U.S. Department of Transportation

Federal Railroad Administration

Point Defiance Bypass Project

FINDING OF NO SIGNIFICANT IMPACT

February 2013 

 
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Table of Contents 

1.0 INTRODUCTION................................................................................................................................................1

2.0 PURPOSE AND NEED ........................................................................................................................................1

3.0 DESCRIPTION OF ALTERNATIVES .......................................................................................................................1

3.1 No Build Alternative................................................................................................................................2

3.2 Build Alternative......................................................................................................................................2

4.0 SUMMARY OF EFFECTS.....................................................................................................................................5

4.1 Air Quality .................................................................................................................................................5

4.2 Noise ..........................................................................................................................................................5

4.3 Vibration....................................................................................................................................................5

4.4 Transportation .........................................................................................................................................6

4.5 Geology and Soils.....................................................................................................................................6

4.6 Water Resources......................................................................................................................................7

4.7 Wetlands...................................................................................................................................................7

4.8 Fish, Vegetation, and Wildlife ...............................................................................................................7

4.9 Hazardous Materials...............................................................................................................................7

4.10 Visual Quality.......................................................................................................................................7

4.11 Cultural and Historic Resources........................................................................................................8

4.12 Section 4(f) Resources........................................................................................................................8

4.13 Socioeconomics...................................................................................................................................8

4.14 Environmental Justice ........................................................................................................................9

4.15 Land Use................................................................................................................................................9

4.16 Public Services, Utilities, and Safety................................................................................................9

4.17 Energy....................................................................................................................................................9

5.0 INDIRECT EFFECTS ......................................................................................................................................... 10

6.0 CUMULATIVE EFFECTS ................................................................................................................................... 10

7.0 PUBLIC INVOLVEMENT .................................................................................................................................. 11

8.0 ENVIRONMENTAL COMMITMENTS................................................................................................................. 11

9.0 CONCLUSION ................................................................................................................................................ 15
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LIST OF TABLES

Table 1.Cumulative Effects of the Project	.......................................................................................................................	10

Table 2. Environmental Commitments	.............................................................................................................................	11

LIST OF FIGURES

Figure 1. Build Alternative Components	............................................................................................................................	4

LIST OF APPENDICES

Appendix A: Agency Correspondence  

Appendix B: Agency and Public Comments and Responses
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1.0 INTRODUCTION

The Washington State Department of Transportation (WSDOT) is implementing a program of 

infrastructure improvement projects along the Pacific Northwest Rail Corridor (PNWRC) also known as 

the PNWRC Improvement Program. The PNWRC Improvement Program is made up of approximately 17 

component projects. To fund these projects, WSDOT applied and was selected for grant funding through 

the Federal Railroad Administration’s (FRA) High Speed Intercity Passenger Rail (HSIPR) Program. 

One such component project is the Point Defiance Bypass Project (the Project or Build Alternative), 

WSDOT has proposed to respond to deficiencies in the existing rail operations around Point Defiance 

between Tacoma and Nisqually in Washington State. As part of the PNWRC Improvement Program, 

when combined with the other component projects, this Project would allow for two additional round 

trips of the Amtrak Cascades service between Seattle, Washington, and Portland, Oregon with improved 

reliability and reduced travel time. This Project would also support Amtrak’s longer-distance Pacific 

Northwest passenger rail service, the Coast Starlight. 

FRA and WSDOT prepared an Environmental Assessment (EA) to analyze and document whether the 

Project would have significant effects on the environment. This Finding of No Significant Impact 

(FONSI) is made based on the information in the EA and has been prepared by FRA and WSDOT to 

comply with the National Environmental Policy Act of 1969 (42 U.S.C § 4321) (NEPA), FRA’s 

Procedures for Considering Environmental Impacts (64 Fed. Reg. 28545, May 6, 1999), and other related 

laws. WSDOT will use FRA’s decision documentation and other supporting documentation to satisfy the 

Washington State Environmental Policy Act (SEPA) (WAC 197-11). The final version of the EA is 

available to the public on FRA’s website at http://www.fra.dot.gov/Page/P0212 and WSDOT’s Project 

website at: 

http://www.wsdot.wa.gov/Projects/Rail/PNWRC_PtDefiance/environmental_assessment.htm 

2.0 PURPOSE AND NEED

As described above, the Project is part of the larger PNWRC. Within Washington State, the vision for the 

PNWRC is to “...improve intercity passenger rail service by reducing travel times and achieving greater 

schedule reliability in order to accommodate growing intercity travel demand...” 

The purpose of the Project is to provide more frequent and reliable intercity passenger rail service along 

the PNWRC between Tacoma and Nisqually. 

The Project is needed to address the deficiencies in the existing rail alignment around Point Defiance. The 

existing alignment (Puget Sound route), shared by freight and passenger rail traffic, is near capacity and 

therefore unable to accommodate additional intercity passenger rail service without substantial 

improvements. In addition, the Puget Sound route has physical and operational constraints that adversely 

affect both passenger train scheduling and reliability. 

3.0 DESCRIPTION OF ALTERNATIVES		

As part of an alternatives analysis process, FRA and WSDOT evaluated three build alternatives: the 

Point Defiance Bypass route, the Shoreline Alternative, and the Greenfield Alternative to identify the 

range of reasonable alternatives to carry forward for detailed analysis. A brief description of each build 

alternative follows: 

 The Point Defiance Bypass route includes railroad track and support facility improvements, and the 

relocation of Amtrak’s Tacoma Station. 

 The Shoreline Alternative would make improvements along the 26-mile-long Puget Sound route 

between Nisqually and Tacoma. This alternative consists of adding 8 miles of new track and realigning 15 miles of existing track. 
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 The Greenfield Alternative includes six routes (Lakewood South Route, Spanaway Route, Lakewood 

to Tacoma Tunnel Route, Fredrickson Route, Rainer Route, and I-5 Median Route). Although each 

route has minor differences each would construct a new alignment and reconstruct an existing route. 

Two of the alternatives (Shoreline Alternative and Greenfield Alternative) were eliminated from further 

study as each was determined to be impracticable and unfeasible due to technical constraints, high 

construction costs, and significant environmental effects. 

Modifications to the proposed Project were suggested during the two-year public involvement process, 

including adding a Cascades station within the Lakewood or DuPont city limits, and constructing one or 

several grade-separated crossings. Consistent with the trip time element of the Project’s purposes and 

need and in order to meet performance standards set by WSDOT, no additional stops are proposed. The 

evaluation of grade separations, as described in the EA, revealed that current and projected future traffic 

volumes do not warrant the construction of new grade-separated crossings. 

Two alternatives are considered in the EA, the No Build Alternative and the Build Alternative. 

3.1 No Build Alternative

Under the No Build Alternative, Amtrak’s Cascades and Coast Starlight passenger train service would 

continue to use the existing Puget Sound route. The No Build Alternative includes only the minor 

maintenance and repair activities necessary to keep the existing Puget Sound route operational but with 

no extensive infrastructure improvements. 

Along the Point Defiance Bypass route, the Tacoma Rail and Burlington Northern Santa Fe (BNSF) 

freight services would continue. The at-grade crossings at Clover Creek Drive Southwest, North Thorne 

Lane Southwest, Berkeley Street Southwest, 41st Division Drive, and Barksdale Avenue Southwest 

would not be upgraded. 

Sound Transit’s Sounder commuter passenger trains became operational in October 2012 between the 

Tacoma Dome Station at Freighthouse Square in Tacoma and Sound Transit’s Lakewood Station (on the 

Point Defiance Bypass route) with up to 18 Sounder trains per day. 

3.2 Build Alternative

The Project consists of railroad track and support facility improvements to facilitate the rerouting of 

Amtrak’s intercity passenger rail to the Point Defiance Bypass route, and the relocation of Amtrak’s 

Tacoma Station. The following details specific components of the Build Alternative (Figure 1). 

Construct New Track Adjacent to the Existing Main Line – A new 3.5-mile track adjacent to 

the existing main line would be constructed from South 66th Street (Rail milepost [MP] 6.9) in 

Tacoma to between Bridgeport Way Southwest (Rail MP 10.4) and Clover Creek Drive 

Southwest (Rail MP 10.9) in Lakewood. 

Reconstruct and Rehabilitate the Existing Main Line – Starting just southwest of Bridgeport 

Way Southwest (Rail MP 10.4) in Lakewood, the existing track would be reconstructed to a 

location southeast of the I-5/Mounts Road Southwest interchange (Rail MP 19.8) at Nisqually 

Junction. 

Improvements at the At-grade Crossings – Five highway-rail grade crossings would be 

improved with wayside horns, gates, traffic signals and signage, sidewalks, median separators, 

and warning devices. These crossings include Clover Creek Drive Southwest, North Thorne 

Lane Southwest, Berkeley Street Southwest, 41st Division Drive and Barksdale Avenue. 

Tacoma Amtrak Station Relocation – The existing Tacoma Amtrak Station would be relocated 

from its Puyallup Avenue location to the Tacoma Dome Station at Freighthouse Square, at 430 E. 

25th Street in Tacoma. This work includes platform modifications to accommodate longer Coast 

Starlight trains. The proposed Freighthouse Square station would provide the same or more 
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parking spaces than are currently available at the Tacoma Amtrak Station. Parking would be 

located on a parcel near Freighthouse Square that either has parking available for lease or which 

can be purchased and developed into a parking lot for exclusive use by Amtrak passengers. In 

addition to this proposed parking, there would be some available on-street parking near the 

station. 

Operational Changes – Amtrak’s existing Cascades and Coast Starlight passenger train service 

would be rerouted from the Puget Sound route along the Puget Sound shoreline to the Point 

Defiance Bypass route. The Project would also provide for additional Amtrak Cascades service 

by increasing the number of roundtrips provided per day from 4 to 6, or a total of 12 Cascades 

service train trips. Two (roundtrip) Amtrak Coast Starlight train trips per day would travel on the 

Point Defiance Bypass route. Train speed would increase from the current 30 miles per hour 

(mph) for Sounder trains to a maximum operating speed of 79 mph for all passenger trains. 
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Figure 1. Build Alternative Components 
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4.0 SUMMARY OF EFFECTS

Environmental effects of the Build Alternative are summarized in this section. 

4.1 Air Quality		

The Project would not result in significant air quality impacts. Construction would result in a temporary 

increase in Mobile Source Air Toxics (MSAT) emissions in the study area, and temporary odors may be 

detected by people near asphalt paving operations. Measures will be implemented to control particulate 

matter emissions during construction. 

Implementation of the Project would be in conformity with Clean Air Act requirements and would not 

cause exceedance of the National Ambient Air Quality Standards. The Project is not predicted to increase 

regional highway vehicle miles traveled and thus not affect regional air pollutant levels. Increased 

locomotive emissions resulting from increased Amtrak Cascades service frequency would be offset to a 

degree by the reduction in track miles traveled with the Build Alternative. 

4.2 Noise		

During construction, there would be localized increases in noise levels (ranging from a maximum of 71 to 

98 decibels [dBA] at 50 feet). The increases in noise would be typical of those emitted from construction 

equipment, which range from 71 to 98 dBA at 50 feet. However, because various pieces of equipment 

would be turned off, idling, or operating at less than full power at any given time, average daytime noise 

levels would be less than the maximum noise levels indicated above. Therefore, construction noise 

effects on sensitive receptors are not anticipated to be significant. 

Operation of the Project would not result in significant noise effects on noise sensitive receptors. Noise 

exposure would be generated by several sources, including passing trains, trains going over special track 

work (such as joints or frogs), and warning equipment (either wayside horns or on-train horns). Moderate 

noise impacts are predicted at two groups of sensitive receptors for the Project: Site 6M and Site 16N. 

Increased noise levels at noise-sensitive receptors would be caused by new warning devices (wayside 

horns) at signalized at-grade crossings. The use of wayside horns by both Amtrak and freight trains will 

replace train mounted horns with quieter wayside mounted horns that would reduce this particular source 

of noise. Wayside train horn volumes would be lower than the maximum noise level allowed by FRA for 

train-mounted horns, which is 92 dBA at 100 feet. Noise effects from wayside horns would be localized 

and only occur during passenger rail operations anticipated to be scheduled between the hours of 7:00am 

and 10:00pm. 

4.3 Vibration		

During construction, typical vibration-producing equipment would produce vibration levels in the range 

of 66 to 112 vibration decibels (VdB) at a distance of 25 feet. Construction-related vibration effects are 

predicted at up to 16 residences. At these residences, vibration occurrences at the higher end of the range 

would be above the Federal Transit Administration’s (FTA) vibration impact criteria of 80 VdB. 

However, because of the linear nature of rail construction, activities and any resulting vibration effects 

would be temporary and occur infrequently. As a result, vibration effects during construction would not 

be significant. 

During operations, vibration effects above the FTA vibration impact criteria of 80 VdB for infrequent 

events are predicted to occur at some locations. Additional impacts resulting from a 3 VdB or higher 

increase over the existing vibration levels in the corridor shared with Sound Transit Sounder service 

(Lakewood Station to TR Junction) are predicted at other locations, but these would be below the FTA 

impact criteria of 80 VdB for infrequent events. However, because the Project would be designed and 

built consistent with the commitments described Section 8.0, the vibration impacts would be below the 

FTA vibration impact thresholds. 
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4.4 Transportation

During construction, some Tacoma Rail freight service would be rerouted to available Tacoma Rail tracks 

when portions of the Point Defiance Bypass route (south of Lakewood) are out of service. WSDOT would 

coordinate with Tacoma Rail to maintain continued freight access during construction. Sounder train 

service would not be affected by construction because the trains operate on adjacent tracks. 

Construction vehicles would increase traffic delay during construction. Temporary lane closures and 

occasional weekend road closures would be required to rebuild the track and install safety improvements 

at the at-grade crossings. Traffic control plans for these closures would include signage and prior notice to 

alert local and I-5 drivers of the work. Construction activities would similarly disrupt and delay transit, 

pedestrians and bicyclists, and parking temporarily. 

Relocating passenger rail service to the Point Defiance Bypass route would have a beneficial 

transportation effect by improving travel time of the Amtrak Cascades service by 10 minutes due to the 

shorter distance (approximately 6 miles) and because the trains will operate at higher speeds (up to 79 

mph) on less congested tracks. Further benefits include improved reliability of the Cascades service by 

avoiding potential delays from freight trains on the Puget Sound route. Freight trains on the Puget Sound 

route would not be affected by relocating passenger trains to the Point Defiance Bypass route but could 

experience a slight benefit by removing passenger rail operations from the Puget Sound route. 

No new at-grade highway or rail crossings are planned and no existing at-grade road crossings would be 

closed with the Build Alternative. The addition of Amtrak passenger service to the Point Defiance Bypass 

route would increase the number of short-term roadway blockages from train crossings throughout the 

day. The additional blockages would cause an increase in the overall time roadways are blocked for the 

Build Alternative by approximately 1 minute during the morning and afternoon peak hour. Roadway 

blockage by additional train crossings would also increase queue length by 2 to 4 vehicles. At some 

locations, the queue length would be reduced because of signal improvements. 

The Build Alternative would reduce the number of intersections exceeding the Level of Service (LOS) D 

standards set by local jurisdictions and WSDOT from nine to eight. With the Build Alternative, several 

intersections experience minor impacts resulting in decreased LOS but would range between LOS A 

through D. The remaining intersections would experience some change in delay (seconds per vehicle) but 

no LOS changes. 

While stopped at Freighthouse Square, the Coast Starlight train would extend beyond the existing station 

platform and across East C Street and East D Street. During an event at the Tacoma Dome, the dwell time 

of the Coast Starlight train at Freighthouse Square would result in a decline of LOS to below LOS D. The 

temporary blockage of these two streets would result in a decline of LOS to below LOS D during an event 

at the Tacoma Dome. Minimization of operational effects on traffic as a result of the Coast Starlight dwell 

time at Freighthouse Square, and during a Tacoma Dome event, would include implementation of a 

detour plan that could include static signs identifying the detour routes, dynamic message signs that 

identify the detour routes during a train blockage, lane striping and controller modification. 

The Tacoma Amtrak Station relocation to Freighthouse Square would improve pedestrian connections 

between Amtrak passenger rail and transit services provided at the Tacoma Dome Station (Sounder, 

Tacoma Link light rail, and bus transit). The Build Alternative would also improve sidewalks thus 

improving pedestrian access and safety. Pedestrians and bicyclists would experience similar intersection 

delays as vehicles with the Build Alternative. Freight trains on the Puget Sound route could experience a 

slight benefit with the shift of passenger rail service from the Puget Sound route. 

4.5 Geology and Soils		

The Build Alternative would not have a significant effect on geology or soils. Use of construction best 

management practices (BMPs) would minimize soil disturbance and erosion during construction. 

Operation of the Build Alternative would not affect existing geologic hazard areas. 
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4.6 Water Resources		

The Build Alternative would not have a significant effect on water resources. During construction, use of 

BMPs would minimize or avoid erosion, sedimentation, and pollutant spill effects to surface water and 

groundwater resources. The Build Alternative would not affect surface waters through changes in volume 

or water quality, because the new impervious surface area is below the thresholds outlined in the WSDOT 

Highway Runoff Manual (HRM). No changes would be made within the boundaries of regulated 

shorelines or floodplains. The operation of the Build Alternative would not affect surface waters, critical 

aquifer recharge, or well protection areas. 

4.7 Wetlands		

While construction activities associated with the Build Alternative could result in temporary effects to 

adjacent wetlands, the effects on the wetlands would not be significant. Construction could result in a 

short-term loss of wetland functions associated with habitat and water quality and ground disturbance 

could result in minor erosion of disturbed soils into wetlands and buffer areas, impairing vegetation and 

habitat. Clearing and grading activities in the vicinity of wetlands would have the potential to affect 

surface water quality during seasonal events when surface water is present. However, through 

implementation of required BMPs, effects during construction would be minimized or avoided. The 

operation of the Build Alternative would not affect wetlands. 

4.8 Fish, Vegetation, and Wildlife

The Build Alternative would not have a significant effect on fish, vegetation, or wildlife. No in-water 

work is proposed and no effects to water quality are anticipated during construction or operation, thus no 

effects to fish would occur. Approximately 24 acres of maintained vegetation, 2.5 acres of disturbed 

mixed forest, and 1 acre of scattered trees would be removed as a result of the Build Alternative. These 

vegetation types do not support habitat for species protected under the Endangered Species Act (ESA), 

thus no effects to ESA-protected species would occur during construction or operation of the Project (see 

Appendix A for the no effect concurrence letter from the National Marine Fisheries Service). Removal of 

vegetation from the Project corridor during construction and maintenance during operations would have 

no effect on wildlife, as the quality of habitat in the Project area is poor and what little wildlife that might 

be present could relocate to other similarly vegetated areas in the vicinity. Visual disturbance and elevated 

noise are expected to be marginally higher than baseline levels during construction, thus the effects on 

wildlife during construction would be minimal. 

4.9 Hazardous Materials		

During construction there is the potential to encounter previously contaminated soil or groundwater, 

which could result in public health or environmental effects. Minimization measures would avoid, 

control, and manage effects associated with earthwork in areas where potential contamination concerns 

have been identified, including near the ASARCO smelter plant in Tacoma, the Lakewood Superfund Site 

near I-5 in Lakewood, and the Freighthouse Square area in downtown Tacoma. The Project is intended to 

improve passenger train operations and there would be no foreseeable increase in the freight rail transport 

of hazardous material as a result of the Build Alternative. 

4.10 Visual Quality

Construction of the Build Alternative would have a minor effect on visual quality as construction would 

be relatively short in duration and not affect any single location along the tracks for a long period of time. 

