Commenter ID #1
 

Commenter ID #1
Response to Comments from Dean Schrader, September 18, 2014 Commenter ID #1 

Response to Comment 1-1 and 1-2 

As noted at the September 18, 2014 public hearing on the Task 5 and 6 projects, the comments 

regarding the grade separation and related matters were made on a different project (Task 4 – 

Toteff Road) than those on which the hearing was held. The impacts of the Task 4 project were 

analyzed under a separate environmental review process: National Environmental Policy Act 

(NEPA) Categorical Exclusion (CE) and State Environmental Policy Act Environmental (SEPA) 

Checklist Determination of Non-Significance (DNS) Task 4: Kelso Martin’s Bluff – Toteff Road 

Siding Extension. Additional opportunities to comment on the Task 4 design and effects were 

afforded when the Washington Department of Transportation (WSDOT) undertook the SEPA 

evaluation in November 2014. 

 
 

Commenter ID #2
 

Commenter ID #2
 

Commenter ID #2
Response to Comments from Tyrel Koistinen, September 18, 2014 Commenter ID #2 

Response to Comment 2-1 and 2-2 

As noted at the September 18, 2014 public hearing on the Task 5 and 6 projects, the comments 

regarding the grade separation and related matters were made on a different project (Task 4 – 

Toteff Road) than those on which the hearing was held. The impacts of the Task 4 project were 

analyzed under a separate environmental review process: NEPA CE and SEPA Checklist DNS 

Task 4: Kelso Martin’s Bluff – Toteff Road Siding Extension. Additional opportunities to 

comment on the Task 4 design and effects were afforded when WSDOT undertook the SEPA 

evaluation in November 2014. 

Response to Comment 2-3 

The Bald and Golden Eagle Protection Act prohibits, without proper permitting, disturbance 

from construction activities to nesting bald eagles during their active nesting period, which 

occurs January 1 through August 15. Guidelines established by the US Fish and Wildlife Service 

require an eagle nest to be within 660 feet of the construction activities or 0.5 miles of blasting to 

trigger review. WSDOT reviewed the most current eagle nest data (April 2014) from the 

Washington Department of Fish and Wildlife (WDFW) and the closest bald eagle nest is located 

approximately 930 feet from the rail line where construction activities are planned. No blasting 

would occur within 0.5 mile of the nest. As such, the construction activities are not considered a 

disturbance to this bald eagle nest and are not subject to timing restrictions or permitting. 

The project area has had a high level of rail, industrial, and highway activity (and associated 

noise) for decades. It is assumed that bald eagles nesting in the project area are acclimated to the 

existing noise environment due to reoccurring use of the site and nesting success. Although the 

horn noise from additional passenger trains could disturb wildlife, including eagles, in the project 

area, disturbances are minor when the existing noise environment is taken into consideration. 

According to BNSF Railway the train horn noise from existing operations and maintenance 

activities has not required either a Disturbance Permit or Take Permit under the Bald and Golden 

Eagle Protection Act. 

The list of applicable laws and regulations in Appendix A of the Environmental Assessment 

(EA) is limited to laws and regulations where an actual approval or permit from an agency would 

be issued. 

Response to Comment 2-4 

The Federal Railroad Administration (FRA) designated the rail line as a high-speed rail corridor 

in 1993. High-speed rail has been in operation since 1994 when WSDOT began providing 

passenger service between Seattle, Washington and Portland, Oregon. The current maximum 

speed for the passenger rail service is 79 mph; this speed would not increase with 

implementation of this project. As stated in the EA, the project supports implementing two 

additional daily passenger rail roundtrips (4 one-way trains) between Seattle and Portland; this 

means there would be four additional Amtrak passenger trains moving through the Toteff Road 

and Hendrickson Drive crossings daily. Although these crossings aren’t designated 
bike/pedestrian routes (and Hendrickson Drive is not a public road) and the closest park is 1.5 

miles north, the reconstruction substantially improves the safety of the crossing for all users by 

eliminating vehicle conflict points, improving sight distances and turning radii, and installing 

industry standard active warning devices. 

Access to Marine Park and Louis Rasmussen Day Use Park for pedestrians and bikes would 

remain via Hendrickson Drive and the Elm Street pedestrian overcrossing. The proposed project 

would not interrupt any existing access to these parks. 

 
Commenter ID #3
Commenter ID #3
Commenter ID #3
Response to Comments from Stacis Searls, September 18, 2014 Commenter ID #3 

Response to Comment 3-1, 3-2, 3-3 

As noted at the September 18, 2014 public hearing on the Task 5 and 6 projects, the comments 

regarding the grade separation and related matters were made on a different project (Task 4 – 

Toteff Road) than those on which the hearing was held. The impacts of the Task 4 project were 

analyzed under a separate environmental review process: NEPA CE and SEPA Checklist DNS 

Task 4: Kelso Martin’s Bluff – Toteff Road Siding Extension. Additional opportunities to 

comment on the Task 4 design and effects were afforded when WSDOT undertook the SEPA 

evaluation in November 2014.

Response to Comment 3-4 

The Port of Kalama’s TEMCO LLC Terminal Expansion project is a privately funded and 

implemented project independent form the federally funded Task 5 and 6 passenger rail projects. 

It was considered in the cumulative effects analysis of the EA (Section 4.18.1.4), which 

documents the overall effects of past, present, and reasonably foreseeable future actions on 

transportation. It was also considered in all no-build alternative assessments. The TEMCO 

expansion project and other planned activities at the Port of Kalama would result in increased 

freight traffic through the Task 5 and Task 6 study areas, irrespective of the build alternatives, 

and would also increase the number of times the railroad crossings would be blocked and 

contribute to a non‐significant cumulative effect on local transportation corridors. In completing 

the cumulative impact analysis, WSDOT reviewed the February 2010/2012 SEPA Checklists and 

DNS for the terminal expansion project. According to the checklists, the project “was not 

anticipated to create additional demand for new employees or increase traffic to the site.” 

According to TEMCO, “most train deliveries arrive from the north, which does not typically 

block the intersection at Toteff Road. The proposed improvements are not anticipated to effect or 

change existing train operations.” 

The roadway improvement projects proposed by the city of Kelso (West Main Street 

Realignment, Yew Street Reconstruction Phase 1, and city of Kelso Railroad Crossing Study) 

would improve roadway flow and potentially reduce traffic in the city of Kelso. These roadway 

improvements could offset potentially adverse impacts from the Millennium Bulk Terminals 

Longview and Port of Kalama Terminal Expansion Project. The Build Alternative would not be 

likely to contribute to a significant cumulative effect on transportation; the EA analyses establish 

that there would be no cumulative effect to transportation as a result of the build alternatives. 

Response to Comment 3-5 

The Bald and Golden Eagle Protection Act prohibits, without proper permitting, disturbance 

from construction activities to nesting bald eagles during their active nesting period, which 

occurs January 1 through August 15. Guidelines established by the U.S. Fish and Wildlife 

Service (USFWS) require an eagle nest to be within 660 feet of the construction activities or 0.5 

miles of blasting to trigger review. WSDOT reviewed the most current eagle nest data (April 

2014) from the WDFW and the closest bald eagle nest is located approximately 930 feet from the 

rail line where construction activities are planned. No blasting would occur within 0.5 mile of the 
nest. As such, the construction activities are not considered a disturbance to this bald eagle nest 

and are not subject to timing restrictions or permitting. 

The project area has had a high level of rail, industrial, and highway activity (and associated 

noise) for decades. It is assumed that bald eagles nesting in the project area are acclimated to the 

existing noise environment due to reoccurring use of the site and nesting success. Although the 

horn noise from additional passenger trains could disturb wildlife, including eagles, in the project 

area, disturbances are minor when the existing noise environment is taken into consideration. 

According to BNSF Railway the train horn noise from existing operations and maintenance 

activities has not required either a Disturbance Permit or Take Permit under the Bald and Golden 

Eagle Protection Act. 

The list of applicable laws and regulations in Appendix A of the EA is limited to laws and 

regulations where an actual approval or permit from an agency would be issued. 

Response to Comment 3-6 

See Response to Comment 3-1, 3-2, and 3-3. 

 
 

Commenter ID #4
 

Commenter ID #4
Response to Comments from Lloyd Flem, September 18, 2014 Commenter ID #4 

Response to Comment 4-1 

Thank you for the input. Comment noted. 

 
Commenter ID #5
Commenter ID #5
Commenter ID #5
Response to Comments from Jerry Sorrell, September 9, 2014 Commenter ID #5 

Response to Comment 5-1 

Coordination with the Federal Aviation Administration (FAA) regarding potential conflicts with 

the Runway Protection Zone, Object Free Area, and airport clear zones is ongoing and would 

continue through final design of the proposed projects. As discussed in Section 4.10.3.2.2 of the 

EA, the Task 6 project would be located partly adjacent to and within approximately 200 feet of 

the runway at the Southwest Washington Regional Airport. Under 49 CFR 77, the FAA is to be 

notified via Form 7460-1 of proposed construction activities that would take place within 20,000 

feet of an airport with a runway of greater than 3,200 feet in length and which exceed a 100 to 1 

imaginary surface height from the runway. The 100 to 1 ratio establishes a threshold of one foot 

of height for every 100 feet of horizontal distance. For the Task 6 project, this means that since 

the project would be approximately 200 feet from the runway, the project requires FAA 

notification as construction equipment would exceed 2 feet in height at that distance. Therefore, 

Form 7460-1 is being prepared for submittal to the FAA to document the proposed activities. 

The FAA would review the submittal and make a determination regarding any potential hazards 

associated with the project. Although the project is close to the runway, the proposed project and 

construction would have a low profile similar to existing activities in the rail corridor and is not 

anticipated to effect airport operations. 

Additional plan sheets, aside from those provided as part of the EA, are not available at this time. 

 
 

Commenter ID #6
Response to Comments from George Ford, September 22, 2014 Commenter ID #6 

Response to Comment 6-1 

Coordination with the FAA regarding potential conflicts with the Runway Protection Zone, 

Object Free Area, and airport clear zones is ongoing and would continue through final design of 

the proposed projects. As discussed in Section 4.10.3.2.2 of the EA, the Task 6 project would be 

located partly adjacent to and within approximately 200 feet of the runway at the Southwest 

Washington Regional Airport. Under 49 CFR 77, the FAA is to be notified via Form 7460-1 of 

proposed construction activities that would take place within 20,000 feet of an airport with a 

runway of greater than 3,200 feet in length and which exceed a 100 to 1 imaginary surface height 

from the runway. The 100 to 1 ratio establishes a threshold of one foot of height for every 100 

feet of horizontal distance. For the Task 6 project, this means that since the project would be 

approximately 200 feet from the runway, the project requires FAA notification as construction 

equipment would exceed 2 feet in height at that distance. Therefore, Form 7460-1 is being 

prepared for submittal to the FAA to document the proposed activities. The FAA would review 

the submittal and make a determination regarding any potential hazards associated with the 

project. Although the project is close to the runway, the proposed project and construction would 

have a low profile similar to existing activities in the rail corridor and is not anticipated to effect 

airport operations. 

