Appendix J: 

Wetlands

Discipline Report

Point Defiance Bypass 

Project

Wetlands

Discipline Report

September 2012

Point Defiance Bypass Project September 2012

Wetland Discipline Report Page i

Table of Contents

Summary......................................................................................................................................................... 1

Chapter 1 – Project Description ...................................................................................................................... 2

Introduction................................................................................................................................................. 2

Purpose and Need ..................................................................................................................................... 2

What alternatives are being considered for the Point Defiance Bypass Project? ....................................... 3

What’s happening in the bypass corridor today?........................................................................................ 3

What would happen if the Project were not built?....................................................................................... 4

What are the proposed improvements and related activities of the Point Defiance Bypass Project?......... 4

What are the proposed operational changes that would result from the Point Defiance Bypass Project?.. 5

Chapter 2 – Methodology................................................................................................................................ 7

What regulatory authority applies to the Project?....................................................................................... 7

What is the study area for the Project? ...................................................................................................... 8

How was information about wetlands collected?........................................................................................ 8

Chapter 3 – Affected Environment ................................................................................................................ 13

Wetland A................................................................................................................................................. 13

Wetland E................................................................................................................................................. 14

Wetland C................................................................................................................................................. 15

Wetland AB .............................................................................................................................................. 16

What functions do the wetlands provide?................................................................................................. 17

Chapter 4 – Project Effects ........................................................................................................................... 18

Would the Project affect wetlands or wetland buffers?............................................................................. 18

What potential indirect and cumulative effects could occur from the Project?.......................................... 19

Chapter 5 – Recommended Minimization Measures..................................................................................... 20

Best Management Practices..................................................................................................................... 20

References.................................................................................................................................................... 22
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List of Exhibits

Exhibit 1. Build Alternative Components ......................................................................................................... 6

Exhibit 2. Project Wetland Locations............................................................................................................... 9

Exhibit 3. Wetland Descriptions .................................................................................................................... 13

Exhibit 4. Wetland Functions......................................................................................................................... 17
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Wetland Discipline Report Page 1

Summary

This report has been prepared in support of the Point Defiance Bypass 

Project Environmental Assessment and in accordance with the National 

Environmental Policy Act (40 CFR 1500-1508), the State Environmental 

Policy Act (WAC 197-11), and the Federal Railroad Administration’s 

Procedures for Considering Environmental Impacts (64 Fed. Reg. 28550).

The purpose of the Project is to provide more frequent high-speed intercity 

passenger rail service between Tacoma and Nisqually. By increasing rail 

capacity, the Project would support additional Amtrak service between 

Portland, Oregon, and Seattle, Washington. 

The Project is located in Pierce County along an approximately 21-mile 

existing railroad corridor,

1 which passes through portions of the cities of 

Tacoma, Lakewood, and DuPont. The northern limit of the Project is near 

the crossing of Interstate 5 (I-5) over the Puyallup River in Tacoma, while 

the southern limit of the Project is near the crossing of Nisqually Road 

over the Nisqually River.

Four wetlands are present within the study area, defined as the railroad 

right-of-way within approximately 50 feet of the rails.

No effects to wetlands are anticipated. All four wetlands occur outside the 

Project footprint and would not be subject to excavation or fill. No effects 

to wetlands buffers are expected as construction activities would be 

restricted to the existing railroad fill prism.

Since no permanent or temporary effects to wetlands and buffers are 

expected, minimization is not required. Best Management Practices would

be implemented during construction to address the potential for 

construction work to temporarily affect wetlands or buffers.

 1 The three owners of the project corridor are Sound Transit, Tacoma Rail, and BNSF.
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Chapter 1 – Project Description

Introduction

Under the High-Speed Intercity Passenger Rail (HSIPR) Program and 

pursuant to a programmatic Tier I Environmental Assessment (EA) the 

Federal Railroad Administration (FRA) has approved an application from 

the Washington State Department of Transportation (WSDOT) to improve 

the Pacific Northwest Rail Corridor (PNWRC), a federally designated 

high-speed rail corridor. One project included in the PNWRC application 

is the Point Defiance Bypass Project (the Project), which would respond to 

deficiencies in the existing rail operations around Point Defiance. This 

Discipline Report has been prepared in support of the project-specific EA 

for the Point Defiance Bypass project.

The Project is located in Pierce County along an existing approximately 

20-mile rail corridor between Tacoma and Nisqually.2 The Project would 

provide for the re-routing of Amtrak passenger trains from the BNSF rail 

line that runs along the southern Puget Sound shoreline (Puget Sound 

route) to the Point Defiance Bypass route, an existing rail corridor that 

runs along the west side of I-5. The Project would consist of railroad track 

and support facility improvements, and relocation of the Tacoma Amtrak 

Station to Freighthouse Square in Tacoma.

Purpose and Need

As described above, the Point Defiance Bypass route is part of the larger 

PNWRC. Within Washington State, the vision for the PNWRC is to 

“...improve intercity passenger rail service by reducing travel times and 

achieving greater schedule reliability in order to accommodate growing 

intercity travel demand...”3.

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

and Nisqually. In conformity with the decisions under the Tier 1 

Programmatic EA, the PNWRC Improvement Program has reduced the 

overall environmental effects of providing improved passenger rail service 

with the use of an existing transportation corridor and associated 

infrastructure, rather than creating a new corridor. 

 2 The three owners of the project corridor are Sound Transit, Tacoma Rail, and BNSF. 3 WSDOT 2009
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The Project is needed to address the deficiencies in the existing rail 

alignment around Point Defiance. The existing alignment (Puget Sound 

route), shared by freight and passenger rail traffic, is near capacity and is 

therefore unable to accommodate additional high-speed intercity 

passenger rail service without substantial improvements. In addition, the 

existing alignment has physical and operational constraints that adversely 

affect both passenger train scheduling and reliability.

Improving intercity passenger rail service in the project area and meeting 

the Project needs would be accomplished by:

• Enhanced Frequency: Increasing Amtrak Cascades round-trips from four 

to six by 2017 to meet projected service demands.

• Improved Reliability: Reducing scheduling conflicts with freight trains 

that often result in delays, and by minimizing or avoiding operational 

delays (e.g., drawbridge openings) and weather-related delays (e.g., 

mudslides), and improving on-time performance from 68 percent to 88 

percent.

