REGION X	 915 Second Avenue U.S. Department Alaska, IdahG, Oregon, Federal Bldg. Suite 3142
 

of Transportation Washington . Seattle, WA 98174-1002
 

206-220-7954
 Federal Transit 206-220-7959 (fax). Administration 

March 26, 2009 

Joni Earl 

Executive Director 

, Sound Transit
 

401 South JacksonSt.
 

Seattle, WA 98104-2826
 

RECEIVED: 

MAtt ii rJ REC'O 

. SOLWDTRANl!IT 

EXEcunvr: DEPARTMENT 

Re:	 Tukwila Commuter Rail Station Project 

Finding of No Significant Impact (FONSI) 

Dear Ms. Earl: 

The Federal Transit Administration (FTA) has completed its review ofthe NEPA Environmental 

Assessment(EA), January 2009, for the Tukwila Commuter Rail Station Project. Based on our' 

review, FTA has issued a Finding ofNo Significant Impact (FONSI) for the project. A copy ofthe 

FONSI is enclosed. 

.The FONSI, EA, and all rela.tedsupporting materials should be made available to the public, with 

notice of availability published in one or more newspapers of general circulation. Notice ofthe 

FONSI's availability should also be sent to the agencies on the EA circulation list. Please note that 

if a construction grant is approved for this project, the standard terms and conditions ofthe FTA 

grant contract will require the granteeto undertake all environmental mitigation measures 

identified in Appendix B of the FONSI. 

Thank you for complying with the National Environmental Policy Act. Please contact John 

Witmer at (206) 220-7964 if you have any questions. 

:;;;~~ R.F. Krochalis
 

. Regional Administrator
 

Enclosure . 

CC:	 Steve Kennedy, ST
 

Paul Cornish, ST
 
Tukwila Commuter Rail Station Project 

Finding of No Significant Impact 

(FONSI) 

And Other Determinations of Environmental Compliance 

March 2009 

Issuing Agency 

Federal Transit Administration 

Prepared in compliance with the National Environmental 

Policy Act (NEPA) 42 USC §4321).and FTA Environmental 

Impact and Related PrQcedures (49'CFR §622) and 

related guidance; and Council on Environmental Quality 

(40 CFR parts 2500-1508) and related ame~dments and 

Executive Orders. 

IRjlSouNDTRANSrr 

A u.s. OflpartmentofTranSportation W Federal Transit Administration 
, ,Tukwila Commuter Rail Station Project
 

Tukwil,a, King County, Washington
 

Finding of No Significant Impact 

By the 

u.s. Department of Transportation 

Federal Transit Administration 

The Federal Transit Administration (FTA) has determined, in accordance with 23 CFR . 

§771.121, thatthe proposed project will have no significant adverse impacts.ontheenvironment. 

This Finding ofNo Significant I~pact (FONSI) is based on'the Environmental Assessment (EA), 

issued in January 2009 and incorporated by reference, other documents and attaclnnents as' 

itemized iIi this FoNSI and the findings herein. The EA and these other documents have been' 

independently evaluated by the FTA and determined to accurately discuss the project purpose, 

need, environmental issues, impacts ofthe pr~posed project, and appropriate mitigation 

measures. It provides sufficient evidence and 'analysis for determining that an Environmental 

Impact Statement is 'not required. 

'Date----------­
·. 

Finding of No Significant Impact'(FONSI) for 

TukWila Commuter Rail Station Project 

Table of Contents 

Finding ofNo Significant Impact 1
 

and Other Determinations of Environmental Compliance 1
 

Proposed Project 1
 

Project Development, Agency Coordination and Public' Opportunity to .Comment 3
 

Comments on the Environmental Assessment.........•.................................. 4
 

M. Itlgatlon ·· · M' easures to M'l~mlze ·
 · Hartn. '.' . 5
 

Detenn.ination an.d Findings 5
 

Farmland Findings ..........•.................................................................................................... 9'
 

Floodplain' Findings ·10
 

Environmental Finding .........................•......... ..........................................................•................ 11.
 

Section 106 Compliance 6
 

Sectio!l 4(f) Findings 7
 

Endangered Species Act Findings 7
 

Magnuson-Stevens Act Finding 8
 

Conformity with Air Quality Plans ..........•.................................. .......•.... 8
 

Environmental Justice Findings 10
 

Wetlands Findings 11
 

Appendix A Written Comments and Responses 

Appendix.B Mitigation Commitments 

March 2009 Page i
 
FEDERAL TRANSIT ADMINISTRATION
 

REGION 10
 

FEDERAL TRANSIT ADMINISTRATION
 

WASHINGTON DIVISION
 

. Finding of No Significant Impact 

and Other "Determinations of Environmental Complia'nce i 

Tukwila Commuter Rail Project
 

Sound Transit
 

Tukwila, King County, Washington
 

Proposed Project 

·Sound Transit is proposing to replace a temporary Sounder commuter rail station in 

Tukwila, Washington with apermanent station known as the Tukwila Commuter Rail 

, Station Project (the project). The project is l~cated south of Interstate 405 (1-405). and 

eastof State Route (SR) 181 (West V.alley Highway), on undeveloped land- extending 

from the east margin ofthe Burlington Northern Santa Fe (BNSF) right-of-way (ROW) 

to the.west margin ofthe Union Pacific Railroad' (UPRR) ROW. The north end.ofthe 

proposed station platforms would be approximately 700 feet south'ofLongacres Way (a 

private road), and the ,south end ofthe sit~ would be near the planned eastward extension 

of Strander Boulevard, as proposed by the City of Renton. The site (rontson Longacres 

Way, with approximately 500 linear feet of frontage including the BNSF and UPRR 

ROWs. 

The project is part ofSound Move, Sound Transit's 10-year'Regional Transit Plan, andwas evaluated in a' 1998 Environme~tal Assessment. The need for the January ~009'

Envirolunental Assessment is the result of design changes made to better a~commodate

future rail and traffic needs of the area. Specifically, changes from the previous 

Environmental Assessment include accommodating the UPRR Re,alignment Project 

proposed by the City of Renton, reducing parking needs, and locating the station , 

platforms approximately 700 feet further south. The proposed changes to the design of 

the permanent station were made' in respon~e to a better understanding ofthe ~xpected

use of this. station, made possible by operating a temporary platform at the site for several 

years,as' well. as the completion of planning for the Strander Boulevard Extension and 

UPRR Realignment projects proposed by the 'City of Renton. 

The proposed station would replace the temporary station, which includes minimal 

commuter amenities and is located adjacent to the north and east of the project site. 

Parking for up to 222 vehicles is provided at the temporary station. 'The existing Tukwila 

Commuter Rail Station was built as a temporary station in order to provide service to the 

March 2009 P,age 1 
area while planning for a permanent stati9n could proceed. The temporary station is 

nearing the end of its anticipated lifespan, and was'not built to accommodate future 

ridership levels. As part of the Tacoma-to-Seattle Commuter Rail Project, a permanent 

station with new parking, bus, ticketing and other facilities will be built on the west side 

of the BNSF tracks, west and south of the temporary station. Construction of the 

Tukwila Commuter Rail Station is expected to begin in 2010 and be completed by 201 J. 

The proposed project,includes the following components: 

•	 350-Space Parking Facility. 'The parking area would b~ located west ofthe proposed 

station platfo'nns at the south end of the site and north of the proposed Strander 

Boulevard'extension. The parking facility would provid~ surface parking for up to . 

350 vehicles. An additiona~ area is included in the site plan for another 40 parking . 

spaces for potential Amtrak use. These parking spaces, while not a part ofthe Sound 

Transit project, could potentially be constructed at a future time ifAmtrak desires to 

proceed with these improvements, and adequate funding is secured. The proposed 

parking lot for the .350 spaces would be approximat~ly700 feet long.by 200 feet 

wide, ~d would connect to Longacres Way via the Western Access Road on'the 

northwest side ofthe 'lot. The area for the potential future Amtrak parkirig spaces 

would be, approximately 110 feet 10lJ.g by 40 feet wide. The existing parking lot, 

which has, been leased from the Boeing Company, will remain but will not be part of 

the statio~ parking. . . 

•	 Station Platforms. The proposed platforms for the Tukwila Commuter Rail Station 

would be consistent with future p~ans for all Tacoma~to-Seattle Sounder stations, and 

sufficient to accommodate the projected needs of both Sounder and Amtrak. The 

current design includes two 16-foot platforrils of up to 700 feet..in length, located at 

th~ south end of the site on the east.and west sides ofthe BNSF tracks. Platforms 

would be constructed to' accommodate people with disabilities, similar to other 

Sounder stations, with "mini-high" platforms that are designed to ease access to 

passenger trains while still accommodating the need for freight trains. to pass through 

the station unobstructed. The platforms ofthe existing temporary station would be 

removed after the permanent statipn is completed. 

•	 Transit and Non-vehicular Access. 'Bus transit service would be accommodated by . 

-	 transit-only lanes, and a boarding and layover zone that would, include awaiting 

shelter. Pedestrian amenities would include sidewalks leading to all parts ofthe 

station and parking lot, 'wheelchair-accessible ramps connecting betwee~ the 

platforms and ground-level faciliti~s, and apedestrian Underpass connecting the 

parking lot and the station platforms. (The portion of the pedestrian way that passes 

wider the UPRR tracks would'be constructed as part ofthe UPRR Realignment 

Project.) 'Bicycles' would use surface streets or sidewalks to arrive at the' Site along 

the same routes as vehicles, primarily from Longacres Way. In addition to 'the 

Western Acc'ess Road, therew9uld be a 12~foQt wide path for non-motorized vehi~les

and pedestrians connecting the station to Longacres Way. It is approximately 250 feet 

from the' Interurban Trail (a multi-purpose path for non-motorized travel) to the 

proposed Western Access Road along Longacres Way, and an additional 150 feet to 

Ma'rch 2009	 Page 2 
the muitipurposepath. The, frontage on Longacres Way would also be improved. 

with sidewalks and street trees per City of Tukwila requirements. 

•	 Vehicular Access. Vehicle access to the station would be via the Western Access 

Road, which would connect to Longacres Way. CUrrently, access to the.temporary 

Tukwila Commuter Rail Station is via Longacres Way. Vehicles pass under both the 

'UPRRand BNSF tracks to aiTive at the parking area, which is located east ofthe 

BNSF· tracks. Under the proposed plan, Longacres ways' would ,still pass under the 

railroad tracks, but most vehicles arriving at the site would likely arrive from the west 

and would not have to cross under any tracks to arrive at the station, since the UPRR 

tracks are anticipated to have been relocated by the start of station operati~n. . 

•	 Stonnwater Treatment and Detention,Facility. A stormwater treatment and detention 

facility is proposed to be located at the north end ofthe parking· lot. 

•	 Amenities. The project includes a broad plaza crossing the parking lot east to west at 

.its .midpoint..Other features and amenities would include ticket vending machines, 

bicycle lockers and racks, seating, informational and wayfmding signs, a guard 

station, and pUblic art. Although Amtrak is not a sponsor ofthis project, the design 

evaluated in the'anuary 2009 EnviroIimental Assessment is intended to 

accommodate potential future .Amtrak parking. and facilities ·associated with the.' . 

Tukwila Commuter Rail Station project. Anticipated elements'for Amtrak's use of 

the site in the future, including'long-term parking, lighting, shelter, and ticketing 

f~cilities, are evaluated in the January 2009 NEPA Environmental Assessment. ' 

•	 Future Development. Potential future development at the site could include the , 

potential additional 4·0 layover and/or overnight parking stalls for'Amtrak customers, 

pedestrian connections to both the West Valley Highway and the Interurban Trail, ' 

and a street co~ection to the planned eastward. extension ofStrander Boulevard. 

These improvements are not a part ofthe proposed Sound Transit project. Because, 

funding fo~ these elements is uncertain, there is no schedule available at this time for 

their completion. . 

Project Development, Agency Coordination and Public Opportunity to Comment 

A Technical Advisory Committee (TAC) was fonnedtofacilitate a collaborative effort 

between stakeholders and Sound· Transit d~ng the Preferred Alternatives Analysis and 

Project Sequencing design phase. The TAC included representatives from City of 

TUkwila, City of Renton, King County Metro (Metro Transit),.Washfngton State 

Department of Transpo~ation(WSDOT), and Amtrak. 