Operational changes would increase the time trains are present and visible along the Point Defiance 

Bypass route. Visual impacts resulting from changes to the Freighthouse Square building and platform to 

accommodate use by Amtrak would be minor. The changes to the Freighthouse Square building and 

parking would be compatible with surrounding land uses and existing visual conditions. 
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4.11 Cultural and Historic Resources		

The Build Alternative would have no adverse effect on cultural or historic resources present in the area of 

potential effect (APE), including Native American traditional cultural or ceremonial places or resources. 

Several historic properties have been identified in the APE, but the Build Alternative would not affect any 

attributes that make the properties eligible to the National Register of Historic Places. Federallyrecognized tribes and the Washington State Historic Preservation Officer (SHPO) were consulted, as 

required by Section 106 of the National Historic Preservation Act. The SHPO concurred with the 

determination of no adverse effect on cultural and historic resources (see Appendix A). 

4.12 Section 4(f) Resources

Section 4(f) of the Department of Transportation Act of 1966 protects certain park and recreational lands, 

refuges, and historic sites from being “used” in transportation projects carried out or funded by modal 

administrations of the U.S. Department of Transportation, including FRA. Section 4(f) resources include 

any publicly-owned public park, recreation area, wildlife or waterfowl refuge, or any publicly- or 

privately-owned historic site. No properties eligible for protection under Section 4(f) are present within 

the study area and therefore no Section 4(f) uses would result from the Project. 

4.13 Socioeconomics		

The Build Alternative would have minor temporary effects on neighborhoods and businesses adjacent to 

the railroad corridor during construction, including localized increases in noise and air emissions from 

construction activities. In general, during construction localized traffic circulation and accessibility to 

neighborhoods and businesses would be disrupted by construction of improvements at the at-grade 

crossings. However, the operation of local businesses would not be disrupted, since most construction 

would occur within the railroad right-of-way, away from intersections and business access locations. 

Construction of the Build Alternative would affect access to some public services during construction. 

Construction employment for the Build Alternative would be small and specialized, so there would be a 

minor benefit for employment and gross income. 

Project Operation would have the following effects on the socioeconomic elements presented below: 

Community Characteristics. The Build Alternative would not cause a direct change in the 

demographics, land use patterns, neighborhoods, or other related community characteristics. 

Community Connectivity and Cohesion. The increased number of trains (up to 14 per day in addition to 

up to 18 Sounder trains) would reduce connectivity during train crossings of local roads. However 

upgrades (intersection and signal improvements) to 5 at-grade crossings would improve connectivity and 

safety for pedestrians, bicyclists, and vehicles as well as improve traffic flow for some intersections. The 

Tillicum, Woodbrook, and Nyanza neighborhoods would continue to experience some isolation because 

of existing geophysical separations and limitations to authorized non-vehicular access across or along the 

railroad tracks. Operation of the Project may increase residents’ feelings of isolation in a few 

neighborhoods during train pass-bys, which would be very short in duration. However, overall the Project 

would result in more intersections with delay decreases than delay increases. Therefore, with the Project, 

and the proposed traffic improvements, community connectivity would experience a minor benefit. 

Although there would be an increase in noise levels, the noise analysis demonstrates that the noise level 

effects on sensitive noise receptors would be moderate. There would be a corollary benefit from the use of 

wayside horns by both Amtrak and freight trains from Lakewood to Tacoma. Replacing train-mounted 

horns with quieter wayside-mounted horns would reduce this particular source of noise in the 

communities. There would be no effect in community cohesion due to noise. 

Economics. The Project is not anticipated to affect property values. The rail corridor is an existing feature 

with portions currently used for freight and commuter service. Measures to minimize or eliminate noise 

and vibration would be implemented by the Project. Operation of the Project would result in a minor 

benefit to the limited freight operations due to safety improvements at crossings, and the replaced rail 
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infrastructure at the southern end. Tacoma Rail may gain improved access to Tacoma suppliers. Freight 

movements are independent of the Sound Transit and Amtrak operations along the Point Defiance Bypass 

route. There would be no change to the operation of freight trains on the Point Defiance Bypass route 

under the Build Alternative. Tacoma Rail and BNSF would continue to operate as many as two trains per 

day or as few as two trains per week. BNSF would continue to operate intermittent freight trains on the 

Point Defiance Bypass route to serve military transportation needs at Joint Base Lewis McCord (JBLM). 

4.14 Environmental Justice

FRA and WSDOT evaluated the construction and operational environmental effects of the Project to 

determine whether Environmental Justice (EJ) communities would experience disproportionately high or 

adverse impacts. Minority/ethnic and low-income populations were identified at locations where noise 

and vibration effects are predicted. While the potential noise and vibration effects would affect lowincome and minority/ethnic populations, the effects would not be appreciably more severe or greater in 

magnitude than the effect on non-minority or non-low-income populations in the vicinity of the Project. 

Therefore, FRA and WSDOT determined no disproportionately high or adverse effect on EJ populations 

would result from the Project and the Project meets the provisions of Executive Order 12898, and Title VI 

of the Civil Rights Act. 

4.15 Land Use

Construction activities associated with the Build Alternative would not displace any existing land uses or 

acquire additional property aside from potential acquisitions adjacent to Freighthouse Square for parking. 

Such acquisitions would occur consistent with State and Federal law. Operationally, the Build Alternative 

is consistent with adopted land use policies. Operational effects on existing and planned land uses would 

result from the Tacoma Amtrak Station relocation by enhancing the accessibility to and between the 

modes of transportation in the downtown Tacoma area. The rail corridor would continue to be compatible 

with surrounding land uses. Relocation of the Cascades and Coast Starlight service to the Tacoma Dome 

Station at Freighthouse Square is consistent with adopted plans specific to the revitalization and 

redevelopment of the Tacoma Dome neighborhood and enhancing the pedestrian connection between rail 

services, with the goal to create economic opportunities at local, statewide, and multi-state levels by the 

increased reliability and frequency of alternative modes of transportation. 

4.16 Public Services, Utilities, and Safety

Temporary traffic delays for emergency vehicles and school and public buses would occur during 

construction. Access for emergency response services would be maintained during construction. During 

Project operation, the addition of Amtrak services would result in minor intersection traffic delays that 

would result in similar effects on all public service sectors. No public services would be displaced by the 

Project and all services would continue to be available to individuals in the study area.

No effects are anticipated for utilities as the Project would relocate, deepen or harden utilities within 

railroad right-of-ways, and access for utility maintenance and upgrades would be provided to utility 

owners. 

With the Build Alternative, 3.2 accidents for every million train crossings are anticipated. This accident 

rate would be a decrease in accidents from current operations along the Puget Sound route (3.6 accidents 

per million train crossings). The Build Alternative would also improve safety at 5 existing at-grade 

crossings by adding signage, wayside horns, median barriers, sidewalks, pre-signals, and more advanced 

signal controllers. 

4.17 Energy

Energy is required for construction of the Build Alternative. The majority of construction emissions are 

from fuel combustion from equipment used on-site. Construction energy requirements are estimated to be 

539,000 million British Thermal Units (Mbtu) and greenhouse gas (GHG) emissions are estimated to be 

41,000 CO2 equivalents (CO2e). 
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Operation of the Build Alternative would produce 3.3 CO2e daily. This would result in a small annual 

reduction in energy consumption (321 CO2e) compared to the current alignment because the Build 

Alternative alignment would be shorter and allow for more energy efficient travel. 

5.0 INDIRECT EFFECTS

FRA and WSDOT considered the potential indirect effects on resource areas and found that the only 

potential indirect effect from the Project is related to the relocation of the Tacoma Amtrak Station from 

Puyallup Avenue to Freighthouse Square. The relocation of Amtrak services to Freighthouse Square may 

indirectly influence minor redevelopment near Freighthouse Square. The redevelopment would be 

consistent with local zoning and approved by state and local agencies, therefore it is unlikely to result in 

indirect effects on the following resources: air quality, noise and vibration, public services and utilities, or 

energy. The redevelopment at Freighthouse Square would not result in indirect effects on fish, wildlife 

and vegetation, geologic and soils, wetlands, or water resources because these resources are not present. 

The following resources may experience a beneficial indirect effect from the redevelopment at 

Freighthouse Square: hazardous materials, visual quality, land use, transportation and socioeconomic and 

EJ. 

6.0 CUMULATIVE EFFECTS			

Since the Build Alternative would have no effect on air quality, geology and soils, water resources, 

wetlands, fish and wildlife, and cultural resources, it would not contribute to a cumulative effect on these 

resources. 

FRA and WSDOT considered the potential for cumulative effects resulting from the Project for resources 

where minor effects may occur. A discussion of the potential cumulative effects for each resource area is 

included in Table 1. The analysis indicated that the Project would not result in significant cumulative 

effects. 

Table 1.Cumulative Effects of the Project

Resource Cumulative Effect 

Noise At sensitive locations north of Lakewood Station, moderate increases in noise would likely result from a 

combination of future Sound Transit operations and Project-related Amtrak operations. FRA and 

WSDOT found that the Project’s contribution to noise in the area would not lead to a significant 

cumulative effect. 

Vibration Vibration effects from the Project were also considered in combination with other reasonably 

foreseeable actions, and WSDOT found that the Project’s vibration minimization measures are 

adequate to prevent an adverse cumulative effect. 

Hazardous Materials In general, development projects improve conditions where hazardous materials are present. Therefore, 

this Project is not likely to contribute to a cumulative environmental effect from hazardous materials 

releases.

Visual Quality In the context of the existing urban environment, the visual elements of the Project would not contribute 

to a cumulative visual effect because it would not change the visual quality of the area.

Vegetation Given the urban and disturbed condition of vegetation, the Project would not contribute to an adverse 

cumulative effect on vegetation.

Land Use The Project would not contribute to a cumulative effect on land use because its direct and indirect 

effects are negligible relative to the overall development in the region.

Energy The long-term energy use associated with the Project would be reduced from current conditions. Thus, 

there would be a beneficial cumulative effect on energy from the Project.

Public Services, 

Utilities, and Safety 

A slight beneficial cumulative effect would result since the improvements made to the intersection 

signals would not occur without the Project.
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Table 1.Cumulative Effects of the Project

Resource Cumulative Effect 

Transportation The reasonably foreseeable future projects would improve traffic conditions in the study area. 

Therefore, the Build Alternative, when considered with the reasonably foreseeable future actions, would 

not result in significant cumulative effects on transportation.

Socioeconomic and 

Environmental 

Justice 

In conjunction with the Project’s intersection and signaling improvements and other reasonably 

foreseeable future projects, there would be a slight beneficial cumulative effect on community 

connectivity near the Berkeley Street Southwest intersection. Connectivity north of Bridgeport Way 

Southwest would be unchanged. The lack of connecting streets and non-motorized access across the 

railroad tracks, combined with increased train activity with the Project, would result in a minor 

contribution to the isolation associated with the cumulative effects of past and present land use and 

transportation patterns in the Tillicum, Woodbrook, and Nyanza neighborhoods. 

Climate Change The results of WSDOT’s recent vulnerability assessment show the section of I-5 along the Project to 

have low vulnerability to climate-related threats. WSDOT is coordinating with Sound Transit on a 

vulnerability assessment of all Sound Transit facilities, and the project corridor appears resilient to 

future climate-related effects.

7.0 PUBLIC INVOLVEMENT		

Opportunities for public involvement on the Project begin with the scoping process and other outreach 

efforts that took place between spring 2010 and summer 2012. Materials provided at these events and 

briefings included electronic PowerPoint presentations, Project maps, photos and videos, fact sheets, and 

illustrated Project timelines. FRA and WSDOTs efforts for the EA included outreach to a wide variety of 

stakeholders along the Project corridor, including meetings with state and local agencies, neighborhood 

associations, farmers markets, city councils, and elected officials. 

The EA was issued by FRA and WSDOT for public review on October 9, 2012 for a period of 

30 calendar days (comment period closed on November 9, 2012). A total of 62 comments on the EA were 

received from individuals or agencies, including comments from 1 federal agency, 2 state agencies, 1 

regional agency, and 5 local agencies. Copies and responses to the comments are included in Appendix B.

8.0 ENVIRONMENTAL COMMITMENTS		

The environmental commitments described below have been identified as the practicable means to avoid 

and minimize effects from the Project. 

Table 2. Environmental Commitments		

Resource Commitments 

Air Quality  Spraying water and operating water trucks on haul roads to reduce dust and particulate matter 

(PM10) emissions. 

 Covering and/or wetting materials on-site and during transport, or providing adequate freeboard 

(space from the top of the material to the top of the vehicle) to reduce PM10 emissions. 

 Providing wheel washers to remove PM that vehicles would otherwise carry off-site. 

 Removing PM (mud and windblown dust) deposited on paved roadways. 

 Properly maintaining construction equipment with required pollution-control devices.
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Table 2. Environmental Commitments		

Resource Commitments 

Noise  Ensure all construction activities comply with local noise regulations, including no nighttime work 

unless a variance is obtained. 

 Use artificial barriers (e.g. baffles, or stockpiles of construction materials) to shield against 

construction noise. 

 Strategically place stationary equipment, such as compressors and generators, to reduce effects 

on noise-sensitive receivers during construction. 

 During construction, equip each internal combustion engine with a manufacturer-recommended 

muffler. 

 Use vibratory or hydraulic insertions for pile driving, or use drilled shafts in place of pile driving at 

locations determined during final design. 

 During operations, use wayside horns at the at-grade crossings to limit the sounding of on-train 

horns and reduce the area exposed to train warning sounds. 

Vibration  Use of track treatments (such as resiliently supported ties, or ballast mats) to reduce the vibration 

transmitted to the ground and reduce vibration effects on below FTA vibration impact criteria. 

Transportation  Development of a traffic control plan with local jurisdictions to minimize traffic delays and periodic 

lane or access revisions during construction of at-grade crossing improvements. 

 Development of framework with Tacoma Rail and BNSF to ensure rail freight deliveries meet 

customer needs during construction. 

 WSDOT will coordinate with local jurisdictions regarding the construction schedule, construction 

areas, and detour routes during Project development to minimize community disruption including 

for events such as the US Open. 

 Implementation of a detour plan that may include static signs identifying detour routes and/or 

dynamic message signs that identify the detour routes during a train blockage at Freighthouse 

Square. 

 FRA and WSDOT would provide additional modeling detail and design at the C and D Street 

intersections as part of the Final Design process. 

Geology and Soils  Preparing and following a Temporary Erosion and Sediment Control (TESC) Plan to implement 

proper erosion control and surface water runoff BMPs. 

 Paving or permanently restoring disturbed areas as soon as possible. 

 Designing temporary excavation slopes to prevent surface sloughing and shallow landsliding. 

 Designing all fill and pavement areas to drain away from construction areas and prevent ponding 

of water and softening of subgrade soils. 

 Limiting cut slopes to 2 horizontal feet to 1 vertical foot (2H:1V) or using retaining walls, and 

including permanent drainage facilities designed for anticipated water flows. 

Water Resources  Prepare and implement a Construction Stormwater Pollution Prevention Plan (CSWPPP) to serve 

as the overall construction stormwater minimization plan. The CSWPPP would include provisions 

for prevention and management of spills in both construction and staging areas, and control 

sediment from ground disturbing activities. 
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Table 2. Environmental Commitments		

Resource Commitments 

Wetlands  Clearing limits would be clearly marked and protected with construction fencing. 

 Various sediment control BMPs would be used to remove sediment prior to any stormwater runoff 

leaving the site. 

 Exposed soils would be stabilized to prevent erosion (i.e., hydroseeding, straw wattles). 

 A temporary erosion control blanket would be placed immediately after seeding, fertilizing, and 

mulching. 

 All on-site pollutants, including waste materials and demolition debris, would be handled and 

disposed in a manner that does not cause contamination of stormwater. 

 On-track vehicle/machinery maintenance and fueling locations would be established away from 

aquatic resources. 

 Any on-site fuel storage would have secondary containment equal to 150 percent of storage 

capacity. 

 All waste oils and machinery fluids would be removed by a maintenance vehicle when they are 

generated. No waste oils or fluids would be stored on-site. 

 Application of chemicals such as fertilizers and pesticides would be conducted in a manner and at 

application rates that would not result in loss of chemicals to stormwater runoff. 

 Highly turbid or contaminated dewatering water would be handled separately from stormwater and 

not allowed to enter local drainage systems. 

Fish, Wildlife, and 

Vegetation 

 Confine construction activities to the minimum area necessary. 

 Develop and implement a TESC Plan and CSWPPP for clearing, vegetation removal, grading, 

ditching, filling, embankment compaction, or excavation. The BMPs in the plans would be used to 

control sediments from ground-disturbing activities. 

 For construction activities that occur within 200 feet of surface water or wetland habitat as 

identified by the Project biologist, use BMPs to ensure that no foreign material, such as railroad 

ballast or other material, is side cast, and to control and prevent sediments from entering aquatic 

systems. 

 Native species would be used for reseeding where possible. 

 Minimize removal of native vegetation to the greatest extent possible.

Hazardous Materials  Performing site-specific hazardous material investigations where and when necessary. 

 Preparing and implementing a project-specific hazardous material management plan. 

 Preparing and implementing a CSWPPP. 

 Preparing and implementing a TESC Plan, including dust control measures as described for Air 

Quality. 

 Preparing and implementing a Spill Prevention, Containment, and Countermeasures Plan 

(SPCCP). 

 Coordinating with Ecology during acquisition and construction for work completed within the 

environmental restrictive covenant at Freighthouse Square. 

Visual Quality  Maintain existing vegetation at the edge of the railroad right-of-way to screen the rail line at 

locations determined during final design and in coordination with the rail line owners (Tacoma Rail, 

BNSF, and Sound Transit). 

 Enhance vegetative buffers and screening where the rail line is adjacent to residential and 

institutional properties at locations determined during final design and in coordination with the rail 

line owners. 

 WSDOT will coordinate with Pierce County and other local jurisdictions regarding the construction 

schedule, construction areas, and detour routes during Project development to minimize 

community disruption including for events such as the US Open attendees. 
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Table 2. Environmental Commitments		

Resource Commitments 

Cultural Resources  Prepare an inadvertent discovery plan and obtain approval from the Washington Department of 

Archaeology and Historic Preservation (DAHP) prior to construction. If during construction, 

unanticipated cultural deposits, artifacts, or human remains are encountered, work in the vicinity 

would be halted and local law enforcement officials and DAHP staff would be contacted 

immediately. 

Public Services, 

Utilities, and Safety 

 WSDOT will coordinate and communicate with public service providers, including school districts, 

emergency service organizations, and agencies such as Sound Transit to ensure they are fully 

informed of construction progress and identify ways to minimize delays. 

 Coordination with utility owners to determine conflicts and a suitable resolution to avoid or 

minimize disruption. This would include coordination with the local fire department if there would be 

effects on fire suppression water and/or pressure. 

 Post construction schedules near affected crossings and provide the information to local 

newspapers for publication or to the local jurisdictions for distribution by mail to residents and 

businesses in the area. Project construction updates could also be posted on WSDOT’s project 

website. 

 Continue the Operation Lifesaver program training on track safety for community members and 

continue to work with communities to ensure there are safe routes that avoid the illegal use of the 

railroad right-of-way for pedestrians and non-vehicular travel. 

Energy Measures to reduce energy use would be employed during construction, which would also reduce GHG 

emissions: 

 Limited equipment idling. 

 Encouraging construction workers to carpool. 

 Locating staging areas near work sites. 

 Scheduling the delivery of materials during off-peak hours to allow trucks to travel to the site with 

less congestion and at fuel-efficient speeds. 

Operationally, additional fuel efficiency would be realized with the use of the new models of locomotives 

that are 10 to 12 percent more energy efficient than currently used locomotives.