Additional plan sheets, aside from those provided as part of the EA, are not available at this time. 

 
 

Commenter ID #7
Response to Comments from Andy Smith, September 25, 2014 Commenter ID #7 

Response to Comment 7-1 

As noted in Section 4.9.3 of the EA, if contaminated soil, sediment, or groundwater were 

encountered, potential environmental effects would be minimized and managed by following 

minimization measures and best management practices. For example, a project-specific 

hazardous materials plan will be prepared and implemented to manage potential hazardous 

material effects from spills or from encountering previously unidentified contaminated media. In 

the event of encountering contaminated media, the Washington Department of Ecology 

(Ecology) will be contacted in accordance with applicable state and federal requirements. No 

long‐term effects from the Task 5 project are anticipated because the project would not increase 

the potential for exposure to hazardous materials from the transport or accidental release of 

hazardous materials. 

Construction practices will comply with applicable requirements for erosion control and 

stormwater management, including those listed in the comments and compliance with the 

National Pollutant Discharge Elimination System (NPDES) Stormwater General Permit. 

Appendix M of the EA lists the practices, techniques, methods, processes, and activities that will 

be implemented to comply with applicable permits and other regulatory requirements, including 

the NPDES Construction Stormwater General Permit, and that provide an effective and 

practicable means of preventing or minimizing the environmental effects of an action. 

 
 

Commenter ID #8
 

Commenter ID #8
Response to Comments from Sonia Mendoza, September 25, 2014 Commenter ID #8 

Response to Comment 8-1 

Construction practices will comply with applicable requirements for erosion control and 

stormwater management, including those listed in the comment, and compliance with the 

NPDES Stormwater General Permit. Appendix M of the EA lists the practices, techniques, 

methods, processes, and activities that will be implemented to comply with applicable permits 

and other regulatory requirements, including the NPDES Construction Stormwater General 

Permit, and that provide an effective and practicable means of preventing or minimizing the 

environmental effects of an action. 

Response to Comment 8-2 

As noted in Section 4.9.3 of the EA, if contaminated soil, sediment, or groundwater were 

encountered, potential environmental effects would be minimized and managed by following 

minimization measures and best management practices. For example, a project-specific 

hazardous materials plan will be prepared and implemented to manage potential hazardous 

material effects from spills or from encountering previously unidentified contaminated media. In 

the event of encountering contaminated media, Ecology will be contacted in accordance with 

applicable state and federal requirements. No long‐term effects from the Task 5 project are 

anticipated because the project would not increase the potential for exposure to hazardous 

materials from the transport or accidental release of hazardous materials. 

Construction practices will comply with applicable requirements for erosion control and 

stormwater management, including those listed in the comments and compliance with the 

NPDES Stormwater General Permit. Appendix M of the EA lists the practices, techniques, 

methods, processes, and activities that will be implemented to comply with applicable permits 

and other regulatory requirements, including the NPDES Construction Stormwater General 

Permit, and that provide an effective and practicable means of preventing or minimizing the 

environmental effects of an action. 

 
 

Commenter ID #9
Response to Comments from Kristopher Johnson, September 5, 2014 Commenter ID #9 

Response to Comment 9-1 

The commenter is referring to an alternative considered by WSDOT as part of a 2003 previous 

rail planning effort for the Kelso Martin’s Bluff suite of projects. However, at the time, the 

environmental impacts of that alternative and the costs associated with it were determined to be 

infeasible, and that alternative and the associated Environmental Impact Statement were not 

advanced. Section 3.3 of the EA describes this planning effort further. 

The Task 5 and 6 projects are key components of the Pacific Northwest Rail Corridor (PNWRC) 

Improvement Program and, when completed, would help facilitate the addition of two additional 

Amtrak Cascades service round trips (4 one-way trains) between Portland, Oregon, and Seattle, 

Washington, with improved reliability and reduced travel time. With the current traffic as well as 

this additional passenger service, it was determined that the additional expansion between 

Ostrander and Rocky Point was not required to meet the Amtrak service outcomes. 

Railroad infrastructure must have the capability to support additional passenger train frequency 

and increased passenger-train on-time performance without degrading existing freight train 

performance and capacity. The infrastructure capacity was tested using operations simulation 

modeling. The improvements proposed for the Kelso Martin’s Bluff Area were deemed required 

by consensus among FRA, WSDOT, and BNSF Railway. This infrastructure and the 

methodology used to identify it were documented in the Cascades Service Development Plan 

approved by the FRA in 2010. 

The new infrastructure would accommodate the efficient operation of passenger and freight rail 

along the same rail line. Passenger rail is generally faster and on a specific schedule, while 

freight trains are generally longer, slower, and not on a specific schedule. The proposed 

infrastructure would support the on-time performance requirements of the Passenger Rail 

Investment and Improvement Act (PRIIA). Further, the two locations of the third mainline 

expansion are specifically designed to expedite passenger trains around the Port of Kalama (Task 

5) and Port of Longview (Task 6). The existing main line infrastructure is not adequate to 

support the expanded and improved passenger service. The new infrastructure proposed under 

Tasks 5 and 6 will help improve intercity passenger rail service. 

With the improvements analyzed in the EA, WSDOT secured a Service Outcome Agreement 

with BNSF Railway that would guarantee the improved passenger rail service would be 

accommodated for 20 years. 

While the improved turnouts identified by the commenter are not a part of the project analyzed in 

the EA, they are being installed by BNSF Railway at Centralia, Wabash, and other locations. 

There will also be new control points in both the Kalama and Kelso area that will also assist with 

traffic congestion. Changes to Amtrak’s schedules are beyond the scope of this EA but may be 

revised upon completion of the PNWRC Program as a whole. 

Your suggestions and recommendations for additional improvements have been forwarded to 

WSDOT Rail Office Planners and would be considered as future improvements are considered to 

grow the passenger train service within the PNWRC. 
 

Commenter ID #10
Response to Comments from George Winn, September 2, 2014 Commenter ID #10 

Response to Comment 10-1 

Thank you for the input. Comment noted. 

 
Commenter ID #11
Commenter ID #11
Response to Comments from Diane Dick, September 26, 2014 Commenter ID #11 

Response to Comment 11-1 

The Project is being funding through the FRA’s High-Speed Intercity Passenger Rail (HSIPR) 

Program which can only be used for passenger rail improvements. The purpose and need for the 

Task 5 and 6 projects is to improve intercity passenger rail service by improving reliability, 

enhancing efficiency, and increasing passenger rail travel frequency. The EA compares the 

environmental effects of the Build Alternative to the No Build Alternative. FRA and the 

WSDOT will consider the environmental consequences and public input as part of their decisionmaking process. 

Response to Comment 11-2 

While the improvements under the Build Alternative will occur on infrastructure owned by the 

BNSF Railway, passenger rail service is operated along the BNSF-owned rail line as a tenant 

service. The Project is being funded with a grant obligated under FRA’s HSIPR Program which 

provides financial assistance for new or improved intercity passenger rail projects which can 

only be used for passenger rail improvements. 

The purpose and need for the Task 5 and 6 projects is to improve intercity passenger rail service 

by improving reliability, enhancing efficiency, and increasing passenger rail travel frequency. 

The Task 5 and 6 projects are key components of the PNWRC Improvement Program and, when 

completed, would help facilitate the addition of two Amtrak Cascades service round trips (4 oneway trains) between Portland, Oregon, and Seattle, Washington, with improved reliability and 

reduced travel time. Although the PNWRC Improvement Program would not increase the 

number of Amtrak Coast Starlight trains (Amtrak’s longer distance passenger rail service 

between Los Angeles, California, and Seattle, Washington), the program could improve the 

speed and reliability of those trains as well. The EA describes the potential effects to resources 

and identifies minimization and mitigation measures to minimize the potential effects. As FRA’s 

grantee, WSDOT is responsible to ensure the mitigation measures are implemented and will 

coordinate that effort with the BNSF Railway. 

As described in Section 4.15.3.1 of the EA, the number of freight trains operating in the corridor 

is anticipated to increase from 40 to 62 by 2030; however, this increase would occur 

independently of the Build Alternative. The expected increase of freight traffic to 62 trains in 

2030 is considered for purposes of establishing a future baseline condition in the transportation 

analysis and was considered as part of the no-build condition for purposes of the Service 

Development Plan. The potential effects associated with an increase in the number of freight 

trains operating in the project area is evaluated as a cumulative effect in Section 4.18 of the EA. 

Railroad infrastructure must have the capability to support additional passenger train frequency 

and increased passenger-train on-time performance without degrading existing freight train 

performance and capacity. The infrastructure capacity was tested using operations simulation 

modeling and the improvements proposed for the Kelso Martin’s Bluff Area were deemed 

required by consensus among FRA, WSDOT, and BNSF Railway. This infrastructure and the 

methodology used to identify it were documented in the Cascades Service Development Plan 

approved by the FRA in 2010. 
The new infrastructure would accommodate the efficient operation of passenger and freight rail 

along the same rail line. Passenger rail is generally faster and on a specific schedule, while 

freight trains are generally longer, slower, and not on a specific schedule. The proposed 

infrastructure would support the on-time performance requirements of the PRIIA. Further, the 

existing main line infrastructure is not adequate to support the expanded and improved passenger 

service. The new infrastructure will help improve intercity passenger rail service. 

Response to Comment 11-3 

The PNWRC Service Development Plan references an average of 45 to 55 freight trains per day 

between Vancouver, WA and Seattle, WA. The estimated increase of 22 freight trains on BNSF 

Railway tracks was provided by BNSF Railway. This estimate is based on the forecasted growth 

for the corridor. It is referenced in the 2011 PNWRC Service Development Plan. 

Ultimately, freight rail volumes are dependent upon market conditions and system capacity, 

which are not regulated by the FRA or WSDOT. The estimates BNSF Railway provided are 

based on reasonably foreseeable future conditions. The Service Outcome Agreement between the 

FRA, WSDOT, and BNSF Railway requires that any additional freight traffic added to the 

project corridor not adversely affect the Cascades passenger rail trips. In order to ensure that 

passenger rail service is not affected, BNSF Railway would alter freight traffic or make 

additional improvements to the corridor. 

Response to Comment 11-4 

See Response to Comment 11-2. 