In. addition to these key stakeholders, significant ,input to the process was received from 

BNSF, UPRR; Amtrak, and Boeing. Additional coordination meetings were held with 

the major utilities within the project site. An Executive Advisory Committee (EAC) was 

formed to advise Sound Transit, the TAC, participating agencies, andthe design team. 

EAC members included Peter Hahn, the City of Renton; Jack Pace,'the City of Tukwila; 

March 2009	 Page 3 
and. Vicki Yourigs, Sound Transit. The EAC was merged with the TAC during the 30% 

design phase. The·TAC/EAC process is described in detail in Section 5.5 ofthe EA. . 

In addition, Sound Transit has attended and presented information in 'Tukwila during 

'several public meetings 'regarding improvements at the.existing Tukwila Station, 

including the following: 

•	 December 3, 2007 and December 10, 2007 - meetings with Tukwila City Council 

about the temporary station and updates on the permanent station. 

•	 June 3,2008 - meeting with.Tukwlla Art Commission regarding public art at the 

temporary station and a status report on the permanent station. . . 

A public open, house on the Tukwila Coinmuter Rail Station project and NEPA 

Environme'ntal Assessment was held January 29, 2009. 

Trib.al involvement included ~ailing a "notice of undertaking" letter forthe Tukwila 

.Commuter Rail Station Project on September 3., 2008 to the following tribes: 

Confederated Tribe ofthe Colville Reservation, DuwamishTribe, Muckleshpot Indian 

Tribe ofthe Muckleshoot, Puyallup Tribe ofthe Puyallup Reservation, Snoqualmie Tribe, ' 

and Confederated Tribes and Bands ofthe Yakama. The letter also included a request to 

tribes about their interest in further consultation. To date, the only response from tribes 

has been from Karen Walter ofthe Muckleshoot Indian Tribe Fisheries Division. FTA· 

and Sound Transit sent Ms. Walter information in December 2008 on the project 

regardingbiologicaVwetlands and water resources impacts and proposed'mitigation. A' 

copy ofthe NEPA EA was sent to each ofthese tribes to provide further opportunity to 

comment. 

In addition, Sound Trans~t'consultedwiththe Washington ,State Department of . 

Archaeology and Historic Preservation on potential impacts to.·c~ltural ~d histpric 

resources. 

Section 5.3 in the EA further describes Agency' and public coordin~tion.

Comments 'on the EA' 

Sound Transit received three written'comment e-mails and letters in response to the EA,
 

including comments from theMlickleshootTribe~ Puget Sound Energy, and a joint letter
 

from the Cities of Tukwila and Renton.
 

Approximately 23 people attended the Janu~ 29, 2009 EA Public Open House. None 

ofthose attending provided written or formal oral comments onthe EA. Several . 

supportive statements w~re made infonnally, and several individuals asked clarifying 

questions about the plans and the design process that can he expected~

March 2009	 P~ge4·
Responses were prepared to all written comments and are included as Appendix A ofthe 

FONSI. The project~related issues identified in the comments included the following 

topics: 

• Impacts to. wetlands and fish habitat 

• Utility impacts and access for maintenance .­

• Parking demand and potential mitigation 

• Construction traffic impacts on roads 

• Off-site amenities (sidewalks, lighting, drainage, landscaping and roadway up.grades) 

• Bike and pe·destrian safety 

• Compliance with noise regulations 

• Safety and security 

• Public restrooms 

• Compatibility with pl~ed and future land uses 

• Hazardous materials 

• Access to' the site from the east (Renton) 

Mitigation Measures to Minimize Harm 

, , 

Appendix:C describes the mitigation measures that are required ofSound Transit as 

c~nditions ofthis FONSI,. These mitigation commitments are based on the pote~tial

mitigation measures.identified in the EA and the mitigation measures required ,for, .. 

compliance under the E~dangered Species Act. FTA.finds that with the accomplishment 

ofthese mitigation commitrn.ents, Sound Transit will have taken all teasonable, prudent, 

and feasible means to avoid or minimize significant impacts, if any, from the proposed ~&a .. 

Determination and Findings 

National EnvironmentalPolicy Act (NEPA) Fih!ling 

FTA served as the lead agency under NEPA for.this project.· Sound Transit prepared the 

EA incompliance with NEPA, 42 U.S.C Sections 4321 et. seq., and with FTA's 

regulations,23 CFR Part 771. FTA has made an independent evaluation ofthe EA. The 

.EA discusses the potential impacts ofthe project so that. FTA can determin~ whether 

significant adverse impacts (CEQ §1508.27) are. probable. Ifsuch'a determination were 

,made, an Environmental Impact Statement would need to be prepared. 

Sound Transit has incorporated environmental considerations into its study of project 

alternatives and has conducted evaluations ofthe project's potential environmental 

impacts. The EA was issued in January 2009. The EA foundthat the project's 

construction and operation would cause no significant 'adverse. environmental effects that ' 

would not be mitigated. This finding applies to all applicable environmental elements, 

including Land Use, Transportation, Social and Economic Impacts, Biological Resources, 

Water Quality and Hydrology, Vil;>ration and Noise, Air Quality, Historic and 

March 2009 
Archeological and Cultural Resources, Visual Quality and Aesthetics, Geology and Soils, 

Utilities and Public Services, Safety and ·SecuritY,·Energy, and Hazardous Materials. 

. . 

.After carefully considering the EA, its supporting doclIDlents, and the public comments 

and responses, FTA finds.under 23 CFR §771.121.that the development and 

operation of the proposed project, with the mitigation to which Sound Transit has . 

committed to implement as part of the project, will have no significant a4verse 

impacts on the environment. The record provides sufficient evidence and analysis for 

determining that an environmental impact statement is not required. 

Section 106 Compliance. 

Section 106 ofthe'National Historic Preservation Act of 1966, as amended, requires the 

review of federally.assisted projects for impacts to districts, sites, buildings., structures, 

and objects listed.in, or eligible for inclusion in, the Nati.onal Register ofHis~oric Places. 

Federal agencies must coordinate with the State Historic Preservation Office (Sl!PO) and 

potentially affected tribes to make this detennination. The Advisory Council on Historic 

Preservation has established procedures for ·the protection of historic and cultural 

'properties in, or eligible for, the National Register (36 CFR Part 800). 

No potentially significant resources were identified during field recomlaissance, and'no. 

archaeological sites have'been recorded within the project site.area. No existing 

structures ofhistoric significance would be affected by the project. Records at the. 

'Washington State Department ofArchaeology and Historic Preservation (DAHP) were 

reviewed on July 31, 2008 to detennine proximity of archaeological or cultural resoUrces 

, eligible for listing in the National Register ofHistoric Places (NRHP}within the project 

Area ofPotential Effect (APE). No resources were, identified. 

As part of early coordination and Section.106 consultation with· tribes; Written contact 

was made with the Confederated Tribe of the Colville Reservation, Duwamish'Tribe~

Muckleshoot Indian Trib~, Puyallup Tribe ofthe Puyallup Reservation, Snoqualmie 

Tribe, and Confederated Tribes and Bands ofthe Yakama. None ofthe tribes expressed 

any concerns about cultural resource~.

In additionto'consultation with potentially affected tribes, FTA coordinated and 

consulted with the DAHP under Section 106 ofthe National Historic Preservation Act. 

In Washington State, DAHP serve~ as the SHPO. On November 25, 2()08a letter was 

s~nt to DAHP fr<?m FTA requesting concurrence with FTA's determination that no 

historic prop~rtiesor cultural resources would.be affected by the project. OnDecember 

10,2008, FTA received a letter from DAHP concurring with the concll:lsion.thatthe. 

project would have no effect on historic or cultural resources listed in or eligible for 

listing in the National Register of Historic Places.DAHP agreed with measures proposed 

by Sound Transit to protect any potential undis~overed cultural resources by 'having a 

professional archaeologist on-site'to monitor excayations, and preparation of an 

inadvertent discovery plan prior to construction. 

March 2009 Page 6 
Based on the cultural resources analysis included in the Environmental Assessment and 

coordination with tribes and DAHP, FTA finds that the project will have no adverse 

e(fect on any'identified or likely 'cultural or historic resources, and that the Section 

106 consultation .requirements for this project have been fulfilled. . 

Section 4(1) Findings 

Section 4(f) of the United' States Department of Transpot1ation (USDOT) Act of 1966, 

cpdified at 49'U.S.C. §303, declares a national policy that a special ,effort should be made 

to preserve the natural beauty ofthe countryside, public park and recreational lands, 

wildlife and waterfowl refuges, and historic sites. The Secretary of Transportation may 

·.not approve transportation projects that require the use ofpublicly .o~ed land of a public 

park, recreation area, or wildlife or waterfowl refuge of national, state or local 

significance, or land.of an historic site of national, state. or local significance (as. 

determined by the Federal, State or local officials having jurisdiction over the park, area, 

refuge or site) url1ess a d~terri1rnation is made that: (i) .there is no feasible and prudent 

alternative to the use ofthe land; and (ii) the action includes all possible planni~g to . 

minimize harm to the property resulting from such use (23 CFR§771.135). 

T~e existence ofpotential Section 4(f) resources was evaluated as part ofthe EA. FTA . 

~nds'that the proposed project will not use or significantly impact any park, 

recreatio.nal, or oth'er re.sources protected by Section 4(t) of the USDOT Act of 1966. 

Endangered Species Act Findings 

The Endangered Species Act of 1973 (ESA), as amended, is inte~ded to protect' 

threatened and endangered species and the ecosystems.on which they depend. The ESA 

requires a federal- agency to ensure th~t any action -it authorizes, funds, or carries out is 

not likely to jeopardize the continued existence of any listed species or result in direct 

mortality or destruction or adverse modification of critical habitat oflisted species. This 

.requirement is fulfilled under Section 7 o'fthe ESA by a review ofthe proposed actions 

~dconsultation with the appropriate agency responsible for the conservation ofthe 

affected species. Ifnecessary, mitigation would be required to avoid jeopardizing listed 

. species or their habitat. 

Both the National Marine Fisheries Service (NMFS)and the US'Fish and Wildlife 

Service (USFWS) provided listings ofthreatened and endangered species under their 

jurisdiction (see enclos~d lists). The current listings from NMF'Sindicate the'potential 

presence ofthe Puget Sound Evolutionary Significant Unit (ESU) ofChinook salmon 

(Oncorhynchus tshawytscha) and Puget SO'undDistinct Population Segment (DPS) , 

steelhead (Oncorhynchus mykiss) within the project area. Additionally, the USFWS lists 

CoastallPuget Sound DPS bull trout (Salvelinus confluentus), marbled murrelet 

(Brachyramphus marmoratus), northern spotted owl (Strix occidentalis caurina), gray 

wolf (Canis lupus), giizzly bear (Ursus horribilis), Canada lynx (Lynx canadensi), marsh 

sandwort (Arenaria paludicola) and golden paintbrush (Castilleja levisecta) as having the 

potential to occur.within King County, Washington.. Critical habitat has been designated 

March 2009 .Page 7 
for Puget·Sound ESU Chinook salmon and Coastal/Puget Sound DPS bull trout within 

the mainstem ofthe Green River, which is located within the general project vicinity. 

The potential presence of listed species within the project area was further evaluated by 

reviewing' Washington Department of Fish and Wildlife (WDFW) Priority Habitats and 

Species (PHS) data, WDFW Wildlife Heritage data set, WDFW Stock Inventory Data, 

and the Washington Department ofNatural Resources (WDNR) Natural Heritage 

Program rare plant. species database. 

.There is one wetland that would be filled by this project, and it is of low quality and is 

not directly connected to ~y fish bearing streams. Best management practices will be in 

place for construction, permanent stormwater facilities will provide treatment of new 

pollution-generating impervious surfaces"no in-water work is proposed, and the nearest· 

fishb~aring stream is approximately mile from the project area. Therefore, FTA has', ' 

determined that the proposed action would have no effect on Puget SoundESU 

Chinook salmon, CoastallPuget Sound DPS bull t~out or Puget So'und DPS 

steelhead. FTA has also determined that the proposed project will not destroy or 

adve'rsely modify designated'critical habitat for Puget ,SoundESU Chinook salmon 

or Coas,tallPuget Sound DPS bull trout. 

The project site does not include suitable habitat 'for the other listed species, therefore 

FTA has determined that the proposed action'would have no,effect on those species. 