• Enhanced Efficiency: Enhancing the efficient movement of people by 

decreasing trip times by 10 minutes, and reducing the amount of time 

passenger trains spend yielding to freight movements.

• Improved Safety: Constructing at-grade crossings with upgraded safety 

features, including wayside horns, median barriers, advance warning 

signals, and traffic signal improvements.

What alternatives are being considered for the Point 

Defiance Bypass Project?

WSDOT conducted an evaluation of three build alternatives: the Point 

Defiance Bypass Alternative, the Shoreline Alternative, and the Greenfield 

Alternative. Two of the alternatives (the Shoreline Alternative, and the 

Greenfield Alternative) were eliminated from further study. Although both 

alternatives could meet the Project’s purpose and need, they were 

determined to be impracticable and unfeasible due to technical constraints, 

high construction costs, and significant environmental effects. Grade 

separations were also evaluated for further consideration. WSDOT’s 

preliminary analysis revealed that current and projected future traffic 

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

What’s happening in the bypass corridor today?

The rail line between TR Junction and East “D” Street in Tacoma hosts 

both freight and commuter trains, including freight operators Tacoma Rail 

and BNSF, and Sound Transit’s Sounder commuter rail service. Freight 

train traffic between TR Junction and East “D” Street averages under two 
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trains per day, while Sound Transit currently operates 18 trains per day 

between Freighthouse Square and Seattle each weekday, and also offers 

occasional special event trains, usually on weekends, to serve sporting and 

other events in Seattle. Sounder service to Lakewood begins in late 2012.

What would happen if the Project were not built?

If the Project were not built (the No Build Alternative), Amtrak’s 

Cascades and Coast Starlight passenger train service would continue to 

use the existing Puget Sound route. The No Build Alternative includes 

only the minor maintenance and repair activities necessary to keep the 

existing Puget Sound route operational. With the No Build Alternative, it 

would be expected that as freight traffic increases, congestion would 

adversely affect Amtrak service reliability, and the travel time for Amtrak 

trains between Seattle and Portland would increase.

Along the Point Defiance Bypass route, the Tacoma Rail and BNSF 

freight services would continue. The at-grade crossings at Clover Creek 

Drive Southwest, North Thorne Lane Southwest, Berkeley Street 

Southwest, 41st Division Drive, and Barksdale Avenue Southwest would 

not be upgraded.

Sound Transit’s Sounder commuter passenger trains will become 

operational in late 2012 between the Tacoma Dome Station at 

Freighthouse Square in Tacoma and Sound Transit’s Lakewood Station 

(on the Point Defiance Bypass route) with as many as 18 Sounder trains 

per day.

What are the proposed improvements and related activities

of the Point Defiance Bypass Project?

The Project consists of railroad track and support facility improvements, 

and the relocation of Amtrak’s Tacoma Station. Exhibit 1 shows the 

components of the Build Alternative. The following details specific 

components of the Build Alternative.

• Construct New Track Adjacent to the Existing Main Line – A new 

3.5-mile track adjacent to the existing main line would be constructed 

from South 66th Street (Rail MP 6.9) in Tacoma to between Bridgeport 

Way SW (Rail MP 10.4) and Clover Creek Drive SW (Rail MP 10.9) in 

Lakewood.

• Reconstruct and Rehabilitate the Existing Main Line – Starting just 

southwest of Bridgeport Way Southwest (Rail MP 10.4) in Lakewood, the 

existing track would be reconstructed to a location southeast of the I5/Mounts Road Southwest interchange (Rail MP 19.8) at Nisqually 

Junction.
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• Improvements at at-Grade Crossings – Several grade crossings would 

be improved with wayside horns, gates, traffic signals and signage, 

sidewalks, median separators, and warning devices. These crossings 

include Clover Creek Drive Southwest, North Thorne Lane Southwest, 

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

• Tacoma Amtrak Station Relocation – The existing Tacoma Amtrak 

Station would be relocated from its Puyallup Avenue location to the 

Tacoma Dome Station at Freighthouse Square, at 430 E. 25th Street in 

Tacoma.

What are the proposed operational changes that would 

result from the Point Defiance Bypass Project?

Amtrak’s existing Cascades and Coast Starlight passenger train service 

would be rerouted from the Puget Sound route along the Puget Sound 

shoreline to the Point Defiance Bypass route. The Project would also 

provide for additional Amtrak Cascades service by increasing the number 

of round trips provided from 4 to 6, or a total of 12 Cascades service train 

trips. Amtrak Coast Starlight would also travel on the Point Defiance 

Bypass route for a total of two Coast Starlight service train trips. The 

speed of these passenger trains would be up to 79 mph.
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Exhibit 1. Build Alternative Components
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Chapter 2 – Methodology

This section provides an overview of wetland regulations and the study 

methods by which wetlands are described.

What regulatory authority applies to the Project?

Wetlands in the Project vicinity are subject to federal, state, and local 

regulations. The following sections outline the regulations applicable to 

the Project at each level of government. An in-depth list of environmental 

regulations is presented in Attachment A.

Federal Environmental Regulations

Wetlands and streams are considered Waters of the United States. Section 

404 of the Clean Water Act (CWA) regulates placement of fill material in

Waters of the United States, and is administered by the US Army Corps of 

Engineers (USACE).

Washington State Environmental Regulations

Activities that affect wetlands and streams may require a water quality 

certification (CWA Section 401), which is implemented at the state level

by the Washington State Department of Ecology (Ecology). Ecology 

reviews projects for compliance with state water quality standards and 

makes permitting and minimization decisions based on the nature and 

extent of effects, and the type and quality of wetlands/streams being 

affected.

Activities that use, divert, obstruct, or change the flow of a Water of the 

State, including some wetlands, may also require a Hydraulic Project 

Approval (HPA) permit. The Washington State Department of Fish and 

Wildlife (WDFW) is responsible for implementing HPAs under the State 

Hydraulic Code.