Response to Comment 11-5 

Rail Investment and Improvement Act. The Regional Transportation Commission modeling 

included in the Service Development Plan, which was approved by the FRA, shows that 

improvements to infrastructure are necessary to accommodate two additional daily round trips (4 

one-way trains) for passenger trains. Moreover, the operational issue to be addressed with the 

proposed projects is that storage off the mainline is inadequate and therefore passenger train 

movements are significantly delayed because of freight traffic. For improvements in passenger 

rail service to occur, freight must be more easily stored off mainline tracks. With the 

improvements and the Service Outcome Agreement, passenger service would be improved and 

expanded. The Service Outcome Agreement between the FRA, WSDOT and BNSF Railway 

requires that any additional freight traffic added to the project corridor not adversely affect the 

Cascades passenger rail trips. In order to ensure that passenger rail service is not affected, BNSF 

Railway would alter freight traffic or make additional improvements to the corridor independent 

of the Build Alternative.

Response to Comment 11-6 

See Response to Comment 11-2. 

Response to Comment 11-7 

The noise effects from implementation of the Task 6 Project are described in Section 4.7.3 of the 

EA. Using the industry accepted standards for rail noise analysis (Federal Railroad 
Administration’s 2012 High‐Speed Ground Transportation Noise and Vibration Impact 

Assessment and Federal Transit Administration’s 2006 Transit Noise and Vibration Impact 

Assessment), the analysis demonstrates that there would be no significant noise effects from 

construction or operation of the Task 6 project; therefore, there would no expected impacts on 

the environmental justice population noted.

Response to Comment 11-8 

See Response to Comment 11-2. 

 
Commenter ID #12
 

Commenter ID #12
 

Commenter ID #12
 

Commenter ID #12
Response to Comments from Bill Vogel, September 26, 2014 Commenter ID #12 

Response to Comment 12-1 

The PNWRC Improvement Program was evaluated under the NEPA in 2009 in the PNWRC, 

Washington State Segment – Columbia River to the Canadian Border, Program EA. This 

Programmatic EA analyzed the 17 individual component tasks between Vancouver, Washington, 

and the Washington State–Canadian border. Based on the identification of potential impacts and 

proposed measures to avoid, minimize, and mitigate potential impacts contained in the 

Programmatic EA, FRA issued a Finding of No Significant Impact (FONSI) in November 2010. 

Both the Programmatic EA and the FONSI anticipated the future need to develop a series of 

more detailed, project-level environmental documents (Tier 2 environmental documents) to 

assess the potential effects of specific component projects prior to implementation. The proposed 

Kelso Martin’s Bluff project is one such project and is being evaluated in a Tier 2 environmental 

document. Section 3.3 of the EA provides an overview of alternatives development and 

previous/related environmental analyses. 

Response to Comment 12-2 

As noted in Section 3.3 of the EA, the Pacific Northwest Rail Corridor, Washington State 

Segment – Columbia River to the Canadian Border, Program Environmental Assessment

assessed the corridor from Oregon to the Canadian border. The Task 5 and Task 6 EA is a tier-2 

or project-level analysis of one of the component projects of the PNWRC Program of 

improvements and is therefore focused on the reasonably foreseeable impacts in the Task 5 and 6 

study areas. 

The Task 5 and 6 EA analyses for wildlife used the same study area as was used for the Task 5 

and 6 Biological Assessments (BA), which were determined by anticipated project construction 

noise. The Task 5 action area from the BA was 1,119 feet and the Task 6 action area extended 

out to a maximum of 5.8 miles. It was greater than Task 5 because of the greater noise from pile 

driving at a few locations, including in the Coweeman River. In addition, noise effects were 

evaluated and the study areas for both noise and wildlife were adjusted accordingly. The 

analysis was prepared in consultation with the USFWS. 

The effects of additional trains documented in Section 4.5.3.2 of the Tasks 5 and 6 EA notes that 

increased passenger rail activities may increase the likelihood of animal mortality due to train 

strikes. However, the increase in rail traffic would be minor compared to existing rail traffic and 

any corresponding increase in strikes would therefore also be minor. 

Response to Comment 12-3 

The Kelso Martin’s Bluff Improvement Projects EA is a tiered document; it incorporates and 

builds upon the analysis and findings documented in the PNWRC, Washington State Segment – 

Columbia River to the Canadian Border, Program EA, including the alternatives evaluation for 

corridor improvements. The process of identifying alternatives is described in Section 3.3 of the 

EA and outlines changes that have occurred to the Task 5 and 6 projects. Through the alternative 

development process, the Build Alternative was refined to reduce environmental impacts. No 

other action alternatives were identified that would meet the purpose and need of the project; nor 

does NEPA require more than a Build and No Build Alternative in an EA. 
While reducing wildlife mortality from existing conditions was not part of the project’s purpose 

and need, and alternatives aimed specifically at reducing wildlife mortality were not considered, 

the EA addresses potential impacts to wildlife from the Build and No Build Alternatives. Impacts 

of the build alternative on wildlife mortality due to train strikes are addressed in Section 4.5.3.2 

of the EA. FRA and WSDOT have coordinated with USFWS on Endangered Species Act (ESA) 

Section 7 consultation to identify minimization measures for these potential environmental 

effects. In addition, WSDOT has engaged USFWS on the issue of potential impacts to Columbia 

white-tailed deer and USFWS has not provided any specific measures to minimize, avoid, or 

mitigate such impacts. 

Response to Comment 12-4 

The 2009 PNWRC, Washington State Segment – Columbia River to the Canadian Border, 

Program EA provided a full corridor study that discussed wildlife species and habitats within the 

corridor. Both aquatic and terrestrial habitats were covered; wetland and aquatic resources were 

assessed within 1,000 feet of the corridor, terrestrial habitats/wildlife within 2,000 feet. The EA 

analyses presented in Section 4.5.3.2 followed standard scientific practices by including an 

analysis of key species found in the study area that would be considered representative of a 

multitude of other species. The EA notes that for general wildlife, “disturbances from increased 

passenger rail activities may increase the likelihood of animal mortality due to train strikes, but 

the increase in rail traffic would be minor compared to existing rail traffic and the probable 

increase in strikes would also be minor.” 

Response to Comment 12-5 

The EA for Tasks 5 and 6 examined effects to the natural environment within the areas that were 

defined in the BAs for the ESA consultations. In both cases, the outer limit of the action area was 

defined as the distance at which project construction noise attenuated to background noise levels. 

For Task 5, the action area was 1,119 feet from the edge of the construction footprint, or the 

centerline of the rail tracks (because there is no pile driving for the project). For Task 6, the 

action area extends 5.8 miles from the construction footprint locations due to varying 

construction activities (e.g., in-water pile driving and grading activities). Specific in-water areas 

of potential effects were also defined. FRA and WSDOT considered potential effects to listed 

species and critical habitats within those areas, and the analyses and conclusions were included 

in the Task 5 and 6 BAs submitted to both the USFWS and the National Marine Fisheries 

Service (NMFS). 

Response to Comment 12-6 

The potential effects to streaked horned lark are addressed in the Task 5 and 6 Biological 

Assessments (BA), provided as Appendices F and G to the EA. With the exception of a proposed 

laydown area on Port of Kalama property, there is no suitable habitat for streak horned lark in the 

Task 5 project area. A survey was conducted for the proposed laydown area on Port of Kalama 

property, which contains the potential habitat. The survey revealed that no viable habitat was 

found in the Task 5 project area. Research for the Task 6 project identified a streaked horned 

lark population on private property adjacent to the rail line. FRA and WSDOT consulted with 

staff from the USFWS to develop strategies for reducing impacts to streaked horned lark at this 

location. The result of the discussion, conducted during development of the BA, was the 

identification of timing restrictions on construction work to be implemented to avoid impacts to 
the species and habitat during the nesting season. As a result, consultation on this issue was 

pursued (see Appendix F and G of the EA). 

Response to Comment 12-7 and 12-8 

FRA and WSDOT acknowledge that lethal effects to a single listed individual are of concern and 

have included that as part of the analyses for Columbian white-tailed deer in the Task 5 and 6 

Biological Assessments. FRA and WSDOT have worked with the USFWS during the Section 7 

consultation to address effects to the Columbian white-tailed deer. The Biological Opinion 

issued by the USFWS on October 30, 2014 included several terms and conditions that minimize 

effects to Columbian white-tailed deer from an increase in passenger rail service, including: 

 The FRA will assess that portion of the Vancouver, BC to Portland, OR rail corridor that 

contains the action area for habitat connectivity in the Washington State Service 

Development Plan, to be finalized in 2017. Measures identified in the plan will be 

implemented in the action area by the FRA, when reasonable to do so, as part of any 

subsequent rail improvement action funded by FRA. 

 The FRA will coordinate with the USFWS and BNSF Railway to develop and implement 

an Animal Retrieval Plan that specifies methods and contacts for retrieval of Columbian 

white-tailed deer found dead or injured on the BNSF Railway right-of-way. Such a plan 

will be completed and implemented by the FRA and BNSF Railway by October 30, 2015. 

 The FRA will monitor and report the number of passenger train trips that occur each 

calendar year. Reports will be submitted annually to the USFWS by March 1 of the 

following year. 

Additional information provided by USFWS in the Biological Opinion indicates that 11 deer 

could be struck over a 20-year period along the corridor between Portland, OR and Vancouver, 

BC. As stated in the Biological Opinion, the total population of deer is estimated to be 850 

individuals. The loss of 11 individuals over a 20-year period represents less than 0.1% of the 

current population on an annual basis and would not be considered significant consistent with the 

Biological Opinion. 

Response to Comment 12-9 

The railway in the Task 5 and 6 areas traverses a variety of habitats that may be used by many 

wildlife species. These habitats include the developed region north of the confluence of the 

Coweeman/Cowlitz Rivers; forested and open wetland habitats along Owl Creek; and the 

developed area associated with the Port of Kalama. Wildlife movements in these areas are 

constrained by both Interstate-5 and the BNSF Railway. Interstate-5 likely constrains wildlife 

movement more than the railway; it is wider, has greater traffic volume, and faster moving 

vehicles. The railway has about 70 trains per day (freight and passenger) in the Port of Kalama 

area. In some areas the tracks are elevated with steep rock ballasted slopes, which could present 

significant movement challenges for all wildlife guilds. However, there are underpasses under 

the rail line in several locations, including the rail and Interstate 5 bridges over the Kalama 

River. More significantly, there are many areas where the railway is at-grade, and would not be a 

barrier to ungulate movement. FRA and WSDOT recognize that at-grade crossings could be a 

barrier to small mammals, amphibians, and reptiles. 
The developed areas within the Task 5 and 6 project areas have relatively inhospitable conditions 

for many wildlife species. In addition to the railway and Interstate 5, there are local roads and 

associated traffic, and industrialized and fenced areas within the Port of Kalama that would be 

barriers or present major challenges to wildlife movement. About half of the widened track area 

in the Task 5 and 6 project areas are in these more industrialized sections. 

