Appendix A:

Alternatives Analysis

Point Defiance Bypass Project

Point Defiance Greenfield Alternative

Technical Memorandum

May 2011
ii

Executive Summary

Purpose of the Technical Memorandum

The intent of a technical memorandum is to capture the reasons why an alternative 

should or should not be carried forward for analysis in a project’s environmental 

documentation.

The purpose of this technical memorandum is to:

Evaluate the Greenfield Alternative’s practicality and feasibility from a 

technical, economic, and environmental standpoint under the Federal Railroad

Administration’s (FRA) National Environmental Policy Act (NEPA) 

regulations;

Determine whether the Greenfield Alternative will be carried forward for further 

evaluation in the Point Defiance Bypass Project (the project) Environmental 

Assessment

WSDOT staff, consisting of a multi-discipline team assigned to the delivering the

project, has attempted to provide the required level of analysis to achieve an impartial 

review. The projected or predicted impacts of this alternative have been measured 

against the baseline (the existing facility and surroundings, assuming the project is not 

built). This technical memorandum summarizes WSDOT’s review.

Point Defiance Bypass: Purpose and Need

The purpose of the project is to provide more frequent and reliable high-speed intercity 

passenger rail service between Tacoma and Nisqually. This proposed work addresses a 

number of deficiencies in the existing rail alignment around Point Defiance. The project 

needs are to enhance rail service frequency, reliability, efficiency and safety. The 

existing alignment, shared with freight rail traffic, is near capacity and is unable to 

accommodate additional high-speed intercity passenger rail service without substantial 

improvements. In addition, the existing alignment has physical and operational 

constraints adversely affecting both passenger and freight train scheduling and 

reliability. 

Project Alternatives

The project team, along with members of the Point Defiance Bypass Technical 

Advisory Group, developed six variations of the Greenfield Alternative for analysis. 

The team evaluated each alternative by assessing the degree to which the route met the 

project purpose and need and by looking at the technical, environmental and socioeconomic impacts. 
iii

The majority of the alternatives examined a combination of building new alignments 

and connecting to existing routes. Alternatives also proposed building a tunnel under

the Point Defiance Bypass route, as well as placing the alignment in the I-5 median.

Below is a summary of the cost ranges between the alternatives.

Fredrickson Lakewood 

South

Tacoma 

Tunnel

Rainier Spanaway

Construction Cost $296M -

$988M

$238M -

$792M

$2.4B -

$7.9B

$205M -

$682M

$361M -

$1.2B

Two alternatives met the project Purpose and Need, but resulted in significant technical, 

economic, and/or environmental barriers, including considerable right of way

acquisitions, tight space constraints, wetland impacts and cost concerns.

Impacts to Protected Lands

In areas containing wetlands rated as a Category I (i.e., highest-functioning wetlands),

mitigation costs could reach into the millions, with permits from multiple tribal and 

governmental jurisdictions likely taking a year or longer to acquire.

One alternative in particular was located within the Central Pierce County sole source 

aquifer1 and the Pierce County critical aquifer recharge area.2 The recharge area is in

close proximity to wellhead protection areas.3 If a project violates state or federal 

drinking water regulations, it cannot receive any federal funds.

A number of the alternatives potentially impacted several publicly owned parks,

prehistoric and historic archaeological sites/resources eligible for the National Register 

of Historic Places. These resources are protected under Section 4(f), 49 U.S.C. 303, of 

the Department of Transportation Act. Section 4(f) resources cannot be impacted if a 

feasible and prudent alternative exists that would avoid Section 4(f) resources.

Recommendation

Staff’s recommendation is that the Greenfield Alternative be eliminated from further 

consideration.

WSDOT staff considers this alternative both impractical and unfeasible from a

technical, economic, and environmental standpoint, and will describe it as such in the 

project Environmental Assessment (EA). Because of the Greenfield Alternative’s 

technical and environmental constraints and high cost, WSDOT does not intend to study 

this alternative in detail within the project’s EA, unless new information becomes 

available that would change these findings.

The Greenfield Alternative has more potentially significant impacts than the Bypass 

Alternative, while the Bypass Alternative has fewer potentially significant impacts, and 

1 Designated by the US Environmental Protection Agency

2 Designated by a city or county under the Growth Management Act

3 Group A systems (Washington State Department of Health) serving 15 or more residential connections, or 25 or 

more people per day for 60 days or more per year
iv

better fulfills the project’s purpose and need. Project characteristics evaluated under the 

Engineering and Feasibility and Environmental Impacts sections of this technical 

memorandum present the reasons for recommending the elimination of this alternative.
v

Contents

EXECUTIVE SUMMARY ........................................................................................... II

PURPOSE OF THE TECHNICAL MEMORANDUM ............................................................... II

POINT DEFIANCE BYPASS: PURPOSE AND NEED ............................................................ II

PROJECT ALTERNATIVES ............................................................................................... II

IMPACTS TO PROTECTED LANDS................................................................................... III

RECOMMENDATION ...................................................................................................... III