Magnuson-Stevens Act Finding 

Under the Magnuson-Steyens Fishery Conservation and Management Act (MSA), federal 

agencies are required to consult with·NMFS regarding any oftheir actions or proposed 

actions authorized, funded, or undertaken that may "adversely ,affect" Essential Fish 

Habitat (EFH) as designated by MSA (16U.S.C. §1855 (b)(2». The P~cific Fisheries 

'Management Council h~ designated EFH for the Pacific Salmon Fishery~ Pacific Coast' 

Gtoundfish Fi~hery, and the ,Coastal Pelagic Fishery. To comply with the MSA, a no-' 

effect letter was prepared by Sound TraIisit dated November 6, 2008 and submitted to 

FTA. FTA concurred with the determination of no-effect in a letter to Sound Transit 

dated November 24, 2008. Based on the information provided.in the letter, FTA has 

'determined that the proposed actions of the project will have no adverse effect on 

EFH fO,r Pacific salmon, Pacific coa~t ,groundfish, or Coastal Pelagics. 

Conformity with Air Quality Plans 

Under the 1990 federal Clean Air Act Amendments (CAAA), no federal agency or 

, department may support, license, permit, or approve any activity that does not confortlJ. to 

the state implementation plan (42 U.S.C. §7506(c». Federal agencies are required to 

make aconfonnity determination under the transportation, conformity regulations 

promulgated by EPA (40 CFR §§93.100 to 93.128). Conformity determinations are 

based on quantitative and qualitative assessments of a project's estimated motor vehicle 

emissions,and po'ssible violations ofthe NAAQS standards. For FTA, the federal 

funding agency for this project, to ,make a conformity determination, it must'be 

March 2009 Page 8 
demonstrated that the project will not cause or contribllteto any new violations of the 

NAAQS, increase the frequency or severity of any existing violations or delay the timely . 

attaimnent of the NAAQS. 

Federally-funded transportation projects in non-attainment ~d maintenance areas must 

be consistent with air quality goals and strategies, as described in the State 

Implementation Plan (SIP). The Proposed Action wou~d be located within the Puget 

Sound carbon monoxide (CO) and ozone maintenance area. A transportation conformity'· 

determination for an individual project in thjs area consists oftwo components: the 

.regional emissions analysis of CO and.o2oneand the project-level analysis of CO. The 

regional emissions analysis compares the emissions for all transportation projects in a, 

region and is performed by the regional Metropoiitan Planning Organization, in this case, 

the Puget Sound Regional Co.uncil (PSRC). A transportation project meets the first part . 

ofthe conformity requirements ifit is identified specifically in the current PSRC 

transportation plan and transportation improvement program (TIP), which have been. 

analyzed forregional air quality impacts and been found by USDOT to conform. i 

The Tukwila Commuter Rail Station Project is included in both Destination 2030, the
 

c\lrrent metropolitan transportation plan for the CentralPuget Sound region, and in· the .
 

2007-2010 Transportatiorz Improvement Program. The·PSRC has' modeled the total
 

· r~gional emissions for the plan and TIP, and d'etermined that 'both the plan and TIP 

conform to the current SIP. USDOT 'has concurred in this determination. Because the 

Proposed Action is included in the current conforming transportation plan and TIP, it 

satisfies regional air quality conformity requirements. ' 

A project-level analysis evaluates local CO concentrations 'at signalized i~tersection~ near 

the Proposed Action. Local CO concentrations related to the Tukwila Commuter Rail 

Station project were predicted using approved' regulatory models and protocol. In the 

project's Opening Year (2012), the maximum calculated I-hour C.O concentration is8.1 

parts per million (ppm), which is far less than the 35 ppmNAAQS. The maximum . 

·calculated 8-hour CO concentration is 5.7 ppm, Which is less than the 9 ppm NAAQS. By 

the Horizon Year (2030), maximum calculated.I-hour and 8-hour CO concentrations are 

.9.2 and 6.4 ppm, respectively, assuming non-optimized traffic delays. Again, these . 

concentrations are far less than the 1~hour NAAQS of 35 ppm and the8-hour NAAQSof 

8 ppm. The proposed' action would not increase the frequency or severity of any existing 

violations ofthe CO standard, nor'would it ,create a new violation ofthe NAAQS for CO. 

Therefo;re, itmeets project-level air quality conformity requirem.ents. . 

At both the regional and project level, the proposed Tukwila Commuter Rail 

Station Project is' found to conform to the purpose of the current SIP, ilndtO all 

requirements of the Clean Air Act Amendments of 1990 and the State Clean Air 

Washington Act of 1991.. 

·Farmland Findings' 

The project site may have. suitable s.oils for farming but does not contain active·fanniJ;1g.
 

Although soils may be' suitable, the site. location between rail lines in an urban ce~ter
 

March 2009 Page.9 
makes fanning unlikely to be economical. FTA finds that there would be no adverse 

impacts to agricultural lands caused by the~project.The project would be consistent 

with the Farmlands Protection Policy Act (FPPA) of 1981 (7 U.S.C. §§4201 - 4209) and 

other applicable state and federal fannlands protection policies, orders, and guidance. 

Envir~nmental Justice Findings, 

Executive Order 12898 provides that "each federal agency shallmake ,achieving 

environmental justice part ofitsmission by identifying and addressing, as appropriate, 

disproportionately high and adverse human health or environmental effects ofits 

, programs, policies, and activities on minority and low-income populations," The 

Department ofTransportation's(DOT) Order to ,Address Environmental Justice in 

Minority Populatio'ns and Low-Income Populations similarly' requires agencies to , 

explicitly consider human health~d environmental effects relate'd to'transit projects that 

may have a disproportionately high and adverse effect on ,minority and low-income' 

populations. It also requires them to implement proce,dures to provide "meaningful 

opportunities for public involvement" by members ofthese populations during proJect 

planning and,developmenf(DOT OrderNo,~ 5680.1). The DOT Order. specifically 

provides for the consideration ofmitigation and enhancement measures, as well as 

project.penefits in making detenninations regarding disproportionately high 'and,adverse ' 

, effects on minority and low-income populations. 

The.Environmental Assessment includes an environmental justice analysis in accordance 

with the Executive and the "DOT's Orders. The analysis determined ~hat there are no 

concentrations of minority or low~income households lo,cated close ,enough to the' project 

site to experience p~tential adverse environmental effects of eith~r construction or 

, operation ofthe proposed development. Project impacts are limited in scope and would 

be mitigated through ~he implementation of effective mitigation'measures. Based on the 

analysis ~f environmental justice included in the Environmental Assessment, FTA finds 

that the construction and operation ofthe Tukwila Commuter Rail Station Project ' 

wo~ld not result in disproportionately high and adverse effectson.minority or lowin~ome populations. The broader community of Tukwila" which for King County has a ' 

higher than average representation.ofseveral'ethnic and racial minorities well as a 

lower than average median income level, should benefit from the permanent station and 

the access to commuterrail service, as it provides additional mobility and thus 'access to a 

wider range of employment and housing opportunities. These benefits further support the 

conclusion that no disproportionately high and adverse effects. on 'minority or low.;.income 

populations would result fro~the·project. ' . 

Floodplain Findings 

Pursuant to Executive Order 1198 (Floodplain Management), Sound Transit assessed 

floodplains within the 100-year floodplains and floodwaysdefined by.the Federal . ' 

, 'Emergency Management Agency (FEMA). The.Environmental Assessment found that 

the project is outs~deofthe IOO-year floodplain as defined in the City of Tukwila's 

critical areas regulations, which are based on FEMA Flo'od InsUrance Rate Maps (FIRM) 

currently in effect. However, based on draft Flood Insurance Rate Maps, the project area 

March 200~ Page 10 
is located within the 100-year floodplain of Springbrook Creek. If the draft FIRMs are 

correct, emergency vehicle'traffic and excavation routes could be impacted by floOdip.g, 

and the proposed pedestrian tunilel would be ~safe during a flood event. If the draft 

FIRMs are adopted as part 'of the regulatorycomplianc.e required for the project, 

compensatory floodplain storage would be reqllired to mitigate for floodplain filIon the 

westportion ofthe site. Because the project area is in a developing urban setting and will 

"be required to comply with local regulations regarding floodplains that protect against the 

loss' offlood storage capacity, the additional impact of constructing the Tukwila' 

Commuter Rail Station is not expected to have a significant impact on natural and 

beneficial floodplain values. FTAfinds that compliance with local regulations will 

'ensure that no significant adverse impacts to lOO-yea,r, floodplains or tloodways 

would occur as a result of the proposed project~

Wetla."ds Findings 

The United States Department of Transportation seeks to assure the protection, 

preservation, and enhancement ofthe nation's wetlands to the fullest extent practicable 

during the planriing, construction, and op~ration oftransportation facilities and projects 

(DOT Order 5660.1A). This is consistent with Executive Order 11990, requiring that 

new construction located in wetlands be avoided unless there is no practicable alternative 

to the construction and that the proposed action include all pra~ticable measures to 

minimize harm to wetlands that may result from such construction. 

The u.S. Army Corps of Engineers (Corps) regulates discharges of dredged or fill 

materials into w~ters oftheUni~ed States, including wetlands, under S,ection 404 of the 

Clean Water Act. In addition, the State Departme~t ofEcology regul~tes activity that 

might result in a discharge o~ dredge or fill material into water or jurisdictional wetlands, 

lmder Section 401 ofthe Clean Water Act. The purpose of~he Clean Water Act is to 

"restore and maintain the ch~mical, physical, and biological.integrity ofthe Nation's 

waters." The Corps requires that wetland impacts be avoided or minimized to the extent 

practicable, and mitigation would likely be required for unavoidable wetland impacts. 

One wetland (Wetland S) with a Category III rating ,will be affected by the Tukwila 

Commuter Rail Station Project. The wetland will be completely filled in order to expand 

the berm supporting the 'BNSF tracks and station platform. Mitigation for impacting the 

wetland will be provided as described in Section 4.4'.4.1 ofthe Environmental 

Assessment. FTA finds that, with the mitigation to which Soun'd Transit has 

committed, no significant adverse impacts to wetlands would occur as a result of 

the proposed project. 

Environmental Finding 

Based on the Environmental Assessment and its associated supporting documents, the 

Federal Transit Administration finds pursuant to 23 CFR' §771.121 th~t there are no 

significant adverse imp~cts on the environment associated·with the development and 

operation of the prdposedSound Transit TukwilaCorrimuter Rail Station Project. 

March 2009 Page 11 
APPENDIX A
 

Written. Comments and Responses
 

Tukwila Commuter Rail Station Project
 

March 2009
 
Appendix A - Response to'Written Comments 

Index to Comment Letters 

Letter 

NumberName of Commenter Topic Page NU,mber 

1 Muckleshoot Indian Tribe 

Fisheries Division 

Wetlands, floodplain fill, and 

fish habitat 

A-2 

2 Cities of Tukwila and 

Renton 

Land use, transportation, Safety 

' and security, biological 

resources, stormwater 

management, noise, and 

hazardous materials 

A-3 

3 Puget Sound Energy . Utility prote~tion and access A-IO 

4 C~ty of Tukwila Parking Analysis; Coordination 

between Sound Transit and City 

of Tukwila' during permitting. 

and fmal design 

A-12' 

. . 

The response to comments begins on page,A-13. 

March 2009 PageA-1 
Appendix A - Response to Written Comments 

Comment Letter No. 1 

From: Karen Walter [mailto:KWalter@muckleshoot.nsn.us]
 

Sent: Friday, February 13, 2009 6:08 PM
 

To: Cornish, Paul
 

Cc: Kennedy, Steven; John Witmer
 

Subject: Tukwila Commuter Rail Station, NEPA Environmental Assessment
 

Mr.· Cornish, 

,The Muckleshoot Indian Tribe Fisheries Division has reviewed the Environmental Assessment for 

the above referenced project. We have some comments' for your review and 'consideration. \	 . 

1.	 We would like to be'notified by Sound Transit early and given a chance to comment on 

the proposed mitigation for the filling of Wetland S. This would include any proposa'i to 

purchase mitigation credits from the Springbrook Creek Wetland. Mitigation ·Bank. 

2.	 .According to the consultant to the City of Renton for the Strander Boulevard project, this 

project has been modified via the Corps 404 and Ecology 401c permitting process and'is 

likely no longer be having the same impacts as discussed in the Tukwila Commuter 

Station EA. If this is correct, then ,Sound Transit should get a copy of the approved 404 

permit and prOVide updated information in ar,. EA addendum. 

