from open stockpiles of coal at the site.

Storage: Coal will be stored in open stockpiles, as the nearest occupied resident is some 6 km away. Ambient air quality modelling will be conducted on the nearest private property.

Operability: Loadout is designed within the minimum standards supplied by CN Rail.

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Constructability: Excavation requirements estimated at 199,000 cubic meters. The site requires 12.0 hectares of loadout site clearing and 18.8 hectares of track clearing. The site is on an alluvial plain with potential for liquefaction; however, the loadout is designed such that this will not be an issue. No difficulties have been identified that would affect the construction of this loadout configuration.

Land Tenure: Tenure for the loadout and associated access is crown land. The loadout is not in the ALR.

4.1.2 Hasler (H4) Option

Key characteristics:

Location: Located west of the community of Hasler, on District Lots 1135, 361, 1131 and crown land. The closest point of contact to an occupied residence is 4.3 km and to the Enersul plant 3.6 km

Haulage: Distance is 49.7 km via Hasler Connector Road; approximately 4.5 km of new road must be constructed for access

Environment: The loadout and rail are in close proximity to the Pine River, less than 50 m in four locations. There are four stream crossings. The area of the rail siding includes both densely forested and existing cleared right of way.

Storage: Coal will be stored in silos, to prevent release of fugitive dust

Operability: Loadout is designed to exceed the minimum standards supplied by CN Rail.

Constructability: Excavation cut and fills requirements estimated at 60,000 cubic meters. The site requires 5.6 ha of right of way clearing. No difficulties have been identified that would affect the construction of this loadout configuration.

Land Tenure: Tenure for the loadout and associated access is a mixture of crown and private ownership (possibly requiring use of BC Rail / CN Rail right of way lands).

Table 4.1.1 Summary of Rankings for Short listed Loadout Options-Engineering

Option F1 Option F3 Option H4

Selection Criteria

Weight Point Score Point Score Point Score

Capital Cost 25% 10 2.5 8 2.0 6 1.5

Annual Operating Cost 45% 8 3.6 6 2.7 10 4.5

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Constructability Cut/Fill Volume 10% 8 0.8 10 1.0 8 0.8

Constructability of Bridges 10% 10 1.0 6 0.6 6 0.6

Reliability 10% 10 1.0 10 1.0 10 1.0

Total 100% 8.9 7.3 8.4

Rank 1 3 2

4.2 ENVIRONMENTAL ANALYSIS

Selection criteria were identified for each environmental discipline, ratings generated for each option, and an overall weighted rating and subsequent ranking calculated (Table 4.2.1). Based on these rankings, the following options are rated the highest from an environmental perspective:

• #1 – Option F1 and Option F3 • #3 – Option F2 • #4 – Option W1

In general, higher ranked options are located in the Falling Creek area. This is largely due to the uneven weighting of certain disciplines (e.g., air quality, land use) where existing communities and related issues were deemed particularly sensitive. The Falling Creek Flats area is relatively distant from residences, while the Hasler community is in closer proximity to proposed loadout options. In addition, wildlife habitat is generally lower in the Falling Creek Flats area.

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Table 4.2.1 Summary of Ratings* for Loadout Options Analysis for Environmental Disciplines

Loadout Option Discipline Weight**

H1 H2 H3 H4 H5 H6 F1 F2 F3 W1 Air Quality 25% 2 2 2 2 2 1 1 1 1 3 Water Quality 25% 1 1.5 1 1 1.5 1.5 1 1 1 1.5 Fish 10% 1 2 3 2 3 3 1 2 1 1 Terrain 10% 3 1 3 3 2 2 1 1 1 1 Wildlife 10% 2 1 3 2 2 3 1 1 1 1 Archaeology & Historical Resources

20% 3 3 3 3 2 2 3 3 3 1

Total*** 100% 1.95 1.875 2.25 2.05 1.975 1.825 1.4 1.5 1.4 1.625 Rank 7 6 10 9 8 5 1 3 1 4

* Potential for adverse effect on resource or discipline (1=low, 2=moderate; 3=high)

** Relative importance of discipline

*** Total rating value for each option was calculated by multiplying relative weight by summed discipline ratings. Lower values represent preferred options.

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4.3 SOCIO-COMMUNITY AND LAND USE ANALYSIS

Selection criteria were identified for socio-community and land use disciplines, ratings generated for each option, and an overall weighted rating and subsequent ranking calculated (Table 4.3.1). Based on these rankings, the following options are rated the highest from a socio-community and land use perspective:

• Low Impacts (preferred) – Options F1, F3, H5, H6, and W1 (provided tenure issues are negotiated)

• Moderate Impacts (less preferred) – Options H4, H3

• High Impacts (not recommended) – Option F2

• Not feasible due to land ownership/tenure issues – Options H1, H2

In general, higher ranked options are located in the Falling Creek area. This is largely due to the uneven weighting of certain disciplines (e.g., air quality, land use) where existing communities and related issues were deemed particularly sensitive. The Falling Creek area is relatively distant from residences, while the Hasler community is in closer proximity to proposed loadout options.