INTRODUCTION .......................................................................................................... 1

PURPOSE OF THE TECHNICAL MEMORANDUM ............................................................... 1

DESCRIPTION OF GREENFIELD ALTERNATIVE.............................................. 2

RELATIONSHIP BETWEEN POINT DEFIANCE BYPASS ROUTE AND GREENFIELD 

ALTERNATIVES.............................................................................................................. 6

ENGINEERING AND FEASIBILITY......................................................................... 7

EFFICIENCY ................................................................................................................... 8

FREQUENCY................................................................................................................... 8

GEOMETRICS ................................................................................................................. 8

STRUCTURES ................................................................................................................. 8

RIGHT OF WAY ............................................................................................................. 8

CONCLUSION ................................................................................................................. 9

ENVIRONMENTAL IMPACTS ................................................................................ 10

THIS PORTION OF THE TECHNICAL MEMORANDUM DESCRIBES THE GREENFIELD 

ALTERNATIVE’S LIKELY IMPACTS TO THE BUILT AND NATURAL ENVIRONMENTAL...... 10

RESOURCES ................................................................................................................. 10

Air Quality.............................................................................................................. 10

Hazardous Materials.............................................................................................. 10

Noise/Vibration....................................................................................................... 10

Hydrology/Water Quality ....................................................................................... 11

ECOSYSTEMS ............................................................................................................... 11

Fish, Wildlife, Vegetation....................................................................................... 11

Endangered Species Act (ESA)............................................................................... 12

Wetlands ................................................................................................................. 12

HUMAN COMMUNITIES................................................................................................ 14

Socioeconomic/Environmental Justice................................................................... 14

Recreation/Section 4(f) and Section 6(f) ................................................................ 14

Historic/Cultural .................................................................................................... 15

CONCLUSION ............................................................................................................... 15

TECHNICAL MEMO SUMMARY ........................................................................... 16

STAFF RECOMMENDATION.................................................................................. 16
vi

APPENDIX A – COMPARISON OF GREENFIELD ALTERNATIVE TO POINT 

DEFIANCE PROJECT................................................................................................ 18

APPENDIX B – ROUTE LOCATIONS..................................................................... 20
1

Introduction

Purpose of the Technical Memorandum

The intent of a technical memorandum is to capture the reasons why an alternative 

should or should not be carried forward for analysis in a project’s environmental 

documentation.

The Federal Railroad Administration’s (FRA) National Environmental Policy Act 

(NEPA) regulations state that the process of considering environmental impacts “should 

begin by identifying all reasonable alternatives to the proposed action, including ‘no 

action’ and including mitigation measures not incorporated into the design of the 

proposed action.” 

The Council on Environmental Quality describes “reasonable” alternatives as those that 

are practical or feasible from the technical or economic standpoint and use common 

sense rather than simply desirable from the standpoint of the applicant.4

NEPA regulations go on to state “It is entirely proper that the number of alternatives 

being considered should decrease as the environmental consideration process proceeds 

and as analysis reveals that certain alternatives would in fact be unreasonable.” For 

alternatives eliminated from further study, a project’s environmental documentation 

must “briefly discuss the reasons for their having been eliminated”5

. Accordingly, this 

technical memorandum will be appended to the Point Defiance Bypass Project’s

Environmental Assessment (EA) and become a part of the permanent project record.

The purpose of this technical memorandum is to:

Evaluate the Greenfield Alternative’s practicality and feasibility from a 

technical, economic, and environmental standpoint 

Determine whether the Greenfield Alternative will be carried forward for further 

evaluation in the project EA

WSDOT staff, consisting of a multi-discipline team assigned to deliver this project, has 

attempted to provide the required level of analysis to achieve an impartial review. The 

projected or predicted impacts of this alternative have been measured against the 

baseline (the existing facility and surroundings, assuming the project is not built). The 

following information summarizes this review.

4 Forty Most Asked Questions Concerning CEQ’s NEPA Regulations

5 Council on Environmental Quality Regulations, Sec. 1502.14(a)
2

Point Defiance Bypass: Purpose and Need

The purpose of the project is to provide more frequent and reliable high-speed intercity 

passenger rail service between Tacoma and Nisqually. This project addresses the 

deficiencies in the existing rail alignment around Point Defiance. The project needs are 

to enhance rail service frequency, reliability, efficiency and safety. The existing 

alignment, 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 adversely affecting both passenger and freight train scheduling 

and reliability. See the Shoreline Technical Memo for an analysis of the technical and 

economic feasibility of improving the existing alignment.

Specific elements of the project needs include:

Enhanced frequency: Increase Amtrak Cascades round-trips from four to six by 

2017 in order to meet projected service demands.

Enhanced efficiency: Enhance the efficient movement of people by reducing the 

amount of time passenger and freight trains spend yielding to other freight 

movements.

Improved reliability: Reduce or eliminate passenger rail service interruptions 

caused by natural factors (e.g., landslides) or operational limitations (e.g., 

drawbridge closures).

