We develop an effective theory which describes black holes with quantum mechanical horizons that is valid at scales long compared to the Schwarzschild radius but short compared to the lifetime of the black hole. Our formalism allows one to calculate the quantum mechanical effects in scattering processes involving black hole asymptotic states. We point out that the EFT Wightman functions which describe Hawking radiation in the Unruh vacuum are not Planck suppressed and are actually {it enhanced} relative to those in the Boulware vacuum, for which such radiation is absent. We elaborate on this point showing how the non-Planck suppressed effects of Hawking radiation cancel in classical observables.
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