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Table 4.3.1 Summary of Ratings* for Loadout Options Analysis for Socio-Community and Land Use Disciplines

Loadout Option Discipline Weight**

H1 H2 H3 H4 H5 H6 F1 F2 F3 W Socio-Community 50% 3 3 2 2 1 1 1 1 1 1 Land Use 50% 4 4 3 3 2 2 1 3 1 1 Total*** 100% 7 7 5 5 3 3 2 4 2 2 Rank 9 9 7 7 4 4 1 6 1 1

* Potential for adverse effect on resource or discipline (1=low, 2=moderate; 3=high, 4=not feasible)

** Relative importance of discipline

*** Total rating value for each option was calculated by multiplying relative weight by summed discipline ratings. Lower values represent preferred options.

Table 4.3.2 Summary of Rankings for Top Road and Loadout Options Analysis for All Disciplines (Engineering, Environmental and Socio-Community Land Use Disciplines)

Discipline Rankings

F1 F3 H4 W1

Engineering 1 3 2

Environmental 1 1 4 3

Socio-Community and Land Use

1 1 7 1

Rank 1 2 3 NR

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Notes:

1. NR = Not Ranked. W1 was eliminated early on in the engineering analyses based on understanding that an additional loadout could not be accommodated.

2. Environmental ranking for W1 related to air quality, assuming nearby residences.

3. Socio-economic and Land Use ranking for H4 related largely to concerns of community of Hasler and to concerns of Enersul.

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5 Proposed Development Program

5.1 ON-GOING FIELD INVESTIGATIONS

Field investigations have been in progress during the first and second quarter of 2005 at several of the proposed haulage route and loadout sites.

Geotechnical investigations are in progress for the F1 option. This option has been advanced to a preliminary design stage. Intent is to advance this to development of general arrangement drawings. Estimates for quantities of materials were developed from conceptual general arrangement drawings. Conceptual planning was used to derive access road design, of right of way clearing requirements, soil stripping area, cut and fill volumes, steel track and accessories quantities and ballast volumes.

5.1.1 Environmental

Environmental field surveys are planned for the F1 option to further investigate baseline conditions. This information will be used to support the ongoing environmental impacts assessment. Proposed field surveys include programs for air quality, water quality, fisheries, wildlife (e.g., songbirds, wildlife habitat assessments)

5.1.2 Socio-Community and Land Use

Field surveys are planned for the F1 option to assess archaeological and historical resources. Public consultations regarding the mine development will be ongoing during July and August 2005

5.2 EA APPLICATION/PERMITTING SCHEDULE

The schedule is as follows:

EA Application Baseline Draft May 2005

EA Application Baseline Final October 2005

EA Application Impacts Draft October 2005

EA Application Impacts Final October 2005

5.3 OVERALL PROJECT DEVELOPMENT SCHEDULE

Brule project milestones:

Award EPCM Contract for Feasibility January 2005

Issue Capital and Operating Cost Estimates September 2005

Issue Feasibility Study September 2005

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Submit EA Application October 2005

Submit Mine Permit and Water Licence Applications

March 2006

Receive Mine Permit July 2006

Start Construction July 2006

Begin Pre-Stripping July 2006

First Coal Production i August 2006 using temporary coal haul route to Bullmoose Loadout

September 2007 using permanent coal haul route to Falling Creek Flats site

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Western Canadian Coal, Brule Mine A Options Analysis – Coal Handling & Transportation, Rev. 1, 142874, July 2005

6 Conclusions / Recommendations

6.1 HAUL ROUTE / LOADOUT LOCATION

The recommended haul route / loadout location is F1, Brule Mine to Falling Creek Flats with the loadout located south of the CN tracks. It is recommended on the basis of favourable constructability, project economic characteristics, environmental considerations, and socio-community and land use constraints and effects. The positive features of the F1 haul route / loadout location include:

6.1.1 Engineering

Location: Located in the Falling Creek Flats area. The closest point of contact to a residence is about 6 km.

Haulage: Distance is 60.1 km via the Falling Creek Connector Haul Route, Storage: Coal will be stored in open stockpiles, as the nearest occupied residence is some 6 km away.

Operability: Loadout is designed within the minimum standards supplied by CN Rail.

Constructability: Excavation requirements estimated at 199,000 cubic meters. The site requires 12.0 ha of loadout site clearing and 18.8 ha of track clearing. No difficulties have been identified that would affect the construction of this loadout configuration.