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Appendix A

Agency Correspondence

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Appendix B

Agency and Public Comments and Responses

 
 
Index of Public Comments and Responses 

COMMENTS FROM JOHN NILES, OCTOBER 8, 2012 – COMMENTER ID #001 .................................................................1

COMMENTS FROM RAYMOND VAN DER ROEST, OCTOBER 8, 2012 – COMMENTER ID #002..........................................2

COMMENTS FROM CAROL BAUER, OCTOBER 9, 2012 – COMMENTER ID #003 .............................................................3

COMMENTS FROM KATHY HUNTER, OCTOBER 10, 2012 – COMMENTER ID #004.........................................................4

COMMENTS FROM JOHN JURGENS, OCTOBER 16, 2012 – COMMENTER ID #005..........................................................5

COMMENTS FROM JORI ADKINS, OCTOBER 16, 2012 – COMMENTER ID #006..............................................................8

COMMENTS FROM NATHANAEL NERODE, OCTOBER 18, 2012 – COMMENTER ID #007 ................................................9

COMMENTS FROM ANDREW MORDHORST, OCTOBER 19, 2012 – COMMENTER ID #008 .......................................... 10

COMMENTS FROM RICK SEMPLE, OCTOBER 19, 2012 – COMMENTER ID #009.......................................................... 11

COMMENTS FROM JASON STYLES, OCTOBER 16, 2012 – COMMENTER ID #010......................................................... 12

COMMENTS FROM ANDREW LUND, OCTOBER 22, 2012 – COMMENTER ID #011 ...................................................... 13

COMMENTS FROM CHRISTINE SHOUP, OCTOBER 24, 2012 – COMMENTER ID #012 .................................................. 15

COMMENTS FROM JEFF RYAN, OCTOBER 24, 2012 – COMMENTER ID #013 .............................................................. 17

COMMENTS FROM BOBBY KUTLER, OCTOBER 24, 2012 – COMMENTER ID #014....................................................... 19

COMMENTS FROM LILA EARLY, OCTOBER 24, 2012 – COMMENTER ID #015 ............................................................. 21

COMMENTS FROM ANONYMOUS, OCTOBER 24, 2012 – COMMENTER ID #016......................................................... 23

COMMENTS FROM WARREN YEE, OCTOBER 25, 2012 – COMMENTER ID #017 ......................................................... 25

COMMENTS FROM JOHN NILES, OCTOBER 25, 2012 – COMMENTER ID #018 ............................................................ 27

COMMENTS FROM RICK SEMPLE, OCTOBER 29, 2012 – COMMENTER ID #019.......................................................... 28

COMMENTS FROM DAHP, OCTOBER 29, 2012 – COMMENTER ID #020.................................................................... 30

COMMENTS FROM MICHAEL RABSTOFF, NOVEMBER 11, 2012 – COMMENTER ID #021............................................ 31

COMMENTS FROM JOHN HELDING, NOVEMBER 2, 2012 – COMMENTER ID #022...................................................... 32

COMMENTS FROM MARLENE KAM, NOVEMBER 5, 2012 – COMMENTER ID #023 ..................................................... 33

COMMENTS FROM DARRELL REECK, NOVEMBER 6, 2012 – COMMENTER ID #024..................................................... 34

COMMENTS FROM TINA LEE, NOVEMBER 6, 2012 – COMMENTER ID #025 ............................................................... 36

COMMENTS FROM JORI ADKINS, NOVEMBER 7, 2012 – COMMENTER ID #026.......................................................... 39

COMMENTS FROM KEITH STONE, NOVEMBER 2, 2012 – COMMENTER ID #027......................................................... 41

COMMENTS FROM ELIZABETH BURRIS, NOVEMBER 7, 2012 – COMMENTER ID #028................................................. 43

COMMENTS FROM TRACI KELLY, NOVEMBER 7, 2012 – COMMENTER ID #029 .......................................................... 45

COMMENTS FROM ELDON JACOBSON, NOVEMBER 7, 2012 – COMMENTER ID #030 ................................................. 47

COMMENTS FROM DEIDRE WILSON, NOVEMBER 7, 2012 – COMMENTER ID #031.................................................... 50

COMMENTS FROM SU DOWIE, NOVEMBER 8, 2012 – COMMENTER ID #032............................................................. 54
COMMENTS FROM DAVID BUGHER, NOVEMBER 8, 2012 – COMMENTER ID #033 ..................................................... 56

COMMENTS FROM JOHN NILES, NOVEMBER 8, 2012 – COMMENTER ID #034 ........................................................... 66

COMMENTS FROM CHRISTINE REICHGOTT, NOVEMBER 8, 2012 – COMMENTER ID #035........................................... 71

COMMENTS FROM ODETTE D’ANIELLO, NOVEMBER 9, 2012 – COMMENTER ID #036 ............................................... 74

COMMENTS FROM KEN MAUERMANN, NOVEMBER 8, 2012 – COMMENTER ID #037................................................ 76

COMMENTS FROM T.C. BROADNAX, NOVEMBER 8, 2012 – COMMENTER ID #038.................................................... 77

COMMENTS FROM JANICE MCNEAL, NOVEMBER 9, 2012 – COMMENTER ID #039.................................................... 82

COMMENTS FROM BRIAN ZIEGLER, NOVEMBER 9, 2012 – COMMENTER ID #040 ...................................................... 85

COMMENTS FROM ERIC BECKMAN, NOVEMBER 9, 2012 – COMMENTER ID #041...................................................... 88

COMMENTS FROM DON WICKSTROM, NOVEMBER 9, 2012 – COMMENTER ID #042 ................................................. 92

COMMENTS FROM GORDON AND ANITA RUSS, LLOYD FLEM, ROCHE SCHERERMAN, OCTOBER 24, 2012 – COMMENTER

ID #043, 044, 045 .................................................................................................................................................... 96

COMMENTS FROM KENNETH BOUNCHER, KEN MAUERMANN, BARBARA BILLINGSLEY, MATT ROYER, BOB BREGENT,

DAVID BUGHER, PENNY COFFEY, JOAN COOLEY, LEE CHASE, SHARON TAYLOR, BILL PALMANTEER, OCTOBER 25, 2012 –

COMMENTER ID #046, 045, 046, 047, 048, 049, 050, 051, 052, 053, 054, 055, 056 .......................................105

COMMENTS FROM MATTHEW RUDOLF, NOVEMBER 9, 2012 – COMMENTER ID #057.............................................136

COMMENTS FROM PETER ZAHN, NOVEMBER 9, 2012 – COMMENTER ID #058........................................................139

COMMENTS FROM MIKE GREEN, NOVEMBER 2, 2012 – COMMENTER ID #059.......................................................144

COMMENTS FROM JOHN MOUNTS, NOVEMBER 9, 2012 – COMMENTER ID #060 ...................................................145

COMMENTS FROM BRANDON ARENAS, NOVEMBER 21, 2012 – COMMENTER ID #061 ...........................................147

COMMENTS FROM THOMAS CORNILLIE, NOVEMBER 26, 2012 – COMMENTER ID #062...........................................150

 
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COMMENTS FROM JOHN NILES, OCTOBER 8, 2012 – COMMENTER ID #001

Response to Comments from John Niles, October 8, 2012 Commenter ID #001

Response to Comment 001-1 

The Traffic and Transportation Discipline Report (Appendix F of the EA) presents details on how the 

accident prediction rates at at-grade crossings were determined. The Build Alternative, with proposed 

signal and crossing improvements, is anticipated to reduce the overall crossing accident rate from 3.6 

accidents for every million train crossings under the No Build Alternative to 3.2 accidents per million 

train crossings under the Build Alternative. 

The accident prediction methodology uses FRA’s accident prediction model to forecast an estimated 

change in accidents in the future. The future accident predictions are based on three primary inputs to the 

model: future vehicle volumes, future train volumes, and the type of at-grade crossing protection. The 

model includes different accident rate factors based on historical national at-grade crossing accidents 

developed by FRA for three categories of warning devices: passive, flashing lights, and gates. 
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COMMENTS FROM RAYMOND VAN DER ROEST, OCTOBER 8, 2012 – COMMENTER ID #002

Response to Comments from Raymond van der Roest, October 8, 2012 Commenter ID #002

Response to Comment 002-1 

As discussed in Section 4.9.3.2 of the EA, the Point Defiance Bypass route would have a different 

character and the view of Puget Sound in the area mentioned in the comments would no longer be 

available. However, the objective of the proposed project is to provide faster, more frequent, and more 

reliable passenger rail service in the corridor and therefore many issues including, but not exclusively, 

aesthetic issues were considered. 
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COMMENTS FROM CAROL BAUER, OCTOBER 9, 2012 – COMMENTER ID #003

Response to Comments from Carol Bauer, October 9, 2012 Commenter ID #003

Response to Comment 003-1 

As described in Section 4.3.3.2 of the EA and the Traffic and Transportation Discipline Report (Appendix 

F of the EA), the proposed Freighthouse Square station would provide the same or more parking spaces 

than are currently available at the Tacoma Amtrak Station. Parking would be located on a parcel near 

Freighthouse Square (see Section 3.2.4 of the EA) that either has parking available for lease or purchase 

by WSDOT and developed into a parking lot for exclusive use by Amtrak passengers. In addition to this 

proposed parking, there would be some available on-street parking near the station (see Section 4.3.3.2 of 

the EA). 

The Tacoma Dome Area Plan was reviewed as part of the Project. As discussed in Section 4.13.3.2 of the 

EA, the Project is consistent with adopted plans and would implement policies adopted by the City of 

Tacoma. No policy was found that would cause the Project to be inconsistent with these adopted plans 

and regulations (see Section 4.13.1 of the EA). Based on this review, the Project is consistent with the 

comprehensive plan and zoning regulations adopted by the City of Tacoma and is not inconsistent with 

the Tacoma Dome Area Plan. 

WSDOT will continue to work with the City of Tacoma and Sound Transit during final design of the 

Project. 

 
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COMMENTS FROM KATHY HUNTER, OCTOBER 10, 2012 – COMMENTER ID #004

Response to Comments from Kathy Hunter, October 10, 2012 Commenter ID #004

Response to Comment 004-1 

WSDOT provided responses to individuals regarding the process for submitting written comments on the 

EA as well as noting times and locations for public meetings. If requested, hard and/or electronic copies 

of the EA were provided. 
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COMMENTS FROM JOHN JURGENS, OCTOBER 16, 2012 – COMMENTER ID #005
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Response to Comments from John Jurgens, October 16, 2012 Commenter ID #005

Response to Comment 005-1 

Construction for this proposed project is scheduled to commence in 2015. The proposed Project includes 

the relocation of the Tacoma station to Freighthouse Square (see Section 3.2.4 in the EA). Once complete, 

Amtrak would not use the tracks running to Puyallup Avenue since the passenger rail operations would 

use the Point Defiance Bypass route and Freighthouse Square station. 

Response to Comment 005-2 

Sounder is currently operating on a portion of the Point Defiance Bypass route, as is Tacoma Rail and 

BNSF. The D to M Street segment recently completed by Sound Transit is owned and used by Sound 

Transit. In addition, the 2.85% grade through D to M is prohibitively steep for freight trains. Thus 

Tacoma Rail would continue serving the Nalley Valley via its existing routes. 

Response to Comment 005-3 

Build Alternative roadway operations as indicated by level of service (LOS) for intersections in the 

vicinity of the Nalley Valley Viaduct and SR 16 would not differ from those of the No Build Alternative. 

Build Alternative roadway operations are documented in detail in EA Section 4.3.3.2 and the Traffic and 

Transportation Discipline Report (Appendix F of the EA). 
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COMMENTS FROM JORI ADKINS, OCTOBER 16, 2012 – COMMENTER ID #006

Response to Comments from Jori Adkins, October 16, 2012 Commenter ID #006

Response to Comment 006-1 

WSDOT provided responses to individuals regarding the process for submitting written comments on the 

EA as well as noting times and locations for public meetings. If requested, hard and/or electronic copies 

of the EA were provided. 

Response to Comment 006-2 

Thank you for your comment. 
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COMMENTS FROM NATHANAEL NERODE, OCTOBER 18, 2012 – COMMENTER ID #007

Response to Comments from Nathanael Nerode, October 18, 2012 Commenter ID #007

Response to Comment 007-1 

Thank you for your comment. 
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COMMENTS FROM ANDREW MORDHORST, OCTOBER 19, 2012 – COMMENTER ID #008

Response to Comments from Andrew Mordhorst, October 19, 2012 Commenter ID #008

Response to Comment 008-1 

As stated in Section 3.0 of the EA, proposals submitted during the public involvement process included 

adding a Cascades station within the Lakewood or DuPont city limits. However, consistent with the 

purpose of the Project to provide more frequent and reliable intercity passenger rail service along the 

PNWRC between Tacoma and Nisqually, and in order to meet performance standards, no additional stops 

are proposed for this Project. 

Freighthouse Square was identified because it is already configured for the passenger volumes

associated with Sound Transit commuter rail service, and is close to freeways.  The site is positioned to 

act as a regional transportation center serving the surrounding communities including Dupont, Lakewood, 

and Tacoma, allowing shorter connections between Amtrak passenger rail and other transit services 

provided at the Tacoma Dome Station. 
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COMMENTS FROM RICK SEMPLE, OCTOBER 19, 2012 – COMMENTER ID #009

Response to Comments from Rick Semple, October 19, 2012 Commenter ID #009

Response to Comment 009-1 

WSDOT provided responses to individuals regarding the process for submitting written comments on the 

EA as well as noting times and locations for public meetings. If requested, hard and/or electronic copies 

of the EA were provided. 

 
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COMMENTS FROM JASON STYLES, OCTOBER 16, 2012 – COMMENTER ID #010

 

Response to Comments from Jason Styles, October 16, 2012 Commenter ID #010

Response to Comment 010-1 

Thank you for your comment. As noted in response to the comment on land use, the EA considered the 

effects of the project in the context of existing and planned land uses, zoning and other regulations, and 

development trends. The Tacoma Dome Area Plan was reviewed in this process. As discussed in Land 

Use, Section 4.13.3 of the EA, the Project is consistent with adopted plans and would implement policies 

adopted by the City of Tacoma. No policy was found that would deem the Project inconsistent with these 

adopted plans and regulations. Based on this review, the Project is consistent with the comprehensive plan 

and zoning regulations adopted by the City of Tacoma. 

Response to Comment 010-2 

As discussed in Section 4.9.3.2 of the EA, the Point Defiance Bypass route would have a different 

character and the view of Puget Sound in the area mentioned in the comments would no longer be 

available. However, the objective of the proposed project is to provide faster, more frequent, and more 

reliable passenger rail service in the corridor and therefore many issues including, but not exclusively, 

aesthetic issues were considered. 

 
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COMMENTS FROM ANDREW LUND, OCTOBER 22, 2012 – COMMENTER ID #011

 
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Response to Comments from Andrew Lund, October 22, 2012 Commenter ID #011

Response to Comment 011-1 

The Shoreline Alternative noted in Section 3.0 of the EA and detailed in the Point Defiance Shoreline 

Alternatives Analysis (Appendix A of the EA) included the addition of one tunnel approximately 1 milelong with a diameter of 39 feet to the south of the existing Nelson Bennett Tunnel. The evaluation 

determined that boring a new tunnel of this size underneath a neighborhood would present many 

structural risks due to the unsuitability of the soil, the condition of the structures, and buildings above the 

proposed tunnel alignment. The new tunnel also would require the acquisition of additional right-of-way 

and increase Project cost. 

This alternative would also require approximately 6.6 miles of retaining walls, ranging in height from 20-

35 feet. The increased cost and potential environmental impacts coupled with the additional right-of-way 

acquisition, large amounts of excavation (approximately 1.7 million cubic yards), 100 acres of clearing 

and grubbing required caused FRA and WSDOT to eliminate it from further evaluation in the EA. 

As described in EA Section 3.0 and further detailed in Appendix A (Alternatives Analysis), FRA and 

WSDOT considered geotechnical, environmental, social and other factors into the potential use of the 

Puget Sound route. The preliminary findings of the Alternative Analysis indicate that needed 

improvements to the route would be prohibitively expensive and would result in significant 

environmental impacts. The possibility of lowering the Nelson Bennett Tunnel floor was not evaluated in 

detail. However, the Nelson Bennett Tunnel represents only one piece of a complex (and high-risk) 

geotechnical puzzle. In addition, it is likely that lowering the Nelson Bennett Tunnel would not meet the 

freight and passenger rail needs of the corridor, as it is not likely that the tunnel floor could be lowered 

without taking both freight and passenger rail out of service during construction. Moreover, the 

geometric requirements to bring the rail back to grade while meeting the grade requirements for freight 

and passenger rail would result in an extremely long tunnel likely resulting in significant environmental 

effects (e.g., property acquisitions, visual impacts from retaining walls, permanent effects to wetlands). 

The Point Defiance Shoreline Alternative Technical Memorandum presents geotechnical and 

environmental challenges south of the tunnel, if it were to be improved to serve both the proposed Amtrak 

Cascades service and existing freight traffic. As discussed in that Memorandum, the Shoreline Alternative 

would likely result in significant environmental impacts and greater construction costs would be 

necessary to reduce or eliminate the route’s geotechnical challenges. 

Response to Comment 011-2 

The accident prediction methodology uses FRA’s accident prediction model to forecast an estimated 

change in accidents in the future. The future accident predictions are based on three primary inputs to the 

model: future vehicle volumes, future train volumes, and the type of at-grade crossing protection. The 

model includes different accident rate factors based on historical national at-grade crossing accidents 

developed by FRA for three categories of warning devices: passive, flashing lights, and gates. 

Response to Comment 011-3 

As discussed in Section 4.9.3.2 of the EA, the Point Defiance Bypass route would have a different 

character and the view of Puget Sound in the area mentioned in the comments would no longer be 

available. However, the objective of the proposed project is to provide faster, more frequent, and more 

reliable passenger rail service in the corridor and therefore many issues including, but not exclusively, 

aesthetic issues were considered. 
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COMMENTS FROM CHRISTINE SHOUP, OCTOBER 24, 2012 – COMMENTER ID #012

 

 
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Response to Comments from Christine Shoup, October 24, 2012 Commenter ID #012

Response to Comment 012-1 

The Traffic and Transportation Discipline Report (Appendix F of the EA) presents details on how the 

accident prediction rates at at-grade crossings were determined. The Build Alternative, with proposed 

signal and crossing improvements, is anticipated to reduce the overall crossing accident rate from 3.6 

accidents for every million train crossings under the No Build Alternative to 3.2 accidents per million 

train crossings under the Build Alternative. 

The accident prediction methodology uses FRA’s accident prediction model to forecast an estimated 

change in accidents in the future. The future accident predictions are based on three primary inputs to the 

model: future vehicle volumes, future train volumes, and the type of at-grade crossing protection. The 

model includes different accident rate factors based on historical national at-grade crossing accidents 

developed by FRA for three categories of warning devices: passive, flashing lights, and gates. 

Response to Comment 012-2 

As stated in Section 3.0 of the EA, additional alternatives suggested during the public involvement 

process included adding a Cascades station within the Lakewood or DuPont city limits. However, the 

additional stops would not be consistent with the purpose and need of the Project to provide more 

frequent and reliable intercity passenger rail service along the PNWRC between Tacoma and Nisqually 

and would not meet WSDOT’s performance standards. Additional intercity passenger rail stops in 

Lakewood or DuPont would reduce the speed of the intercity passenger rail and would not decrease travel 

time along the Pacific Northwest Rail Corridor. Therefore, no additional stops were evaluated or 

proposed for this Project. 

The proposed Freighthouse Square site is positioned to act as a regional transportation center serving the 

surrounding communities including Dupont, Lakewood, and Tacoma, allowing shorter connections 

between Amtrak passenger rail and other transit services provided at the Tacoma Dome Station. This 

reduction in connection time would improve passenger connections and convenience for passengers 

connecting between Amtrak, Sounder, Tacoma Link light rail, and bus transit (Section 4.3.3.2 of the EA). 