In addition to the above regulatory requirements, Washington State 

Department of Transportation (WSDOT) projects are required to meet the 

requirements of the Governor’s Executive Order 89-10 (Protection of 

Wetlands 1989) which commits state agencies to a no net loss policy, and 

the Governor’s Executive Order 90-04 (Protection of Wetlands 1990) that

requires state agencies to rigorously enforce wetland regulations.
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To meet the requirements of these two Executive Orders, WSDOT has 

developed its own regulations to protect wetlands. These regulations are 

described in WSDOT Directive 31-12 Protection of Wetlands Action Plan

(1990) and WSDOT’s Environmental Procedures Manual, Section 431

(March 2006).

WSDOT has also entered into two Memoranda of Agreements (MOAs) 

with regulatory agencies to develop appropriate wetland minimization. 

The MOAs are the WSDOT Wetland Compensation Bank Program 

Memorandum of Agreement (1994) and the Alternative Mitigation Policy 

Guidance Interagency Implementing Agreement: State of Washington 

Alternative Mitigation Policy Guidance for Aquatic Permitting 

Requirements from Ecology and WDFW (2000).

Local Environmental Regulations

The Project passes through portions of the cities of Tacoma, Lakewood,

and DuPont, federal military (Army) installations at Camp Murray and 

JBLM, and portions of unincorporated Pierce County. Municipal 

governments in the study area are required by the Growth Management 

Act to enact regulations to protect critical areas within their jurisdiction, 

including wetlands. The relevant code citations for these ordinances are 

presented in Attachment A.

What is the study area for the Project?

The study area for the Project is defined as the railroad right-of-way, 

which varies in width from approximately 80-100 feet, along the proposed 

rail corridor between approximately Rail MP 38.24X near the crossing of 

I-5 over the Puyallup River in Tacoma to MP 24.7 in Pierce County near 

the crossing of Nisqually Road over the Nisqually River.

How was information about wetlands collected?

In August 2007, a Wetlands Technical Memorandum (WTM) was 

prepared by HDR Engineering, Inc. (HDR) for the Point Defiance Bypass 

Project that identified four wetlands within the Project right-of-way as 

defined at that time (see Exhibit 2), between approximately South 66th

Street in Tacoma and the BNSF main line south of DuPont. Since 2007, 

the Project was subsequently expanded to include additional rail within the 

city limits of Tacoma from approximately South 66th Street north to the 

crossing of I-5 over the Puyallup River. As a result, the study area is the 

same as that evaluated by HDR in 2007 but also includes the new segment 

added within the developed city limits of Tacoma.
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Exhibit 2. Project Wetland Locations
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In order to provide a status update for the wetlands delineated by HDR 

and to determine if additional wetlands are present within the revised 

(expanded) study area, three field visits were conducted by WSDOT on 

March 10, April 14, and June 7, 2011.

Based on the information collected, including observation of the existing 

plant community, hydrology, soils, and wetland boundaries,

4 it is

determined that no new wetlands are present within the revised (expanded) 

study area, and data presented by HDR in its 2007 WTM are still accurate 

in describing the four wetlands.

Accordingly, the wetland information presented in this report is, in large 

part, derived from HDR (2007), with updates incorporated where relevant.

Background Data

The following data sources were reviewed to provide background 

information on vegetation patterns, topography, drainage, and the potential 

for wetlands or wildlife habitats to occur in the Project vicinity:

• National Wetland Inventory (NWI) maps

• Inventory maps for Pierce County, the cities of Tacoma, 

Lakewood, and DuPont, and , Camp Murray, and JBLM

• US Geologic Survey (USGS) 7.5 minute topographic maps

• Natural Resources Conservation Service (NRCS) soils surveys and 

county hydric soils lists

• Aerial photography

• Correspondence with the US Fish and Wildlife Service (USFWS), 

NOAA Fisheries, WDFW, and the Washington State Department 

of Natural Resources (WDNR);

• Threatened, Endangered, and Sensitive (TES) species lists 

maintained by the WDNR Natural Heritage Program, the WDFW 

Priority Habitats and Species Program, and the USFWS and NMFS 

databases

• Cross Base Highway Final EIS (Parametrix 2003)

Wetland Delineation

Wetlands in the study area were delineated by HDR wetland scientists on 

November 17, December 12, and December 22, 2006, using the three 

parameter approach described in the Washington State Wetlands 

 4 Wetlands C and AB are located on BNSF property. WSDOT was escorted to these wetlands by 

BNSF on April 14, 2011, during which BNSF indicated that any updates to the wetland status shall 

be made by BNSF. As such, WSDOT’s evaluation of these two wetlands was limited to a visual 

confirmation of the vegetative community, hydrology, and wetland boundary.
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Identification and Delineation Manual (Ecology 1997) and the Corps of 

Engineers Wetland Delineation Manual (USACE 1987).5

Wetland boundaries were marked with flagging tape, the acreages of 

which were determined based on GIS estimates. A detailed description of 

the field methods employed by HDR and WSDOT is provided in 

Attachment B.

HDR did not delineate wetlands outside the railroad right-of-way within 

federal reservations (JBLM and Camp Murray). In JBLM, existing 

documents were supplemented by a site review with on-site biologists. At 

Camp Murray, staff members indicated that no wetlands are located in the 

area, and access was not allowed. Copies of existing environmental 

documents were provided in lieu of field inspection.

The 2011 Project scope has not been modified to an extent that a wetland 

investigation is necessary outside the railroad right-of-way on the above 

federal reservations.

Wetland Classification and Rating

Wetlands were classified according to the system outlined by the USFWS

in Classification of Wetlands and Deepwater Habitats of the United States 

(Cowardin 1979). The Cowardin system allows for the classification of 

wetlands based on their vegetative and hydrologic characteristics.

Wetland ratings are utilized by regulatory agencies to help determine 

wetland buffers, minimization replacement ratios and permitted uses in 

wetlands. Ratings are based on a wetland’s sensitivity to disturbance, 

rarity within a region, functions, and values. Generally, wetlands that 

haven’t been altered significantly by urbanization, have structural and 

spatial diversity, and are hydrologically connected to streams, have a high 

rating. Attachment C summarizes the wetland rating systems used by

various agencies. 

Wetland Functions and Values

The functions and values of delineated wetlands were evaluated using the 

Wetland Functions Characterization Tool for Linear Projects (Null 2000). 