3.	 We'would also like to be notified if the project is required to complete compensatory 

floodplain storage. . 

4.	 The proposed use of low impact development measures isa good mitigation measure 

. and should be implemented. 

5.	 While'the project is having no direct impacts to Springbrook Creek, its tributaries or the 

Green' River, it is important to note that the salmon information discussed in the 

November 6,2008 No Effects Letter regarding impacts to ESA listed species is incorrect 

The letter indicates that chinook salmon are not known to occur in Spri.ngbrook Creek 

,based on WDFW PHS and Salmonscape data). However, chinook salmon do occur in 

Springbrook Creek as documented in the Water Resource Inventory Area (WRIA) 9 Fish 

Oistribution Map for this area. ' 

http://your.kingcounty.gov/dnrp/library/2000/kcr728/vo.12/partV/FISHDIST/ChinooklCHINO 

OKdistroLOWER. pdf. Sound Transit Biologists need to consult more that just ,the WDFW 

PHS database and Salmonscape information as these databases may not reflect local 

knowledge regarding salmonidspecies and their distribution that was gathered during the 

Watershed Limiting Factors Analyses as part of the Puget Sound salmon recovery plans. 

There are fish distribution maps available for both WRIAs 8 and 9 that are readily , 

accessible on King County's website. 

We appreciate the opportunity to comment on this proposal and look forward to continuing. to 

work with, Sound Transit as this project progresses through permitting. If you have anyquestion~

regarding these comments, plea~e email me or call me at 253-876-3116. 

Thank you very much, 

Karen Walter 

Watersheds and Land Use Team Leader 

Muckleshoot Iridian Tribe Fisheries Division 

'39015 172nd Ave SE 

March 2009	 PageA-2 
Auburn, WA98092 

Appendix A - Response to Written Comments 

Comment Letter No.2 

February 13, 2009 

Paul Cornish
 

Project Manager
 

Sound Transit
 

401 S. Jackson Street
 

Seattle, WA. 98 104-2826.
 

'" Dear Paul, 

. Stafffrom the Cities ofTukwilaaild Renton has reviewed'the NEPA Environmental, 

Assessment (EA) for the permanent Tukwila Commuter Rail Station. Our 'comments fall 

into two categories: 1) specific comments on EA issue areas, including land use, 

wetlands," and noise impacts and mitigation; and 2) A reminder ofthe outstanding issues 

that still need to be resolved by Sound Transit and the Cities, that when resolved] may. 

necessitate additional environmental review. Our comments are as follows: 

Specific Comm~nts - City of Tukwila 

1. Parking 

•	 The Parking Determination by the City may require the EA to be ainended. 

•	 Table 4..4. Existing Parking Space Inventory & Utilization. The parking counts 

and utilization' rates are outdated. More'recent counts taken in .June 2'008 show' 

that V,anShare spaces are at almost a 100%"utilization rate, and at certain times,' 

the parking lot .utilization rate is over 100%. 

.. -	 Section 4.2.3'.6 states' that "Demand for parking at the Tukwila Station could 

exceed future parking lot-capacity by 2030." A parking garage to accommodate an 

,increase. in parking capacity needs to be mentioned as one ofthe mitigation 

. alternatives addressing parking overflow. 

2. TransportationlTraffic Impacts 

•	 Page 4-12. Comniuter rail station traffic. This is accurate data from the study of 

11 typical car/transit park and ride lots. However, this is a multi-modal commuter 

rail/intercity passenger rail/transit/car/bicycle/pedestrian/park and ride lot that 

March 2009	 Page A-3. 
Appendix A - Respons(J to Written Comments 

warrant a specific parking study to. represent its Unique character.·The car/transit 

park and ride lo~ analysis is not adequate. 

•	 Page 4-22. Section 4.2.2.1 Short rerm Construction Impacts. Due to the 

deteriorated condition of Longacres Way, Tukwila will sttidythe pavement 

mitigation necessary by requiring Sound Transit to perfonn structural evaluation 

ofthe roadwaY.pavement before and after hauling the 44,000 cubic yards of 

excavation~dfill soils, in order to measure the roadway pavement strength 

degradation. As a result, Tukwila will assess a pavement c9nditionloss fee due to 

these construction truck roadway pavement impacts. Ifthis is not adequately 

addressed by Sound Transit in the EA response, Tukwila will discuss with the 

· development agreement. process.. 

•	 Page 4-24. With-Project Conditions. The City of Tukwila.standards require
 

·Sound Transit to construct.continuous reconstructed
 

. pavement/curb/gutter/sidewalk/illumination all the way out to West Valley
 

Highw(J.y, including filling in gaps where no sidewalks and street . 

lighting/illumination exists due to the increased volume of pedestrians, bicycles, 

tnicksand passenger vehi"cles. This is especially true due to large number of' 

construction truck trips. for excavation and fill, as well. as potential for Strander' 

acce.ss to not be available for years. -While there are. segments of'existing curbs' 

·and sidewalks with street lights, the gaps must be completed. Ifthe developer to 

the north ofLongacres Way' (Tukwila Townhomes) constructs their project after 

Sound Transit, Sound Transit shall lower the profile of Longacres Way in the 

common private road so as to allow Boeing ·access before, during and after 

.construction ofimprovements on both sides. . 

3. Non-Motorized Facilities . 

•	 Page 4-39. Section·~.2.2.6. Nelson Place. The Interurban trait" is a recreation tr~l

that runs from Algona up to Fort Dent Park. This bicycle/running/walking trail 

does not replace the needs for sidewalks on Nelson Place. The· City' ofTukwila , 

will require public frontage improvements as part ofmitigation. Required 

improvements include curb, gutter, sidewaJk, roadw~y reconstruction, storm 

drainage, illun;linatiop- and landscaping. 

• .	 The'City ofTukwila's draft plan for theSouthcenter area includes anonmotorized . 

trail connecting the heart ofthe urban center to th~ Commuter Rail Station via an 

'extension ofBaker BOl:llevard. Sound Transit should be a partner in this proje,ct 

. with the City, since it is Sound Transit policy to provide pedestrian access within 

a quarter mile ofthe station. Also, the EA should address pedestrian circulation to: 

and within the site, particularly from the existing Strander Blvd and areas south. 

This will be even more important ifthe UP railroad lines do not get relocated as 

part ofRenton's Strander Blvd overpass projec~.

March 2009 .	 PageA-4 
Appendix A - Response to Written·Comments 

The EA does not address non-motorized access from the east side of the project, from' . rTl.·. Renton. Also, the EA does not mention Tukwila's requirement for Sound Transit to L-J 

construct,bicycle.lanes on Longacres Way. . 

•	 Page. 4-56 & 57. Section 4.2.4 Mitigation Measures for Transportation Impacts. Ii6l 

As previously stated, The 1998 EAfor the Tacoma-to-Seattle Commuterrail L..:-J 

stated, on page 3.3-13 "Mitigation measures would,however, be needed to 

improve the proposed park-and-ride lot access. Longacres Way is currently in 

poor condition and would need to· be reconstructed and channelized to support 

project-related traffic. This access improve~ent would 'be pursued by SOWld 

Transit in conjunction with other benefited property owners." Sound Transit 

should stand behind all previous commitments. 

4. Safety & Security 

•	 Page 4-120. 4.12.1 Affected Environment. This section does not adequately 0 

characterize the remoteness ofthe proposed station and the, car theft and break-ins 

currently occUrring.at the site. 

•	 Page 4-121. ,Section 4.12.3 inadequately describes impacts on personal safety at 

the station. The EA statesthat the waiting areas will be visually accessible from 

adjacent streets and populated areas, and ,that the design will allow surveillance by 

patrol cars. ,However, the station and parking area are of considerable distanc~

south of Longacres Way, aItd there is no visual access from adjacent streets and 

cars ofthe following areas: in the tunnels, between the railroad tracks, and on the 

east side ofthe·BNSF track. 

•	 rhere are no mitigation measures proposed to mitigate vehicular break-ins during
 

the day, when the trains are not arriving or departing from the station. Also, there
 

is no discussion of mitigation proposed to ensure the, safety and security of
 

Amtrak pass'engers arriving or departing. Included in the proposal is an Amtrak
 

shelter. No mention is made of safety issues regarding this facility. Tukwila is
 

concerned about who will be responsible for security ofthis facility and for the
 

passengers that use.it.
 

•	 One ofthe Tukwila~s significant concerns is safety and the perception ofsafety
 

in the tunnel beneath the ·BNSFrailroad tracks. The EA does not address this
 

issue. Tukwila would like to see mQrediscussionof specific mitigation in the
 

form oftunnel design, lighting, sounds, alarms, etc.
 

5.	 Agreements with Cities 

Page 1.;.13, Section 1.3.4. Omitted from tllis section is the agreementthat Sound 

Transit entered into with the City of Tukwila and Renton - The Joint HOV and 

Transit Action Plan between the Cities of Renton & Tukwila and Sound Transit, 

dated Apri126, 2005..Contained in this agreement are issues related to ~oundTransit . 

commitments to provide secondary access to the Station and improve~ents to 

March 2009	 PageA-5 
I 

Appendix A - Response to Written Comments 

Longacres Way. Another agreement is a September 5, 2002, Settlement Agreement 

between Sound Transit and the City ofRenton. 

6. Comfort Station 

•	 Page 3-5. Table 3.;.2. See previous comment under "outstanding issues" related to 

public restrooms. 

7. Land Use 

•	 Section 4.1 ~2 Impacts. Tukwila is in the process ofreviewing, adopting, and' 

implementing their plan for the Tukwila urban center. The plan calls for an 

intensification ofthe area surrounding the Tukwila Station with more urbanfonns 

of mixed use. While a commuter rail station does contrIbute to the planned uses in 

the area, the current station configuration does not~fit in with the envisioned· 

neighborhood's more urban and pedestrian ,oriented character. The EA does 'not 

acknowledge'this significant change in future land use, and analyze the, impacts of 

the project with this in mind, particularly related to the station's approach towards 

,stormwater detention pond and surface parking. These are uses that are	 ' 

inconsistent with the community's mi~ to long term vision for the 'area. ' 

•	 Section 4.3.1 ,'Affected Environment. The EA inadequately characterizes the 

current 4evelopment potentiai ofthe area immediately adjacent to the' station. 

Current zoning permits residential uses at 65 units per acre within % mile ofthe 

station site. When the City ofTukwila's urban center plan is adopted (Fall 2009) 

'warehouse and ~dustri~ uses will not be pennitted in this area. Instead, only 

transit supportive mix of office, ,retail, and residential uses will be permitted. 

8. Biological Resources	 , 

•	 Section 4.4.2.1, Page 4-62, paragraph just beneath Table 4-9. It is stated that the 

hydrology .of Wetland S is driven by precipitation. The EA should ,re~ect that it is 

also likely driven by groundwater due to the shallow groundwater levels in certain 

'.	 ,areas ofthe site (per Section 4.10.1 where it states that "high groundwater and 

surface water occurring in places, as evidenced by the 'several wetland patches 

onsite...."). . 

'. Section 4.4.1, page 4-76, second paragraph from top.. Off-site mitigation for
 

, buffer impacts to Wetland N would not be an acceptable mitigatiop approach.
 

9. Water·Quality & Hydrology 

•	 No analysis is made of alternative st~rmwater detention facilities, including 

underground vaults~,The EA lacks an analysis of using a significant portion ofthe , ..

site for a stonnwater detention pond and the 'impact on the site's redevelopment 

potential. 

•	 Section 4.5.3.3, page 4";86, last paragraph. The last sentence seems to· be missing
 

some words, and makes no sense~
 

March 2009	 .Page A-6 
Appendix A - Response to Written Comments 

10. Hazardous Materials 

•	 Section 4.14~2, page 4-125 third paragraph from top. Another potential soutce of 

, contamination along the railroad right of ways is historic herbicide use. This
 

.should be mentioned in &EA.
 

11.' Noise 

.,	 Section 4.6.3.1, page' 4-89 end of second sentence, first paragraph revise to say
 

"...isexempt from the noise limits of 8.22.040 but subject to the noise limits of
 

8.22.060-090 (TMC 8.22.100)."
 

•	 Section 4.6'.3.1, page 4-89 end ofthird sentence, first paragraph revise to say 

tt •• .is exempt from the limits of 8.22.040 but subject t~ the noise limits of
 

'8.22.060-090 except when received with a Residential..."
 