Response to Comment 012-3 

The Traffic and Transportation Discipline Report (Appendix F of the EA) describes how the additional 

trains on the Point Defiance Bypass would result in an average overall increase in the time at-grade 

crossings are blocked as the train passes (approximately one minute during the morning and afternoon 

peak hour). However, the proposed signal improvements and the relative short blockage time are not 

anticipated to create significant overall operational changes on the local roadways when compared to the 

No Build Alternative (see Section 4.4.3 of the EA). 

Cascades service would occur throughout the day, and Sounder service would be during a.m. and p.m. 

peak hours. The train schedule will be developed collaboratively with Sound Transit during final design 

(2013-2015). A schedule will be broadly distributed through multiple media outlets several months prior 

to the beginning of Cascades service. 

 
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COMMENTS FROM JEFF RYAN, OCTOBER 24, 2012 – COMMENTER ID #013

 

 
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Response to Comments from Jeff Ryan, October 24, 2012 Commenter ID #013

Response to Comment 013-1 

WSDOT determined that Freighthouse Square is the best location for the new Amtrak station because it

will become a key component of an existing multi‐modal transportation hub, is already configured for

the passenger volumes associated with Sound Transit commuter rail service, and is close to freeways.

 
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COMMENTS FROM BOBBY KUTLER, OCTOBER 24, 2012 – COMMENTER ID #014

 

 
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Response to Comments from Bobby Kutler, October 24, 2012 Commenter ID #014

Response to Comment 014-1 

As discussed in Section 4.2.3.2 of the EA, noise effects are not significant and therefore noise mitigation 

is not required. However, Section 4.2.4 of the EA notes two specific noise reduction measures during 

operations: 1) use wayside horns at at-grade crossings to limit the sounding of on-train horns and reduce 

the area exposed to train warning sounds, and 2) use of track treatments (such as resiliently supported ties, 

or ballast mats) to reduce the vibration transmitted to the ground. These measures will be incorporated 

into the project as described further in Section 8.0 of the FONSI. 

Although not warranted, noise barrier placement is not feasible because openings in the walls would be 

needed for roadway crossings. Noise barriers could also create vehicular sight-distance hazards (see page 

55, Noise and Vibration Discipline Report, Appendix E of the EA). 

 
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COMMENTS FROM LILA EARLY, OCTOBER 24, 2012 – COMMENTER ID #015
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Response to Comments from Lila Early, October 24, 2012 Commenter ID #015

Response to Comment 015-1 

As discussed in Section 4.9.3.2 of the EA, the Point Defiance Bypass route would have a different 

character and the view of Puget Sound in the area mentioned in the comments would no longer be 

available. However, the objective of the proposed project is to provide faster, more frequent, and more 

reliable passenger rail service in the corridor and therefore many issues including, but not exclusively, 

aesthetic issues were considered. 

Response to Comment 015-2 

The Traffic and Transportation Discipline Report (Appendix F of the EA) describes how the additional 

trains on the Point Defiance Bypass would affect vehicular travel times. The EA reports “the average 

additional blockage time per crossing is approximately one minute during the morning and afternoon peak 

hour. However, the proposed signal improvements and the relative short blockage time are not 

anticipated to create significant overall operational changes on the local roadways when compared to the 

No Build Alternative (see Section 4.3.3 of the EA). 

Response to Comment 015-3 

Improved signage and signals would minimize safety risks associated with at-grade crossings and 

increased passenger rail traffic on the Point Defiance Bypass route. Traffic and Transportation Discipline 

Report (Appendix F of the EA) presents details on proposed crossing improvements that would minimize 

safety risk at at-grade crossings. Measures include: 

 Signage: “Do Not Stop On Tracks” signs will be installed at the crossings. 

 Wayside horns: A wayside horn system is an automated warning system that is installed at a 

rail/roadway at-grade crossing to warn people of an approaching train. 

 Median barriers: Median barriers will be installed in the middle of the roadway approaching the 

railroad tracks to discourage vehicles from driving around the railroad crossing gates. 

 Sidewalks: Sidewalks provide an ADA-accessible route over the tracks. Additionally, tactile 

strips provided with the improvements alert the sight-impaired to changes ahead. 

 Pre-signals: Pre-signals control vehicle traffic approaching a railroad crossing and minimize 

queuing across the at-grade railroad crossing. 

In addition, as stated in Section 4.14.4 of the EA, WSDOT would continue the Operation Lifesaver

program training on track safety for community members and continue to work with communities to 

ensure there are safe routes that avoid the illegal use of the railroad right-of-way for pedestrians and nonvehicular travel. 

Response to Comment 015-4 

As noted in EA Section 4.2.3.2, the increased noise levels would be caused by new warning devices at 

signalized at-grade crossings. Warning devices such as wayside horns must be heard to be effective and 

therefore volumes cannot be reduced; however the noise effects from their use would be short duration 

and localized. 
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COMMENTS FROM ANONYMOUS, OCTOBER 24, 2012 – COMMENTER ID #016
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Response to Comments from Anonymous, October 24, 2012 Commenter ID #016

Response to Comment 016-1 

The Freighthouse Square site will be reconfigured as described in Section 3.2.4 of the EA. The sizing and 

configuration of the station is designed to accommodate the Coast Starlight trains.

Response to Comment 016-2 

As stated in Section 3.0 of the EA, additional alternatives suggested during the public involvement 

process included adding a Cascades station within the Lakewood or DuPont city limits. However, the 

additional stops would not be consistent with the purpose and need of the Project to provide more 

frequent and reliable intercity passenger rail service along the PNWRC between Tacoma and Nisqually 

and would not meet WSDOT’s performance standards. Additional intercity passenger rail stops in 

Lakewood or DuPont would reduce the speed of the intercity passenger rail and would not decrease travel 

time along the Pacific Northwest Rail Corridor. Therefore, no additional stops were evaluated or 

proposed for this Project. 

The proposed Freighthouse Square site is positioned to act as a regional transportation center serving the 

surrounding communities including DuPont, Lakewood, and Tacoma, allowing shorter connections 

between Amtrak passenger rail and other transit services provided at the Tacoma Dome Station. This 

reduction in connection time would improve passenger connections and convenience for passengers 

connecting between Amtrak, Sounder, Tacoma Link light rail, and bus transit (Section 4.3.3.2 of the EA). 

Response to Comment 016-3 

Thank you for your comment. 

 
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COMMENTS FROM WARREN YEE, OCTOBER 25, 2012 – COMMENTER ID #017
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Response to Comments from Warren Yee, October 25, 2012 Commenter ID #017

Response to Comment 017-1 

The Amtrak Cascades schedule would be coordinated with Sound Transit to preserve the line capacity 

needed for Sound Transit to operate existing commuter rail service (see Section 4.3.3.2 of the EA). 

Response to Comment 017-2 

Currently, there are no plans to construct double track around Freighthouse Square station. 

Response to Comment 017-3 

As discussed in Section 4.9.3.2 of the EA, the Point Defiance Bypass route would have a different 

character and the view of Puget Sound in the area mentioned in the comments would no longer be 

available. However, the objective of the proposed project is to provide faster, more frequent, and more 

reliable passenger rail service in the corridor and therefore many issues including, but not exclusively, 

aesthetic issues were considered. 

 
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COMMENTS FROM JOHN NILES, OCTOBER 25, 2012 – COMMENTER ID #018

Response to Comments from John Niles, October 25, 2012 Commenter ID #018

Response to Comment 018-1 

WSDOT provided responses to individuals regarding the process for submitting written comments on the 

EA as well as noting times and locations for public meetings. If requested, hard and/or electronic copies 

of the EA were provided. 

 
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COMMENTS FROM RICK SEMPLE, OCTOBER 29, 2012 – COMMENTER ID #019

 
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Response to Comments from Rick Semple, October 29, 2012 Commenter ID #019

Response to Comment 019-1 

FRA and WSDOT worked with City of Tacoma and Sound Transit and others through the technical 

advisory groups which included discussions regarding the relocation of the Amtrak station to 

Freighthouse Square. Section 4.13.3.2 of the EA includes an analysis of the Project’s consistency with 

local plans. 

WSDOT identified that the west end of the Freighthouse Square building, beginning immediately west of 

the Sound Transit atrium, presented the least challenge with respect to the elevation differences between 

the existing floor and the platform. This configuration would make passenger movements, including 

Americans with Disabilities Act (ADA) compliance and baggage movements, easier. The west end also 

allows for upgrades to the station entrance. 

WSDOT will work with the local agencies and the community to ensure that the Project remains 

consistent with local area plans during final design and construction. 

As described in Section 4.3.2 of the EA and Appendix F of the EA, the Coast Starlight train would extend 

beyond the existing station platform and across East C Street and East D Street for approximately 6 

minutes. Coast Starlight trains arrive and depart during non-peak periods. These arrivals and departures 

may coincide with Tacoma Dome events. The temporary blockage of these two streets would result in a 

decline of LOS to below LOS D during an event at the Tacoma Dome (see page 4-13 of the EA for 

definition of LOS D). Minimization of operational effects (Section 4.3.4 of the EA) on traffic as a result 

of the Coast Starlight dwell time at Freighthouse Square, and during a Tacoma Dome event, would 

include implementation of a detour plan that could include static signs identifying the detour routes, 

dynamic message signs that identify the detour routes during a train blockage, lane striping and controller 

modification. With the detour signage in place, LOS would not go below LOS D. During final design, 

WSDOT will continue modeling and coordination efforts with the City of Tacoma to identify refinements 

of the suite of minimization measures, as noted above. 

 
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COMMENTS FROM DAHP, OCTOBER 29, 2012 – COMMENTER ID #020

Response to Comments from DAHP, October 29, 2012 Commenter ID #020

Response to Comment 020-1 

Thank you for your comment. 

 
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COMMENTS FROM MICHAEL RABSTOFF, NOVEMBER 11, 2012 – COMMENTER ID #021

Response to Comments from Michael Rabstoff, November 11, 2012 Commenter ID #021

Response to Comment 021-1 

Thank you for your comment. 

Response to Comment 021-2 

As stated in Section 3.0 of the EA, additional alternatives suggested during the public involvement 

process included adding a Cascades station within the Lakewood or DuPont city limits. However, the 

additional stops would not be consistent with the purpose and need of the Project to provide more 

frequent and reliable intercity passenger rail service along the PNWRC between Tacoma and Nisqually 

and would not meet WSDOT’s performance standards. Additional intercity passenger rail stops in 

Lakewood or DuPont would reduce the speed of the intercity passenger rail and would not decrease travel 

time along the Pacific Northwest Rail Corridor. Therefore, no additional stops were evaluated or 

proposed for this Project. 

The proposed Freighthouse Square site is positioned to act as a regional transportation center serving the 

surrounding communities including Dupont, Lakewood, and Tacoma, allowing shorter connections 

between Amtrak passenger rail and other transit services provided at the Tacoma Dome Station. This 

reduction in connection time would improve passenger connections and convenience for passengers 

connecting between Amtrak, Sounder, Tacoma Link light rail, and bus transit (Section 4.3.3.2 of the EA). 

 
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COMMENTS FROM JOHN HELDING, NOVEMBER 2, 2012 – COMMENTER ID #022

Response to Comments from John Helding, November 2, 2012 Commenter ID #022

Response to Comment 022-1 

WSDOT provided responses to individuals regarding the process for submitting written comments on the 

EA as well as noting times and locations for public meetings. If requested, hard and/or electronic copies 

of the EA were provided. 

 
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COMMENTS FROM MARLENE KAM, NOVEMBER 5, 2012 – COMMENTER ID #023

Response to Comments from Marlene Kam, November 5, 2012 Commenter ID #023

Response to Comment 023-1 

As discussed in Section 4.9.3.2 of the EA, the Point Defiance Bypass route would have a different 

character and the view of Puget Sound in the area mentioned in the comments would no longer be 

available. However, the objective of the proposed project is to provide faster, more frequent, and more 

reliable passenger rail service in the corridor and therefore many issues including, but not exclusively, 

aesthetic issues were considered. 

 
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COMMENTS FROM DARRELL REECK, NOVEMBER 6, 2012 – COMMENTER ID #024

 
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Response to Comments from Darrell Reeck, November 6, 2012 Commenter ID #024

Response to Comment 024-1 

Thank you for your comment. 

Response to Comment 024-2 

There would be up to twelve additional Cascades and two Coast Starlight trips through the Point Defiance 

Bypass route, which would increase the number of times trains pass by (at speeds of up-to 79 MPH). The 

Build Alternative includes signal improvements that would reduce the effect of additional trains on local 

roadway operations. In addition, all crossings, including Exit 119, would comply with FRA crossing 

requirements to reduce hazards associated with rail crossings. The analysis in the EA indicates that the 

overall roadway delay would not be significantly adversely affected, including that of Exit 119. Also, the 

Proposed Action’s proposed signal and crossing signage improvements are anticipated to result in no 

substantial change to rail crossing safety (see Traffic and Transportation Discipline Report, Appendix F 

of the EA). 

Response to Comment 024-3 

As shown on Figure 4 in EA Section 4.2.3.2, three noise receptors are in the City of DuPont. Results of 

the noise impact evaluation determined that moderate noise effects would occur in areas of the City of 

Lakewood but not in the City of DuPont. As noted in EA Section 4.2.3.2, the increased noise levels would 

be caused by new warning devices at signalized at-grade crossings. Warning devices such as wayside 

horns must be heard to be effective and therefore volumes cannot be reduced; however the noise effects 

from their use would be short duration, localized, and would be an improvement over train mounted 

horns. Noise effects would be below the maximum noise level of 92 dBA at 100 feet, as set by FRA 

Guidance on Assessing Noise and Vibration Impacts. Also, operation of the Amtrak trains would not 

occur during nighttime sleeping hours (10:00 p.m. to 7:00 a.m.). 

Response to Comment 024-4 

As stated in Section 3.0 of the EA, additional alternatives suggested during the public involvement 

process included adding a Cascades station within the Lakewood or DuPont city limits. However, the 

additional stops would not be consistent with the purpose and need of the Project to provide more 

frequent and reliable intercity passenger rail service along the PNWRC between Tacoma and Nisqually 

and would not meet WSDOT’s performance standards. Additional intercity passenger rail stops in 

Lakewood or DuPont would reduce the speed of the intercity passenger rail and would not decrease travel 

time along the Pacific Northwest Rail Corridor. Therefore, no additional stops were evaluated or 

proposed for this Project. 

The proposed Freighthouse Square site is positioned to act as a regional transportation center serving the 

surrounding communities including Dupont, Lakewood, and Tacoma, allowing shorter connections 

between Amtrak passenger rail and other transit services provided at the Tacoma Dome Station. This 

reduction in connection time would improve passenger connections and convenience for passengers 

connecting between Amtrak, Sounder, Tacoma Link light rail, and bus transit (Section 4.3.3.2 of the EA). 

 
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COMMENTS FROM TINA LEE, NOVEMBER 6, 2012 – COMMENTER ID #025
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Response to Comments from Tina Lee, November 6, 2012 Commenter ID #025

Response to Comment 025-1 

Thank you for your comment. 

Response to Comment 025-2 

As described in Section 4.3.2 of the EA and Appendix F of the EA, the Coast Starlight train would extend 

beyond the existing station platform and across East C Street and East D Street for approximately 6 

minutes. Coast Starlight trains arrive and depart during non-peak periods. These arrivals and departures 

may coincide with Tacoma Dome events. The temporary blockage of these two streets would result in a 

decline of LOS to below LOS D during an event at the Tacoma Dome (see page 4-13 of the EA for 

definition of LOS D). Minimization of operational effects (Section 4.3.4 of the EA) on traffic as a result 

of the Coast Starlight dwell time at Freighthouse Square, and during a Tacoma Dome event, would 

include implementation of a detour plan that could include static signs identifying the detour routes, 

dynamic message signs that identify the detour routes during a train blockage, lane striping and controller 

modification. With the detour signage in place, LOS would not go below LOS D. During final design, 

WSDOT will continue modeling and coordination efforts with the City of Tacoma to identify refinements 

of the suite of minimization measures, as noted above. WSDOT will continue to coordinate with local 

agencies through final design and implementation of the project to address any potential operational 

concerns including those related to local bus service. See Chapter 5 of the EA. 

In regards to future projects, WSDOT will work collaboratively with the City and Dome Development 

Group on any subsequent re-design or relocation of the Tacoma Amtrak station in response to transit 

oriented development opportunities. 

Response to Comment 025-3 

WSDOT will continue to coordinate with local agencies through final design and implementation of the 

project to address any potential operational concerns including those related to local bus service. See 

Chapter 5 of the EA. 

In regards to future projects, WSDOT will work collaboratively with the City and Dome Development 

Group on any subsequent re-design or relocation of the Tacoma Amtrak station in response to transit 

oriented development opportunities. 

Response to Comment 025-4 

As described in Section 4.3.3.2 of the EA and the Traffic and Transportation Discipline Report (Appendix 

F of the EA), the proposed Freighthouse Square station would provide the same or more parking spaces 

than are currently available at the Tacoma Amtrak Station. Parking would be located on a parcel near 

Freighthouse Square (see Section 3.2.4 of the EA) that either has parking available for lease or purchase 

by WSDOT and developed into a parking lot for exclusive use by Amtrak passengers. In addition to this 

proposed parking, there would be some available on-street parking near the station (see Section 4.3.3.2 of 

the EA). 

The proposed sites for additional parking are across the street from Freighthouse Square to the west, 

similar to the garage to the east. The proposed sites for parking are equidistant, thus would not be located 

further that the Pierce Transit’s Tacoma Dome Station facility. In addition to this proposed parking, there 

would be some available on-street parking near the proposed station. If the demand increases it may be 

necessary to consider building a small parking structure but currently parking is considered adequate. 

 
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COMMENTS FROM JORI ADKINS, NOVEMBER 7, 2012 – COMMENTER ID #026

 
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Response to Comments from Jori Adkins, November 7, 2012 Commenter ID #026

Response to Comment 026-1 

As described in Section 4.3.3.2 of the EA and the Traffic and Transportation Discipline Report (Appendix 

F of the EA), the proposed Freighthouse Square station would provide the same or more parking spaces 

than are currently available at the Tacoma Amtrak Station. Parking would be located on a parcel near 

Freighthouse Square (see Section 3.2.4 of the EA) that either has parking available for lease or purchase 

by WSDOT and developed into a parking lot for exclusive use by Amtrak passengers. In addition to this 

proposed parking, there would be some available on-street parking near the station (see Section 4.3.3.2 of 

the EA). 

The Tacoma Dome Area Plan was reviewed as part of the Project. As discussed in Section 4.13.3.2 of the 

EA, the Project is consistent with adopted plans and would implement policies adopted by the City of 

Tacoma. No policy was found that would cause the Project to be inconsistent with these adopted plans 

and regulations (see Section 4.13.1 of the EA). Based on this review, the Project is consistent with the 

comprehensive plan and zoning regulations adopted by the City of Tacoma and is not inconsistent with 

the Tacoma Dome Area Plan. 

WSDOT will continue to work with the City of Tacoma and Sound Transit during final design of the 

Project. 

Response to Comment 026-2 

As noted in Section 4.13.1 of the EA, the land use determination of effects included an examination of 

potential effects in the context of the Tacoma Dome Subarea Plan. As discussed in the EA, the Project is 

consistent with adopted plans and would implement policies adopted by the City of Tacoma. WSDOT 

will continue to work with the City of Tacoma and Sound Transit to ensure that project final design is 

aligned with the goals and actions of the dome area plan. 