The method integrates field observations and best professional judgment

regarding 14 wetland functions, including hydrologic, biological, and 

cultural functions, to assign values of low, moderate or high. 

 5 The results of the HDR wetland delineation were verified by WSDOT in the field on June 7, 2011. 

Verified data were transferred to current data sheets derived from the Regional Supplement to the 

Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys, and Coast Region 

(Version. 2.0). 
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Hydrologic functions include flood flow alteration, sediment removal, 

nutrient and toxicant removal, erosion control, shoreline stabilization, and 

production and export of organic matter. Biological functions assessed 

include general habitat suitability, specific habitat suitability (aquatic 

invertebrates, amphibians, wetland mammals, wetland birds, and general 

fish habitat), and native plant richness. Cultural functions include 

educational or scientific use, uniqueness and heritage.

Wetland Buffers

Buffer widths are assigned to wetlands based on their rating. Wetland 

buffers are the adjacent areas that add value to wetlands insofar as they 

can remove sediments, nutrients, and toxics, influence microclimate,

maintain transitional habitat, reduce the effect of nearby disturbances, and 

maintain habitat connectivity (Sheldon et al. 2003).

Wetland buffers are regulated by local jurisdictions. Pierce County and the 

cities of Tacoma, Lakewood, and DuPont have regulations that define and 

protect wetlands. There are no federal regulations requiring buffers for 

wetlands located on federal lands. As such, buffers for wetlands on federal 

lands, if applicable, are assigned based on Pierce County regulations in 

order to determine potential effects.
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Chapter 3 – Affected Environment

Four wetlands were identified in the study area. A description of the 

characteristics of each wetland is provided in Exhibit 3. Wetland 

delineation forms are presented in Attachment D; site photographs are

provided in Attachment E; wetland rating forms are available in 

Attachment F.

Exhibit 3. Wetland Descriptions

Wetland

ID

Cowardin Classification1,5

and HGM Class2,5

Estimated Size

(Acres)3,5 Rating4,5

Jurisdiction and

Buffer6

A PSS

Depressional 0.27 III Lakewood75 feet

E PEM

Riverine 0.3 III

Joint Base Lewis McChord

(Pierce County)

80 feet

C PFO

Slope 1.7 IV Pierce County50 feet

AB PFO

Slope 1.2 III Pierce County80 feet

1 Cowardin et al. (1979).

2 Hydrogeomorphic (HGM) Class (Brinson 1993).

3 Wetland sizes are based on GIS estimates.

4 Wetland ratings are based on Hruby (2004), and City of DuPont Municipal Code, DMC Chapter 

25-105. 5 Verified by WSDOT in April 2011.

6 The buffer would end at the toe of the existing embankment.

Wetland A

Wetland A is approximately 0.27 acre in size, and is located between the 

railroad and Union Avenue Southwest, just south of Thorne Lane 

Southwest. Wetland A is a depressional wetland dominated by scrub-shrub 

vegetation. The following description is based on delineation performed 

by HDR in 2006, supplemented with information from Parametrix (2003), 

and updated by WSDOT in 2011.

Vegetation

The scrub-shrub vegetation is dominated by Pacific willow (Salix lucida 

var. lasiandra) and Himalayan blackberry (Rubus armeniacus). Dominant 

herbaceous species include purple loosestrife (Lythrum salicaria),

softstem bulrush (Scirpus tabermontanii), common cattail (Typha 

latifolia), and reed canarygrass (Phalaris arundinacea). Some areas of 
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Page 14 Wetland Discipline Report

shallow ponding are present on the east side of the wetland in which 

duckweed (Lemna minor) is dominant. The presence of these hydrophytic 

species meets the wetland vegetation criterion.

Hydrology

The primary source of hydrology is an unnamed tributary to American 

Lake that is culverted under I-5 from the east. The presence of surface 

saturation and inundation in 2006 and 2011 meet the wetland hydrology 

criterion.

Soils

Soils vary from a gray (10YR 5/1) gravelly silt loam that extends to a 

depth of 18 inches to very dark gray 10YR 3/1) gravelly sandy loam that 

extends to 12 inches overlying dark grayish brown (2.5Y 4/2) gravelly 

sandy loam with coarse, common, faint olive brown (2.5Y 4/3) 

redoxymorphic features. The low chroma colors of these soils and the 

presence of redoxymorphic features is indicative of hydric soils.

Buffer

Fill slopes surround Wetland A on all sides. The east edge of the wetland 

abuts the railroad fill prism. Undeveloped portions of the wetland buffer 

are dominated by a mixture of upland forest and shrub communities, 

dominated by black cottonwood (Populus balsamifera), red alder (Alnus 

rubra), Oregon white ash (Fraxinus latifolia), Oregon white oak (Quercus 

garryiana), and Douglas fir (Parametrix 2003). Himalayan blackberry is 

the dominant shrub in the buffer, particularly to the east along the railroad 

right-of-way. Soils in the buffers appear to be a mixture of fill material, 

and somewhat lighter colored (10YR 2/2 - 10YR 3/3) gravelly sandy 

loam.

Wetland E

Wetland E is located between the fill prisms of the railroad and I-5. The 

wetland is approximately 40 feet wide, 100 feet long, and encompasses 

approximately 0.3 acre. Wetland E is a riverine wetland dominated by an 

emergent plant community. The following description is based on 

delineation performed by HDR in 2006, updated by WSDOT in 2011.

Vegetation

Common cattail (Typha latifolia) and reed canarygrass (Phalaris 

arundinaceae) are the dominant emergent plants.
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Hydrology

Wetland E receives water as overbank flow from Murray Creek. Culverts 

convey Murray Creek into and out of the wetland. Soils in Wetland E were 

inundated in 2006 and 2011. The presence of inundated areas meets the 

wetland hydrology criterion.

Soils

Soils are composed of a black (10YR 2/1) gravelly sandy loam that

extends from the surface to a depth of 18 inches. The low chroma color of 

this soil is indicative of hydric soils.

Buffer

The fill slope for I-5 abuts Wetland E on the east, and the ballast slope of 

the existing rail line forms the western boundary. Undeveloped areas to 

the north and south occur within the maintained rights of way, dominated 

by mixed grasses, Scot’s broom, and Himalayan blackberry.