•	 Section'4.6.3.1, page 4-89 final sentence, fIrst paragraph is incorrect. Noise
 

generated on private property is subject to 8.22.040 without distinction for
 

private road versus ,private property.
 

•	 Section 4.6.6, first sentell.-ce, first paragtaph incorrectly st~tes that temporary
 

construction noise is exempt. Construction noise received in commercilll and
 

Ind~strial Districts~ although specifically exempt,from being classified as a
 

public disturbance noise, in not exempt from the noise limits appliedto
 

Commercial and: Industrial Districts. For these districts, a noise v~ance would
 

be'required if construction sound levels' are shown to exceed the allowable limits
 

described in TMC 8.22.040.
 

	 Section 4.6.6 discusses possible mitigation measures while recognizing that
 

construction noise could negatively affect people at nearby businesses and
 

facilities. Various mitigation techniqu~s are,explained but are not specifically
 

being.offered.
 

Other Outstanding Issues - City ofTukwila 

1.	 Parking Determination. 

We have not,yet seen the parking' demand study promised by Sound Transitdwing 

the 2008 Unclassified Use Perlnit process, justifying the amount ofparking needed~t

final build out. We recommend, that Sound Transit prepare a parking analySis now, 

prior to issuing a FONSI, to ensure that the EA sufficiently analyzes parking demand 

and that the final station design accommodates the necessary amount ofparking.. If 

the parking determination indicates a need for additional parking, this could·have
 ,EJ

implications for stonnwater detention requirements and the' station.site design.
 

Additional analysis and mitigation may' be required in the EA. A parking'
 

detennination study, ~imilar to the- one prepared for the light rail station at .154th, must
 

be approved prior to the Tukwila City Council issuing the Unclassified Use Permit
 

for the permanent station.
 

March 2009	 PageA-7 
. Appendix A - Response to Written Comments 

2.	 Public Restroori1s~

Tukwila Stationis an area of public assembly serving co~uter rail, Amtrak, and 

Metro bus riders. Given the remoteness ofthe site 'and the lack. of public facilities 

close by, public restrooms should be included in the proposal and construction funded 

by Sound Transit. The Tukwila City Councilwill,look to those provided at the 154th 

Street LINK station as a precedent. The City Council will a4dress this issue as part of 

the Unclassified Use Perinitifit is not addressed as part ofthe EA. 

3.	 Traffic Improvements. 

. As n.oted in our comments on the EA, off-site Traffic Improvements Longacres Way 

and Nelson Place must be brought up to current City of Tukwila Public Works 

. standar~s due to the increased volume ofpedestrians, bicycles, trucks and passenger 

vehicles. This is especially true due to large number of construction truck trips for 

excavation and fill, as well"as potential for Strander access to not be available for 

,years. While there are segments of existing curbs and sidewalks with street lights, the 

g·aps must·be completed. If not adequately addressed in the, EA and through·final 

design, these issues will be discussed with the Development ~greement process. 

4.	 Unclassified Use Permit. 

Asa reminder, the Tukwila City Councilwill be' guided by the criteria in. TMC 

Chapter 18.66.060 in their review of Sound.Transit's request for. a UUP for the 

. , permanent station. These criteria include undergrounding offacilities, compatibility 

with surrounding land uses and the comprehensive plan, and mitigation of all impacts~

If not adequately addressed in the EA and through final engineering, these issues will 

b,e revisited by the Tukwila City Council as part ofthe UUP process. 

Specific.EA Comments - City of.Renton 

Section 1.2.2, pg. 1-9, Relationship to the Strander Boulevard Extension and Union. 

Pacific Railroad Realignment Project. The text in this section states that.the "Tukwila' 

Comniuter Rail Stationprojec~is functionally independent ofthe UPRR relocation 

project and.will proceed regardless ofthat project." In the EA document Sound Transit 

,acknowledges thattlleStrander project would provide important east~west access; but 

implies that ev~nwithoutsuch a road, tratisportation needs .are·met. We want to remind 

Sound Transit that adequate east-west access was identified as being r~quired in the 

original programmatiq environmental work for the commuter rail plan as a whole. 

'Furtheimore, the 2002 Settlement Agreement with Renton also identified access from the 

east, from Renton. With recent newconditiQns being placed on the Strander project by 

UPRR, this important project is facing some very difficult obstacles and is in some 

jeopardy. We believe that access from the east(Renton) as well as adequate public road 

access from the west (Tukwila) needs to be adequately addressed, including 

contingencies for a possible change in the Strander project, or alternative east 'access 

options.. The options that may need to be re-evaluated .are an undercrossing ofthe two 

railroad tracks, or an at-grade access by'providing new Renton streets which connect to 

Longacres Way (from the east as well as from the west), or other options. Sound Transit 

needs to participate in the process and, ifnecessary, make adjustments in either the 

Station design and/or schedule to acco~odateaccess from Renton. We believe that 

March 2009	 PageA-8 
Appendix A - Response to Written Comments 

constructing what appears to be the only commuter rail station in the region whose sole 

,access is from a private road {virtl;1allya long driveway) is not adequate. 

Conclusion 

We would like to acknowledge that Sound Transit has faced many on-going challenges 

during the Tukwila station area planning process, such as the uncertainty regarding the 

, Strander Boulevard extension and the relocation ofthe Union Pacific right of way. We 

appreciate So'und Transit's continuing efforts in trying to overcome these challenges, and 

look forward to 'moving ahead togeth~r with the planning process. 

Please don't hesitate to contact us, Lynn Miranda at 206.431.3670, or Peter Hahn at 

425430 7242,. if you have any questions on these issues. . 

Sincerely, 

~~'ff ??P'lI1/ef~ Jack Pace 'Gregg, Zimmennan , Direotor Administrator
 

Dept.' ofCommunity Development Public Wo~ Dept.
 

CityofTukwita ' City ofRenton
 

CC:Peter Hahn~ City ofRenton ,
 

Bob Giberson, City ofTukwila
 

Nor~ Gi~rloff, City ofTukwila
 

Lynn Miranda, City ofTukwila
 

March 2009 Page A-9 
Appendix A - Response to Written Comments 

Comment Letter No. 3 

From: Wingate, Angela [mailto:Angela.Wingate@pse.com] 

sent: Saturday, February 14,2009 8:41 AM 

To: Cornish, Paul 

Cc: Hempstead, Susan B; Kelly, Julie A; Namura, David 

Subject: Sound Transit. Tukwila Commuter Rail Station NEPA Environmental Assessment (EA) ­

PSE's Comment Letter ' 

February 14, 2009 

Sent Via E-Mail topaul.comish@soundtransit.org 

Sound Transit 

'Attention: Paul Corn'ish, Project Manager 

'S9und Transit~ Union Station 

401 S Jackson St Seattle, WA 98104-2826 

Dear Mr. Cornish, 

Puget Sound Energy (PSE) appreciates the opportunity to provide the following comments to the ' 

Sound Transit Tukwila Commuter Rail Station NEPA Environmental Assessment (EA). PSE is 

Washington State's oldest and larg'est energy utility wi'th a 6,000~square-mile service area 

. stretching. across·11.counties. PSE serves more than 1 million electric customers and 735,000 

natural gas customers, primarily in western Washington. 

PSE strives to maintain a. positive,· professional and 'productive relationship with all the customers 

we serve and the relationship we have with Sound Transit is extremely important to PSE. We 

view our partnership as critical to our ability in providing safe, reliable, efficient and cost-effective 

electric and nat~ral' gas services to our customers in and around the Puget Sound region. 

As part of PSE's service obligation, we are required to maintain and reinforce our electric and 

, natural gas systems as the need arises. New growth places increased demand for electric and 

natural'gas"services and the associated utility infrastructure., All of thi.s r~quires, PSE to be . 

particularly responsive to all service needs. PSE must have the ability to access and maintain' 

safe, immediate and re'liable ~ervice toou,r customers. . 

We have reviewed your Tukwila Commuter Rail Station NEPAEA and respectfully request the
 

,following revisions to betaken into consideration: .
 

) There are a number of areas where the EA document speaks to the placement of 

various station eleme~ts '(including but not limited to: Station platforms, canopies, minihigh platforms, .pedestrian amenities, broad plaza elements, future third track expansion, 

art, bike storage, comfort stations, ticket vending machines,landscaping, lighting, rail 

platforms and signage). It is important to recognize these elements must be sited in such 

a manner to maintain required safe distances from PSE's overhead and underground 

facilities. . 

Figure'1-2 Aerial Photo of Project Site: This photo is missing PSE's east-west 

. transmission .line near the center 'of Sound Transit's property'. Also, the not.ed "PSE 

Substation" should be listed .as "PSE Cable Station". 

0
 

' 1 ' 

0
 

" 2 

March 2009 Page A-10 
4 

App,ndix A - Response'to Written Comments 

» Chapter 3.2.1 Station Location: If the proposed platforms are located farther north this 0 . . would help in avoiding a conflict with PSE's transmission line. 

>	 Chapter 3.2.2 Parking.Facilities: Construct the parking areas at such a grade that will 1:l.

allow for maintenance vehicle access into PSE's Nelson Cable Station and transmission L:J 

lines. 

»	 Chapter 4.11.2.1 Construction: The noted 'IIPSE substation" should be listed as "PSE f5l 

Cable Station". ProtectPSE's Nelson Cable Station and transmission Ii'nes from LJ 

disruptions in ~ervice and relocation. 

APPENDIX A Alternatives Considered. ~6'

>, ,Do not install Layover or Ponds near PSE's N,elson Cable Station or transmis$ion lines LJ 

due to the n,eed for PSE to maintain these facilities. 

»	 Do not install TBD stalls on PSE Right-of-Way (ROW), due to the need for PSE to· [2]

maintain overhead and underground facilities. 

»	 Do not suggest the relocation of PSE's Nelson Cable StatiOn, or any transmission lines I'8l 

due to PSE needing to be particularly responsive to all service needs. Due to the highly 

complex nature of these facilities, it is inappropriate to consider the relocation. of a facility 

of t,his nature. ,In addition, PSE musthave the ability to maintain safe,immediate and ' 

reliable access to these facilities in order to continue to provide uninterrupted service to 

our customers. 

These requests are based upon PSE's safety concerns so as to avoid,hazardous situations 

where the transmission lines could either fall or arch onto Station, elements. 

'As you continue to develop the Tukwila Commuter Rail Station, we request:you to carefully 

consider the complexities associated, with PSE's .need for access to our facilities and private 

property. Sound Transit should place a high priority on as~isting PSE, to provide continuity ~nd

uninterrupted service to ourcustomer$ in western Washington, including your own agency, since 

PSE is prOViding electrical service for portions of your Link LightRaii system. 

Th~nk you for the opportunity to comment We look forward to working with your project team as
 

you dev~lop the Tukwila Commuter. Rail ,Station. If you have any questions concerning these
 

comments,. please contact me, at 425.462.3351 or ahgela.wingate@pse,com .
 

'Thank you, 

Angela Wingate 

Mun,icipal Liaison Manag~r

PUGET SOUND ENERGY 

425.462.3351 tel 

425.213.2315 cell 

355 110th AveNEEST-IIW 

Bellevue, WA 98004 

www.PSE.com 

March 2009	 Page A-11 
Appendix A - Response to Written Comments 

, Comment Letter No.4 

City of1ltkWlla 

Paul Cornisht: Project Mlnager
 

Sound Transit
 

401 s. Jac:bon Street
 

~Ie. WA981094
 

DearPau1~

Jwo~ld like to elarify the Ci,ty o(T'Ukwila~s commen. in our February 13, 2009 rcvi~

ofthe ,Tukwila Station NHPA Environmental Auesl,ment.. 