Response to Comment 026-3 

The public involvement process for the EA has been ongoing since 2010 and consisted of meetings 

(including meetings with the City of Tacoma and several Tacoma neighborhood councils), newsletter 

flyers, NEPA public comment period, and other outreach efforts to obtain feedback and input from 

adjacent property owners, communities, and other stakeholders. As FRA and WSDOT move forward in 

final design they will conduct targeted outreach to local agencies and interested parties, providing 

periodic briefings and email updates. 
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COMMENTS FROM KEITH STONE, NOVEMBER 2, 2012 – COMMENTER ID #027

 
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Response to Comments from Keith Stone, November 2, 2012 Commenter ID #027

Response to Comment 027-1 

The public involvement process for the EA has been ongoing since 2010 and has included meetings, 

newsletter flyers, NEPA public comment period, and other outreach efforts to obtain feedback and input 

from adjacent property owners, communities, and other stakeholders. 

Response to Comment 027-2 

As described in the EA Section 4.3 and Traffic and Transportation Discipline Report (Appendix F of the 

EA), parking needs associated with the relocation to Freighthouse Square would be satisfied with a parcel 

near Freighthouse Square that either has parking available for lease or purchase or can be developed into 

a parking lot for exclusive use by Amtrak passengers. The existing Tacoma Amtrak Station has an onsite parking lot with 82 parking spaces. There are 2,283 parking spaces at the Tacoma Dome Station. 

Currently, parking is free in the garage, but vehicles cannot remain longer than 24 hours in the parking 

garages. On-street parking is also provided on Puyallup Avenue, East 25th Street, and East 26th Street. 

Along these roadways, on-street parking is either restricted to a time limit between one and two hours, or 

is unrestricted (no time limit specified). The supply of on-street two-hour parking, approximately 69 

spaces, is much higher than the supply of one-hour parking, and had a utilization rate of more than half. 

The majority of on-street parking supply is unrestricted and is close to 100% utilized. Parking is already 

used in and around the Freighthouse Square Station, and the Build Alternative would utilize the available 

parking areas. 

Response to Comment 027-3 

WSDOT determined that Freighthouse Square is the best location for the new Amtrak station because it

will become a key component of an existing multi‐modal transportation hub, is already configured for

the passenger volumes associated with Sound Transit commuter rail service, and is close to freeways.
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COMMENTS FROM ELIZABETH BURRIS, NOVEMBER 7, 2012 – COMMENTER ID #028

Commenter ID #028 
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Response to Comments from Elizabeth Burris, November 7, 2012 Commenter ID #028

Response to Comment 028-1 

Thank you for your comment. As noted in response to the comment on land use, the EA considered the 

effects of the project in the context of existing and planned land uses, zoning and other regulations, and 

development trends. The Tacoma Dome Area Plan was reviewed in this process. As discussed in Land 

Use, Section 4.13.3 of the EA, the Project is consistent with adopted plans and would implement policies 

adopted by the City of Tacoma. No policy was found that would deem the Project inconsistent with these 

adopted plans and regulations. Based on this review, the Project is consistent with the comprehensive plan 

and zoning regulations adopted by the City of Tacoma. 

Response to Comment 028-2 

The public involvement process for the EA has been ongoing since 2010 and consisted of meetings 

(including meetings with the City of Tacoma and several Tacoma neighborhood councils), newsletter 

flyers, NEPA public comment period, and other outreach efforts to obtain feedback and input from 

adjacent property owners, communities, and other stakeholders. As FRA and WSDOT move forward in 

final design they will conduct targeted outreach to local agencies and interested parties, providing 

periodic briefings and email updates. 
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COMMENTS FROM TRACI KELLY, NOVEMBER 7, 2012 – COMMENTER ID #029

 
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Response to Comments from Traci Kelly, November 7, 2012 Commenter ID #029

Response to Comment 029-1 

As described in Section 4.3.3.2 of the EA and the Traffic and Transportation Discipline Report (Appendix 

F of the EA), the proposed Freighthouse Square station would provide the same or more parking spaces 

than are currently available at the Tacoma Amtrak Station. Parking would be located on a parcel near 

Freighthouse Square (see Section 3.2.4 of the EA) that either has parking available for lease or purchase 

by WSDOT and developed into a parking lot for exclusive use by Amtrak passengers. In addition to this 

proposed parking, there would be some available on-street parking near the station (see Section 4.3.3.2 of 

the EA). 

The Tacoma Dome Area Plan was reviewed as part of the Project. As discussed in Section 4.13.3.2 of the 

EA, the Project is consistent with adopted plans and would implement policies adopted by the City of 

Tacoma. No policy was found that would cause the Project to be inconsistent with these adopted plans 

and regulations (see Section 4.13.1 of the EA). Based on this review, the Project is consistent with the 

comprehensive plan and zoning regulations adopted by the City of Tacoma and is not inconsistent with 

the Tacoma Dome Area Plan. 

WSDOT will continue to work with the City of Tacoma and Sound Transit during final design of the 

Project. 

Response to Comment 029-2 

As noted in Section 4.13.1 of the EA, the land use determination of effects included an examination of 

potential effects in the context of the Tacoma Dome Subarea Plan. As discussed in the EA, the Project is 

consistent with adopted plans and would implement policies adopted by the City of Tacoma. WSDOT 

will continue to work with the City of Tacoma and Sound Transit to ensure that project final design is 

with the goals and actions of the dome area plan. 
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COMMENTS FROM ELDON JACOBSON, NOVEMBER 7, 2012 – COMMENTER ID #030
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Response to Comments from Eldon Jacobson, November 7, 2012 Commenter ID #030

Response to Comment 030-1 

As described in the Grade Separation Concept Evaluation (Appendix B of the EA), some concepts have 

rail under the roadway while others have rail over the roadway. As the concept evaluation proceeded, a 

host of factors were considered when deciding whether to elevate the roadway or trench it, or to elevate or 

trench the rail bed. These factors include maintaining a reasonable rail grade before and after the grade 

crossing (approximately 2% or less), clearance at structures, underground utilities, and groundwater, as 

well as the acquisition of adjacent properties that would be required to accommodate the grade separation, 

roadway structures and slopes. 

The Grade Separation Concept Evaluation Report revealed that current and projected future traffic 

volumes do not warrant the construction of new (or modified) grade-separated crossings. The report 

found that the construction and operation of grade-separated crossings would result in significant 

environmental impacts to the surrounding community (e.g., noise, property acquisitions, visual impacts 

from retaining walls, and the increased perception of community isolation, particularly in Tillicum). 

However, the construction of the Build Alternative would not preclude the future construction of gradeseparated crossings within the Project Area. 

Response to Comment 030-2 

The addition of intercity operations and the resulting potential effects to at-grade crossings in the corridor 

were evaluated for the Project in the Grade Separation Concept Evaluation Report and were discussed in 

Section 3.0 of the EA (the report is available in Appendix B of the EA). As part of the evaluation, traffic 

demand modeling was completed, and considered traffic volumes and flow at the existing at-grade 

crossings based on the traffic projected to 2030. The evaluation revealed that current and projected future 

traffic volumes do not warrant the construction of new (or modified) grade-separated crossings. 

Instead, the analysis found that the construction and operation of grade-separated crossings would result 

in significant environmental impacts to the surrounding community (e.g., noise, property acquisitions, 

visual impacts from retaining walls, and the increased perception of community isolation, particularly in 

Tillicum). However, the construction of the Build Alternative would not preclude the future construction 

of grade-separated crossings within the Project Area. 

Response to Comment 030-3 

Vegetation within the railroad right-of-way would be maintained by the operator and owner to facilitate 

line of sight for rail car operators. For safety purposes it is standard practice to maintain vegetation within 

the rail corridor. Sound Transit clears invasive species and replants areas not in active use with native 

species. Disturbed areas are hydroseeded, and significant trees are avoided when possible. Sound Transit 

has a vegetation management plan for their overall corridor. 

Response to Comment 030-4 

Comment noted; however, this topic is outside the scope of the EA. 

Response to Comment 030-5 

Fencing locations and type will be determined during final design in collaboration with Sound Transit. 

The fencing and barriers currently in place are adequate and sufficient for the currently planned level of 

service of Sound Transit. 

Response to Comment 030-6 

The proposed improvements included in the Point Defiance Bypass would be undertaken by WSDOT, as 

the Project proponent, and grantee receiving FRA funds under the High-Speed Intercity Passenger Rail 

program. 
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COMMENTS FROM DEIDRE WILSON, NOVEMBER 7, 2012 – COMMENTER ID #031
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Response to Comments from Deidre Wilson, November 7, 2012 Commenter ID #031

Response to Comment 031-1 

As noted in EA Section 4.2.3.2, the increased noise levels would be caused by new warning devices at 

signalized at-grade crossings. Warning devices such as wayside horns must be heard to be effective and 

therefore volumes cannot be reduced. However, no wayside horns are proposed through Nalley Valley. 

In addition, under the proposed Amtrak Cascades and Coast Starlight schedule, there would be no train 

noise effects during normal sleeping hours (10 p.m. to 7 a.m.). 

It should be noted that Quiet Zones are initiated by localities. The process to establish new Quiet Zones 

can be found on the FRA webpage at http://www.fra.dot.gov/rpd/freight/1318.shtml. 

Local public authorities may designate or request approval of, quiet zones in which train horns may not be 

routinely sounded (local public authorities are those that are responsible for traffic control or law 

enforcement at the highway-rail grade crossing). The details for establishment of quiet zones differ 

depending on the type of quiet zone to be created (Pre-Rule or New) and the type of safety improvements 

implemented (if required). In general, the process starts with selection of the crossings to be included in 

the Quiet Zone. Once selected, the conditions of the crossing are documented. The Quiet Zone Calculator 

is then used to determine whether the Quiet Zone Risk Index of the proposed Quiet Zone is less than or 

equal to the Nationwide Significant Risk Threshold (NSRT). If it is greater than the NSRT, then 

supplementary or alternative safety measures must be used to reduce that risk to fully compensate for the 

absence of the train horn or to reduce risk below the NSRT. The analysis above is submitted with an 

application to FRA Office of Railroad Safety for approval. 

Response to Comment 031-2 

Study area and methods for noise and vibration analysis are described in Section 4.2 of the EA and 

detailed in the Noise and Vibration Discipline Report (Appendix E of the EA). Noise and vibration 

analyses were conducted to evaluate construction and operation effects from noise and vibration. 

Although wayside horns were not measured in the field, the noise effects from wayside horns were 

modeled using standard methods to evaluate the effects of wayside horns on noise sensitive receptors. 

Receptors are residential, commercial, and industrial uses where noise has the potential to disrupt the 

activities that take place there. 

Section 4.2.1 of the EA states that noise and vibration effects were evaluated within 1,000 feet of the 

track centerline. A study area of 1,000 feet was selected based on WSDOT’s professional judgment to 

capture the area within which project-generated noise effects would occur prior to conducting the noise 

analysis and was verified using the results of the analysis to determine that the area was sufficient to 

capture the project effects. The noise analysis determined that all project impacts would occur within 500 

feet of the track or crossing location. As such a 1,000 foot study area was considered more than sufficient 

to characterize the noise effects of the project. 

Response to Comment 031-3 

Warning devices such as wayside horns (which are proposed as part of the Project) must be heard to be 

effective and therefore volumes cannot be reduced. However, the noise effects from their use would be 

short duration and localized (as compared to on-train horns) (see EA Section 4.2.3.2). 

 
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COMMENTS FROM SU DOWIE, NOVEMBER 8, 2012 – COMMENTER ID #032
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Response to Comments from Su Dowie, November 8, 2012 Commenter ID #032

Response to Comment 032-1 

Thank you for your comment. 

Response to Comment 032-2 

As described in Section 4.3.2 of the EA and Appendix F of the EA, the Coast Starlight train would extend 

beyond the existing station platform and across East C Street and East D Street for approximately 6 

minutes. Coast Starlight trains arrive and depart during non-peak periods. These arrivals and departures 

may coincide with Tacoma Dome events. The temporary blockage of these two streets would result in a 

decline of LOS to below LOS D during an event at the Tacoma Dome (see page 4-13 of the EA for 

definition of LOS D). Minimization of operational effects (Section 4.3.4 of the EA) on traffic as a result 

of the Coast Starlight dwell time at Freighthouse Square, and during a Tacoma Dome event, would 

include implementation of a detour plan that could include static signs identifying the detour routes, 

dynamic message signs that identify the detour routes during a train blockage, lane striping and controller 

modification. With the detour signage in place, LOS would not go below LOS D. During final design, 

WSDOT will continue modeling and coordination efforts with the City of Tacoma to identify refinements 

of the suite of minimization measures, as noted above. 

 
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COMMENTS FROM DAVID BUGHER, NOVEMBER 8, 2012 – COMMENTER ID #033
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Response to Comments from David Bugher, November 8, 2012 Commenter ID #033

Response to Comment 033-1 

As described in Section 4.3.3.2 of the EA, the 14 additional passenger trains per day under the Build 

Alternative would increase the number of times local crossings temporarily closed as trains pass by. Total 

closing time for each crossing would be relatively short (about one minute per occurrence). The effects of 

additional trains (and the associated crossing closing at at-grade crossings) would be reduced by the 

proposed signal and intersection improvements. Based on the analysis presented in the Transportation 

Discipline Report, the overall effect to local roadway system operations would not be significant, and in 

some cases represents an improvement over the existing condition. The Project will follow FRA design 

standards and track design standards set by each jurisdiction as applicable. 

Response to Comment 033-2 

FRA and WSDOT are also concerned about trespassing on the rail right of way, but do not anticipate that 

the Project would increase the amount of trespass on rail right-of-way. With increased passenger rail 

traffic, the opportunities for trespassers on rail right-of-way to interact with trains could increase, causing 

potential safety issues. In addition to state and federal safety requirements, the infrastructure owner is 

responsible for developing and implementing security procedures to reduce the likelihood of rail trespass. 

These security procedures implement and follow the BNSF Railway’s Transportation Security 

Administration: 24 Security Action Items flyer, 49 CFR 1580: TSA Rail Regulations Regarding Rail 

Security Sensitive Materials, Sound Transit’s Safety and Security Plan, and the system safety program 

plans for both BNSF Railway and Tacoma Rail. 

Response to Comment 033-3 

FRA and WSDOT are also concerned about trespassing on the rail right of way, but do not anticipate that 

the Project would increase the amount of trespass on rail right-of-way. With increased passenger rail 

traffic, the opportunities for trespassers on rail right-of-way to interact with trains could increase, causing 

potential safety issues. In addition to state and federal safety requirements, the infrastructure owner is 

responsible for developing and implementing security procedures to reduce the likelihood of rail trespass. 

These security procedures implement and follow the BNSF Railway’s Transportation Security 

Administration: 24 Security Action Items flyer, 49 CFR 1580: TSA Rail Regulations Regarding Rail 

Security Sensitive Materials, Sound Transit’s Safety and Security Plan, and the system safety program 

plans for both BNSF Railway and Tacoma Rail. 

Response to Comment 033-4 

Both WSDOT and FRA agree that rail suicide is a deeply traumatic event for anyone affected, and FRA is 

currently funding research being conducted by the Railroad Research Foundation to evaluate rail suicides 

(see http://www.railroadresearch.org/safety). It remains that there is “no Specific Public Safety 

Consideration of rail suicide” within the EA. The Build Alternative would use an existing rail corridor 

and FRA and WSDOT do not agree with the commenter’s statement regarding the proposed change in 

route, vulnerable individuals and grade separation. The safety of pedestrians and vehicle drivers is 

adequately assessed in the EA. 

As stated in Section 4.14.1 of the EA, health facilities within 1⁄2 mile of the Point Defiance Bypass route 

were included in the analysis. The Western State Hospital and Greater Lakes Mental Health Facility is 

located approximately 3.6 and 1.6 miles from the route, respectively; therefore neither facility was 

identified in the analysis. The EA finds that access to public services as well as emergency response 

would not be significantly affected by the Project. 

Ongoing outreach and educational efforts, particularly in the form of Operation Lifesaver, including a 

potential focus on at-risk populations (e.g., providers/clients at these mental health facilities; service 

providers to the homeless), will continue after construction of the Project. 
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Response to Comment 033-5 

The scope of the Project was limited to evaluation of improvements to rail movement for Amtrak service. 

A statewide evaluation of transportation system improvements for all modes of transportation is outside 

the scope of this evaluation. In addition, funding from FRA is mandated for only passenger rail 

improvements. 

Response to Comment 033-6 

The EA Section 4.3.3.2, presents a summary of the traffic analysis from the Traffic and Transportation 

Discipline Report (Appendix F of the EA). This Report, which was discussed in detail with local 

stakeholder members of the Technical Advisory Group, presents a more detailed description of the traffic 

modeling and analysis, including how additional train operations on the Point Defiance Bypass route will 

affect traffic on the local roadway network. 

In short, the Project used two calibrated models: Lakewood/I-5 VISUM travel demand model, and the 

Pierce County EMME travel demand model. The results of the travel demand modeling efforts were used 

as an input to the VISSIM and Synchro traffic operations modeling software. VISSIM and Synchro are 

industry standards that are used nationally as well as throughout Washington state. 

Response to Comment 033-7 

Traffic and Transportation Discipline Report (Appendix F of the EA) notes that the shift and increase of 

passenger rail from the Puget Sound route to the Point Defiance Bypass route would create multiple daily 

crossings at at-grade crossings, with resulting delays to vehicles on roadways, as well as pedestrians. Atgrade crossings would be closed for about one minute per passenger train crossing. Extensive traffic 

modeling confirms that there are no significant impacts to the local arterial system. In addition to the one 

minute crossing time mentioned above, only one Cascades trip is scheduled to occur during the AM peak 

hour, and one in the PM peak hour. All but two Cascades trips through Lakewood would occur during 

off-peak hours. 

The signals proposed for the Project would be installed in coordination with the City of Lakewood during 

final design and permitting. Operation and maintenance of the signals would be conducted by WSDOT. 

Local agency concerns about traffic and transportation were heard by WSDOT, and were made a core 

part of the Technical Advisory Group’s meetings between January and October, 2011. Transportation 

topics discussed in detail included traffic assumptions, baseline traffic counts, modeling outputs, and 

initial findings. 

Response to Comment 033-8 

FRA and WSDOT understand there exists the potential for accidents in any transportation corridor where 

pedestrians and vehicles ignore or avoid safety precautions (see EA page 4-38). For purposes of 

analyzing risk and comparing alternatives, standard FRA analytical methods were used to determine 

accident rates at rail crossings associated with the project alternatives. Additional detail is in the Traffic 

and Transportation Discipline Report, Appendix F of the EA, Chapters 2, 4, and 5. 

Response to Comment 033-9 

When compared to the No Build Alternative, the Project does not split or isolate areas, generate new 

development, or separate neighborhoods from services. The existing conditions, such as geographic, land 

use, and transportation features, would all continue to contribute to the sense of isolation and division in 

neighborhoods. The operation of the Project may increase residents’ sense of division during train 

passbys; however this disruption would be very short in duration (i.e., 12 minutes per day) (see Section 

4.12 of the EA and the Socioeconomic and Environmental Justice Discipline Report (Appendix N of the 

EA) and Section 4.16). The benefit the EA identifies is associated with improvements at several grade 
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crossings that will aid the traffic flow through the community. FRA and WSDOT assessment complies 

with the federal executive orders, and is similar to what has been applied elsewhere in the region. 

Response to Comment 033-10 

Decisions to add Freight traffic is independent of the Sound Transit and Amtrak service along the Bypass 

route. Sound Transit, as the owner of the majority of the corridor, cannot prohibit freight use but does set 

the terms and conditions for any freight use of their infrastructure. The operations of the freight will 

continue to be directed by Tacoma Rail and BNSF. 