The freight and passenger rail operators do not keep records of train collisions with deer or other 

wildlife, so there is no specific information available on that issue. 

FRA and WSDOT are awaiting data from radio-telemetered Columbia white-tailed deer from the 

US Fish and Wildlife Service to help inform where deer habitats intersect with the rail line, and 

to determine if deer are crossing the tracks. The California High-Speed Rail Project presents a 

condition significantly different with the Task 5 and 6 projects. The Project in California is 

proposed as a new rail corridor; whereas for this Project, the improvements for passenger rail are 

proposed within an existing rail corridor where freight and passenger movements have been 

accommodated for nearly a century. The proposed Build Alternatives for Task 5 and 6 are 

limited main line additions and spurs provided to separate freight and passenger rail service 

within an existing corridor as opposed to establishing a new rail corridor. 

FRA and WSDOT have worked with the USFWS during the Section 7 consultation to address 

effects to the Columbian white-tailed deer. The Biological Opinion issued by the USFWS on 

October 30, 2014 included several terms and conditions that minimize effects to Columbian 

white-tailed deer on passenger rail service, including: 

 The FRA will assess that portion of the Vancouver, BC to Portland, OR rail corridor that 

contains the action area for habitat connectivity in the Washington State Service 

Development Plan, to be finalized in 2017. Measures identified in the plan will be 

implemented in the action area by the FRA, when reasonable to do so, as part of any 

subsequent rail improvement action funded by FRA. 

 The FRA will coordinate with the USFWS and BNSF Railway to develop and implement 

an Animal Retrieval Plan that specifies methods and contacts for retrieval of Columbian 

white-tailed deer found dead or injured on the BNSF Railway right-of-way. Such a plan 

will be completed and implemented by the FRA and BNSF Railway by October 30, 2015. 

 The FRA will monitor and report the number of passenger train trips that occur each 

calendar year. Reports will be submitted annually to the USFWS by March 1 of the 

following year. 

Response to Comment 12-10 

The deer from Cottonwood Island within the Task 5 and 6 areas are not part of a population that 

is part of the recovery plan for Columbian white-tailed deer. These are not “secure” areas 

according to recovery plan criteria. Although the evaluation must account for potential take, 

adding minimization measures in this location would not help overall recovery. 

FRA and WSDOT have worked with the USFWS during the Section 7 consultation to address 

effects to the Columbian white-tailed deer. The Biological Opinion issued by the USFWS on 
October 30, 2014 included several terms and conditions that minimize effects to Columbian 

white-tailed deer on passenger rail service. These include the following: 

 The FRA will assess that portion of the Vancouver, BC to Portland, OR rail corridor that 

contains the action area for habitat connectivity in the Washington State Service 

Development Plan, to be finalized in 2017. Measures identified in the plan will be 

implemented in the action area by the FRA, when reasonable to do so, as part of any 

subsequent rail improvement action funded by FRA. 

 The FRA will coordinate with the USFWS and BNSF Railway to develop and implement 

an Animal Retrieval Plan that specifies methods and contacts for retrieval of Columbian 

white-tailed deer found dead or injured on the BNSF Railway right-of-way. Such a plan 

will be completed and implemented by the FRA and BNSF Railway by October 30, 2015. 

 The FRA will monitor and report the number of passenger train trips that occur each 

calendar year. Reports will be submitted annually to the USFWS by March 1 of the 

following year. 

Response to Comment 12-11 

As described in Section 4.15 of the EA, with the two additional round trip (4 one-way trains) 

daily passenger trains, passenger train traffic may increase by 40% but this increase is about 6% 

of total daily train movements (passenger + freight) (4 additional trains/70 total trains). Any 

additional mortality of an endangered species is of concern and was addressed as part of the ESA 

Section 7 consultation and associated BAs for Task 5 and 6. 

FRA and WSDOT have worked with the USFWS during the Section 7 consultation to address 

effects to the Columbian white-tailed deer. The Biological Opinion issued by the USFWS on 

October 30, 2014 included several terms and conditions that minimize effects to Columbian 

white-tailed deer on passenger rail service. These include the following: 

 The FRA will assess that portion of the Vancouver, BC to Portland, OR rail corridor that 

contains the action area for habitat connectivity in the Washington State Service 

Development Plan, to be finalized in 2017. Measures identified in the plan will be 

implemented in the action area by the FRA, when reasonable to do so, as part of any 

subsequent rail improvement action funded by FRA. 

 The FRA will coordinate with the USFWS and BNSF Railway to develop and implement 

an Animal Retrieval Plan that specifies methods and contacts for retrieval of Columbian 

white-tailed deer found dead or injured on the BNSF Railway right-of-way. Such a plan 

will be completed and implemented by the FRA and BNSF Railway by October 30, 2015. 

 The FRA will monitor and report the number of passenger train trips that occur each 

calendar year. Reports will be submitted annually to the USFWS by March 1 of the 

following year. 

Response to Comment 12-12 

See Response to Comment 12-10. 
 

Commenter ID #13
 

Commenter ID #13
 

Commenter ID #13
 

Commenter ID #13
 

Commenter ID #13
 

Commenter ID #13
 

Commenter ID #13
Response to Comments from Christine Reichgott, September 27, 2014 Commenter ID #13 

Response to Comment 13-1 

For the Task 5 EA, groundwater investigations determined that there was little risk of infiltration 

because construction activities are extremely shallow and the project is located outside of the 

Troutdale Sole Source Aquifer. Cowlitz County groundwater is sourced by aquifers located in 

Tertiary sedimentary and igneous rocks and Holocene alluvium. Well levels can range from 6 to 

600 feet below the surface. Alluvial aquifers near the Columbia River fluctuate with changes in 

the Columbia River levels caused by seasonal flood stages, tidal influences, and management of 

the river by upstream hydroelectric dams. Soil deposits in the vicinity of the study area generally 

consist of sand and gravel fill, and alluvial silt, sand, and gravel deposits, underlain by bedrock. 

Cowlitz County is underlain by the Lewis and the Cowlitz aquifers. Cowlitz County’s online 

mapping system shows Critical Aquifer Recharge Areas of moderate and severe sensitivity along 

portions of the project area. Areas of severe sensitivity within the Task 5 project area include the 

southern terminus of the project near Site #6, and the northern terminus of the project near Sites 

#1 through #4. However, construction activities would be shallow and are not anticipated to 

impact any recharge areas. 

Areas of severe sensitivity within the Task 6 project area include an area between Talley Way 

and Interstate 5 near the Coweeman River, and adjacent to the project corridor between Cedar 

Street and Colorado Street, adjacent to Site #6. One moderate risk hazardous materials site 

(1113 Pacific Avenue) was identified within the areas of severe sensitivity; this site was 

identified in an area where earthwork is expected to be shallow and not likely to reach 

groundwater. No hazardous materials sites of concern were identified within 2 miles of the 

Coweeman River bridge crossing. 

Response to Comment 13-2 

During development of the EA, an initial review of the potential effects to groundwater 

determined that there would be negligible effects to groundwater that did not warrant analysis in 

the EA. Additional information regarding the potential effects to groundwater is included in the 

administrative record in the groundwater memorandum dated 11-20-14. With the exception of 

the installation of the Coweeman River Bridge associated with Task 6, minimal subsurface 

impacts would occur as the result of the Build Alternative. 

The project improvements are not anticipated to increase freight traffic; any projected increase in 

freight traffic is independent of the construction of the improvements. As such, an increase in 

release of hazardous materials as a result of operations and maintenance associated with this 

project is minimal. 

A search of Ecology’s well database did not identify public or private drinking water wells 

within the study area. Hazardous materials sites of concern have not been identified in areas 

where deep piles would be driven (Coweeman River bridge crossing). 

Response to Comment 13-3 

During development of the EA, an initial review of the potential effects to groundwater 

determined that there would be negligible effects to groundwater that did not warrant analysis in 
the EA. Additional information regarding the potential effects to groundwater is included in the 

administrative record in the groundwater memorandum dated 11-20-14. 

Response to Comment 13-4 

Maps of hazardous materials sites of concerns are included in Appendix H of the EA and 

discussion of groundwater and soil contamination is included in Section 4.9 of the EA. A search 

of Ecology’s well database did not identify public or private drinking water wells within the 

project area 

[https://fortress.wa.gov/ecy/waterresources/map/WCLSWebMap/WellConstructionMapSearch.a

spx]. Hazardous materials sites of concern have not been identified in areas where deep piles 

would be driven (Coweeman River bridge crossing). 

Response to Comment 13-5 

During development of the EA, an initial review of the potential effects to groundwater 

associated with project construction and operation determined that there would be negligible 

effects to groundwater that did not warrant more detailed analysis. As described in Section 4.18 

of the EA, the scope of the cumulative effects analysis was limited to those resources where FRA 

and WSDOT determined that the Build Alternative would have direct or indirect effects could 

contribute to a cumulative effect. Because no substantial direct or indirect effects to 

groundwater were identified, groundwater effects were not considered in the cumulative effects 

analysis. Pilings are expected to be driven during construction of the Coweeman River bridge 

crossing associated with Task 6. As noted in Section 4.9 of the EA (Hazardous Materials), the 

closest hazardous materials site of concern is located over 2 miles north of the Coweeman River 

bridge crossing. As such, existing contamination is unlikely to be transported to a deeper part of 

the aquifer system during construction of the Coweeman River bridge crossing. No pilings are 

required for construction of the Task 5 project. 

No long‐term effects from the Task 5 and Task 6 projects are anticipated during operations 

because the project would not increase the potential for exposure to hazardous materials from the 

transport or accidental release of hazardous materials. Amtrak Cascades trains operating in the 

study area would not be carrying hazardous material as cargo. 

Response to Comment 13-6 

Details regarding the specific accounting structure are still under development with the 

mitigation banking instrument. The U.S. Army Corps of Engineers (Corps) and Ecology are 

actively participating in the banking process and are supportive of the use of this bank for the 

project. It’s also important to note that the mitigation strategy includes bank credits, as well as 

construction, enhancement and preservation elements to provide a robust, holistic approach to 

offsetting impacts. The final mitigation accounting to offset the functions and values lost from 

the Task 6 project would be finalized with the issuance of permits from Corps. 