. ParkiDS, Determination , 

In our February 13t 2009 letter (page ;$ comment I - Other Outstanding Issues) we 

I'eOO1nmended Sound Trauit prepare a parking analysis.MWt prior to issuing'tho PONSl" 

Based on addjdo~1 discussions with youJ SOtDJ Tramlt CEO Joni Earlt otber Sound, 

T-.sit staffand intemal,diacuss. the City no longer recommends that an additional 

par~ng analysis be prepared prior to issuing the FaNSI.. The City is committed.to , working in partnership wlrh Sound Transit as the Cllrrent NBPA mvironmental process is 

completed and Final DMip is initiated this IUtllmer~

Ourtw<l aacncics will ltart to work together this spring 1he parking detennination and . 

unclassified use permit approvals required by the City ofTukwila, and hold a pre-­

appUeauonmeeting priorto the iDitiati'em offinal desian~

Sincerely, 

}¥~ Jack Pace 

Community Development Director 

, Cityof'TukwUa 

. 6300 $outhtenter BouleRrd, SUite , /()(} .• TukwIla. w;.shlllIlon PIlI' • Phon,: 206·4.3'1..3610 • File: 306·431·36fJS 

March 2009 Page A-12 
Appendix A - Response to Written Comments 

RESPONSES TO WRITTEN COMMENTS 

COMMENT LETTER #1 -Karen Walter, Muckleshoot Indian Tribe Fisheries 

Division 

1.	 Thank you 'for your comments. Sound Transit will continue to provide notification 

to the Muckleshoot Tribe on the project as the ,design and nlitigation program is 

,developed and permits are obtained. ' 

2.	 Sound Transit made use ofthe most recent documents provided by the City of 

Renton for this EA. Pursuant to an agreement between Sound Transit and the 

City ofRenton in 2008, all wetlands on the Tukwila Commuter Rail Station site 

except Wetland S would be filled'as part ofthe UPRRtrack relocation (ifthat 

project goes forward) and Renton'will provide mitigation for the loss ofthose 

wetlands. Sound Transit has not been notified <?f any change in,that comn~.itment.

3.	 Sound Transit will continu.e to provide notification to the Muckleshoot Tribe on 

, the project as the design and mitigation p~ogram is developed and permits are 

obtained. ',' , 

4.	 Sound Transit has committed to implementation of LID measures as described. 

5.	 Comment noted. To clarify, the,WRIA map referred to in the comment'letter 

shows that the tributary on the project site is not known to support Chinook 

salmon, while themainstem of Springbrook Creek (labeled Black River on the 

WRIA map) shows "known" use as of2000 when the map was published.' 

The findings and conclusions in the no effect letter are narrowly construed' and are 

based on the conclusion that the action will result in no change to the 

environmental baseline as defmed by NMFS and USFWS guidelines and the 

ability ofthe action to meet prescribed stormwater .standards and regulatory 

thresholds. Sp~cifically, there will be no in-water work in a waterbody connected 

to the stre~ and, this project will be designed to meet the requirements ofthe 

2005 King C;ounty Surface Water M,!nual,., . 

The '''no effect" detenninations were not based on the absence or preclusion of 

Chinook in the larger watershed. The information on distribution ofChinook 

salmon is provided as background to provide context and tp indicate that the 

potentially affected 4rainages are not known to be ofprimary use by significant 

numbers ofthe larger affected ESU. The fact that the various databases disagree 

is evident ofthis fact. The no effect letter was included as documentation as it 

pertains to meeting ESA regulatory requirements. It is not intended to provide an 

extensive or even complete assessment offish or fish use in the Springbrook 

Creek drainage or larger wa:tershed. 

March 2009	 Page A-13 
Appendix A Response to Written Comments 

COMMENT LETTER #2 - Jack Pace, Director, Tukwila Department of
 

Community Development, and Gregg Zimmerman, Administrator, Renton
 

Department of Public Works . . '
 

1.	 Thank you for your comments. We note that Sound Transit met with 

representatives ofthe cities subsequent to this letter and that Tukwila 

subsequently provided a clarifying letter to Sound Transit regarding the parking 

analysis. That letter. states that Tukwila is.no longer recommending that additional 

parking analysis be done by Sound Transit prior to issuance of a FONSI, as' stated 

in their 2/13/09 comment.letter. This clarifying letter is included with the FONSI 

as Comment Letter #.4. Also see the respon~e to Comment 29 belo~.

2.	 As the Cities are aware, parking enforcement at the site is limited, and many nontransit users, including City ofTukwila vehicles, are'parked at the site both during' 

and after t~mes when transit service is provided. As s.uch, observed parking 

u~ilization rates are not necessarily reflective of demand generated by the station. 

It is acknowledged that without stricter enforcement, this pro~lem could be . 

greater as the area develops further, especially because Tukwila has proposed, in 

its 2009 draft Tukwila Urban Center Plan, elimination ofminimum parking . 

requirements for all other dev~lopmentwithin 600 feet ofthe Tukwila Commuter 

Rail Station. 

We are pleased with the. amount ofVanShare space being utilized as this mode of 

use for the station is supportive of our overall mission. Sound Transit will 

increase space avail~ble for VanShare if demand increases.. 

. 3..	 The voter-approved budget for the project do.es not support 'provision of a parking 

garage. Constructing additional parking would also encourage more use ofsingle 

occupant vehicles to arrive at the site, and would appear to be contrary to the 

proposed City ofTukwila policy of eliminating minimum parking require~ents

for other uses in·the station area. 

4~	 A specific study ofthe current site trip generation was performed, .and was 

compared with the rate developed from 11 other studies and published in the 2003 

ITETrip Generation. The reason for citing the park-and-ride studies was to 

corroborate the results ofthose studies with the observed ratio oftrips to park41g 

spaces. The strong correlation found in the other studies generally confirmed the 

correlation observed inthe Tukwila Sta~ion site-specific study. As noted, the ratio 

'oftrips per parking space at the Tukwila Station was slightly higher than the ratio 

observed by'the.ITE. Sound 'Transit chose to.usethe rate ratio found in the sitespecific study for the analysis in ~he EA because' it is the more 'con~ervative

nuniber, Le. it result~ in a higher estimate ofimpacts than the ITE rate would . 

suggest. ' 

5.	 SOWld Transit acknowledges that construction traffic could damage the roadways 

used for hauling material to or from the site, although.significant impacts are not 

anticipated. As is typical with all construction projects, if a construction'vehicle 

March 2009	 .Page A-14 
Appendix A - .Response to Written Comments 

damages a roadway, the builder,ni.ayberequired to restore the roadway. Sound 

Transit will work with the City of Tukwila to document road conditions prior to 

construction and mitigate damage to public roads 'caused by construction traffic.. 

6. . As noted in the City's comments on the draft EA "There is acontinuous sidewalk 

, on the south side of Longacres Way from W Valley Highway,to the Sounder 

station." The comnlent did not provide a code citation for the requirement of offsite improvem~nts such ~s sidewalks, lighting, and drainage on.public streets. 

Sound Transit was not able to confiim this requirement, other than immediate 

public frontage, in the Tukwila Municipal Code. Sound Transit will meet all 'City 

requirements for roadway improvements for public and private roads. 

7.' See comment 6 above. ,The proposed station would likely generate a small 

portion ofthe non-motorized traffic on Nelson Place. Sound Transit does npt 

, vIew a minor addition, of pedestriantraffic to Nelson Place as an impact that 

requires mitigation~

8.	 Pedestrian access to and within the site is discussed in the EA. Th~ project has . 

been designed to accommodate connections to the Baker Boulevard trail 'by 

creating a central plaza on that'axis, but ,SoUnd Transit is not proposing'building 

,any connections. . 

9.	 Sound Transit is not proppsing any new, dedicated, non-motorized access from 

east ofthe station but has made a financial cotn.tnjtmentto devel~ping an east 

west road, which can also accommodate non-motorized,access. 

10.	 Sound Transit is aware of and will complete its commitments regarding 

transportation mitigation for this project. 

11.	 In the short ternl, the p~oposed station will remain somewhat isolated from 

,surrounding development, although no more isolated than the temporary station 

on the east side ofthe tracks. Car thefts and break-ins are common in any large 

parking area, even at regional shopping malls. ,Sound Transit recognizes that 

because the exis~ing lot is used extensively during non-transitservice hours, the 

existing lot is vulnerable to these types of crimes. How~ver, with the mitigation 

meas~es described in the EA, such as CCTV and security patrols, this is not 

expected to be a significant,impact with the development of a larger station and 

parking area. In addition, with expected' additional development in the vicinity 

that has be~n described in Tukwila's Urban, Center Plan and in plans for the, 

Boeing property to the east, the visibility ofthe site should improve. over time. 

12.	 See comment response #11 above. Although the project design is not complete, 

the design will be evaluated for such areas ofloW visibility and other security 

concerns. Where appropriate, the mitigation measures described in the EA will be 

provided to mitigate security concerns.. 

March 2009	 Page A-1-q 
Appendix A- Response to Written Comments 

13.	 The mitigation measures· described would provide greater surveillance than at the 

current si~e. If and when Amtrak proposes to build a shelter for its passengers, 

Amtrak will consider security issues in the design of that facility, and provide 

appropriate mitigation, which could include.measures listed in the EA or other 

appropriate measures. 

14.	 The design will be evaluated for areas of low visibility and the mitigation 

measures described in the EA will be provided to mitigate security concerns. 

Sqund Transit employees (Station Agents) are on site assisting p·assengers when 

Sounder.is operating. 

15.	 Sound Transit acknowledges that the ~greemei1ts referred to -in the. comment letter 

still have effect. T~e specific list in S.ection 1.3.4 was regarding specific 

environmental issues associated with previous environmental review. The reason 

that the. 2008 agr~ement·with Renton was listed was because it identifjedRenton's 

int~ntions with regard to wetlands on the site, which was directly relevant to the 

environmental assessment and a determination on whether the· Tukwila Commuter 

Rail Station p~oject would·have significant impacts. 

16.	 Sound Transit has made a pqlicy decision that it will not provide restrooms at its 

commuter rail stations. 

17..	 The EA does note in Section.4.1.1.2 that Tukwila has' been preparing a plan for an 

urban center and that density in the area is expected to incr~ase. In the Draft 

Urban Center Plan that has just been published in·early 2009, both landscaped 

detention ponds and. surface parking are described in the proposed. development 

guidelines for the.area and are'therefore considered·compatible withotlier planned 

uses. 

18.'	 The section referred to (4.3.1) does acknowledge the potential for a chang~ in the 

nature of development in the area.. However, that section focused on social and 

economic factors pertaining to environmental justice as it relates to the 

construction ofthe rail station. Please refer to the land use section for information 

pertaining to future land use. It is acknowledged that the proposed prohibitio~ of 

warehouse and industrial uses in the area would be supportive of a shift to the 

types of uses described in section 4.1.1.2. 

19.	 The'statement in the EA about Wetland S is based on the wetlanq report prepared 

.	 for the City ofRenton and on field observation. The hydrology of Wetland S 

does not appear to be driven by a high water table. 

20.	 Comment acknowledged.' Wetland N is considered non-jurisdictional by the US 

Army Corps ofEngineers and may be exempt under the City of Tukwila . 

regulations, since it is a ditch created by the railroad for drainage purposes. Ifthe 

UPRR tracks 'are not relocated, Sound Transit will work with the City of Tukwila 

to determine the appropriate mitigation, ifany, for the reduction in buffet around 

this wetland. 

March 2009	 Page A-16 
Appendix A·- Response to Written Comments 

21.	 The ,first comment listed under Wate,r Quality and Hydrology is related to land 

use effects of'the proJect. Sound Transit has worked with and will continue to 

work with the City of Tukwila to identify opportunities to develop the portion of 

its property that is not needed for the· station. The site has also been designed so 

that, if appropriate, the detention facilit,y could be replaced with an un4erground 

system to accommodate additional develo,pment at some future date..The .. 

proposed stormwater design is based a report prepared for theproj e.ct by INCA 

Engineers in June 2008. The design team evaluated five storm water alternatives. 

Two ofthe five proposed included underground storm water storage facilities. 

.The results ofthi,sanalysishad been presented to City Tukwila staff on May 6, 

2008. 

22.	 Thank you pointing out this typographical error. The statement at the end ofthe 

bottom ofpage 4-86 was 'intended to read: "Vegetation planned for t9.e perimeter 

.ofthe storm~ater detention pond will provide shade, which can also reduce 

surface water temperature in the pond." Thank'youfor point~g 'out the error. 

23.	 While use of herbicides has been common in the past ~ong railroad tracks, the 

evidence on this site suggests that there has not been wide use of herbicides here ' 

for some time. It is not ~ticipatedthat there would be any persistent herbicide 

residues that could be adanger to workers or the general public during 

construction or operation ofthe Tukwila Commuter Rail.Station. 