6.1.2 Environmental

• Maintenance of tall (ca. 20-22 m in height) treed area to reduce noise dispersion, reduce air quality impacts (limited dust dispersal), and maintain wildlife habitat

• Load out and stock piles (including drainage ditches) will be set back from watercourses (minimum 50 m) to limit potential effects on water quality, fisheries, and wildlife habitat

• Limited terrain issues, with minimal cut and fill requirements, resulting in minimal ground disturbance and reduced impacts on water quality, fisheries, or wildlife habitat

• Loadout location has been fine tuned to avoid private property, does not occur on ALR, is distant from residences, and occurs within an area with existing industrial development (e.g., Pine Valley Coal loadout)

• No new stream crossings on fish bearing streams for the Falling Creek Connector Route (although a previously developed bridge will need to be upgraded) which limits effects on water quality, fisheries, and wildlife habitat

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• Limited clearing (e.g., 15 m width) along Falling Creek Connector Haul Route will be required when upgrading, which will limit effects on water quality, fisheries, and wildlife habitat

• Lower volumes of existing traffic on Falling Creek Connector Haul Route, and therefore fewer traffic conflicts and lower wildlife mortality risk

6.1.3 Socio-Community and Land Use

• Distant from local communities and occupied residences with the consequent virtual elimination of negative effects.

• WCC has initiated discussions with owner of neighbouring 600 acre parcel with regard to use of land for air quality monitoring and also with regard to potential effects of rail loadout site on these lands. Property owner also holds commercial recreational tenure to Pine River in this area.

6.2 STORAGE / HANDLING

The recommended option for F1 is an open stockpile without wind fencing. The Falling Creek Flats loadout is far enough away from residences and there is good tree cover around the site to provide natural wind breaks. The positive features of the open stockpile configuration include:

6.2.1 Engineering

This option has the lowest capital and operating costs of the storage / handling option and can be expanded for increasing capacity and can therefore accommodate coal shipments from other potential coal producers.

6.2.2 Environmental

The location in a forested area results in controlled dust dispersal, which limits potential effects on air quality, water quality, fisheries, and wildlife habitat

6.2.3 Socio-Community and Land Use

Controlled dust dispersal, which limits potential effects on air quality, water quality

6.3 TRANSPORTATION

The preferred method for coal transportation for the proposed up to 2 M tonnes per annum and for a project life of approximately 11 years is the trucking option. The trucking option provides the best economics for the project.

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6.3.1 Engineering

Other schemes such as slurry pumping, conveying and rail haul are too capital intensive and cannot be justified for this size of project.

6.3.2 Environmental

Existence of road corridors for much of the potential haul routes reduces clearing and construction impacts for the road options. Slurry pumping, conveying, and rail hauls would involve increased habitat disturbance and clearing for new corridors, resulting in potential to increased impacts on water quality (stream crossings), fisheries (stream crossings of potential fish bearing streams), and wildlife habitat (fragmentation, increased access and associated mortality, and direct habitat loss). Construction costs rule out the rail option. Operating impacts would be expected to be highest for the slurry pipeline option (due to water management and coal dryer issues), intermediate for roads (animal mortality being the biggest issue), and lowest for the conveyor)

6.3.3 Socio-Community and Land Use

The potential negative impacts described in environmental translate into negatives in the socio-community area, for example the value of recreational stream and forest area could be diminished through negative impacts on fish bearing streams and on vegetation if there are spills from the slurry pipeline or from the dewatering facility.

More long-term employment is provided by the truck haul which is an advantage from a socio-community perspective.

CONCLUSION

Combining the three disciplines of Engineering, Environmental and Socio-Community and Land Use, this study concludes that the Falling Creek Flats location identified as F1 has the most favourable characteristics for development as a loadout site, as there is a good prospect for resolution of all the engineering, environmental, socio-community and land tenure issues. The favourable economics of this site are based on open stockpiles without a wind fence.

Willow Creek Flats (W1) would require further negotiations with the tenure holders at the site (Pine Valley Coal / Falls Mountain Coal), before it could be considered as a viable location. However, if an agreement can be reached with the tenure holders, this site has many favourable characteristics for co-development as a loadout site for both coal companies. The favourable economics of this site are based on open stockpiles without a wind fence, and the assumption that some of the infrastructure could potentially be shared

Should the approval process for both the Falling Creek sites (F1) and the Willow Flats site (W1) fail, WCC would propose the H4 site in Hasler Flats which has the most favourable characteristics of the 6 sites evaluated in the Hasler Flats area, from an Engineering, Environmental and Socio-Community and Land Use standpoint. This site, if selected, would be developed using silos for storage of the coal.

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Western Canadian Coal, Brule Mine D Options Analysis – Coal Handling & Transportation, Rev. 1, 142874, July 2005

Appendix A – Site Maps

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Appendix B – Road Maps