Response to Comment 13-7 

The combination of mitigation measures that would be used for Task 6 project, which includes 

preservation, has been developed in consultation with the Corps, Ecology, WDFW, and the 

Cowlitz Indian Tribe. The proposed mitigation package meets the Federal compensatory 

mitigation final rule, the Joint Guidance for Mitigation in Washington State, and is likely to 
provide protection and preservation of suitable habitats for all of the listed species in the Task 6 

project area. The property acquisition negotiation is not complete at this time and therefore the 

specific properties to be acquired cannot be shared. However, the information requested on the 

preservation area would be provided to the Corps and Ecology as part of a mitigation plan once 

the properties are acquired to satisfy the requirements of the Section 401 and 404 permits under 

the Clean Water Act. If the preservation is insufficient to address all of the project impacts they 

are intended to compensate for, then the Corps and Ecology may require additional mitigation 

credits to be purchased. 

Response to Comment 13-8 

According to the Federal Emergency Management Agency (FEMA) Floodplain Management 

Requirements Guide, fill placed in the floodplain (Zone AE), or flood fringe, is allowed without 

further encroachment analysis. However, a review (below) of the potential displacement effects 

of the project floodplain fills identifies that the effects of this action fall well below the 

regulatory criteria that fills within AE zones shall not increase the water surface elevation of the 

base flood more than one foot at any point. 

Floodplain Fill Displacement Review: 

 The total volume of floodplain fill is approximately 13,000 cubic yards. 

 The total floodplain area fill footprint is 4 acres. However, the existing track support 

prism is included within that footprint. The volume of impact to the floodplain is defined 

as the wedge of soil between the average toe of fill elevation (13 feet) and the 1% flood 

elevation (19 feet above sea level). Thus, the actual volume of displacing fill in the 

floodplain is approximately one-third of the total track support structure fill volume. (4 

acres x 43,560 ft2

/acre x 6ft x 0.333 = 348,131 ft3 fill displacement in the affected 

floodplain; = 12,894 cubic yards of displacement fill; = 7.99 acre feet; = 95.9 acre 

inches.) 

 The total area of the 1% floodplain south of the Kalama River and east of the Columbia 

River directly connected to the project impacts, is 263 acres. 

 By projecting 95.9 acre inches of displacement over the 263 acres of immediate 

connected area floodplain, a potential rise 0.36 inches in flood elevation is obtained. By 

utilizing the entire 1% flood plain actually shown as connected to the project area in the 

FEMA maps, this effect becomes immeasurably small. 

Based on this analysis, the initial estimated 15,000 cubic yards of floodplain displacement fill, 

revised to 13,000 cubic yards after design improvements, constitutes a minimal, if even 

measurable, impact to the overall mapped floodplain either indirectly or directly connected to 

this project. The rock fringe fill to the floodplain along Wetland B does not result in an increase 

in stormwater runoff peak flows or volume. Wetland B is the conveyance from the city of 

Kalama stormwater outfall. As the analysis has demonstrated, the project would not affect the 

stormwater conveyance ditch from the city of Kalama to the Kalama River. No excavations in or 

adjacent to any wetlands are being proposed given the minimal impact to the floodplain storage 

volume. Additionally, because the Build Alternative is not anticipated to impact flooding or 

stormwater conveyance, there would be no indirect effects to adjacent properties. 
As described in Section 4.3 of the EA (Water Resources), other culverts, such as Unnamed 

Tributary 3 will be modified to provide fish passage and increase available conveyance capacity 

in the area. While not part of this project, WSDOT will refer the comment to WDFW for future 

consideration. 

Response to Comment 13-9 

According to the FEMA Floodplain Management Requirements Guide, the fill placed in the 

floodplain (Zone AE), or flood fringe, is allowed without further encroachment analysis. FRA 

and WSDOT would submit a hydraulic analysis report along with an MT-2 Conditional Letter of 

Map Revision application to FEMA review of the projects effects to the regulated floodplain and 

floodway areas. 

Response to Comment 13-10 

FRA and WSDOT acknowledge the effects of historical habitat fragmentation caused by the rail 

line. The issue of habitat fragmentation on all species is a baseline condition because the rail line 

has been in operation for over a century; all work would occur within the existing rail right-ofway; and, no new corridor would be established. FRA and WSDOT considered connectivity as 

part of the project, as it related to Columbia white-tailed deer and aquatic species. 

In the project area, the project would replace three undersized culverts and would reconnect 

stream habitat used by listed Lower Columbia River coho and steelhead lost by historic road and 

railway work. These new connections would provide access to additional upstream rearing and 

spawning habitat. Furthermore, WSDOT considered impediments to crossing for Columbia 

white-tailed deer and determined the track is not a complete barrier to Columbia white-tailed 

deer movement within the project area. There are track sections with steep, rock-ballasted side 

slopes that Columbia white-tailed deer would probably not use. However, there are many areas 

that would allow passage, including at-grade track sections, underpasses, and bridges. WSDOT 

would work with USFWS and utilize Columbia white-tailed deer data developed by USFWS to 

inform future decisions on rail improvements where 1) crossing appears to be an issue; and, 2) a 

project exists that can accommodate a habitat connectivity element. 

Please note that high-speed (79 MPH) service already is provided in this corridor. Speeds are 

not planned to increase as a result of either Task 5 or Task 6. There is no additional 

implementation of any other high-speed rail service, such as that contemplated in California that 

is part of this project or the State’s PNWRC Improvement Plan. 

Response to Comment 13-11 

Although there are no known studies of similar rail grain-associated wildlife mortality area in the 

lower 48 states, the issue of how chronic grain loss from train cars during transport could attract 

wildlife and result in additional mortality was publicized in Banff National Park, where Canadian 

Pacific Railway trains struck and killed seven grizzly bears between 2000 and 2007. Chronic 

grain loss was primarily attributed to faulty grain cars (Wells, et al, 1999. Wildlife Mortality on 

Railways: Monitoring Methods and Mitigation Strategies). Although bear mortality was the 

primary concern, there was additional mortality of other wildlife, such as moose, deer, wolves 

and coyotes. About 2.7 deer per year were killed from 1982 to 2001 in Banff and Yoho National 
Parks in areas associated with grain spills. The area where this problem was identified has large 

populations of carnivores and ungulates. 

It is also important to keep in mind that the purpose and need for the Task 5 and 6 projects is to 

improve intercity passenger rail service by improving reliability, enhancing efficiency, and 

increasing passenger rail travel frequency. As stated in Section 4.15 of the EA, freight rail would 

increase in the Task 5 and 6 study areas but the exact makeup of that increase is currently 

unknown. Therefore, it is not possible to reasonably anticipate any increase in the transportation 

of grain along the study area. However, grain capacity improvements at the Port of Kalama are 

underway as part of an unrelated privately sponsored action. Grain loading areas at the Port are 

not readily accessible to wildlife because of fencing and other exclusion measures that are 

required by the US Department of Homeland Security. 

The location of the railway bed and associated infrastructure provide variable conditions and 

corridors for wildlife in the project area. The close proximity of Interstate-5 and industrialized 

areas, such as the Port of Kalama to the rail corridor, create barriers to smaller, less mobile 

wildlife (e.g., reptiles and small mammals). Other larger, more mobile wildlife species (deer) are 

able to move through the rail corridor through underpasses, at-grade crossings, and under 

bridges. The rail corridor itself would also provide a corridor for the movement of wildlife; 

however, the proposed project would not create any new pathways as the entire project would be 

built within the existing corridor. 

Response to Comment 13-12 

The railway in the Task 5 and 6 areas traverses a variety of habitats that may be used by many 

wildlife species. These habitats include the developed region north of the confluence of the 

Coweeman/Cowlitz Rivers; forested and open wetland habitats along Owl Creek; and the 

developed area associated with the Port of Kalama. Wildlife movements in these areas are 

constrained by both Interstate-5 and the BNSF Railway. Interstate-5 likely constrains wildlife 

movement more than the railway; it is wider, has greater traffic volume, and faster moving 

vehicles. The railway has about 70 trains per day (freight and passenger) in the Port of Kalama 

area. In some areas the tracks are elevated with steep rock ballasted slopes, which could present 

significant movement challenges for all wildlife guilds. However, there are underpasses under 

the rail line in several locations, including the rail and Interstate 5 bridges over the Kalama 

River. More significantly, there are many areas where the railway is at-grade, and would not be a 

barrier to ungulate movement. FRA and WSDOT recognize that at-grade crossings could be a 

barrier to small mammals, amphibians, and reptiles. 

The developed areas within the Task 5 and 6 project areas have relatively inhospitable conditions 

for many wildlife species. In addition to the railway and Interstate 5, there are local roads and 

associated traffic, and industrialized and fenced areas within the Port of Kalama that would be 

barriers or present major challenges to wildlife movement. About half of the widened track area 

in the Task 5 and 6 project areas are in these more industrialized sections. 

The freight and passenger rail operators do not keep records of train collisions with deer or other 

wildlife, so there is no specific information available on that issue. 

FRA and WSDOT are awaiting data from radio-telemetered Columbia white-tailed deer from the 

USFWS to help inform where deer habitats intersect with the rail line, and to determine if deer 
are crossing the tracks. The California High-Speed Rail Project presents a condition significantly 

different with the Task 5 and 6 projects. The Project in California is proposed as a new rail 

corridor; whereas for this Project, the improvements for passenger rail are proposed within an 

existing rail corridor where freight and passenger movements have been accommodated for 

nearly a century. The proposed Build Alternatives for Task 5 and 6 are limited main line 

additions and spurs provided to separate freight and passenger rail service within an existing 

corridor as opposed to establishing a new rail corridor. 

FRA and WSDOT have worked with the USFWS during the Section 7 consultation to address 

effects to the Columbian white-tailed deer. The Biological Opinion issued by the USFWS on 

October 30, 2014 included several terms and conditions that minimize effects to Columbian 

white-tailed deer on passenger rail service, including: 

 The FRA will assess that portion of the Vancouver, BC to Portland, OR rail corridor that 

contains the action area for habitat connectivity in the Washington State Service 

Development Plan, to be finalized in 2017. Measures identified in the plan will be 

implemented in the action area by the FRA, when reasonable to do so, as part of any 

subsequent rail improvement action funded by FRA. 

 The FRA will coordinate with the USFWS and BNSF Railway to develop and implement 

an Animal Retrieval Plan that specifies methods and contacts for retrieval of Columbian 

white-tailed deer found dead or injured on the BNSF Railway right-of-way. Such a plan 

will be completed and implemented by the FRA and BNSF Railway by October 30, 2015. 

The FRA will monitor and report the number of passenger train trips that occur each calendar 

year. Reports will be submitted annually to the USFWS by March 1 of the following year. 