. ·24.	 'The provisions ofTMC 8.22.060-090 apply to motor vehicles. The following is 

the .definition ofMotor Vehicles at TMC 8.22.020.11: "Motor vehicle" means any 

vehicle that is self-propelled, used primarily for transporting persons· or property . 

upon public highways,and.required to b~ licensedun~er RCW 46.16.010. 

(Aircraft, watercraft and vehicles used exclusively on stationary rails or tracks are 

not '~motor vehicles" as that term is used herein.)". 

25.	 See response to item #24 'above. 

26.	 'The sentence in the EA is correct, but may have ·been misunderstood. Noise from, 

trams is not.regulated by the noise ordinance. It is ackn,owledged that noise from 

vehicle's operated'on private property or private roads that is received within a 

Residential zone is re·gul~ted.the same as any other sound source on private 

property.' 

27.	 Thank you for the clarification regarding when a noise variance would be 

required. The project will comply with local noise regulations ,~d a variance Will 

be sough~ if necessary. 

28.	 Construction noise will be dependent largely on the contractor's means and 

methods of constructing the project. The ·examples ofmitigation are offered as 

possible approaches, but the contract specifications will require that the contractor 

ensure compliance with local noise regulations. 

March 2009	 Page A-17 
Appendix A - Response to Written Comments 

29.	 Outstanding issues- Parking Determination. Sound' Transit recognizes that, as an 

unclassified use, a parking determination is required and will work with the City 

of Tukwila as part .ofthe City permitting process. As noted in the EA, the parking 

required for the station was determined based on So~d Transit's analysis' of 

future ridership developed for Sound Transit 2 planning purposes. That analysis 

is based on many interrelated factors that are expected to change over a .long'time 

peri04. Sound Transit believes that this is the best estimate available of future 

demand at this station. S,ound Transit also recognizes that the outcome 'of the 

permit process could affect the project and require a modification to the EA. 

Pursuant to our meeting with City staff after receiving the comment-letter, we 

understand that the City of Tukwila has changed its position and no longer 

recommends that ST do additional'parking analysis now, prior to issuance of a 

FONSI. The City·ofTukwilasent a clarification letter to this effect included as 

Comment Letter #4.. 

30.'	 Sound Transit has made a policy decision that it will not provide restrooms at its 

commuter rail stations. 

31.	 Off-site traffic improvements. are not cUrrently proposed,thus'none are,evaluated 

in' the EA. Sound Transit recognizes'.that mitigation may be required in 

proportion to adve~se impacts that have a demonstrated nexus to the station 

project. For temporary construction.traffic impacts, Sound Transit will develop a 

traffic management plan that will be provided to the City· for review and approval. 

32.	 Sound Transit recognizes that an Unclassified Use Pennit is required and is'aware 

ofthe criteria for approval. In.~ound Transit's perspect~v~, none ofthe features 

ofthe Tukwila station is incompatible with existing or expect~d future uses in the 

station ,ar~a. Indeed, it is our understanding that the reason Tukwila has wanted 

the station to be located in the urban center is because it would help attract the 

.type of development that Tukwila would like to see in that area. As the Cities 

know, however there isa limited budget for the station ~hat was approved by the 

region's voters. Sound Trarisit will continueto work with the City to maximize 

benefits to trans~t users and the cities ofRenton and Tukwila that is possible with 

the available funds. . 

33.	 . Sound. Transit has made a financial commitment to an east-west connection 

between the station and. R.enton. In' a recent meeting, Sound Transit reiterated its 

commitment to provide those funds for whatever solution proves most feasible. 

Sound Transit will continue to work with both the City ofRenton and the City of 

Tukwil~ on the·best method to provide access-to the site in both the short and the 

long term. . 

March 2009	 Page A-1'S 
Appendix A'- Response "to Written Comments 

COMMENT LETTER #3 - Angela Wingate, Puget Sound Energy (PSE) . 

1.	 Thank"you for your comments. Thestation"will be designed in accordance with 

overhead and underground "rights held by PSE. No significant conflicts with PSE 

facilities are anticipated. . 

,2."	 The aerial photo was not intended to be an exhaustive inventory of features in and 

around the site, but rather to provide landmarks. It is acknowledged that.'PSE has 

a transmission line parallel and adjacent to t!le Cedar River Pipeline No.4 shown 

in the-center of the site. 

3.	 The platfonn location has been determIned based on critical track geometry and 

~annot be moved further north without affecting the trestle at Longacres Way. 

Sound Transit does not anticipate that any platfoI111; features would conflict with 

"the overhead transmission lines.	 ' 

4.'	 The parking wlilbe designed so that access can, be provided to the PSE Cable, 

Station. 

5.	 Thank you"for the clarification 'on the proper label for the cable statiOIi. Labeling' ' 

on the figures for the EAhas not been changed,butfuture design drawings will 

include the proper labeling to help ensure clear communication between Sound 

Tr~sit, its contractors, and PSE". "The contract plans and specifications will also 

include requirements to protect utilities~

6.	 As noted in the introduction to "Appendix A of the EA, Alternative 6 was chosen 

as the preferred alternative and a hybrid design was developedincorporating,the 

pest features of other alternatives with the basic concept ofAlternative 6. The 

current design develop'ed from this alternative does not include ponds near PSE 

facilitie~. The layover facilities, .which are primarily roadway where buses can 

be parked between runs, are not expected to conflict with nearby utility facilities. 

7.	 No parking is proposed" on the'PSE right-of-way. The design includes up to 40 

additional.parking stalls that could be constructed in the future to the south ofthe 

PSE transmission line easement. These would be designed to· avoid conflicts with 

PSE" operations and maintenance. 

8.	 No relocation ofthePSE cable station is anticipated forthis project in the current 

design.' " 

March 2009	 Page A-19 
Appendix.A - Response to Written Comments 

. . 

COMMENT LETTER #4 -Jack Pace, Director,'Tukwila Department of 

.Community Development, 

. Thank you. for your comment. Sound Transit looks forward to working with the City on 

this and other permitting requirements for the. station. 

March 2009 PageA-20 
APPENDIXB
 

Tukwila Commuter, Rail Station
 

Mitigation Commitments
 

March 2009 
Appendix B - Mitigation Commitments 

Tukwila Commuter Rail Station
 

Mitigatio~ Commitments
 

March 2009
 

Following the issuance ofthe Finding ofNo Significant Impact (FONSI) by the Federal 

, Transit Administration, Sound Tr~sit proposes to initiate final design of the project 

elements. The Environmental Asses'sment (EA) discusses a variety of potential 

mitigation measures; those to be implemented are described below. With the 

construction ofthe project, Sound Transit shall implement the followi~g mitigation 

measllfes: 

Land use. As discussed in Section 4.1.3 ofthe EA, the proposed action is not ~xpected to 

have any adverse land use impacts. Therefore, ~itigation measures are not necessary. ' 

SOWld Transit comni.its,to the,following'measure'to ensure that the design fits 

appropriately into ~ts surroundings: . 

•.. .Coordinate planningan<J design ofthe station with the City ofTukwila, the City of 

Renton, and with owners of nearby businesses (e.g. the BoeingLong~crescampus). 

Transportation. Transportation mitigation measures are discussed in Section 4.2.4 of 

the EA. By year 2030, increases in background traffic and ph:~nned, changes to the 

ro~dway network would result in degraded levels ofservice at study-areaintersectio~s.

The project traffic'would add some delay to theselocations. However, optimization of 

traffic signals along the West Valley Highway corridor is expected to o'ffset delay 

impacts ofthe proposed permanent ,commuter rail station traffic. Since the City is 

responsible for traffic signal operations on state highways, mitigation by S·ound Transit is 

.not proposed.	 ' 

,To ~ddress street network, and parking impacts, Sound Transit will implement the 

follo\Ying mitigation measures: ' 

•	 Construct street frontage and vehicle access improvements to Longacres Way- on the 

,project site as part ofthe project.­

•	 Construct pedestrian access improvements that would enhance,th~ non-motorized,
 

environment in the site vicinity, including.
 

o	 A 15-foot sidewalk with landscaped tree wells on the south half ofLongacres 

Way 'along the frontage of thep~nnanentstation property. ' 

o	 A 12-f06t wide path for non-motorized vehicles and,pedestrians connecting the 

station to Longacres Way. 

o	 A -pedestrian underpass connecting the parking lot and the station platforms. 

The portion ofthe pedestrian way that passes under the UPRR tr.acks would be 

constructed as part ofthe UPRR Realignment Project. 

March 2009	 Page B-1 
Appendix B .... Mitigation· Commitments 

•	 Prepare an updated parking study if it is required by the City of Tukwila Parking
 

Determination.
 

•	 ' Coordinate with other transitprovi4ers to improve transit 9ptions to the station to
 

,reduce the demand for parking.
 

•	 Coordinate with the City of Renton and City ofTukwila to implement on-street
 

parking time restrictions, parking enforcement, or other measures to minimize
 

impacts from overflow parking, if and when it occurs.
 

•	 Design the station to accommodate a future access to' Strander Boulevard, a planned 

but as yet unfunded, arterial overpass adjacent to the south side ofthe site. Sound 

Transit has cQmmitted $4~208,OOO to the Strander Boulevard,Project for HO,V lanes 

and transit queue by-pass lanes on Strander Boulevard. 

Social and Economic Impacts: As discussed in Section 4.3.3 ofthe EA, the proposed 

action is' not anticipated to have adverse social or economic impacts. Therefore, 

mitigation measures are not needed. However, Sound Transit has co11111iitted to,'the 

following to help ensure that potential social and economic impacts of construction and 

operation of ~he station are avoided or minimized: ' 

•	 All project elements will be planned 'alid designed in coordin8:tion with Tukwila,
 

Renton, local residents, business owners, land o~ers, and other stakeholders. '
 

Biological Resources: Biological resource mitigatiol1 measures are discussed in Section 

4.4.4 ofthe EA. " 

,To address wetland impacts, Sound 'Transit will implement the following mitigation 

measures: 

•	 Mitigate for filling Wetland S and its buffer in accordance with applicable permits
 

using one ofthe following options:
 

a.	 On-site or off-site wetland mitigation, or 

b.	 Purchasing credits from an approved wetland mitigation bank. 

Off-site mitigation in a wetlandb~ is preferred. If appropriate off-site mitiga~jon is 

unavailable, then an on-site mitigation project may be necessary and will be, provided. 

•	 Ifthe City of Renton's UPRRRealignment Project does not occur prior to the 

Tukwila Commuter Rail Station Project, Sound Transit will provide any required, 

mitigation for impacts to the buffer of Wetland N in accordance with applicable 

permits. This· could include wetlandbuffe~ enhancement on or near the project site, 

,or <?ff~site mitigation such as purchasing wetland bank credits. 

March 2009	 Page B-2 
Appendix B- Mitigation Commitments 

•	 Incorporate stormwater detention ponds and rain gardens in the project desig,n to
 

maintain the flood flow alteration functions provided by wetlands in the project
 

vicinity.
 

To address wildlife and fish.impacts, Sound Transit will implement the following 

mitigation measures: 

•	 Reyegetate areas that are not paved or built upon, plant trees in the parking area, and 

plant the stormwater detention area with appropriate plants to enhance wildlife use as 

part ofthe landscape plan~

•	 'Hydroseed the existing railroad embankment after the station platform is complete. as 

,part ofthe landscape plan 

•	 Use appropriate BMPs to control potential water quality and quantity issues during 

and after construction as described below under Water Quality and Hydrology. 

Water Quality. and Hydrology. Water quality and hydrology mitigation measures are 

discussed in Section 4.5.3 ofthe EA. 

. No direct impacts to the Green,Riv,er or Springbrook Creek are expected 'as a result of 

this project. Impacts from stonnwater runoff will be minimized with the!ollowing 

mitigation measures: 

•	 Storm:water design will comply with the 2005 King County Surface Water Design 

Manual and the 2,005 King County Stormwater Pollution Preventi~n Manual to 

minimize runoff, sediment, and erosion impacts. The project will c,omply with local 

permitting requirements for storrp.water design prior to construction, which may 

include the implementation ofmeasures s~ch as covering stockpile4 soils, using 

sediment traps and ponds, clearing areas just prior to construction, and replanting 

'cleared areas as soon as possible. 

•	 Implem~nt a spill controi and prevention plan for all construction areas ofthe site. 

The plan should include such measures,as clean-~p procedures in the event ,of small 

and large spills and training for personnel on the reduction and elimination of 

'potential spill sources. 