There would be no change to the operation of freight trains on the Point Defiance Bypass route under the 

Build Alternative (EA Section 3.2.5). Tacoma Rail and BNSF would continue to operate as many as two 

trains per day on some portions of the Point Defiance Bypass route to as few as two trains per week on 

other portions of the Point Defiance Bypass route. BNSF would continue to operate intermittent freight 

trains on the Point Defiance Bypass route to serve military transportation needs at JBLM. The Project 

would not enable freight traffic to move beyond the East “D” Street and Tacoma Avenue Overpass due to 

existing grade restrictions and Sound Transit running rights. The operations of the freight (including 

freight speeds) will continue to be directed by Tacoma Rail and BNSF. 

Response to Comment 033-11 

EA Section 4.16.2, Cumulative Effects, contains a list of current and reasonably foreseeable future 

transportation related projects. As part of the Cumulative Effects analysis, FRA and WSDOT examined 

the known local and regional roadway improvements. The project identified by the commenter has been 

added to EA Table 17 and WSDOT and FRA find that it does not change the analysis or conclusions 

described in the EA.

Response to Comment 033-12 

Preliminary design of the Project includes the use of more advanced signal controllers, noted in Traffic 

and Transportation Discipline Report (Appendix F of the EA). These signal controllers are identified for 

use as they would reduce the likelihood of the vehicles on the tracks as noted in the report. The details of 

intersection signal phasing and timing will be developed during the final design phase of the project. 

Upon approval by WSDOT and each applicable local jurisdiction, and once the intersection signals are 

constructed and become operational, their phasing and timing would be adjusted to ensure that they are 

accounting for actual traffic conditions. In addition, as a standard practice, WSDOT works with local 

jurisdictions prior to and once traffic signals are operating to ensure optimized traffic flow. 

Response to Comment 033-13 

Each resource specific study area was determined based on the independent resource being evaluated and 

may be different depending on the resource. WSDOT coordinated and consulted with SHPO regarding 

the Area of Potential Effect (APE) of the Project and the Section 106 analysis. Historic properties within 

the APE were identified and project impacts were assessed. That information is included in Section 4.10 

of the EA. WSDOT received concurrence from SHPO on September 26, 2012, on the APE and findings 

contained within the Cultural Resources Report. 

Response to Comment 033-14 

Both the state and federal decision documents will be made available on the WSDOT Project website at 

http://www.wsdot.wa.gov/projects/rail/pnwrc_ptdefiance. With respect to appeals, SEPA appeal 

process is outlined in the state regulations RCW 43.21C.060, 075, and 080 and WAC 197‐11‐680. 

NEPA decisions may be challenged pursuant to Federal law. 

 
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COMMENTS FROM JOHN NILES, NOVEMBER 8, 2012 – COMMENTER ID #034
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Response to Comments from John Niles, November 8, 2012 Commenter ID #034

Response to Comment 034-1 

Details on the crossing safety analysis are presented in the Traffic and Transportation Discipline Report 

(EA Appendix F), and incorporated by reference into the EA. As noted in the Traffic and Transportation 

Discipline Report, “Overall, the time between accidents would be 0.1 years less with the Build 

Alternative than with the No Build Alternative; however, the number of crossing events increases and the 

accident rate per million train crossings improves with the Build Alternative.” 

Response to Comment 034-2 

Details on the crossing safety analysis are presented in the Traffic and Transportation Discipline Report 

(EA Appendix F), and incorporated by reference into the EA. As noted in the Traffic and Transportation 

Discipline Report, “Overall, the time between accidents would be 0.1 years less with the Build 

Alternative than with the No Build Alternative; however, the number of crossing events increases and the 

accident rate per million train crossings improves with the Build Alternative.” 

Response to Comment 034-3 

Concerning accident frequency, Section 4.14.3.1 of the EA states: “3.2 accidents for every million train 

crossings are anticipated. This accident rate would be a decrease in accidents from the No Build 

Alternative (3.6 accidents per million train crossings).” When expressed in years between accidents, the 

Build Alternative would have 0.9 years between accidents whereas the No Build Alternative would have 

1.0 years between accidents. This shorter period between accidents is attributable to the increased number 

of crossing events with the Build Alternative. Although the Build Alternative would reduce the accident 

rate per train crossing event, the increased number of crossing events shortens frequency between 

accidents relative to the No Build Alternative by 0.1 years. 

WSDOT evaluated the both the Puget Sound Route and Point Defiance Route in their entirety to 

determine potential crash frequency with the No Build Alternative and Build Alternative. The 

methodology is described in detail in Chapter 2 of the Traffic and Transportation Discipline Report and 

results reported in Exhibit 58 and 59 (see the Traffic and Transportation Discipline Report, Appendix F of 

the EA). In short, analysts reviewed the last five years of historical data from the FRA Office of Safety 

Analysis from October 2006 through September 2011. The FRA database describes the severity and type 

of accidents and the analysts used that information to describe the safety issues associated with the current 

rail crossings, as well as the likely safety issues expected with the Project. In addition to reviewing 

historical data, analysts used the FRA accident prediction model to consider the effects of the Project on 

safety. Inputs into the model were taken mostly from the FRA crossing inventory database and traffic 

volumes gathered for the Project to estimate annual average daily traffic (AADT) on the roadways. 

 
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COMMENTS FROM CHRISTINE REICHGOTT, NOVEMBER 8, 2012 – COMMENTER ID #035
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Response to Comments from Christine Reichgott, November 8, 2012 Commenter ID #035

Response to Comment 035-1 

Upgrades to the intersections and signaling would maintain or improve traffic flow overall and thus 

improve connectivity compared to the No Build Alternative. Intersection and signal improvements would 

improve connectivity and safety for pedestrians, bicyclists and vehicles as well as improve traffic flow for 

some intersections, which is more fully discussed in Section 4.3.3.2 of the EA. 

Therefore, with the Project and the proposed traffic improvements, community connectivity would 

experience a minor benefit (See Section 4.1.2.3 of the EA). No mitigation measures are required and 

minimization measures are described in the EA. 

Earlier implementation of at-grade crossing improvements will be dependent on project funding and 

completion of all permitting processes. The remaining proposed considerations will be kept in mind for 

other future projects in the area but are outside the scope of this EA. 

The information gained through this project will continue to inform WSDOT’s engagement and outreach 

strategies with the environmental justice communities in the area. WSDOT will provide regular updates 

about the project via the project web pages. 
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COMMENTS FROM ODETTE D’ANIELLO, NOVEMBER 9, 2012 – COMMENTER ID #036

 
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Response to Comments from Odette D’Aniello, November 9, 2012 Commenter ID #036

Response to Comment 036-1 

As described in Section 4.3.2 of the EA and Appendix F of the EA, the Coast Starlight train would extend 

beyond the existing station platform and across East C Street and East D Street for approximately 6 

minutes. Coast Starlight trains arrive and depart during non-peak periods. These arrivals and departures 

may coincide with Tacoma Dome events. The temporary blockage of these two streets would result in a 

decline of LOS to below LOS D during an event at the Tacoma Dome (see page 4-13 of the EA for 

definition of LOS D). Minimization of operational effects (Section 4.3.4 of the EA) on traffic as a result 

of the Coast Starlight dwell time at Freighthouse Square, and during a Tacoma Dome event, would 

include implementation of a detour plan that could include static signs identifying the detour routes, 

dynamic message signs that identify the detour routes during a train blockage, lane striping and controller 

modification. With the detour signage in place, LOS would not go below LOS D. During final design, 

WSDOT will continue modeling and coordination efforts with the City of Tacoma to identify refinements 

of the suite of minimization measures, as noted above.

Response to Comment 036-2 

The process to establish new Quiet Zones can be found on the FRA webpage at 

http://www.fra.dot.gov/rpd/freight/1318.shtml. 

Local public authorities may designate or request approval of, quiet zones in which train horns may not be 

routinely sounded (local public authorities are those that are responsible for traffic control or law 

enforcement at the highway-rail grade crossing). The details for establishment of quiet zones differ 

depending on the type of quiet zone to be created (Pre-Rule or New) and the type of safety improvements 

implemented (if required). In general, the process starts with selection of the crossings to be included in 

the Quiet Zone. Once selected, the conditions of the crossing are documented. The Quiet Zone Calculator 

is then used to determining whether the Quiet Zone Risk Index of the proposed Quiet Zone is less than or 

equal to the Nationwide Significant Risk Threshold (NSRT). If it is greater than the NSRT, then 

supplementary or alternative safety measures must be used to reduce that risk to fully compensate for the 

absence of the train horn or to reduce risk below the NSRT. The analysis above is submitted with an 

application to FRA Office of Railroad Safety for approval. 
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COMMENTS FROM KEN MAUERMANN, NOVEMBER 8, 2012 – COMMENTER ID #037

Response to Comments from Ken Mauermann, November 8, 2012 Commenter ID #037

Response to Comment 037-1 

As described in Section 4.2.1.2 of the EA, vibration effects from train operations were assessed using 

the FTA vibration impact assessment procedures. Land uses along the alignment were investigated to 

determine those that would be affected by the project. No vibration effects were identified in the “M” 

Street vicinity (see Section 4.2.3.2 of the EA and page 46, Noise and Vibration Discipline Report, 

Appendix E of the EA). 
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COMMENTS FROM T.C. BROADNAX, NOVEMBER 8, 2012 – COMMENTER ID #038
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Response to Comments from T.C. Broadnax, November 8, 2012 Commenter ID #038

Response to Comment 038-1 

As described in Section 4.3.2 of the EA and Appendix F of the EA, the Coast Starlight train would extend 

beyond the existing station platform and across East C Street and East D Street for approximately 6 

minutes. Coast Starlight trains arrive and depart during non-peak periods. These arrivals and departures 

may coincide with Tacoma Dome events. The temporary blockage of these two streets would result in a 

decline of LOS to below LOS D during an event at the Tacoma Dome (see page 4-13 of the EA for 

definition of LOS D). Minimization of operational effects (Section 4.3.4 of the EA) on traffic as a result 

of the Coast Starlight dwell time at Freighthouse Square, and during a Tacoma Dome event, would 

include implementation of a detour plan that could include static signs identifying the detour routes, 

dynamic message signs that identify the detour routes during a train blockage, lane striping and controller 

modification. With the detour signage in place, LOS would not go below LOS D. During final design, 

WSDOT will continue modeling and coordination efforts with the City of Tacoma to identify refinements 

of the suite of minimization measures, as noted above. 

Response to Comment 038-2 

As described in Section 4.3.3.2 of the EA and the Traffic and Transportation Discipline Report (Appendix 

F of the EA), the proposed Freighthouse Square station would provide the same or more parking spaces 

than are currently available at the Tacoma Amtrak Station. Parking would most likely be located on a 

parcel near Freighthouse Square (see Section 3.2.4 of the EA) that either has parking available for lease or 

which can be purchased and developed into a parking lot for exclusive use by Amtrak passengers. In 

addition to this proposed parking, there would be some available on-street parking near the station (see 

Section 4.3.3.2 of the EA). 

The Tacoma Dome Area Plan was reviewed as part of the Project. As discussed in Section 4.13.3.2 of the 

EA, the Project is consistent with adopted plans and would implement policies adopted by the City of 

Tacoma. No policy was found that would cause the Project to be inconsistent with these adopted plans 

and regulations (see Section 4.13.1 of the EA). Based on this review, the Project is consistent with the 

comprehensive plan and zoning regulations adopted by the City of Tacoma and is not inconsistent with 

the Tacoma Dome Area Plan. 

WSDOT will continue to work with the City of Tacoma and Sound Transit during final design of the 

Project. 

Response to Comment 038-3 

Noise analysis was conducted to evaluate construction and operation effects on noise-sensitive receptors. 

The noise effects from wayside horns were modeled using standard methods to evaluate the effects of 

wayside horns at locations near to noise-sensitive receptors. EA section 4.2.2.1 states that horn noise 

modeling indicates that Ldn noise levels of 60 dBA would be experienced at up to 190 feet from the 

intersection. Noise-sensitive receptors (such as residences) were not found within 190 feet of the 

crossings listed. Also, there would be no noise effects during common sleeping hours (10 p.m. to 7 a.m.) 

due to the proposed Amtrak Cascades and Coast Starlight schedule (trains will run after 7 a.m. and until 

10 p.m.). 

Response to Comment 038-4 

Proposed crossing improvements include ADA-accessible route over tracks. 

Response to Comment 038-5 

The Cultural Resources Report for the Point Defiance Bypass Project notes that the S-Turn Bridge (a.k.a. 

Freighthouse Square Bridge) was completed in 1909. This is the same as the East G Street trestle bridge. 

As stated in this Report, “This timber trestle structure has been rebuilt several times over the years, 
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including a complete refurbishment in the 1960s and the subsequent replacement of all structural 

members (e.g., stringers and pilings) in the 1990s.” Since replacement of structural components 

completed in the 1990s, no additional analysis was conducted for the Project. The structures are currently 

used by Sound Transit and routinely inspected and maintained. To date no structural issues have been 

identified. 

Response to Comment 038-6 

Section 4.3.3.3 of the EA summarizes the findings of the Traffic and Transportation Discipline Report. 

This Report (Appendix F of the EA) presents detailed documentation of the traffic analysis. Impacts to 

levels of service and queue length on South 56th Street and South 74th Street were specifically addressed 

per the City of Tacoma’s request. Overall, the Levels of Service (LOS) at local intersections that exist 

now are not predicted to change with the Build Alternative. LOS at South 56th Street and South 74th Street 

would be same under the Build and No Build Alternative. Signal improvements, which would include 

installation of more advanced devices to control intersections, are included as part of the Project and 

would reduce the delay and vehicle queues at improved intersections. 
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COMMENTS FROM JANICE MCNEAL, NOVEMBER 9, 2012 – COMMENTER ID #039

 
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Response to Comments from Janice McNeal, November 9, 2012 Commenter ID #039

Response to Comment 039-1 

As described in Section 4.3.2 of the EA and Appendix F of the EA, the Coast Starlight train would extend 

beyond the existing station platform and across East C Street and East D Street for approximately 6 

minutes. Coast Starlight trains arrive and depart during non-peak periods. These arrivals and departures 

may coincide with Tacoma Dome events. The temporary blockage of these two streets would result in a 

decline of LOS to below LOS D during an event at the Tacoma Dome (see page 4-13 of the EA for 

definition of LOS D). Minimization of operational effects (Section 4.3.4 of the EA) on traffic as a result 

of the Coast Starlight dwell time at Freighthouse Square, and during a Tacoma Dome event, would 

include implementation of a detour plan that could include static signs identifying the detour routes, 

dynamic message signs that identify the detour routes during a train blockage, lane striping and controller 

modification. With the detour signage in place, LOS would not go below LOS D. During final design, 

WSDOT will continue modeling and coordination efforts with the City of Tacoma to identify refinements 

of the suite of minimization measures, as noted above. 

Response to Comment 039-2 

As described in Section 4.3.3.2 of the EA and the Traffic and Transportation Discipline Report (Appendix 

F of the EA), the proposed Freighthouse Square station would provide the same or more parking spaces 

than are currently available at the Tacoma Amtrak Station. Parking would be located on a parcel near 

Freighthouse Square (see Section 3.2.4 of the EA) that either has parking available for lease or purchase 

by WSDOT and developed into a parking lot for exclusive use by Amtrak passengers. In addition to this 

proposed parking, there would be some available on-street parking near the station (see Section 4.3.3.2 of 

the EA). 

The Tacoma Dome Area Plan was reviewed as part of the Project. As discussed in Section 4.13.3.2 of the 

EA, the Project is consistent with adopted plans and would implement policies adopted by the City of 

Tacoma. No policy was found that would cause the Project to be inconsistent with these adopted plans 

and regulations (see Section 4.13.1 of the EA). Based on this review, the Project is consistent with the 

comprehensive plan and zoning regulations adopted by the City of Tacoma and is not inconsistent with 

the Tacoma Dome Area Plan. 

WSDOT will continue to work with the City of Tacoma and Sound Transit during final design of the 

Project. 

Response to Comment 039-3 

As noted in EA Section 4.2.3.2, the increased noise levels would be caused by new warning devices at 

signalized at-grade crossings. Warning devices such as wayside horns must be heard to be effective and 

therefore volumes cannot be reduced. However, no wayside horns are proposed through Nalley Valley. 

In addition, under the proposed Amtrak Cascades and Coast Starlight schedule, there would be no train 

noise effects during normal sleeping hours (10 p.m. to 7 a.m.). 

It should be noted that Quiet Zones are initiated by localities. The process to establish new Quiet Zones 

can be found on the FRA webpage at http://www.fra.dot.gov/rpd/freight/1318.shtml. 

Local public authorities may designate or request approval of, quiet zones in which train horns may not be 

routinely sounded (local public authorities are those that are responsible for traffic control or law 

enforcement at the highway-rail grade crossing). The details for establishment of quiet zones differ 

depending on the type of quiet zone to be created (Pre-Rule or New) and the type of safety improvements 

implemented (if required). In general, the process starts with selection of the crossings to be included in 

the Quiet Zone. Once selected, the conditions of the crossing are documented. The Quiet Zone Calculator 

is then used to determine whether the Quiet Zone Risk Index of the proposed Quiet Zone is less than or 
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equal to the Nationwide Significant Risk Threshold (NSRT). If it is greater than the NSRT, then 

supplementary or alternative safety measures must be used to reduce that risk to fully compensate for the 

absence of the train horn or to reduce risk below the NSRT. The analysis above is submitted with an 

application to FRA Office of Railroad Safety for approval. 
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COMMENTS FROM BRIAN ZIEGLER, NOVEMBER 9, 2012 – COMMENTER ID #040
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Response to Comments from Brian Ziegler, November 9, 2012 Commenter ID #040

Response to Comment 040-1 

The EA considered the potential effects of the project on existing and future sewer facilities, including 

those identified in the Pierce County Unified Sewer Plan. The EA identifies potential utility conflicts (i.e., 

areas where utilities cross under or over the tracks), although the need for relocations, hardening, and 

deepening has not been finalized. As noted in the EA, locations of potential conflicts are detailed in the 

Public Services and Utilities Discipline Report, Appendix P of the EA, Exhibits 9 and 10. During final 

design and permitting, additional coordination with the County and City would occur and address sewer 

facilities that would be affected by the project. 

Response to Comment 040-2 

Verification of utilities locations will occur during final design and as noted in Section 4.14.4 of the EA, 

WSDOT will coordinate with utility owners to determine conflicts and determine a suitable resolution to 

avoid or minimize disruption. 

Response to Comment 040-3 

References to the service start date for Sounder service was accurate when the EA was published. The 

correct service start date has been added to the revised EA. 

Response to Comment 040-4 

WSDOT will coordinate with Pierce County and other local jurisdictions regarding the construction 

schedule, construction areas, and detour routes during Project development to minimize community 

disruption including for events such as the US Open. This commitment has been included in the EA and 

FONSI. 
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COMMENTS FROM ERIC BECKMAN, NOVEMBER 9, 2012 – COMMENTER ID #041
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Response to Comments from Eric Beckman, November 9, 2012 Commenter ID #041

Response to Comment 041-1 

Noise effects to sensitive receptors are below the FTA noise impact threshold for severe effects and 

wayside train horn volumes are below the maximum noise level allowed by FRA for train-mounted horns; 

therefore, noise effects to sensitive receptors would not be significant (see EA Section 4.2.3.2). WSDOT 

will coordinate with Sound Transit regarding potential minimization for the remaining moderate impacts. 