Response to Comment 13-13 

The funding realities of the proposed Pacific Northwest Rail Corridor program necessitated 

developing the current plan for 8 round trips; there is no current intent to increase passenger rail 

service beyond these levels. The EA discusses the reasonably foreseeable future actions in 

Section 4.18. 

Response to Comment 13-14 

The estimated increase of 22 freight trains on BNSF Railway tracks was provided by BNSF 

Railway based on reasonably foreseeable future conditions. This estimate is based on the 

forecasted growth for the corridor. It is referenced in the 2011 PNWRC Service Development 

Plan. Ultimately, freight rail volumes are dependent upon market conditions and system 

capacity, which are not regulated by the FRA and WSDOT. 

Response to Comment 13-15 

The projected increase to 62 trains per day is based on the projected increase in commodity 

shipments to/from the Pacific Northwest ports independent of the construction of the 

improvements. The projected increase was developed by BNSF Railway based upon reasonably 

foreseeable estimates of the future condition. The cumulative effects analysis presents the 

“snapshot in time” of other known and projected rail projects in the study areas. One of the goals 
of the improvements is to increase passenger services on-time performance without degrading 

freight operations. 

Additional capacity may be added at any time by the railroad company without any Federal 

involvement. While it is possible to estimate additional expected capacity on rail lines, the FRA 

has limited ability to control the number of trains operating on a particular rail line. 

Response to Comment 13-16 

The potential effects associated with an increase in the number of freight trains operating in the 

project area is evaluated in the cumulative effects analysis in the EA (Section 4.18). Although an 

analysis of the specific safety risks associated with the increase in freight traffic is conjectural, 

the increase is not anticipated to significantly impact safety or project design. The increase in 

train traffic resulting from the reasonably foreseeable future actions described in Section 4.18 

would likely result in a slight increased safety risk. There would be an increased potential for 

accidents involving vehicles and pedestrians; however, the current accident rate, as described in 

Section 4.16 of the EA, is very low and the increased freight traffic would not be anticipated to 

increase the accident rate substantially. Therefore, no cumulative effect on safety is anticipated. 

The service operating plan agreements between WSDOT and BNSF Railway provide for 

improved passenger rail service while ensuring effective operation of the private rail freight 

activities. Additionally, the proposed projects provide for improved separation of freight and 

passenger rail services, allowing for improved passenger rail speed and reliability. The projects 

will be accommodated within the existing BNSF-owned rail corridor. The preliminary design 

work, which is the basis for effects analysis in this EA, has been developed in the context of the 

PNWRC Improvement Plan for passenger rail service, and in coordination with BNSF Railway. 

As noted in Sections 4.15 (Transportation) and 4.18 (Indirect Effects) of the EA, the roadway 

improvement projects proposed by the city of Kelso (West Main Street Realignment, Yew Street 

Reconstruction Phase 1, and city of Kelso Railroad Crossing Study) would improve roadway 

flow and potentially reduce traffic in the city of Kelso. Whether these improvements could 

accommodate roadway travel requirements from the Millennium Bulk Terminal Logistics 

(MBTL) Project and Port of Kalama Terminal Expansion Project will be more reasonably 

assessed in the context of those projects and in the MBTL Project NEPA analysis and other 

environmental documentation. The roadway improvement crossing projects are not presently 

identified as mitigation for those efforts. In addition, the health and safety effects of that 

proposal would likely be evaluated and documented in detail. Based on the best available 

information about the MBTL Project proposal and the comparative stage of planning (currently 

in preliminary stages compared to Kelso Martin’s Bluff projects), the MBTL Project is unlikely 

to affect the Task 5 or Task 6 Build Alternatives or their design. Rather, Tasks 5 & 6 represent 

conditions to which the MBTL improvements would need to conform. 

Response to Comment 13-17 

To evaluate anticipated changes that may affect the project area, FRA and WSDOT considered 

the results of WSDOT’s recently completed Climate Impacts Vulnerability Assessment Report 

(November 2011). That study examined climate change risks to state-owned infrastructure, and 

therefore did not include the BNSF-owned railway. WSDOT and FRA considered the results for 

SR 411, SR 432 and I-5 in the Project area and found there is a potential for increased slope 
failures, river flooding and susceptibility to sea level rise. SR 432 shows a high vulnerability, 

while Interstate 5 and SR 432 within the Project area show a low vulnerability to climate change. 

FRA and WSDOT considered this information about climate change with regard to preliminary 

design as well as the potential for changes in the surrounding natural environment. The Build 

Alternative projects are designed to last more than 50 years. The proposed projects have 

incorporated features such as modification and extension of existing culverts and armoring 

portions of the line to protect against scouring. Although these features were not added due to the 

findings of the vulnerability analysis, the features would provide greater resilience and function 

with regard to the potential effects of climate change. WSDOT and BNSF Railway are not aware 

of other armoring or additional features needed to protect against future climate change. 

Response to Comment 13-18 

The analysis of the potential effects of the proposed projects on environmental justice 

populations presented in Section 4.13.3 of the EA concludes that the effects described 

throughout the EA, including noise and safety, would not be appreciably greater for any 

environmental justice population than for the population as a whole. The additional 2 roundtrip 

(4 one-way) daily passenger trains would represent a minor increase in train traffic over existing 

levels that would not be anticipated to markedly change the existing safety or noise environment. 

Further, train whistles would not blow between the hours of 10 PM and 7 AM; thus, sleep would 

not be disturbed. 

As the impacts on environmental justice populations would not be appreciably greater than the 

population as a whole, further outreach associated with the NEPA process is not anticipated. The 

effects described in the EA from the implementation of the proposed project are not anticipated 

to disproportionately affect children; therefore, Executive Order 13045 was found not to apply to 

this action. 

 
 

Commenter ID #14
 

Commenter ID #14
 

Commenter ID #14
 

Commenter ID #14
Response to Comments from Steven Fischer, September 23, 2014 Commenter ID #14 

Response to Comment 14-1 

A navigation evaluation has been completed and will be submitted with the Section 9 permit 

application. The proposed horizontal and vertical clearances of the new bridge are greater than 

all other known bridges on the Coweeman River and thus prove no impediment to navigation 

over current conditions. During construction, the Coweeman River width and height clearances 

would be constricted. However, based on communications with local, recreational fisherman and 

guide services, fishing via a boat from the Cowlitz to the Coweeman rivers is unlikely. 

Motorized boats and flat water boats that likely use the Coweeman River are less than 16 feet 

and 22 feet in length, respectively. Navigation on the Cowlitz River is not expected to be 

affected during construction or operation of the new bridge.

Response to Comment 14-2 

Comment noted. The General Bridge Act of 1946 authorizes the Secretary of Homeland 

Security, through the U.S. Coast Guard (USCG) to issue permits for bridges or structures that 

cross or could otherwise affect navigation on waters of the U.S.

Response to Comment 14-3 

A navigation evaluation has been completed and will be submitted with the USCG Bridge Permit 

application. 

Response to Comment 14-4 

The list of preparers is presented in Section 7 of the EA.

Response to Comment 14-5 

The project is not listed on the 2014-2017 State Transportation Improvement Program. The Task 

5 and 6 projects are key components of the PNWRC Improvement Program and, when 

completed, would help facilitate the addition of two Amtrak Cascades service round trips (4 oneway trains) between Portland, Oregon, and Seattle, Washington, with improved reliability and 

reduced travel time. Although the PNWRC Improvement Program would not increase the 

number of Amtrak Coast Starlight trains (Amtrak’s longer distance passenger rail service 

between Los Angeles, California, and Seattle), the program could improve the speed and 

reliability of those trains as well.

Response to Comment 14-6 

Thank you for the comment.

Response to Comment 14-7 

Please refer to Appendix A for a complete list of all required permits, laws and regulations, 

including the Clean Water Act (CWA). As part of the CWA Section 404 permitting process, a 

Section 401 Water Quality Certification would be obtained from Ecology. Although the USCG 

Bridge Permit would require a CWA Section 401 Water Quality Certification, it is unlikely that 
Ecology would include additional requirements beyond those in the Water Quality Certification 

issued as part of the CWA Section 404 permit.

Response to Comment 14-8 

As discussed in Section 5 of the EA, a NPDES Construction Stormwater General Permit will be 

required for the projects.

Response to Comment 14-9 

The Safe Drinking Water Act ensures safe drinking water for the public. It requires public water 

systems to regularly monitor their water for contaminants. A search of Ecology’s well database 

performed for this EA analysis did not identify public or private drinking water wells within the 

study area for hazardous materials or water resources. As such, the proposed projects would not 

contribute to any degradation of public water systems.

Response to Comment 14-10 

Thank you for the comment.

Response to Comment 14-11 and 14-12 

The primary purpose of the Emergency Planning and Community Right-to-Know Act and 

Executive Order 12856 is to encourage and support emergency planning efforts at the state and 

local level and provide the public with information regarding potential chemical hazards in their 

communities. The proposed projects would not involve any chemicals that would require 

notification under the act or which could result in changes to any local emergency planning 

efforts; it is, therefore, not applicable.

Response to Comment 14-13 

The hazardous material sites of concern in the Task 5 and 6 study areas are presented in the 

Section 4.9.2 of the EA. Some of these sites are subject to the stipulations of the Resource 

Conservation and Recovery Act (RCRA); however, these sites would not be affected by or affect 

the proposed projects and no hazardous waste subject to RCRA would be generated by the 

projects.

Response to Comment 14-14 

The proposed project would be in accordance with EO 12088, which requires that Federal 

agencies are compliant with applicable pollution control standards. Appendix M of the EA 

includes minimization measures for pollution control. Compliance with EO 12088 will be a 

commitment of the proposed mitigation/minimization measures for the built alternatives.

Response to Comment 14-15 

The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) does 

not apply because the proposed projects do not involve superfund sites.
Response to Comment 14-16 

As the project would be constructed within the existing BNSF Railway right-of-way and no 

property would be acquired, there is no potential for impacts to prime and unique farmlands.

Response to Comment 14-17 

Funding for the Noise Control Act of 1972 and the Quiet Communities Act of 1978 was phased 

out in 1982; however, the analysis of noise and vibration from construction and operation of the 

proposed projects is described in Sections 4.7 and 4.8 of the EA. 

Response to Comment 14-18 

The project is located within Cowlitz County, which is not one of the fifteen counties that 

comprise Washington’s coastal zone. 

Response to Comment 14-19 

In accordance with EO 11990, construction within areas containing wetlands is avoided, where 

practicable. The wetland effects that cannot be avoided and the appropriate proposed mitigation 

measures are discussed in Section 4.4 and Section 5.0 of the EA.