•	 Wherever possible, minimize on-site refueling areas and areas of fuel or chemical 

storage. Berm, or curb and l~e with impermeable materials all refueling areas where 

possible, and dive~ drainage' away from these areas. Maintain 'facilities for proper 

collection and disposal of any waste produ~ts, such as used mot~r oil. 

•	 Install permanent stormwater treatment facilities to treat runoff from one-hundred' 

percent ofthe new po~lutiongeneratingimpervious surfaces. 'Storm drainage c~ntrol

will consist of onsite drainage (one pond to the north ofthe parking area) and low 

, impact development (LID) measures. 

March'2009	 Page 8-'3 
Appendix B - Mitigation Commitments 

•	 ' Plant vegetation along the' perimeter of the drainage pond to provide sh,!de. cover for 

the stormwaterdetention pond. ' 

•	 Detain.stormwater.in rain g~rdens.along the western side ofthe parking areato slow 

the velocity of surface runoff and'allowparticles to settle out and nutrients to be 

filtered from runoff. 

The project area is outs'ide ofthe IOO-year floodplain a~ defined in the City of Tukwila's 

,critical areas regulations, which are based on the Federal Emergency Management 

Administration (FEMA) Flood Insurance'Rate Maps (FIRM) currently in effect.. 

However, based on draft Flood Insurance Rate.Maps, the project area is located within, 

the 100-year floodplain of Springbrook Creek. Ifthe draft FIRMs are correct, emergency 

vehicle traffic and excavation routes could be impacted by flooding, and the pedestrian 

tunnel would be unsafe during'a flood event. Minor fill would be ne'cessary 'on the, west 

portion.ofthe site. Ifthe draft FIRMs are adopted as part ofth~ regulatory compliance 

.required for the project, any floodplain fill will require compensatory floodplain ,storage. 

, However, compensatory floodplain storage is not currently required. As such, only the 

following mitigation commitment is required to address floodplain iinpacts: 

•	 Incorporate stormwater detention ponds and rain gardens in the project to, maintain
 

the flood flow alteration functions provided by wetlands· in the project 'vicinity'.
 

Noise. Noise mitigation measur~s are discussed in· Section 4.6.6 ofthe EA. Because the 

proposed action is not anticipated to create noise impacts dUring the op'eration ofthe ' 

Tukwila, Commuter Rail Station Project, no operational noise mitigation is warranted,. 

Con$truction ~oise couldtemporarily negatively affect people ~tnearby businesses and
 

facilities. While some noise exemptions do apply to these te~porary'constru9tion
 

activities, some relatively simple and inexpensive practices could reduce the extent to
 

which people are affected. Sound Transit commits to the following mitigation measures
 

that address noise impacts during construction: '
 

•	 Reduce' const~ctio~ noise wi~h properly sized and maintained mufflers, engine intake 

silencers, engine enclosures, and by tumiIlg off idle equipment. ' Construction 

activities that could negatively affect people at nearby businesses and facilities will be 

confined to daytime hours when feasible. Specify in the construction contract that 

mufflers be·in good working order and that engine ,enclosures be used on equipment 

when the engine is the dominant source ofnoise. . 

•	 Place st~tionary pumps, conlpressors, welding ,machines, and similar equipment in
 

~ontinuous operation as far away from sensitive receiving locations as possible.
 

Where this.is infeasible, place portable.noise barriers around the equipment with the
 

openi~g directed away from the sensitive receiving property, as appropriate~
 

March 2009	 Page 8-4 
Appendix B - Mitigation Commitments 

•	 Obtain and comply with local noise variances that maybe required under applicable 

local.noise regulations, if any. 

Air Quality. Air quality mitigation measures are discussed i~ Section 4.7.5 ofthe EA. 

Because the proposed Tukwila Commuter Rail Station Project would not result in any 

adverse air quality impacts in the study area, no operational impact mitigation measures 

related to impacts in the study area are· warranted or proposed. . 

During construction, the construction contractor(s) will be required to comply with all 

relevant federal, state, and local air quality laws,and would be required to prepare a plan 

for minimizing dust and odors sufficiently to comply with PSCAA Regulation I, S~ctions

9.11 and 9.15.	 . 

'SoWld Transit cOnuilits to implement the following mitigation measures to reduce, 

potential air quality impacts during construction ofthe project. 

•.	 Use only equipment and trucks that are'main~ined in optimal operational condi~ion.

•	 Require all off-road eqUipment to be retrofit with emission reduction equipment (Le., 

require participation in Puget Sound region Diesel· Solutions by ·project sponsors and 

contractors). . 

.	 . 

•	 Implement construction clrrbs on hot days when region is at risk for exceeding the 

ozone NAAQS, and work at night instead. 

•	 Implement restrictions on construction truck idling (e.g., limit idling to a maximum of 

5 minutes). 

•	 Locate cQnstruction equipment away from sensitive receptors such as fresh .air intakes 

to buildings, air conditioners, and sensitive populations. 

•	 Spray exposed soil with water or other ~uppressant to reduce emissions ofPMl0 and 

deposition of particulate matter. 

•	 Pave or use gravel on staging areas at)d·roads that would be exposed for long periods. 

•	 Cover all trucks transporting material~, wet materials in trucks, or provide adequate 

freeboard (space from the top ofthe material to the top ofthe truck bed), to reduce 

PMlO emissions and deposition during transport. 

March 2009	 Page 8-5 
Appendix B - Mitigation Commitments 

'.	 Provide wheel washers to remove particulate matter that,would otherwise be carried 

off-site by vehicles to decr~ase deposition ofpart~culate matter on area roadways. 

•	 Remove p~rticulate matter deposited on paved, public' roads, sidewalks, and bicycle 

and pedestrian paths. as a result ofthe project co'nstruction in order to reduce~m~d and 

dust; sweep and wash affected streets regularly as 'needed during construction to 

reduce emissions. 

•	 Cover dirt, gravel, and debris pile~ as needed to reduce dust and wind blown debris. 

•	 Route and schedule constructiontrucks:to'reduce delays to traffic during peak travel 

times to r~duce air quality impacts caused by a reduction in traffic speeds. 

Archaeological and Cultural Resources. Mitigation measures to reduce the potential 

-for impacts toarchaeological and ~ultural resources are discussed in Section 4.8.3 of 

theEA. No eviden,ce of cultural resoUrces ~as identified within the'proposed station site. 

Sound Transit will implement the fqlloWing mitigation measures to protect resources if 

any are uncovered:	 ­

•	 Site excavation which exte~ds below fill and into native soils, will'be monitored by a 

professional ar~haeologist.

•	 'If archaeologically significant resources are enco~tered during proposed project 

construction, work shall be halted while DAHP is'consulted to detennine an 

appropriate course of action. 

'.	 Tribe,S with jurisdiction shall be notified in the event potentially significant Native, 

American cultural r~sources are discovered 'during excavations. 

•	 Sound Transit and FTA will prepare'an Inadvertent Discovery Plan'to be followed 

during station construction for excavations into potential native soils. 

Geology and Soils.' Mitigation measures to reduce geology and soil hazards are discussed 

in Section 4.10.3 of the EA. During a seismic event, alluvial soils underlying the site can 

lose cohesion and liquefy or settle. Structures built on these soils could be damaged as a 

result 'ofthese movements. 

Sound Transit makes the following mitigation commitments to address potential 

liquefa~tion or settling impacts to station facilities: ' 

March'2009	 Page 8-6 
Appendix B - Mitigation Commitments 

•	 Implement proper subgrade preparation in embankments and paved areas, and adopt 

modern earthquake-resistant building methods and practices for station-related 

structures to help minimize the potential for damage to structures or pavement during 

seismic events. 

•	 Establish emergency procedures that would detail specific responses to seismic 

events. The responses shall include evacuating station facilitiOes and ii)specting the 

facilities for earthquake damage. Emergency procedures shall be planned in 

coordination with local emergency service providers. 

Utilities and Public Services. As discussed in Section 4.11.3 ofthe EA, careful 

coordination would help minimize impacts to utility and seryice providers during 

construction. Sound Transit makes the following commitment to mitigate impacts on 

public services and u~ilities. ' 

•	 Coordinate with public services and utility providers through development of specific 

construction-related mitigation measures such.as avoidance, scheduling of temporary 

disruptions, or replacement of facilities. C;oordination shall be on-going throughout. 

the construction process~

Safety and Security. Mitigation measures for safety and security concerns are discussed 

in Section 4.12.3 ofthe EA. Sound Transit commits to the following mitigation measures: 

•	 Station design and ~rientation on the site will allow waiting areas to be visually 

acce~sible by police and security patrol cars from adjacent streets'and populated 

areas. , 

•	 Station entrance locations will provide easy access· from Longacres Way (with a 

potential future ·access way comiection proposed at Strander Boulevard), allowing 

monitoring·byo~her passengers and system personnel. . 

•	 . Shelters will be well lit, well maintained, and patrolled by a transit security force to 

ensure passenger safety at waiting areas. . 

•	 Emergency telephon~s will be readily available for individuals to call for help.if 

needed. 

•	 Closed circuit television (CCTV) cameras and monitors will be used to monitor 

activity at the station. . 

•	 For pn-board security, passengers will be informed and educated on personal s·afety 

practices when using transit. 

•	 The proposed self-service fare .system will provide added passenger securitY on 

commuter trains and·buses. Self-service fare systems require transit personnel to be 

present on the vehicles. These individuals, by their presence, will help to deter 

March 2009	 Page B-7 
Appendix B - Mitigation Commitments 

criminal behavior, and' will have the means to respond or react to problem situations 

as they.. occur. 

•	 The·CCTV, security patrols, .and train personnel described above will also help. to 

watch for possible flooding problems in the pedestrian tunnel. Should" flooding occur, 

train operators will be notified so thatpasse~gers would not be deboarded .on the east 

platform and become stranded. 

•	 Soils reports for bridges will be used to identify known earthquake faults in the area, 

geologic-seismic features ofthe area, potential for liquefaction,depthofbedrock and . 

recommended design acceleration at the site. 

•	 All structures will be designed and built according to the most current seismic design 

standards. 

•	 Emergency procedures for responding to. earthquakes shall be' established. In the 

event of an ~arthquake, track work and bridges would need to be inspected 

thoroughly but rapidly, so service can resume as soon as it is .safeto do so. 

•	 Train operators shall betrained in emergency inspection procedures, including visual 

inspection ofthe line and checking the conditiori ofthe rails, signals and switches.. 

The initial assessment·would be followed by a detailed inspection process where. track 

service crews are deployed along the corridor. The crews would conduct close . 

inspections ofea~h track section:to detect changes in·the a1ignment ofthe rail and 

ties,. broken bolts, downed wires, and damage to retaining·walls, embankments, 

bridges .or other structures. 

•	 SoUnd Transit shall follow Federal· Railroad Administration (FRA) track safety 

standards and BNSF safety standards. 

•	 Develop a safety"plan for the proposed commuter rail station prior to the start of 

operations at the new statiol1;. This plan is to be developed in cooperation with Sound 

Transit Security staff and BNSF, and will involve .coordination with all local police 

and fire departments to ensure that emergency access routes and procedures are 

understood by all parties. The safety plan will also include detailed plans for the 

evacuation of trains' an.d station areas. in the event of an emergency. 

Hazardous Ma~erials. As described in Section 4.14.4 of theEA, the co~uter rail 

service will not transport hazardous materials, therefore, no mitigation measures for 

operation ofthe Tukwila'Commuter Rail Statiqn"Project are proposed. In addition, 

exposure ofthe public to hazardous materials during -construction is not expected to 

occur. Construction could pose a risk of small spills, however, from on-site machinery. 

Sound Transit ·commits to the following measures to mitigate for the potential of 

encountering' hazardous materials during construction: 

March 2009	 .Page 8-8 
Appendix B - Mitigation Commitments 

•	 Prepare a site safety plan,' and spill prevention and countermeasures plan. Ensure that 

personnel are trained to recognize potential hazards. Ifhazardous substances are 

encountered, they should be addressed in accordance with applicable regulations. 

•	 Spill control plans'and other site safety measures shall.be implemented as part of the , 

construction process. 

•	 If any suspected contamination is encountered, use prop.er protective equipment 

(clothing, gloves, breathing equipment, etc.) and other measures consistent with 

federal and state,standards'to provide a safer working environment for construction 

vvorkers. ' 

March 2009	 Page 8-9