Wetland C

Wetland C is located on BNSF property, adjacent to the eastern toe of the 

fill prism, and immediately south of the intersection of the railroad and 

Nisqually Road Southwest. The wetland varies from 20-50 feet wide, and 

is approximately 1.7 acres in size. Wetland C is classified as a slope 

wetland and is forested. The following description is based on delineation 

performed by HDR in 2006, updated by WSDOT in 2011.

Vegetation

Vegetation is dominated by red alder, Himalayan blackberry, and scouring 

rush (Equisetum hymale). The presence of these species meets the wetland 

vegetation criterion.

Hydrology

Water enters Wetland C as seepage from the slope immediately above the

wetland to the east. Water then leaves the wetland via a ditch along the 

existing railroad ballast before being directed under the railroad through a 

culvert. Soils were saturated to the surface in 2006 and 2011, which meets 

the wetland hydrology criterion.

Soils

Soils are composed a gravelly silty clay loam. The A horizon is a dark 

grayish brown color (2.5Y 4/2) that extends from the surface to a depth of 
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eight inches. The B horizon is similar in color but has a few fine, distinct 

dark yellowish brown (10YR 4/4) redoxymorphic features. The low 

chroma colors of these soils and the presence of redoxymorphic features 

are indicative of hydric soils.

Buffer

The railroad fill slope abuts the wetland on the west, and natural slopes are 

present on the north, south, and east. Undeveloped portions of the buffer 

are dominated by a mixture of upland forest and shrub communities. The 

forested areas are dominated by red alder and Himalayan blackberry.

Wetland AB

Wetland AB is located on BNSF property, at the southern end of the study

area, on the east side of the railroad, and south of the intersection of the 

railroad and Nisqually Road Southwest. Present at the bottom of a deep 

draw, and approximately 1.2 acres in size, Wetland AB is a depressional

wetland and is forested. The following description is based on delineation 

performed by HDR in 2006, updated by WSDOT in 2011.

Vegetation

The vegetation in Wetland AB is dominated by red alder, salmonberry, 

and youth-on-age (Tolmiea menziesii). Bracken fern (Pteridium 

aquilinum), vine maple (Acer circinatum), and scouring rush are locally 

dominant. The presence of these species meets the wetland vegetation 

criterion.

Hydrology

Water enters Wetland AB as seepage from the slope immediately above 

the wetland to the east. It is also supplemented by a small, apparently 

seasonal stream on the east side. A debris dam detains water in the 

wetland. Water exits Wetland AB via a small stream that passes through 

an approximately 5-foot diameter concrete culvert in the northern end of 

the wetland. Soils were saturated to the surface in 2006 and 2011. The 

presence of surface saturation meets the wetland hydrology criterion.
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Soils

Soils in Wetland AB are composed a gravelly sandy loam. The A horizon 

is a very dark gray color (10YR 3/1) that extends from the surface to a 

depth of 12 inches. The B horizon is a dark grayish brown (2.5Y 4/2) 

gravelly sandy loam with common, coarse, faint, olive brown (2.5Y 4/3) 

redoxymorphic features. The low chroma colors of these soils and the 

presence of redoxymorphic features are indicative of hydric soils.

Buffer

The slope for the existing railroad fill prism abuts Wetland AB on the 

west, and natural slopes are located to the north, south, and east. 

Undeveloped portions of the buffers are dominated by a mixture of upland 

forest and shrub communities. The forested areas are dominated by red 

alder, salmonberry, and sword fern. Stinging nettle (Urtica dioica), and 

licorice fern (Polypodium glycyrrhiza) are also present on the railroad 

prism. The eastern slope also includes Douglas fir and western red cedar. 

Although low chroma colors and redoxymorphic features were present, the 

soils west of Wetland AB were dry and appear to be well drained.

What functions do the wetlands provide?

The wetlands in the study area provide a variety of wetland functions. A 

summary of the functions is presented in Exhibit 4, and detailed function 

assessment forms can be found in Attachment G.

Exhibit 4. Wetland Functions

Wetland NameFlood Storage andFlow AlterationSediment RemovalNutrient/Toxicant RemovalErosion Control and Shoreline StabilizationOrganic Production and ExportGeneral Habitat SuitabilityHabitat – Aquatic InvertebratesHabitat - AmphibiansHabitat - MammalsHabitat - BirdsHabitat – General FishNative Plant RichnessEducational/Scientific UseUniqueness/Heritage

A M L L L M L L,M M L,M L M L,M -- --

E L L L -- L L,M L L -- L L,M -- -- --

C -- -- -- -- L,M L,M -- L -- -- -- -- -- --

AB L,M M -- M M M H M,H -- M -- L -- --

Functions are qualitatively rated as: -- (None), L (Low), M (Moderate), or H (High).
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Chapter 4 – Potential Project Effects

Effects to wetlands and buffers are assessed by examining the potential for 

disturbance within the Project footprint, including the extent of wetland 

and/or buffer to be cleared, filled, and/or excavated, or temporarily 

disturbed.

Would the Project affect wetlands or wetland buffers?

No Build Alternative

No direct, indirect, or cumulative effects to wetlands or wetland buffers

would result. Amtrak service would continue to operate on the Puget 

Sound route within a landscape disturbed by development and urban 

activity. No additional construction or maintenance activities would result 

from the No Build Alternative.

Build Alternative

Although all four wetlands occur within the railroad right-of-way and 

adjacent to the fill prism, all Project activities near the wetlands would be 

restricted to the fill prism. As such, the wetlands would not be subject to 

excavation or fill, and wetland buffers would not be impacted.

Construction effects to wetlands could occur as a result of the Project and 

result in a short-term loss of wetland functions associated with habitat and 

water quality. Ground disturbance could result in erosion of disturbed soils 

into wetlands and buffer areas, impairing vegetation and habitat. Clearing 

and grading activities in the vicinity of wetlands would have the potential 

to affect surface water quality during seasonal events when surface water 

is present. However, these effects would be avoided or minimized through 

the use of Best Management Practices (BMPs) described below in 

Chapter 5. 