Response to Comment 14-20 

In accordance with EO 11988, Federal agencies have a responsibility to evaluate the potential 

effects of any actions they may take in a floodplain. The potential effects to floodplains and 

proposed mitigation measures are discussed in Section 4.3 and Section 5.0 of the EA.

Response to Comment 14-21 

The proposed project would not involve construction of a water resource development project, as 

defined in the Fish and Wildlife Coordination Act. Consultation with the USFWS regarding 

impacts to listed species under Section 7 of the ESA has been completed.

Response to Comment 14-22 

EO 13112 directs Federal Agencies to not authorize, fund, or carry out actions that it believes are 

likely to promote the introduction or spread of invasive species. As discussed in Section 4.5 of 

the EA, the proposed projects could result in the introduction of noxious weeds; however, the 

minimization measures and best management practices described in Appendix M of the EA 

would minimize the potential for the spread of invasive species. 

Response to Comment 14-23 and 14-24 

The Migratory Bird Treaty Act (MBTA) of 1918 (16 U.S.C. 703–712), as amended, and 

Executive Order 13186, Responsibilities of Federal Agencies to Protect Migratory Birds, require 

Federal agencies to minimize or avoid impacts on migratory birds. Both would be applicable to 

the proposed projects. Unless otherwise permitted by regulations, the MBTA makes it unlawful 

to (or attempt to) pursue, hunt, take, capture, or kill any migratory bird, nest, or egg. In 

accordance with these measures, the Build Alternative will be conducted in a manner to avoid 

adverse effects on migratory birds to the extent practicable; therefore, no effects on migratory 
birds would be anticipated. This will be a commitment of the proposed mitigation/minimization 

measures for the build alternatives. 

Response to Comment 14-25 

The Bald and Golden Eagle Protection Act prohibits, without proper permitting, disturbance 

from construction activities to nesting bald eagles during their active nesting period, which 

occurs January 1 through August 15. Guidelines established by the USFWS require an eagle nest 

to be within 660 feet of the construction activities or 0.5 miles of blasting to trigger review. The 

WSDOT reviewed the most current eagle nest data (April 2014) from the WDFW and the closest 

bald eagle nest is located approximately 930 feet from the rail line where construction activities 

are planned. No blasting will occur within 0.5 mile of the nest. As such, the construction 

activities are not considered a disturbance to this bald eagle nest and are not subject to timing 

restrictions or permitting. 

The project area has had a high level of rail, industrial, and highway activity (and associated 

noise) for decades. It is assumed that bald eagles nesting in the project area are acclimated to the 

existing noise environment due to reoccurring use of the site and nesting success. Although the 

horn noise from additional passenger trains could disturb wildlife, including eagles, in the project 

area, disturbances are minor when the existing noise environment is taken into consideration. 

According to BNSF Railway the train horn noise from existing operations and maintenance 

activities has not required either a Disturbance Permit or Take Permit under the Bald and Golden 

Eagle Protection Act. 

The list of applicable laws and regulations in Appendix A of the EA is limited to laws and 

regulations where an actual approval or permit from an agency would be issued.

Response to Comment 14-26 

The project area is near the Columbia River. Marine mammals have been known to migrate up 

the Columbia River; however, no marine mammal haulout sites are documented near the Task 5 

or Task 6 study areas. As discussed in the Task 6 BA (Appendix G of the EA) the Task 6 project 

action area does not extend to the Columbia River and marine mammals, such as Steller sea 

lions, are not known to occur within the action area. The Task 5 project BA (Appendix F of the 

EA) also concludes that the action area would not affect the Columbia River as no work is 

occurring in the Columbia River. Consultation with the NMFS has not identified concerns with 

marine mammals or the need to obtain authorizations under the Marine Mammal Protection Act 

for the Task 5 or 6 projects.

Response to Comment 14-27 

Thank you for the comment.

Response to Comment 14-28 

Thank you for the comment.

Response to Comment 14-29 

EO 13158 is not applicable as there are no Marine Protected Areas in the project area.
Response to Comment 14-30 

Thank you for the comment.

Response to Comment 14-31 

Thank you for the comment.

Response to Comment 14-32 

Thank you for the comment.

Response to Comment 14-33 

Thank you for the comment.

Response to Comment 14-34 

In accordance with the National Historic Preservation Act and EO 11593, several cultural 

resource surveys have been conducted within the Area of Potential Effects (APE) for the Task 5 

and Task 6 projects. A Cultural Resources Discipline Report was prepared in 2003 for the Kelso 

– Martin’s Bluff Rail Project NEPA/SEPA Preliminary Draft Environmental Impact Statement, 

which incorporates the Task 5 and Task 6 project area. Cultural resource surveys, including 

archaeological investigations and historic property inventories, were also undertaken in the Task 

5 and Task 6 study areas in 2002, 2003, and 2006. FRA and WSDOT conducted a supplemental 

survey of National Register of Historic Places-eligible properties located within the Task 6 APE 

in 2013 (see Appendix J of the EA). Effects of the Task 5 and Task 6 projects were determined 

by comparing the projects’ design information with data on the existing cultural resources 

present in the Task 5 and Task 6 study areas. Coordination with the Washington Department of 

Archeological and Historic Preservation (DAHP) included the USCG -required lighting and 

workers’ walkway improvements on the existing historic Coweeman River Bridge, and on the 

proposed new bridge. The consultation with DAHP resulted in a finding of no significant effect 

(see Appendix J for correspondence).

Response to Comment 14-35 

The proposed projects are not anticipated to impact the treatment, repatriation, and disposition of 

Native American human remains, funerary objects, sacred objects, and objects of cultural 

patrimony. The tribes consulted with during preparation of the EA are listed in Appendix J.

Response to Comment 14-36 

The proposed projects would not involve any actions which would appropriate, excavate, injure, 

or destroy any historic or prehistoric ruin or monument, or any object of antiquity, situated on 

lands owned or controlled by the Government of the United States. 

Response to Comment 14-37 

Thank you for the comment.
Response to Comment 14-38 

The proposed projects are not anticipated to have any effects on Native American’s continued 

free exercise of native religion. The tribes consulted with during preparation of the EA are listed 

in Appendix J.

Response to Comment 14-39 

Potential impacts to Section 6(f) and 4(f) properties are described in Section 4.10 and 4.12 of the 

EA, respectively. No Section 6(f) properties would be affected by either Task 5 or Task 6.

Response to Comment 14-40 

EO 13045 would not be applicable to the Build Alternative as it is not a “covered regulatory 

action” as defined in EO 12866. Actions covered under EO 13045 include those that may be 

“economically significant” (as defined in EO 12866) and “concern an environmental health risk 

or safety risk that an agency has reason to believe may disproportionately affect children.” An 

economically significant action is one that would have an annual effect on the economy of $100 

million or more. The Build Alternative is not anticipated to have this annual effect on the 

economy. Further, the effects described in the EA from the implementation of the proposed 

project are not anticipated to disproportionately affect the environmental health and safety of 

children in the project area. EO 13045 defines environmental health and safety as “risks to 

health or to safety that are attributable to products or substances that the child is likely to come in 

contact with or ingest (such as the air we breath, the food we eat, the water we drink or use for 

recreation, the soil we live on, and the products we use or are exposed to).” The proposed 

projects are not anticipated to increase the health and safety risk to children from exposure to any 

products or substances that would increase the exposure risk; therefore, no disproportionate 

effects on children are anticipated. 

The list of applicable laws and regulations in Appendix A of the EA is limited to laws and 

regulations where an actual approval or permit from an agency would be issued. 

Response to Comment 14-41 

BNSF Railway will follow all applicable provisions of the Occupational Safety and Health Act 

(OSHA) and its implementing regulations at all times during construction and operation of the 

proposed projects. In addition, public and worker safety will be maintained by adhering to a jobspecific Safety Action Plan that WSDOT will ensure is developed by the construction contractor 

prior to groundbreaking. This plan will provide a complete safety program, including risk 

identification procedures, emergency response plan, safety communication, and other safety 

initiatives. Additionally, this plan will comply with FRA’s On-Track Safety Program (49 CFR 

214.303), which affords on-track safety to all workers whose duties are performed on the 

railroad. 

The list of applicable laws and regulations in Appendix A of the EA is limited to laws and 

regulations where an actual approval or permit from an agency would be issued. 

 
Commenter ID #15
Response to Comments from Tyrel Koistinen, Undated Commenter ID #15 

Response to Comment 15-1 

The Bald and Golden Eagle Protection Act prohibits, without proper permitting, disturbance 

from construction activities to nesting bald eagles during their active nesting period, which 

occurs January 1 through August 15. Guidelines established by the US Fish and Wildlife Service 

require an eagle nest to be within 660 feet of the construction activities or 0.5 miles of blasting to 

trigger review. WSDOT reviewed the most current eagle nest data (April 2014) from the WDFW 

and the closest bald eagle nest is located approximately 930 feet from the rail line where 

construction activities are planned. No blasting would occur within 0.5 mile of the nest. As such, 

the construction activities are not considered a disturbance to this bald eagle nest and are not 

subject to timing restrictions or permitting. 

The project area has had a high level of rail, industrial, and highway activity (and associated 

noise) for decades. It is assumed that bald eagles nesting in the project area are acclimated to the 

existing noise environment due to reoccurring use of the site and nesting success. Although the 

horn noise from additional passenger trains could disturb wildlife, including eagles, in the project 

area, disturbances are minor when the existing noise environment is taken into consideration. 

According to BNSF Railway the train horn noise from existing operations and maintenance 

activities has not required either a Disturbance Permit or Take Permit under the Bald and Golden 

Eagle Protection Act. 

The list of applicable laws and regulations in Appendix A of the EA is limited to laws and 

regulations where an actual approval or permit from an agency would be issued. 

 
Commenter ID #16
Response to Comments from Iloba Odum, Undated Commenter ID #16 

Response to Comment 16-1 

Thank you for the comment. The website location where the requested materials can be found 

was made available to the public on August 28, 2014. 

 
Commenter ID #17
Commenter ID #17
Response to Comments from Darold Dietz and Sharon Zimmerman, September 18, 2014 Commenter ID #17 

Response to Comment 17-1 

As noted in Section 4.15 of the EA, a traffic control plan will be prepared to maintain access 

along the corridor during construction. Currently, construction access is not anticipated along 

South Pacific Avenue. As such, South Pacific Avenue is anticipated to stay open throughout 

construction. 

Response to Comment 17-2 

South Pacific Avenue is not anticipated to be utilized for construction access. However, the 

condition of South Pacific Avenue in the vicinity of the project will be documented prior to 

construction. If construction vehicles used for the Project operate over South Pacific Avenue 

and damage the road surface the contractor will be responsible for restoring those areas to a 

condition similar and equal to pre-construction condition. As a requirement of the contract plans 

and specifications, the contractor will be held liable to protect existing structures, including 

roads. 

