The proposal to expand the Johnson Creek Mine, owned by Weyerhaeuser, from 10.4 acres to 228 acres has red flags that should alarm Thurston County residents. While this issue may seem like it is isolated to residents in a pocket of Tenino, the breakdown in the Washington State Environmental Policy Act (SEPA) process demonstrates a much larger issue for how the County processes and makes very important decisions with potential for far reaching long-term environmental impacts on Thurston County residents.
I think we can all agree that we want to drink safe and clean water, to not wipe out protected species and habitats, and we want our regulators and developers in the region to be up front and honest with us about development plans. I, and many others in the community, are baffled by the County and the Applicant’s efforts to push the Johnson Creek Mine expansion project through without sufficient analysis, thereby totally bypassing Washington’s SEPA process meant to determine the project’s short- and long-term impacts on the human and natural environment.
Sidelining the SEPA Process
The first step in the SEPA process is to determine if a project will have significant adverse environmental effects. If it is determined that it will, a Determination of Significance (DS) should be issued which may trigger the requirement that an Environmental Impact Statement (EIS) be conducted. Having received notice that the project will receive a DS, if the Applicant can prove that certain mitigations will mitigate adverse impacts, the County can then issue a Mitigated Determination of Non-significance (MDNS) detailing exactly what mitigations will be used to correct the adverse impacts throughout the life of the project.
The May 2025 issuance of an MDNS by the County for a proposed expansion to the Johnson Creek Mine was erroneous because that determination clearly bypassed the SEPA process. It did not adequately document, disclose, and assess the probable significant adverse environmental impacts of the expansion, as was acknowledged by the County planning department and detailed by the County hydrogeologist.
This mine expansion could result in short- and long-term impacts to groundwater and aquifers, stormwater management and runoff, noise, air quality, neighborhood character, climate, traffic, infrastructure, native and protected species, wetlands, and cultural resources, as well as to land use consistency and planning compliance issues. These factors alone necessitate an EIS to analyze those potentially irreversible environmental impacts.
Also, the professional discrepancy between the County hydrogeologist’s professional assessment from the Applicant’s hydrogeologist’s professional should have automatically warranted an EIS requirement to resolve the professional discrepancy and determine the actual impacts to groundwater from expanded mining activities. The County’s own Staff Report dated June 24, 2025 states that, “staff did not receive sufficient information to make a complete determination with regard to negative impacts to surface and groundwater flows and quality.” And the County testified during the public meeting, that there was not enough information to properly evaluate the project and make a decision, that the permit should be denied, the project should be remanded, and that an EIS should be required; essentially admitting the County issued the MDNS in error.
Is the County averse to doing an EIS? A search of publicly available records show that less than a handful of DSs have been issued since 2005, while it has approved over 600 MDNSs.
The Applicant is a Scofflaw
There were early concerns and warning signs with the Applicant’s initial SEPA Checklist in 2020, and throughout the SEPA process that culminated with the County’s issuing an MDNS.
In the last 4 years, the mine operator has not been compliant with the permits they currently possess and has been cited by the Department of Ecology for permit violations 23 times since 2021 (Violations and Permit Triggers), including one as recent as April of this year. These permit violations demonstrate a pattern of noncompliance and a lack of commitment to protecting the environment, as the State cannot then detect pollution problems from unauthorized and unmonitored discharges that could impact water quality. When an operator does not conduct basic monitoring, the County should demand stricter scrutiny before granting more land to mine. Instead, the County issued an MDNS, sidestepping a full EIS and potentially allowing the mine to expand to over 20 times the current operating size.
An Undefined Project Cannot Be Considered Under the Law
A review of the 2025 MDNS, as well as of the 2020 SEPA checklist, highlights the most glaring issue: there is NO clear project description. The MDNS states the request is for a “228-acre hard rock mine.” However, during the public meeting before the Hearing Examiner held on July 15, 2025, the legal team for the mine asserted the intention is to expand to 42 acres over 30 years, which will create 1,242 acres of impervious surfaces. If that is in fact the intent, why is so much time and money being spent to obtain the rights to 228 acres? During the public meeting, it was also stated that the long-term intention was to expand mining activities to the full 228-acre permit area after 30 years.