The Project would facilitate an increase in rail capacity, resulting in a 

corresponding increase in visual disturbance and noise. This disturbance 

could marginally reduce the suitability of wetland habitat. However, the 

wetlands are already subject to baseline disturbance from traffic on I-5, 

local roads, and/or the existing rail line and currently offer low quality 

habitat. Thus, the disruption added by an increase in rail capacity is not 

expected to affect wetlands.
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What potential indirect and cumulative effects could occur 

from the Project?

Indirect Effects

The Project is located within an existing rail corridor and urbanized area. 

The only potential indirect effect tied to the Project is that it may 

indirectly influence redevelopment near the relocated Amtrak Station at 

Freighthouse Square (see Land Use Discipline Report6). Such 

redevelopment would be consistent with local zoning and approved by

state and local agencies and would take place in previously disturbed areas 

where wetlands are not present. Thus, no indirect effects to wetland 

resources are expected.

Cumulative Effects

The Project would have no direct or indirect effect on wetlands. Thus, the 

Project would not contribute to a cumulative effect on these resources.

 6 WSDOT 2012
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Chapter 5 – Recommended 

Minimization Measures

Since no permanent or temporary effects to wetlands or wetland buffers 

are expected, minimization and compensation will not be required.

BMPs will be included in the final design to address the potential for 

construction work to temporarily affect wetlands or wetland buffers.

Best Management Practices

The following BMPs will be implemented during construction in order to 

address the potential for wetland effects:

• Construction effects will be confined to the minimum area 

necessary to complete the Project and clearing limits will be 

clearly marked by staking done by the contractor’s surveyor. Areas 

of landscape or vegetative preservation will be protected with 

construction fencing.

• Sensitive areas such as the four identified wetlands within the 

Project limits will be protected from any intrusion by construction 

fencing.

• A Temporary Sediment and Erosion Control (TESC) Plan and 

Stormwater Site Plan will be developed and implemented for all 

projects requiring clearing, vegetation removal, grading, ditching, 

filling, embankment compaction or excavation. The BMPs in the 

plans will be used to control sediments from all vegetation or 

ground disturbing activities.

• BMPs will be implemented for construction activities that occur 

within 150 feet of surface water or wetland habitat as identified by 

the Project biologist, to ensure that no foreign material, such as 

railroad ballast or other material is sidecast, and to control and 

prevent sediments from entering aquatic systems.

• No contractor staging areas will be allowed within 300 feet of any 

jurisdictional wetland, stream, river, or drainage, as identified by 

the Project biologist, unless site-specific review completed by the 

Project biologist indicates that no effects to the sensitive resource 

areas will occur due to topography or other factors.

• Application of chemicals such as fertilizers and pesticides will be 

conducted in a manner and at application rates that will not result 

in loss of chemicals to stormwater runoff.
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• Highly turbid or contaminated dewatering water will be handled 

separately from stormwater and not allowed to enter local drainage 

systems.
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References

Cooke, S.S. 1997. A Field Guide to the Common Wetland Plants of 

Western Washington and Northwest Oregon. Seattle Audubon 

Society, Seattle, Washington.

Cowardin, L.M., V. Carter, F.C. Golet, and E.T. LaRoe. 1979. 

Classification of wetlands and deepwater habitats of the United 

States. Government Printing Office, Washington, D.C.

Ecology (Washington State Department of Ecology). 1997. Washington 

State wetland identification and delineation manual, Publication 

#96-94. Olympia, Washington.

Environmental Laboratory. 1987. Corps of Engineers Wetland Delineation

Manual. Technical Report Y-87-1, Environmental Laboratory, 

Department of the Army, Waterways Experiment Station, 

Vicksburg, Mississippi.

HDR Engineering, Inc. August 2007. Wetland Technical Memorandum for 

the Point Defiance Bypass Project. Prepared for the Washington 

State Department of Transportation.

Hitchcock, C.L. and A. Cronquist. 1973. Flora of the Pacific Northwest.

University of Washington Press, Seattle, Washington.

Hruby, T. 2004. Washington State Wetland Rating System for Western

Washington – Revised. Washington State Department of Ecology 

Publication #04-06-025.

NRCS (Natural Resource Conservation Service). 2003. Field Indicators of

Hydric Soils in the United States. U. S. Department of Agriculture 

in cooperation with the National Technical Committee for Hydric 

Soils.

Null, W.S.; G. Skinner, and W. Leonard. 2000. Wetland functions

characterization tool for linear projects. Washington State 

Department of Transportation, Environmental Affairs Office. 

Olympia.

Pierce County. 2003. Cross-Base Highway Final EIS - Wetland Biology

Discipline Report. Prepared by Parametrix, Inc.

Pojar, J. and A. MacKinnon. 1994. Plants of the Pacific Northwest Coast.

Lone Pine Publishing, Redmond, Washington.
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Wetland Discipline Report Page 23

Reed, P.B., Jr. 1997. Revision of the national list of plant species that 

occur in wetlands. US Department of Interior, Fish and Wildlife 

Service. Washington, D.C.

Sheldon, D., T. Hruby, P. Johnson, K. Harper, A. McMillan, S. Stanley, E.

Stockdale. August 2003 Draft. Freshwater Wetlands in 

Washington State Volume 1: A Synthesis of the Science. 

Washington State Department of Ecology Publication # 03-06-016.

Technical Report WRP-DE-4, Prepared for the US Army Corps of 

Engineers Waterways Experiment Station. Vicksburg, MS.

USDA, NRCS. 2011. The PLANTS Database (http://plants.usda.gov/java/, 

12June 2011). National Plant Data Center, Baton Rouge, LA 

70874-4490 USA.

Washington State Department of Ecology (Ecology). August 2004 Draft.

Wetlands in Washington State Volume 2: Managing and Protecting 

Wetlands. Washington State Department of Ecology Publication # 

04-06-024.

WSDOT (Washington State Department of Transportation). 2000. 

Wetland functions characterization tool for linear projects. 

Washington State Department of Transportation Environmental 

Affairs Office, Wetland Strategic Plan Implementation Project.

WSDOT. 2009. Pacific Northwest Rail Corridor Tier 1 Environmental 

Assessment. Available at: 

http://wadot.wa.gov/Freight/publications/PNWRCReports.htm

WSDOT. 2012. Point Defiance Bypass Project Land Use Discipline 

Report, September 2012.