Response to Comment 041-2 

As described in Section 4.3.2 of the EA and Appendix F of the EA, the Coast Starlight train would extend 

beyond the existing station platform and across East C Street and East D Street for approximately 6 

minutes. Coast Starlight trains arrive and depart during non-peak periods. These arrivals and departures 

may coincide with Tacoma Dome events. The temporary blockage of these two streets would result in a 

decline of LOS to below LOS D during an event at the Tacoma Dome (see page 4-13 of the EA for 

definition of LOS D). Minimization of operational effects (Section 4.3.4 of the EA) on traffic as a result 

of the Coast Starlight dwell time at Freighthouse Square, and during a Tacoma Dome event, would 

include implementation of a detour plan that could include static signs identifying the detour routes, 

dynamic message signs that identify the detour routes during a train blockage, lane striping and controller 

modification. With the detour signage in place, LOS would not go below LOS D. During final design, 

WSDOT will continue modeling and coordination efforts with the City of Tacoma to identify refinements 

of the suite of minimization measures, as noted above. 

Response to Comment 041-3 

FRA and WSDOT worked with City of Tacoma and Sound Transit and others through the technical 

advisory groups which included discussions regarding the relocation of the Amtrak station to 

Freighthouse Square. Section 4.13.3.2 of the EA includes an analysis of the Project’s consistency with 

local plans. 

WSDOT identified that the west end of the Freighthouse Square building, beginning immediately west of 

the Sound Transit atrium, presented the least challenge with respect to the elevation differences between 

the existing floor and the platform. This configuration would make passenger movements, including 

Americans with Disabilities Act (ADA) compliance and baggage movements, easier. The west end also 

allows for upgrades to the station entrance. 

WSDOT will work with the local agencies and the community to ensure that the Project remains 

consistent with local area plans during final design and construction. 

As described in Section 4.3.2 of the EA and Appendix F of the EA, the Coast Starlight train would extend 

beyond the existing station platform and across East C Street and East D Street for approximately 6 

minutes. Coast Starlight trains arrive and depart during non-peak periods. These arrivals and departures 

may coincide with Tacoma Dome events. The temporary blockage of these two streets would result in a 

decline of LOS to below LOS D during an event at the Tacoma Dome (see page 4-13 of the EA for 

definition of LOS D). Minimization of operational effects (Section 4.3.4 of the EA) on traffic as a result 

of the Coast Starlight dwell time at Freighthouse Square, and during a Tacoma Dome event, would 

include implementation of a detour plan that could include static signs identifying the detour routes, 

dynamic message signs that identify the detour routes during a train blockage, lane striping and controller 

modification. With the detour signage in place, LOS would not go below LOS D. During final design, 

WSDOT will continue modeling and coordination efforts with the City of Tacoma to identify refinements 

of the suite of minimization measures, as noted above.

Response to Comment 041-4 
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As stated in Section 3.2.4 of the EA, the reconstructed portion of the existing Freighthouse Square 

building (to create a passenger ticketing and waiting area, and baggage handling space) would be ADA 

compliant. The platform at the Freighthouse Square Station will be constructed to meet the needs of the 

Cascades, Coast Starlight, and Sounder trains. WSDOT will continue to coordinate with Amtrak and FRA 

to ensure that ADA requirements are met throughout final design and construction of the Project. 
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COMMENTS FROM DON WICKSTROM, NOVEMBER 9, 2012 – COMMENTER ID #042

Commenter ID #042 
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Response to Comments from Don Wickstrom, November 9, 2012 Commenter ID #042

Response to Comment 042-1 

WSDOT and FRA propose crossing improvements as part of the project (signals, signage) to minimize 

potential safety effects of increased passenger rail. WSDOT and FRA applied standard methods for 

analyzing rail crossing safety, and determined that the Project would result in generally lower accident 

rates than the No Build Alternative (see Section 4.14.3.2 of the EA and the Traffic and Transportation 

Discipline Report, Appendix F of the EA). The crossing improvements are designed to provide for 

vehicle and pedestrian safety at crossings. In addition, the horns and crossing gates will be controlled in a 

manner that provides for the clearing of the crossing well in advance of the train approach. 

Response to Comment 042-2 

Decisions to add Freight traffic is independent of the Sound Transit and Amtrak service along the Bypass 

route. Sound Transit, as the owner of the majority of the corridor, cannot prohibit freight use but does set 

the terms and conditions for any freight use of their infrastructure. The operations of the freight will 

continue to be directed by Tacoma Rail and BNSF. 

There would be no change to the operation of freight trains on the Point Defiance Bypass route under the 

Build Alternative (EA Section 3.2.5). Tacoma Rail and BNSF would continue to operate as many as two 

trains per day on some portions of the Point Defiance Bypass route to as few as two trains per week on 

other portions of the Point Defiance Bypass route. BNSF would continue to operate intermittent freight 

trains on the Point Defiance Bypass route to serve military transportation needs at JBLM. The Project 

would not enable freight traffic to move beyond the East “D” Street and Tacoma Avenue Overpass due to 

existing grade restrictions and Sound Transit running rights. The operations of the freight (including 

freight speeds) will continue to be directed by Tacoma Rail and BNSF. 

Response to Comment 042-3 

Chapter 2 of Traffic and Transportation Discipline Report (Appendix F of the EA) documents the 

assumptions used in the traffic model. These assumptions were also provided during the Technical 

Advisory Group meetings to solicit input in to the assumption development and review the results of the 

VISSIM modeling. Additional input and coordination with the City of Lakewood will be sought during 

final design, including the design of signal timing, permitting, and construction. 

Local agency concerns about traffic and transportation were heard by WSDOT, and were made a core 

part of the Technical Advisory Group’s meetings between January and October 2011. Transportation 

topics discussed in detail included traffic assumptions, baseline traffic counts, modeling outputs, and 

initial findings. 

Response to Comment 042-4 

FRA and WSDOT examined Puget Sound Regional Council’s current program, which included the 

Madigan Access Improvement Project and the funded improvement projects in the state transportation 

improvement program. The projects noted in the comment are not yet complete but are reasonably 

foreseeable future projects that are considered as part of the cumulative impacts analysis in Section 

4.16.2, Cumulative Effects, of the EA. These projects are also noted in Exhibit 120 of the Traffic and 

Transportation Discipline Report (Appendix F of the EA). 

Response to Comment 042-5 

Improved signage and signals would minimize safety risks associated with at-grade crossings and 

increased passenger rail traffic on the Point Defiance Bypass route. Traffic and Transportation Discipline 

Report (Appendix F of the EA) presents details on proposed crossing improvements that would minimize 

safety risk at at-grade crossings. Measures include: 
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 Signage: “Do Not Stop On Tracks” signs will be installed at the crossings. 

 Wayside horns: A wayside horn system is an automated warning system that is installed at a 

rail/roadway at-grade crossing to warn people of an approaching train. 

 Median barriers: Median barriers will be installed in the middle of the roadway approaching the 

railroad tracks to discourage vehicles from driving around the railroad crossing gates. 

 Sidewalks: Sidewalks provide an ADA-accessible route over the tracks. Additionally, tactile 

strips provided with the improvements alert the sight-impaired to changes ahead. 

 Pre-signals: Pre-signals control vehicle traffic approaching a railroad crossing and minimize 

queuing across the at-grade railroad crossing. 

In addition, as stated in Section 4.14.4 of the EA, WSDOT would continue the Operation Lifesaver

program training on track safety for community members and continue to work with communities to 

ensure there are safe routes that avoid the illegal use of the railroad right-of-way for pedestrians and nonvehicular travel. 

Response to Comment 042-6 

Operational problems, such as the one cited in the comment, are not expected to occur as trains proposed 

for use on the tracks would be designed and maintained to operate at the grades along the Point Defiance 

Bypass route. As the rail operators, Amtrak and Sound Transit are responsible for remedying those types 

of problems as quickly as possible should they occur.

Response to Comment 042-7 

The Interstate 5 – Joint Base Lewis-McCord Area Congestion Management Project and SR 510 to SR 

512, a TIGER III improvement, has been added to Table 17 in the revised EA. The potential effects 

associated with these projects are intended to improve traffic flow and relieve I-5 congestion primarily 

through traffic management strategies and operational enhancements. Improvements to local roads and 

key connections within JBLM will not contribute to a cumulative effect on resources potentially affected 

by the Point Defiance Bypass. The conclusions described in Chapter 4.16.2 of the EA, Cumulative 

Effects, remain valid. 
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COMMENTS FROM GORDON AND ANITA RUSS, LLOYD FLEM, ROCHE SCHERERMAN, OCTOBER

24, 2012 – COMMENTER ID #043, 044, 045
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Response to Comments from Gordon and Anita Russ, October 24, 2012 Commenter ID #043

Response to Comment 043-1 

The Shoreline Alternative noted in Section 3.0 of the EA and detailed in the Point Defiance Shoreline 

Alternatives Analysis (Appendix A of the EA) included the addition of one tunnel approximately 1 milelong with a diameter of 39 feet to the south of the existing Nelson Bennett Tunnel. The evaluation 

determined that boring a new tunnel of this size underneath a neighborhood would present many 

structural risks due to the unsuitability of the soil, the condition of the structures, and buildings above the 

proposed tunnel alignment. The new tunnel also would require the acquisition of additional right-of-way 

and increase Project cost. 

This alternative would also require approximately 6.6 miles of retaining walls, ranging in height from 20-

35 feet. The increased cost and potential environmental impacts coupled with the additional right-of-way 

acquisition, large amounts of excavation (approximately 1.7 million cubic yards), 100 acres of clearing 

and grubbing required caused FRA and WSDOT to eliminate it from further evaluation in the EA. 

As described in EA Section 3.0 and further detailed in Appendix A (Alternatives Analysis), FRA and 

WSDOT considered geotechnical, environmental, social and other factors into the potential use of the 

Puget Sound route. The preliminary findings of the Alternative Analysis indicate that needed 

improvements to the route would be prohibitively expensive and would result in significant 

environmental impacts. The possibility of lowering the Nelson Bennett Tunnel floor was not evaluated in 

detail. However, the Nelson Bennett Tunnel represents only one piece of a complex (and high-risk) 

geotechnical puzzle. In addition, it is likely that lowering the Nelson Bennett Tunnel would not meet the 

freight and passenger rail needs of the corridor, as it is not likely that the tunnel floor could be lowered 

without taking both freight and passenger rail out of service during construction. Moreover, the 

geometric requirements to bring the rail back to grade while meeting the grade requirements for freight 

and passenger rail would result in an extremely long tunnel likely resulting in significant environmental 

effects (e.g., property acquisitions, visual impacts from retaining walls, permanent effects to wetlands). 

The Point Defiance Shoreline Alternative Technical Memorandum presents geotechnical and 

environmental challenges south of the tunnel, if it were to be improved to serve both the proposed Amtrak 

Cascades service and existing freight traffic. As discussed in that Memorandum, the Shoreline Alternative 

would likely result in significant environmental impacts and greater construction costs would be 

necessary to reduce or eliminate the route’s geotechnical challenges. 

Response to Comment 043-2 

As discussed in Section 4.9.3.2 of the EA, the Point Defiance Bypass route would have a different 

character and the view of Puget Sound in the area mentioned in the comments would no longer be 

available. However, the objective of the proposed project is to provide faster, more frequent, and more 

reliable passenger rail service in the corridor and therefore many issues including, but not exclusively, 

aesthetic issues were considered. 

Response to Comments from Lloyd Flem, October 24, 2012 Commenter ID #044

Response to Comment 044-1 

Improved signage and signals would minimize safety risks associated with at-grade crossings and 

increased passenger rail traffic on the Point Defiance Bypass route. Traffic and Transportation Discipline 

Report (Appendix F of the EA) presents details on proposed crossing improvements that would minimize 

safety risk at at-grade crossings. Measures include: 

 Signage: “Do Not Stop On Tracks” signs will be installed at the crossings. 
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 Wayside horns: A wayside horn system is an automated warning system that is installed at a 

rail/roadway at-grade crossing to warn people of an approaching train. 

 Median barriers: Median barriers will be installed in the middle of the roadway approaching the 

railroad tracks to discourage vehicles from driving around the railroad crossing gates. 

 Sidewalks: Sidewalks provide an ADA-accessible route over the tracks. Additionally, tactile 

strips provided with the improvements alert the sight-impaired to changes ahead. 

 Pre-signals: Pre-signals control vehicle traffic approaching a railroad crossing and minimize 

queuing across the at-grade railroad crossing. 

Response to Comment 044-2 

As discussed in the Section 4.12 of the EA and the Socioeconomic and Environmental Justice Discipline 

Report (Appendix N of the EA), the Project is not anticipated to affect property values, given that the rail 

corridor already exists, is used for freight and commuter service, and measures to minimize or eliminate 

noise and vibration will be implemented by the Project. 

Response to Comments from Roche Schererman, October 24, 2012 Commenter ID #045

Response to Comment 045-1 

Coast Starlight trains, which are 1,234 feet long, require a longer platform than both Sounder and 

Cascades trains, which are 700 feet long. However, the proposed platform as described in Section 3.2.4 

of the EA will be of sufficient length to support Coast Starlight, Cascades, and Sounder trains. 
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COMMENTS FROM KENNETH BOUNCHER, KEN MAUERMANN, BARBARA BILLINGSLEY, MATT

ROYER, BOB BREGENT, DAVID BUGHER, PENNY COFFEY, JOAN COOLEY, LEE CHASE, SHARON

TAYLOR, BILL PALMANTEER, OCTOBER 25, 2012 – COMMENTER ID #046, 045, 046, 047, 048,

049, 050, 051, 052, 053, 054, 055, 056
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Response to Comments from Kenneth Bouncher, October 25, 2012 Commenter ID #046

Response to Comment 046-1 

Thank you for your comment. 

Response to Comments from Ken Mauermann, October 25, 2012 Commenter ID #047

Response to Comment 047-1 

The extension of Sounder service into Thurston County is outside the scope of this EA and not within the 

control of FRA or WSDOT. In addition, there are procedural hurdles if Sound Transit sought to extend 

the Sounder service. For example, prior to extending service into Thurston County, Sound Transit would 

need to extend its service area and taxing authority to include Thurston County since currently only King, 

Pierce and Snohomish counties are included in Sound Transit jurisdiction. If Sounder decides to 

implement additional service as suggested, it would need to lead a separate environmental review. 

Response to Comments from Barbara Billingsley, October 25, 2012 Commenter ID #048

Response to Comment 048-1 

Analysis of crossing accidents indicates that the rate of accidents would actually be lower for the Build 

Alternative (3.2 accidents for every million train crossings) than for the No Build Alternative (3.6 

accidents per million train crossings). The Build Alternative includes safety improvements for crossings 

on the Point Defiance Bypass Route. Additional detail is in the Traffic and Transportation Discipline 

Report, Appendix F of the EA, Chapters 2, 4, and 5. 

Response to Comment 048-2 

Amtrak trains would pass through neighborhoods along the rail corridor and would not sit idle in one 

spot. Amtrak trains would dwell for approximately 6 to 10 minutes at the Freighthouse Square Station. As 

described in Section 4.2.1 of the EA, the existing air quality (including odors associated with emissions) 

in the study area would not be affected by Amtrak trains. 

Response to Comment 048-3 

Amtrak trains would pass through neighborhoods along the rail corridor and would not sit idle in one 

spot. Amtrak trains would dwell for approximately 6 minutes at the Freighthouse Square Station. As 

described in Section 4.2.1 of the EA, the existing air quality (including odors associated with emissions) 

in the study area would not be adversely affected by Amtrak trains. 

Response to Comment 048-4 

Section 4.2.3.2 of the EA states that no noise effects as a result of the project are anticipated during 

common sleeping hours (10 p.m. to 7 a.m.) due to the proposed Amtrak Cascades and Coast Starlight 

schedule (trains will run after 7 a.m. and until 10 p.m). Noises related to existing yard operations for 

Tacoma Rail and Sound Transit were considered as part of the baseline noise analysis for the project. 

Tacoma Rail owns and operates the line referred to in the comment, and operations on the line are an 

existing condition. While Tacoma Rail’s operations on this line are outside the scope of this EA, 

WSDOT will continue working with Tacoma Rail on improving rail operations in the Barksdale-vicinity. 

Response to Comment 048-5 

As discussed in the Section 4.12 of the EA and the Socioeconomic and Environmental Justice Discipline 

Report (Appendix N of the EA), the Project is not anticipated to affect property values, given that the rail 
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corridor already exists, is used for freight and commuter service, and measures to minimize or eliminate 

noise and vibration will be implemented by the Project. 

Response to Comments from Matt Royer, October 25, 2012 Commenter ID #049

Response to Comment 049-1 

As stated in Section 3.0 of the EA, additional alternatives suggested during the public involvement 

process included adding a Cascades station within the Lakewood or DuPont city limits. However, the 

additional stops would not be consistent with the purpose and need of the Project to provide more 

frequent and reliable intercity passenger rail service along the PNWRC between Tacoma and Nisqually 

and would not meet WSDOT’s performance standards. Additional intercity passenger rail stops in 

Lakewood or DuPont would reduce the speed of the intercity passenger rail and would not decrease travel 

time along the Pacific Northwest Rail Corridor. Therefore, no additional stops were evaluated or 

proposed for this Project. 

The proposed Freighthouse Square site is positioned to act as a regional transportation center serving the 

surrounding communities including Dupont, Lakewood, and Tacoma, allowing shorter connections 

between Amtrak passenger rail and other transit services provided at the Tacoma Dome Station. This 

reduction in connection time would improve passenger connections and convenience for passengers 

connecting between Amtrak, Sounder, Tacoma Link light rail, and bus transit (Section 4.3.3.2 of the EA). 

Response to Comments from Bob Bregent, October 25, 2012 Commenter ID #050

Response to Comment 050-1 

As noted in EA Section 4.2.3.2, the increased noise levels would be caused by new warning devices at 

signalized at-grade crossings. Warning devices such as wayside horns must be heard to be effective and 

therefore volumes cannot be reduced. However, no wayside horns are proposed through Nalley Valley. 

In addition, under the proposed Amtrak Cascades and Coast Starlight schedule, there would be no train 

noise effects during normal sleeping hours (10 p.m. to 7 a.m.). 

It should be noted that Quiet Zones are initiated by localities. The process to establish new Quiet Zones 

can be found on the FRA webpage at http://www.fra.dot.gov/rpd/freight/1318.shtml. 

Local public authorities may designate or request approval of, quiet zones in which train horns may not be 

routinely sounded (local public authorities are those that are responsible for traffic control or law 

enforcement at the highway-rail grade crossing). The details for establishment of quiet zones differ 

depending on the type of quiet zone to be created (Pre-Rule or New) and the type of safety improvements 

implemented (if required). In general, the process starts with selection of the crossings to be included in 

the Quiet Zone. Once selected, the conditions of the crossing are documented. The Quiet Zone Calculator 

is then used to determine whether the Quiet Zone Risk Index of the proposed Quiet Zone is less than or 

equal to the Nationwide Significant Risk Threshold (NSRT). If it is greater than the NSRT, then 

supplementary or alternative safety measures must be used to reduce that risk to fully compensate for the 

absence of the train horn or to reduce risk below the NSRT. The analysis above is submitted with an 

application to FRA Office of Railroad Safety for approval. 

Response to Comment 050-2 

Thank you for your comment. 
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Response to Comments from David Bugher, October 25, 2012 Commenter ID #051

Response to Comment 051-1 

The EA contains the appropriate environmental commitments and design features to minimize or avoid 

the potential environmental effects of the Project. Those commitments are included in Section 8.0 of 

FRA’s Finding of No Significant Impact. 

Response to Comments from Penny Coffey, October 25, 2012 Commenter ID #052

Response to Comment 052-1 

Noise barrier placement is not feasible because openings in the walls would be needed for roadway 

crossings. Noise barriers could also create vehicular sight-distance hazards (see page 55, Noise and 

Vibration Discipline Report, Appendix E of the EA). Section 4.2.3.2, Noise and Vibration, of the EA 

notes that that noise effects to sensitive receptors would not be significant and no mitigation is required. 

Fencing locations and type will be determined during final design in collaboration with Sound Transit. 