Response to Comment 17-3 

The addition of the third track, service road, and the culverts adjacent to the airport within the 

existing BNSF Railway right of way would not increase stormwater runoff onto airport property; 

rather the discharge would infiltrate within BNSF Railway right of way similar to current 

conditions. BNSF Railway would construct the third track using pervious railroad ballast and 

the service road from similar pervious materials, which would allow for continued infiltration of 

stormwater. This would result in stormwater runoff conditions similar to existing conditions and 

would be consistent with Washington state stormwater regulations. These construction activities 

would not be required to obtain coverage under the Washington Department of Ecology 

(Ecology) National Pollutant Discharge Elimination System (NDPES) Industrial Stormwater 

General Permit. As described in Section S1 of the permit, Ecology does not require “industrial 

facilities that discharge stormwater only to groundwater (e.g., on-site infiltration) with no 

discharge to surface waters of the state under any condition” to obtain coverage under the permit. 

Response to Comment 17-4 and 17-5 

BNSF Railway met with the Southwest Regional Airport Manager and staff and agreed to review 

airport leases on BNSF Railway property. No construction access from airport property is 

currently proposed or anticipated. The proposed single-track bridge at the Coweeman River 

would also be evaluated in accordance with FAA regulations under 49 CFR 77 regarding 

potential conflicts with the Runway Protection Zone, Object Free Area, and airport clear zones.

 
 

Commenter ID #18
Response to Comments from Terry Cornelius, September 27, 2014 Commenter ID #18 

Response to Comment 18-1 

The EA analysis is based on a preliminary design sufficient to understand the environmental 

effects of the Build Alternative in comparison to the no build alternative. Designs would be 

further developed to include detailed stormwater management plans that address maintaining 

existing drainages per the Washington State stormwater manual requirements. During design, a 

stormwater pollution prevention plan would be implemented to minimize sediment from entering 

surface water, which would minimize the potential for sediment to enter the drainage in question. 

Response to Comment 18-2 

Section 5.1.3 of the EA identifies drainage improvements that are proposed as part of the project 

and outlines how these improvements meet WDFW fish passage requirements. WDFW has been 

consulted for development of this EA, and WDFW data sets and other applicable data sets were 

reviewed and summarized in the EA. Personal communications with WDFW, NMFS and 

USFWS were part of the effort to assess and document existing conditions in the study area. 

FRA and WSDOT considered habitat connectivity as part of the project. Within the project area, 

three undersized culverts would be replaced and would reconnect stream habitat used by listed 

Lower Columbia River coho and steelhead lost by historic road and railway work. These new 

connections would provide access to additional upstream rearing and spawning habitat. 

 
 

Commenter ID #19
 

Commenter ID #19
Response to Comments from Bill Berry, September 27, 2014 Commenter ID #19 

Response to Comment 19-1 

According to the FEMA Floodplain Management Requirements Guide, fill placed in the 

floodplain (Zone AE), or flood fringe, is allowed without further encroachment analysis. 

However, a review (below) of the potential displacement effects of the project floodplain fills 

identifies that the effects of this action fall well below the regulatory criteria that fills within AE 

zones shall not increase the water surface elevation of the base flood more than one foot at any 

point. 

Floodplain Fill Displacement Review: 

 The total volume of floodplain fill is approximately 13,000 cubic yards. 

 The total floodplain area fill footprint is 4 acres. However, the existing track support 

prism is included within that footprint. The volume of impact to the floodplain is defined 

as the wedge of soil between the average toe of fill elevation (13 feet) and the 1% flood 

elevation (19 feet above sea level). Thus, the actual volume of displacing fill in the 

floodplain is approximately one-third of the total track support structure fill volume. (4 

acres x 43,560 ft2

/acre x 6ft x 0.333 = 348,131 ft3 fill displacement in the affected 

floodplain; = 12,894 cubic yards of displacement fill; = 7.99 acre feet; = 95.9 acre 

inches.) 

 The total area of the 1% floodplain south of the Kalama River and east of the Columbia 

River directly connected to the project impacts, is 263 acres. 

 By projecting 95.9 acre inches of displacement over the 263 acres of immediate 

connected area floodplain, a potential rise 0.36 inches in flood elevation is obtained. By 

utilizing the entire 1% flood plain actually shown as connected to the project area in the 

FEMA maps, this effect becomes immeasurably small. 

Based on this analysis, the initial estimated 15,000 cubic yards of floodplain displacement fill, 

revised to 13,000 cubic yards after design improvements, constitutes a minimal, if even 

measurable, impact to the overall mapped floodplain either indirectly or directly connected to 

this project. The rock fringe fill to the floodplain along Wetland B does not result in an increase 

in stormwater runoff peak flows or volume. Wetland B is the conveyance from the city of 

Kalama stormwater outfall. As the analysis has demonstrated, the project would not affect the 

stormwater conveyance ditch from the city of Kalama to the Kalama River. No excavations in or 

adjacent to any wetlands are being proposed given the minimal impact to the floodplain storage 

volume. Additionally, because the Build Alternative is not anticipated to impact flooding or 

stormwater conveyance, there would be no indirect effects to adjacent properties. 

As described in Section 4.3 of the EA (Water Resources), other culverts, such as Unnamed 

Tributary 3 will be modified to provide fish passage and increase available conveyance capacity 

in the area. While not part of this project, WSDOT will refer the comment to WDFW for future 

consideration. 
 

Commenter ID #20
Response to Comments from Gary Lindstrom, September 27, 2014 Commenter ID #20 

Response to Comment 20-1 

The purpose and need for the Task 5 and 6 projects is to provide improved passenger rail service 

speed and reliability. In Washington State, as for much of the country, passenger rail service is 

accommodated on corridors owned by Class I (freight) rail operators. BNSF Railway would 

make improvements to its infrastructure that it sees fit to accommodate its market, and while it is 

acknowledged in the EA that some benefits to freight movements would likely result from the 

proposed projects, the purpose and intent of these projects is focused on the improvement of 

passenger rail service for a contractually agreed-upon period of time. 

As part of the HSIPR Program, any additional capacity created by railroad infrastructure 

improvements are intended to improve passenger rail operations by supporting additional 

passenger train frequency and increased passenger-train on-time performance. However, these 

improvements to passenger rail operations will be implemented without degrading existing 

freight train performance and capacity. Currently, the existing main line infrastructure is not 

adequate to support the expanded and improved passenger service. Infrastructure improvements 

were tested using operations simulation modeling under FRA’s review and the resulting 

improvements proposed for the Kelso Martin’s Bluff Area were determined to be those required 

by among FRA, the WSDOT, and BNSF Railway. 

This infrastructure and the methodology used to identify it are documented in the Cascades

Service Development Plan approved by the FRA in 2010. This infrastructure is required to 

accommodate scheduled, faster passenger trains when mixing with freight trains which are 

longer, slower, and unscheduled, and maintain station-to-station on-time performance 

requirements of PRIIA. 

 
 

Commenter ID #21
Response to Comments from Diane Dick, September 27, 2014 Commenter ID #21 

Response to Comment 21-1 

Scheduled stops at the Kelso Amtrak Station were included in the modelling efforts; however, 

scheduled stops at the station do not adversely affect speed and on-time performance. Rather, 

the factors that affect passenger train speed and efficiency in the project area are congestion at 

critical points on the rail system where freight trains access port facilities. The Task 5 and 6 

projects improve passenger rail performance by reducing this congestion. 

Response to Comment 21-2 

As part of the Service Development Plan effort, WSDOT modeled operations at Kelso Station 

and did not find that it was a point of congestion for passenger rail service. The modelling and 

evaluation showed that two tracks at the station are sufficient for passenger rail service and to 

allow through traffic to continue while a passenger train is in the station. 

 
 

Commenter ID #22
Response to Comments from Susan Eugenis, September 23, 2014 Commenter ID #22 

Response to Comment 22-1 

The project will comply with floodplain management requirements, which are based on FEMA 

floodplain elevations. FRA and WSDOT will submit a hydraulic analysis report along with an 

MT-2 Conditional Letter of Map Revision application to FEMA for review of the projects effects 

to the regulated floodplain and floodway areas. 

As discussed with the Diking District and stated in Section 4.3.2.2.2 of the EA, there are no 

confirmed federal levees affected by the project that would require authorization and permits 

under the Rivers and Harbors Act Section 408. However, given assertions by the Corps and the 

Diking District that portions of the railroad embankment were designed as and function as a 

federal levee, BNSF Railway is coordinating with the Diking District and Corps on the potential 

project effects to the levees. 

 
Commenter ID #23
Response to Comments from Scot Walstra, September 24, 2014 Commenter ID #23 

Response to Comment 23-1 

Coordination with the FAA regarding potential conflicts with the Runway Protection Zone, 

Object Free Area, and airport clear zones is ongoing and would continue through final design of 

the proposed projects. As discussed in Section 4.10.3.2.2 of the EA, the Task 6 project would be 

located partly adjacent to and within approximately 200 feet of the runway at the Southwest 

Washington Regional Airport. Under 49 CFR 77, the FAA is to be notified via Form 7460-1 of 

proposed construction activities that would take place within 20,000 feet of an airport with a 

runway of greater than 3,200 feet in length and which exceed a 100 to 1 imaginary surface height 

from the runway. The 100 to 1 ratio establishes a threshold of one foot of height for every 100 

feet of horizontal distance. For the Task 6 project, this means that since the project would be 

approximately 200 feet from the runway, the project requires FAA notification as construction 

equipment would exceed 2 feet in height at that distance. Therefore, Form 7460-1 is being 

prepared for submittal to the FAA to document the proposed activities. The FAA would review 

the submittal and make a determination regarding any potential hazards associated with the 

project. Although the project is close to the runway, the proposed project and construction would 

have a low profile similar to existing activities in the rail corridor and is not anticipated to effect 

airport operations. 

Additional plan sheets, aside from those provided as part of the EA, are not available at this time. 

 
 

Commenter ID #24
Response to Comments from Dean Schrader, September 19, 2014 Commenter ID #24 

Response to Comment 24-1 

The Section 6(f) map in the EA represents the approximate boundary of the Section 6(f) resource 

to illustrate that the project impacts are occurring south of the Section 6(f) resource. It is not nor 

is it intended as an exact legal representation of the boundary. As noted by the commenter, the 

underlying factual findings in the EA, that the Section 6(f) property at the Louis Rasmussen Day 

Use Park is not affected by the restoration project proposed at unnamed tributary 3, remains 

correct.