USFWS (US Fish and Wildlife Service). 1987. National Wetland 

Inventory.

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Wetland Discipline Report Page A-1

Attachment A – Regulatory Authority

Regulation Agency Oversight Resource Protected

Federal

NEPA, 42 USC 4321 Federal agencies

Major actions sponsored, funded, 

permitted, or approved by federal 

agencies

Clean Water Act, 33 USC 1251, Section 

401

US Army Corps of 

Engineers (USACE) 

(administered by 

Ecology)

Waters of the United States

Clean Water Act, 33 USC 1344, Section 

404 USACE Waters of the United States, including wetlands

Rivers and Harbors Act, Section 10, 33 

USC 403, 407 US Coast Guard Navigable waters

DOT Order 5660.1a Federal Highway 

Administration (FHWA) Preservation of the Nation’s wetlands

CZMA, 6 USC 1451, 15 CFR 923-930

USACE (or other federal 

permitting agency), 

Ecology

Coastal zones

Endangered Species Act, Section 7 USFWS, NOAA Fisheries Listed plant and animal species, their 

habitats, and food resources

State

SEPA, WAC 197-11 and 468-12 WSDOT

Major actions sponsored, funded, 

permitted, or approved by state/local 

agencies

Governor’s Executive Order 89-10 

(Protection of Wetlands), 1989 WSDOT, Ecology Wetlands

Governor’s Executive Order 90-04 

(Protection of Wetlands), 1990 WSDOT, Ecology Wetlands

Washington State Water Pollution Control 

Act, RCW 90.48 Ecology Waters of the State

Washington State Growth Management 

Act (GMA), RCW 36.70A Local Agencies Critical areas including wetlands and buffers

Shoreline Management Act, RCW 90.58 Ecology All fish and wildlife within designated 

shoreline zones

Coastal Zone Management See Federal Regulations See Federal Regulations

Wetland Mitigation Banking, RCW 90.84 

(WAC 173-700) Ecology Mitigation banks

Hydrologic Permit Approval (HPA) WDFW Waters of the State

Aquatic Use Authorization

Washington State 

Department of Natural 

Resources

State-owned aquatic lands

WSDOT Directive 31-12 (Protection of 

Wetlands Action Plan), 1990 WSDOT Wetlands 
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Regulation Agency Oversight Resource Protected

Intergovernmental Agreements

Alternative Mitigation Policy Guidance for 

Aquatic Permitting, 2000 WSDOT, Ecology, WDFW Wetland mitigation

Wetland Mitigation Banking Memorandum 

of Agreement, 1994

USACE, Ecology, FHWA, 

NMFS, US Environmental 

Protection Agency, 

USFWS, WDFW

Wetland mitigation banks

Local

DuPont Municipal Code Land Use Code 

(Sensitive Areas), DMC Chapter25-105 City of DuPont Sensitive areas including wetlands,streams, and buffers

City of Lakewood Municipal Code 

Environmental Protection, Chapter 14A City of Lakewood Sensitive areas including wetlands, streams, and buffers

Pierce County Code Development 

Regulations (Critical Areas), Title 18E.30 Pierce County Critical areas including wetlands, streams, and buffers

City of Tacoma Municipal Code Critical 

Areas Preservation, Title 13.11 City of Tacoma Critical areas including wetlands, streams, and buffers
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Attachment B – Field Methodology

In 2006, wetlands were identified and delineated using the three parameter 

method described in Washington State Wetland Identification and 

Delineation Manual (Ecology, 1997). HDR Engineering, Inc., staff 

collected data for each of the three parameters (hydrophytic vegetation, 

hydric soils, and wetland hydrology) in areas that represent typical site 

conditions. Staff collected additional data in associated uplands as needed 

to confirm wetland boundaries. These data were recorded on standard 

wetland delineation data sheets.

Vegetation

The dominant plants and their wetland indicator status were evaluated to

determine if the vegetation was hydrophytic. Hydrophytic vegetation is 

defined as vegetation adapted to wetland conditions. To meet the 

hydrophytic vegetation criterion, more than 50 percent of the dominant 

plants must be Facultative, Facultative Wetland, or Obligate, based on the 

wetland indicator category assigned to each plant species by the USFWS

(Reed 1997). Definitions of the indicator categories follow:

Obligate Wetland Plants (OBL) - Plants that almost always 

(> 99 percent of the time) occur in wetlands, but which may rarely 

(< 1 percent of the time) occur in non-wetlands.

Facultative Wetland Plants (FACW) - Plants that often (67 percent to 99

percent of the time) occur in wetlands, but sometimes (1 percent to 33

percent of the time) occur in non-wetlands.

Facultative Plants (FAC) - Plants with a similar likelihood (34 percent to 

66 percent of the time) of occurring in both wetlands and non-wetlands.

Facultative Upland Plants (FACU) - Plants that sometimes (1 percent to 

33 percent of the time) occur in wetlands, but occur more often 

(67 percent to 99 percent of the time) in non-wetlands.

Upland Plants (UPL) - Plants that rarely (< 1 percent of the time) occur 

in wetlands, and almost always (> 99 percent of the time) occur in 

non-wetlands.

HDR biologists used A Field Guide to the Common Wetland Plants of 

Western Washington and Northwest Oregon (Cooke, 1997) and Plants of 

the Pacific Northwest (Pojar and MacKinnon, 1994) as field references to 

assist with plant identification. Scientific and common plant names follow 

currently accepted nomenclature. Most names are consistent with Flora of 
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the Pacific Northwest (Hitchcock and Cronquist, 1973) and the PLANTS 

Database (USDA, 2011).

Hydrology

Project staff examined the area for evidence of hydrology. Wetland 

hydrology criteria were considered to be satisfied if it appeared that the 

soil was seasonally inundated or saturated to the surface for a consecutive 

number of days greater than or equal to 12.5 percent of the growing 

season. The growing season begins when the soil reaches a temperature of 

41 degrees Fahrenheit in the zone of root penetration. The growing season 

in low elevations in western Washington is typically considered to be from 

March 1 to October 31 (244 days) (Ecology 1997). Primary indicators of 

hydrology include surface inundation and saturated soils. Secondary 

indicators of hydrology include drainage patterns, watermarks on 

vegetation, water-stained leaves, and oxidized root channels.