Despite the Applicant’s clearly stated intentions, to mine beyond 42 acres, the County’s MDNS failed to reconcile the 228-acre hard rock mine request stated in the project description with the 42 acres, and the County did not get clarification on what 1,242 acres of impervious surfaces meant or where it was within the Proposed Action. The Washington Administrative Code specifically states that under SEPA, proposals need to be considered as a whole, not piecemealed; the range of impacts, both short- and long-term must be evaluated “over the lifetime of the proposal.” In the Johnson Creek Mine case, environmental impact analysis was not done for either the short-term 42-acres or the long-term 228-acres.
And where are those 1,242 acres of impervious surfaces located and what impacts will ensue from them within the project area? There is no way to assess the direct, indirect, and cumulative impacts of the impervious surfaces because this information was not disclosed in the SEPA Checklist.
Forest Land Conversion and Climate Change were not Considered
Digging deeper, the land in question is classified as Forestland of Long-Term Commercial Significance. But the applicant glossed over the direct question on the SEPA Checklist and the County did not ask for clarification or additional discussion. This is important because this type of conservation takes place to discourage incompatible land uses, and to promote and protect forestry.
Again, the County’s Staff Report notes that the staff did not believe there was sufficient information provided to ensure that the action would not adversely impact adjacent or nearby land uses, or public health and safety; indicating there are incompatible land uses with nearby residences. Building on this oversight further, no forestland conversion permit was required as a part of this process. A Class IV-General forest practices application is standard with any development proposal that would convert forestland. Such a permit would have provided essential information to the State and the public about the scope and environmental impacts of permanent forestland loss; to include effects on habitat, carbon sequestration, watershed integrity, and rural land use patterns. A change in land use in itself should trigger an EIS.
Moreover, SEPA regulations require the County to consider “climate” as part of a SEPA environmental review. This was not done and is problematic given that the expansion would remove over 200 acres of forestland. Thurston County’s own 2024 Climate Vulnerability Assessment projects significantly hotter, drier summers through the years, up to ~8°F warmer with much less rain, meaning reforestation will be slower and drought conditions more severe while heavy rainfall events intensify, all of which magnifies the mine’s short- and long-term adverse impacts. The permit application states the expansion will mine “incrementally” and that post-mining, the Applicant will return the lands to forestry. That is great in theory, but it does not account for the loss of carbon storage and ecosystem functions that will occur during the many decades of mining activity. This specific analysis of the system is the main reason to require a Class IV forest practices permit along with the Special Use Permit.
Proposed “Adaptive Management” Means No Accountability
Finally, I would like to bring up that during the course of the public meeting, “adaptive management” was used frequently as the method for how impacts, when discovered, would be addressed. Adaptive management is most successful in a reinforcing loop of cause and effect; you see a problem, you fix the problem, you reassess to ensure the solution is effective. It does not work as well with indirect impacts that happen incrementally over time; by the time the impact is fully realized the damage is already done. Without clearly understanding the system to be able to apply comprehensive mitigations and monitoring as a part of the conditions of the action, means significant and irreversible adverse impacts might only be detected too late to mitigate or reverse.
Why should you care? While, it is true, this specific situation with the proposed Johnson Creek Mine expansion and Special Use Permit may be geographically isolated to a degree, the fact that the SEPA process broke down so thoroughly and completely should be a cautionary tale for the 300,000 residents that trust the County to monitor and protect the environment that we must live with in perpetuity.
Isha Alexander is an environmental scientist with 20 years of experience supporting state and federal environmental compliance requirements, and one of the adjacent property owners neighbors appealing the County MDNS for the Johnson Creek Mine expansion. WIP will continue to cover this story in future editions.
Permit Violations of the Johnson Creek Quarry from the Department of Ecology (click to enlarge):
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