The fencing and barriers currently in place are adequate and sufficient for the currently planned level of 

service of Sound Transit. If it appears that additional fencing and/or barriers are needed to meet 

WSDOT’s Cascades level of service, WSDOT would evaluate, install, and maintain additional barriers. 

Response to Comment 052-2 

Chapter 4.16.2 of the EA, Cumulative Effects, includes a list of current and reasonably foreseeable future 

transportation related projects. In addition, Page 4-69 explains that FRA and WSDOT considered the 

prior studies related to Joint Base Lewis McCord and the projects outlined in the Grow the Army Final 

EIS and other decision documents. This specific project was not included in Table 17 in the EA under 

known local and regional roadway improvements. This project has been added to Table 17 in the EA and 

does not change the analysis or conclusions described in the EA. 

Traffic studies conducted for the Point Defiance Bypass Project were informed by the Technical Advisory 

Group (which City of DuPont participated in). The potential for a new JBLM access control point at 

Wharf Road was mentioned by the City of DuPont during the October 2011 facilitated review of the 

Traffic and Transportation Discipline Report. The JBLM project was not included in the traffic analysis 

because at the time, it was considered speculative and JBLM/Department of Defense had not issued a 

notice of intent or other formal notice to stakeholders that an EA was being prepared. Subsequent 

qualitative analysis of the Wharf Road access control point (ACP) EA indicates that this ACP is located 

off the Steilacoom-DuPont Road into the Lewis North portion of JBLM. As part of Appendix C of the 

JBLM Lewis North Access Control Facility Traffic Study (prepared by Black & Veatch dated September 

7, 2011), the redistribution of vehicles was determined by an Origin Destination Analysis for the roadway 

network as a result of the new ACP at Steilacoom-DuPont Road. Based on this analysis, an additional 

135 vehicles will take the southbound I-5 off-ramp at Barksdale and an additional 129 vehicles will take 

the northbound I-5 off-ramp at Barksdale to use the new ACP. In total, 264 additional vehicles will divert 

to the Barksdale interchange in order to access the new ACP. Ultimately, according to analyses made as 

part of the JBLM EA for the new ACP, channelization lanes would be added at the DuPont-Steilacoom 

and Barksdale Avenue intersections, which would result in overall intersection operations of LOS C. 

Coupled with the Point Defiance Bypass project and the improvements proposed at Barksdale Avenue as 

part of the project, significant effects would not occur at this location. Nonetheless, WSDOT and FRA 

would continue to work with the City of DuPont and JBLM to evaluate the coordination of intersection 

improvements at this location as part of the final design effort, and as part of the larger planning studies 

being conducted for I-5 interchanges by WSDOT. 
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Response to Comments from Joan Cooley, October 25, 2012 Commenter ID #053

Response to Comment 053-1 

As noted in EA Section 4.2.3.2, the increased noise levels would be caused by new warning devices at 

signalized at-grade crossings. Warning devices such as wayside horns must be heard to be effective and 

therefore volumes cannot be reduced; however the noise effects from their use would be short duration 

and localized. 

Response to Comment 053-2 

As discussed in the Section 4.12 of the EA and the Socioeconomic and Environmental Justice Discipline 

Report (Appendix N of the EA), the Project is not anticipated to affect property values, given that the rail 

corridor already exists, is used for freight and commuter service, and measures to minimize or eliminate 

noise and vibration will be implemented by the Project. 

Response to Comment 053-3 

As stated in Section 4.3.3.2 of the EA, 14 additional passenger train trips per day are proposed for the 

Point Defiance Bypass route. Passenger trains are substantially shorter and travel faster than freight 

trains. Section 4.3.3.2 of the EA states that “road closure time for a train crossing would be similar to 

crossing closures for Sounder trains (approximately one minute or less).” With proposed signal 

improvements, overall traffic operations are not anticipated to be significantly affected when compared to 

the existing condition. 

Response to Comment 053-4 

When compared to the No Build Alternative, the Project does not split or isolate areas, generate new 

development, or separate neighborhoods from services. The existing conditions, such as geographic, land 

use, and transportation features, would all continue to contribute to the sense of isolation and division in 

neighborhoods. The operation of the Project may increase residents’ sense of division during train 

passbys; however this disruption would be very short in duration (i.e., 12 minutes per day) (see Section 

4.12 of the EA and the Socioeconomic and Environmental Justice Discipline Report (Appendix N of the 

EA) and Section 4.16). The benefit the EA identifies is associated with improvements at several grade 

crossings that will aid the traffic flow through the community. FRA and WSDOT assessment complies 

with the federal executive orders, and is similar to what has been applied elsewhere in the region. 

Response to Comments from Lee Chase, October 25, 2012 Commenter ID #054

Response to Comment 054-1 

Section 4.2.3.2 of the EA states that no noise effects as a result of the project are anticipated during 

common sleeping hours (10 p.m. to 7 a.m.) due to the proposed Amtrak Cascades and Coast Starlight 

schedule (trains will run after 7 a.m. and until 10 p.m.). Noises related to existing yard operations for 

Tacoma Rail and Sound Transit were considered as part of the baseline noise analysis for the project. 

Tacoma Rail owns and operates the line referred to in the comment, and operations on the line are an 

existing condition. While Tacoma Rail’s operations on this line are outside the scope of this EA, 

WSDOT will continue working with Tacoma Rail on improving rail operations in the Barksdale-vicinity. 
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Response to Comments from Sharon Taylor, October 25, 2012 Commenter ID #055

Response to Comment 055-1 

The use of the Point Defiance Bypass route by Amtrak would not preclude the use or sale of adjacent 

land. 

Response to Comment 055-2 

Proposed signal and signage improvements described in the Traffic and Transportation Discipline Report 

(Appendix F of the EA) would provide practicable measures to reduce safety risks associated with 

crossings. Furthermore, as state in Section 4.14.4 of the EA, FRA and WSDOT would continue the 

Operation Lifesaver program training on track safety for community members and continue to work with 

communities to ensure there are safe routes that avoid the illegal use of the railroad right-of-way for 

pedestrians and non-vehicular travel. 

Response to Comments from Bill Palmanteer, October 25, 2012 Commenter ID #056

Response to Comment 056-1 

Proposed signal improvements and rail operations planning as detailed in the Traffic and Transportation 

Discipline Report (Appendix F of the EA) would reduce risks associated with at-grade crossings. A 

Safety and Security Plan is being developed by WSDOT and will be finalized prior to the Cascades 

becoming operational on the Point Defiance Bypass route. 
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COMMENTS FROM MATTHEW RUDOLF, NOVEMBER 9, 2012 – COMMENTER ID #057

 
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Response to Comments from Matthew Rudolf, November 9, 2012 Commenter ID #057

Response to Comment 057-1 

As described in Section 4.3.2 of the EA and Appendix F of the EA, the Coast Starlight train would extend 

beyond the existing station platform and across East C Street and East D Street for approximately 6 

minutes. Coast Starlight trains arrive and depart during non-peak periods. These arrivals and departures 

may coincide with Tacoma Dome events. The temporary blockage of these two streets would result in a 

decline of LOS to below LOS D during an event at the Tacoma Dome (see page 4-13 of the EA for 

definition of LOS D). Minimization of operational effects (Section 4.3.4 of the EA) on traffic as a result 

of the Coast Starlight dwell time at Freighthouse Square, and during a Tacoma Dome event, would 

include implementation of a detour plan that could include static signs identifying the detour routes, 

dynamic message signs that identify the detour routes during a train blockage, lane striping and controller 

modification. With the detour signage in place, LOS would not go below LOS D. During final design, 

WSDOT will continue modeling and coordination efforts with the City of Tacoma to identify refinements 

of the suite of minimization measures, as noted above. 

Response to Comment 057-2 

As described in Section 4.3.3.2 of the EA and the Traffic and Transportation Discipline Report (Appendix 

F of the EA), the proposed Freighthouse Square station would provide the same or more parking spaces 

than are currently available at the Tacoma Amtrak Station. Parking would be located on a parcel near 

Freighthouse Square (see Section 3.2.4 of the EA) that either has parking available for lease or purchase 

by WSDOT and developed into a parking lot for exclusive use by Amtrak passengers. In addition to this 

proposed parking, there would be some available on-street parking near the station (see Section 4.3.3.2 of 

the EA). 

The Tacoma Dome Area Plan was reviewed as part of the Project. As discussed in Section 4.13.3.2 of the 

EA, the Project is consistent with adopted plans and would implement policies adopted by the City of 

Tacoma. No policy was found that would cause the Project to be inconsistent with these adopted plans 

and regulations (see Section 4.13.1 of the EA). Based on this review, the Project is consistent with the 

comprehensive plan and zoning regulations adopted by the City of Tacoma and is not inconsistent with 

the Tacoma Dome Area Plan. 

WSDOT will continue to work with the City of Tacoma and Sound Transit during final design of the 

Project. 

Response to Comment 057-3 

As noted in EA Section 4.2.3.2, the increased noise levels would be caused by new warning devices at 

signalized at-grade crossings. Warning devices such as wayside horns must be heard to be effective and 

therefore volumes cannot be reduced. However, no wayside horns are proposed through Nalley Valley. 

In addition, under the proposed Amtrak Cascades and Coast Starlight schedule, there would be no train 

noise effects during normal sleeping hours (10 p.m. to 7 a.m.). 

It should be noted that Quiet Zones are initiated by localities. The process to establish new Quiet Zones 

can be found on the FRA webpage at http://www.fra.dot.gov/rpd/freight/1318.shtml. 

Local public authorities may designate or request approval of, quiet zones in which train horns may not be 

routinely sounded (local public authorities are those that are responsible for traffic control or law 

enforcement at the highway-rail grade crossing). The details for establishment of quiet zones differ 

depending on the type of quiet zone to be created (Pre-Rule or New) and the type of safety improvements 

implemented (if required). In general, the process starts with selection of the crossings to be included in 

the Quiet Zone. Once selected, the conditions of the crossing are documented. The Quiet Zone Calculator 

is then used to determine whether the Quiet Zone Risk Index of the proposed Quiet Zone is less than or 
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equal to the Nationwide Significant Risk Threshold (NSRT). If it is greater than the NSRT, then 

supplementary or alternative safety measures must be used to reduce that risk to fully compensate for the 

absence of the train horn or to reduce risk below the NSRT. The analysis above is submitted with an 

application to FRA Office of Railroad Safety for approval. 

 
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COMMENTS FROM PETER ZAHN, NOVEMBER 9, 2012 – COMMENTER ID #058
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Response to Comments from Peter Zahn, November 9, 2012 Commenter ID #058

Response to Comment 058-1 

Decisions to add Freight traffic is independent of the Sound Transit and Amtrak service along the Bypass 

route. Sound Transit, as the owner of the majority of the corridor, cannot prohibit freight use but does set 

the terms and conditions for any freight use of their infrastructure. The operations of the freight will 

continue to be directed by Tacoma Rail and BNSF. 

There would be no change to the operation of freight trains on the Point Defiance Bypass route under the 

Build Alternative (EA Section 3.2.5). Tacoma Rail and BNSF would continue to operate as many as two 

trains per day on some portions of the Point Defiance Bypass route to as few as two trains per week on 

other portions of the Point Defiance Bypass route. BNSF would continue to operate intermittent freight 

trains on the Point Defiance Bypass route to serve military transportation needs at JBLM. The Project 

would not enable freight traffic to move beyond the East “D” Street and Tacoma Avenue Overpass due to 

existing grade restrictions and Sound Transit running rights. The operations of the freight (including 

freight speeds) will continue to be directed by Tacoma Rail and BNSF. 

Response to Comment 058-2 

Overall, traffic effects of the Proposed Build Alternative would be minimized by proposed signal 

improvements and would not be substantially different from conditions under the No Build Alternative. 

Details of anticipated traffic effects of the Build and No Build Alternative are presented in detail in the 

Traffic and Transportation Discipline Report (Appendix F of the EA). Appropriate measures to further 

minimize identified impacts are described in Section 4.3.4 of the EA. 

Response to Comment 058-3 

The Traffic and Transportation Discipline Report (Appendix F of the EA) documents the general 

assumptions, methods, and results of the traffic analysis. This information was shared with local 

stakeholders during the Technical Advisory Group meetings to solicit input on assumptions and methods, 

and review the results. During the final design and the associated permit process, additional coordination 

with the City of DuPont would occur. 

Response to Comment 058-4 

Noise barrier placement is not feasible because openings in the walls would be needed for roadway 

crossings. Noise barriers could also create vehicular sight-distance hazards (see page 55, Noise and 

Vibration Discipline Report, Appendix E of the EA). Section 4.2.3.2, Noise and Vibration, of the EA 

notes that that noise effects to sensitive receptors would not be significant and no mitigation is required. 

Fencing locations and type will be determined during final design in collaboration with Sound Transit. 

The fencing and barriers currently in place are adequate and sufficient for the currently planned level of 

service of Sound Transit. 

Response to Comment 058-5 

The City of DuPont City Hall location in the EA is incorrect and the error is noted and included in the 

revised EA. The area land uses are summarized in the EA Section 4.13.2. Supporting material, including 

current development zoning descriptions, are in the Land Use Discipline Report (Appendix O of the EA). 

Dental offices and hotel facilities are typically private businesses and included in the general 

characterization of commercial areas. Since they are not classified as public facilities or services they are 

not shown on Figure 15 in Section 4.14.2 of the EA. Barksdale Avenue crossing was evaluated for traffic 

effects in the Traffic and Transportation Discipline Report (Appendix F of the EA) and noise effects in 

the Noise and Vibration Discipline Report (Appendix E of the EA). The location of City Hall in relation 

to the Barksdale Avenue crossing does not change the impact evaluations completed for that intersection. 
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Response to Comment 058-6 

Chapter 4.16.2 of the EA, Cumulative Effects, includes a list of current and reasonably foreseeable future 

transportation related projects. In addition, Page 4-69 explains that FRA and WSDOT considered the 

prior studies related to Joint Base Lewis McCord and the projects outlined in the Grow the Army Final 

EIS and other decision documents. This specific project was not included in Table 17 in the EA under 

known local and regional roadway improvements. This project has been added to Table 17 in the EA and 

does not change the analysis or conclusions described in the EA. 

Traffic studies conducted for the Point Defiance Bypass Project were informed by the Technical Advisory 

Group (which City of DuPont participated in). The potential for a new JBLM access control point at 

Wharf Road was mentioned by the City of DuPont during the October 2011 facilitated review of the 

Traffic and Transportation Discipline Report. The JBLM project was not included in the traffic analysis 

because at the time, it was considered speculative and JBLM/Department of Defense had not issued a 

notice of intent or other formal notice to stakeholders that an EA was being prepared. Subsequent 

qualitative analysis of the Wharf Road access control point (ACP) EA indicates that this ACP is located 

off the Steilacoom-DuPont Road into the Lewis North portion of JBLM. As part of Appendix C of the 

JBLM Lewis North Access Control Facility Traffic Study (prepared by Black & Veatch dated September 

7, 2011), the redistribution of vehicles was determined by an Origin Destination Analysis for the roadway 

network as a result of the new ACP at Steilacoom-DuPont Road. Based on this analysis, an additional 

135 vehicles will take the southbound I-5 off-ramp at Barksdale and an additional 129 vehicles will take 

the northbound I-5 off-ramp at Barksdale to use the new ACP. In total, 264 additional vehicles will divert 

to the Barksdale interchange in order to access the new ACP. Ultimately, according to analyses made as 

part of the JBLM EA for the new ACP, channelization lanes would be added at the DuPont-Steilacoom 

and Barksdale Avenue intersections, which would result in overall intersection operations of LOS C. 

Coupled with the Point Defiance Bypass project and the improvements proposed at Barksdale Avenue as 

part of the project, significant effects would not occur at this location. Nonetheless, WSDOT and FRA 

would continue to work with the City of DuPont and JBLM to evaluate the coordination of intersection 

improvements at this location as part of the final design effort, and as part of the larger planning studies 

being conducted for I-5 interchanges by WSDOT. 

Response to Comment 058-7 

Data and methods, including collection of traffic data and analytical tools and methods, are documented 

in Chapter 2 of the Traffic and Transportation Discipline Report (Appendix F of the EA). This 

information was shared during the Technical Advisory Group meetings to solicit input on assumptions 

and methods, and review the results. During the final design and the associated permit process, additional 

coordination with the City of DuPont would occur. 

Response to Comment 058-8 

As described in the Grade Separation Concept Evaluation (Appendix B of the EA), some concepts have 

rail under the roadway while others have rail over the roadway. As the concept evaluation proceeded, a 

host of factors were considered when deciding whether to elevate the roadway or trench it, or to elevate or 

trench the rail bed. These factors include maintaining a reasonable rail grade before and after the grade 

crossing (approximately 2% or less), clearance at structures, underground utilities, and groundwater, as 

well as the acquisition of adjacent properties that would be required to accommodate the grade separation, 

roadway structures and slopes. 

The Grade Separation Concept Evaluation Report revealed that current and projected future traffic 

volumes do not warrant the construction of new (or modified) grade-separated crossings. The report 

found that the construction and operation of grade-separated crossings would result in significant 

environmental impacts to the surrounding community (e.g., noise, property acquisitions, visual impacts 

from retaining walls, and the increased perception of community isolation, particularly in Tillicum). 
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However, the construction of the Build Alternative would not preclude the future construction of gradeseparated crossings within the Project Area. 

 
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COMMENTS FROM MIKE GREEN, NOVEMBER 2, 2012 – COMMENTER ID #059

Response to Comments from Mike Green, November 2, 2012 Commenter ID #059

Response to Comment 059-1 

Amtrak would utilize the existing trains that are used on the current Puget Sound route. 

Motive power needs will be evaluated during the testing phase that will precede Amtrak operations on the 

Point Defiance Bypass route. Sound Transit tested Sounder extensively with multiple train configurations 

and multiple runs. WSDOT/Amtrak will do the same prior to the Point Defiance Bypass route becoming 

operational. This analysis will determine if a helper engine will be required. 

 
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COMMENTS FROM JOHN MOUNTS, NOVEMBER 9, 2012 – COMMENTER ID #060
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Response to Comments from John Mounts, November 9, 2012 Commenter ID #060

Response to Comment 060-1 

WSDOT is planning to conduct a load-rating analysis as part of the Final Design portion of the Point 

Defiance Bypass Project. If required, necessary structural upgrades will be implemented prior to Amtrak 

operations over the bridges. 

 
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COMMENTS FROM BRANDON ARENAS, NOVEMBER 21, 2012 – COMMENTER ID #061
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Response to Comments from Brandon Arenas, November 21, 2012 Commenter ID #061 

Response to Comment 061-1 

Once approved, WSDOT intends for this to be the permanent intercity rail service route for Amtrak 

Cascades service. 

Response to Comment 061-2 

If the project is approved, the rail crossing at Clover Creek Drive Southwest would be improved with the 

following features: 

 Crossing gates and flashing lights 

 Median barriers 

 Wayside horns 

 Related rail safety signage 

 
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COMMENTS FROM THOMAS CORNILLIE, NOVEMBER 26, 2012 – COMMENTER ID #062

Response to Comments from Thomas Cornillie, November 26, 2012 Commenter ID #062

Response to Comment 062-1 

In Chapter 2 of the Energy Discipline Report (Appendix Q of the EA), it notes that operational energy use 

was estimated from train fuel efficiency information prepared as part of the Pacific Northwest Rail 

Corridor (PNWRC) Washington State Segment – Columbia River to the Canadian Border, Program 

Environmental Assessment (EA) (WSDOT, 2009). In the PNWRC EA, page 5-26 and in Table 13, fuel 

consumption was calculated for the Amtrak Cascades rail passenger service on a daily, gallon, and trip 

basis. The Point Defiance Bypass Project energy analysis focused on the Cascades service because it is 

the service being added as a result of the Project.