Soils

Generally, an area must contain hydric soils to be a wetland. Hydric soil 

forms when soils are saturated, flooded, or ponded long enough during the 

growing season to develop anaerobic conditions in the upper part 

(12 inches). Biological activities in saturated soil result in reduced oxygen 

concentrations and organisms turn to anaerobic processes for metabolism. 

Over time, anaerobic biological processes result in certain soil color 

patterns, which are used as indicators of hydric soil. Typically, 

low-chroma colors are formed in the soil matrix, and bright-colored 

redoximorphic features form within the matrix. Soil colors at sample 

locations were determined using the Munsell Color Chart. Other important 

hydric soil indicators observed in the field were recorded. Examples of 

these indicators include organic matter accumulations in the surface 

horizon, reduced sulfur odors, and organic matter staining in the 

subsurface (NRCS, 2003).

Boundary Identification

The delineated wetland boundaries were flagged with sequentially 

numbered, bright pink flagging. Boundaries were numbered in the order in 

which they were encountered in the field, and numbering does not 

necessarily reflect geographic location. Data plot locations were flagged 

with blue and white striped flagging and labeled with the wetland and plot 

number.

2011 WSDOT Wetland Verification

In order to provide a status update for the wetlands delineated by HDR in 

2006 and to determine if additional wetlands were present within the 
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revised (expanded) study area, three field visits were conducted by 

WSDOT on March 10, April 14, May 5, and June 7, 2011.

Evidence of wetland vegetation and hydrology were visually verified. Soil 

test pits were dug to match soils colors against those described by HDR in 

its 2007 WTM. Wetland boundaries observed in the field were compared 

to the 2007 WTM maps and wetland descriptions. Based on the 

information collected in 2011, including observation of the existing plant 

community, hydrology, soils, and wetland boundaries,

7 it is determined 

that no new wetlands are present within the revised (expanded) study area, 

and data presented by HDR in its 2007 WTM is still accurate in describing 

the four wetlands. Updated delineation forms are provided in Attachment 

4.

 7 Wetland C and Wetland AB are located on BNSF property. WSDOT was escorted to these 

wetlands by BNSF on April 14, 2011, during which BNSF indicated that any updates to the wetland 

status shall be made by BNSF. As such, WSDOT’s evaluation was limited to a visual confirmation 

of the vegetative community, hydrology, and wetland boundary.

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Attachment C – Wetland Rating 

System

Regulatory 

Agency

Category

I II III IV

Washington

State

Department of 

Ecology8,9

Category I wetlands represent a unique or 

rare wetland type; or are more sensitive 

to disturbance than most wetlands; or are 

relatively undisturbed and contain 

ecological attributes that are impossible 

to replace within a human lifetime; or 

provide a high level of functions.

Specific wetlands that meet the Category 

I criteria include:

1. Relatively undisturbed estuarine 

wetlands over one acre in size; or 

2. Natural Heritage Wetlands, 

specifically, Wetlands identified by 

the Washington Natural Heritage 

Program/WDNR as high quality 

relatively undisturbed wetlands; and 

Wetlands that support State listed 

threatened or endangered plants;

3. Bogs;

4. Mature and old-growth forested 

wetlands over one acre in size;

5. Wetlands in coastal lagoons; and

6. Wetlands that perform many 

functions very well, as indicated by a 

score of 70 or more points out of 100 

on the wetland rating form.

Category II wetlands 

are difficult, though 

not impossible; to 

replace, and provide 

high levels of some 

functions. 

Specific wetlands 

that meet the

Category II criteria 

include:

1. Estuarine 

wetlands less 

than one acre in 

size, or disturbed 

estuarine

wetlands larger

than one acre;

2. Interdunal 

wetlands greater 

than one acre; 

and

3. Wetlands 

scoring between 

51 and 69 points 

out of 100.

Category III 

wetlands 

provide a 

moderate level 

of functions.

Specific 

wetlands that 

meet the 

Category III 

criteria include:

1. Wetlands 

scoring 

between 30 

and 50 

points out 

of 100 on 

the wetland 

rating 

form; and

2. Interdunal 

wetlands 

between 

0.1 acre 

and 1.0 

acre in 

size.

Category IV

wetlands have 

the lowest 

levels of 

functions and 

are heavily 

disturbed. 

Specific 

wetlands that 

meet the 

Category IV

criteria 

include:

1. Wetlands 

scoring 

less than 

30 points 

out of 100 

on the 

wetland 

rating 

form.

City of 

DuPont10

These are wetlands that are very valuable 

for a particular rare species or represent 

a high quality example of a rare wetland 

type or are rare within the region or 

provide irreplaceable functions and 

values, i.e., they are impossible to replace 

within a human lifetime, if at all.

These are wetlands 

that provide habitat 

for very sensitive or 

important wildlife or 

plants or are difficult 

to replace or provide 

very high functions 

and values, 

particularly for 

wildlife habitat and/or 

their association with 

ground water and 

aquifers. These

wetlands occur more 

commonly than Class 

I wetlands and need a 

high level of 

protection.

Not 

Implemented

City of 

DuPont34

 8 Hruby (2004).

9 The Washington State Wetland Rating System for Western Washington (Hruby 2004) has been 

adopted by the cities of Tacoma, Lakewood and Pierce County.

10 City of DuPont Municipal Code, DMC Chapter 25-105.

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Attachment D – Wetland Delineation 

Forms
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Attachment E – Wetland Photos
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Photo 1. Wetland A. North end, facing west from the Project footprint (2006).

Photo 2. Wetland A. North end, facing west from the Project footprint (2011).
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Photo 3. Wetland East Murray Creek, facing west (2006).

Photo 4. Wetland East Murray Creek, facing north (2011).
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Photo 5. Wetland C. Facing northwest along the BNSF rail (2011).

Photo 6. Wetland C. Culvert through which water flows out of wetland and under BNSF 

rail. Facing northwest (2011).
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Wetland AB. Facing north (2006).

Wetland AB. Facing east and downward from the BNSF rail (2011).

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Attachment F – Wetland Rating 

Forms
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Attachment G – Wetland Function 

Forms
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