Improved safety: Construct at-grade crossings with improved safety features 

including wayside horns, median barriers, advanced warning signals, and traffic 

signal improvements.

Description of Greenfield Alternative

During the project’s October 2010 Technical Advisory Group (TAG) meeting, the TAG 

brainstormed a rough alignment (the Greenfield Alternative). The Technical Advisory 

Group member jurisdictions consist of the City of Tacoma, City of Lakewood, City of 

Dupont, Pierce County, Joint Base Lewis-McChord, Clover Park School District, 

Washington National Guard – Camp Murray, Sound Transit, and WSDOT. Based on 

suggestions by TAG members following the meeting and additional research, WSDOT 

staff developed several variations of the rough alignment for analysis. The following six

routes were analyzed as part of the Greenfield Alternative. See Appendix B for the 

location of the routes.

Greenfield Alternative - Lakewood South Route

The Greenfield Alternative – Lakewood South route would construct a new alignment 

and reconstruct an existing route. This alternative leaves the BNSF main northeast of 

the Olympia/Lacey station, travels east on a new alignment to just north of Roy, then 
3

turns north and follows the existing BNSF route to Lakewood and continues on the 

baseline route to the Freighthouse Square vicinity.

The length of the improved route is approximately 29 miles with 10 miles of track on a 

new alignment, 10 miles of reconstruction of the existing alignment, and 9 miles on the 

baseline route. The overall route would be single track with a four mile-long segment 

of double track required between Roy and Lakewood. The 10 miles of reconstruction 

includes subballast, ballast, concrete ties, and continuously welded rail. Two existing 

curves slightly over two degrees totally about 0.4 mile would need to be realigned to 

two degrees or less. Two public at-grade crossings between Roy and Lakewood would 

be upgraded with new flashing lights and gates. 

Included with the improvements would be new track, new connections to the BNSF 

main, rebuilt track, centralized traffic control, grade crossings, new Nisqually River 

Valley bridge, and other miscellaneous items.

This alternative would require a number of right-of-way acquisitions and residential 

relocations.

The estimated cost of this alternative ranges from $238 million to $792 million and is 

included in the Appendix A.

Greenfield Alternative - Spanaway Route

The Greenfield Alternative – Spanaway route would construct a new alignment and 

reconstruct an existing route. This alternative leaves the BNSF main northeast of the 

Olympia/Lacey station, travels east on a new alignment to just north of Roy, then turns 

northeast and follows the existing Tacoma Rail Mountain Division route to just south of 

the junction of State Highway 507 and State Highway 7. The alignment then travels 

north on a new alignment through the Spanaway/Brookdale area to a point where the 

Tacoma Rail Mountain Division line passes over State Highway 512 where it rejoins 

the existing rail line to the Freighthouse Square vicinity.

The length of the improved route is approximately 30 miles with 19 miles of track on a 

new alignment and 11 miles of reconstructed existing alignment. The overall route 

would be single track with a four mile-long segment of double track required 

somewhere in the vicinity of the new segment through the Spanaway/Brookdale area. 

The 11 miles of reconstruction includes subballast, ballast, concrete ties, and 

continuously welded rail. Ten existing curves, as sharp as six degrees, and totaling 

about 1.7 miles would need to be realigned to two degrees or less. Twenty-four (24) 

public at-grade crossings would be upgraded with new flashing lights and gates. 

Included with the improvements would be new track, new connections to the BNSF 

main, rebuilt track, centralized traffic control, upgraded existing grade crossings, new 

Nisqually River Valley bridge, and other miscellaneous items.
4

This alternative would require a number of right-of-way acquisitions, residential 

relocations, and commercial relocations.

The estimated cost of this alternative ranges from $361 million to $1.2 billion and is 

included in the Appendix A.

Greenfield Alternative - Fredrickson Route

The Greenfield Alternative – Fredrickson route would construct a new alignment and 

reconstruct an existing route. This alternative leaves the BNSF main northeast of the 

Olympia/Lacey station, travels east on a new alignment to just north of Roy, then turns 

northeast and follows the existing Tacoma Rail Mountain Division route over State 

Highway 507 and on to Fredrickson. The existing alignment then turns and follows the 

existing Tacoma Rail Mountain Division route north – northwest to the Freighthouse 

Square vicinity.

The length of the improved route is approximately 32.5 miles with 10.5 miles of track 

on a new alignment and 22 miles of reconstructed existing alignment. The overall route 

would be single track with a four mile-long segment of double track required 

somewhere between Fredrickson and State Highway 512. The 10.5 miles of 

reconstruction includes subballast, ballast, concrete ties, and continuously welded rail. 

Fifteen (15) existing curves, as sharp as six degrees, totaling about 2.9 miles would 

need to be realigned to two degrees or less. Thirty-three (33) public at-grade crossings 

would be upgraded with new flashing lights and gates. 

Included with the improvements would be new track, new connections to the BNSF 

main, rebuilt track, centralized traffic control, upgraded existing grade crossings, new 

Nisqually River Valley bridge, and other miscellaneous items.

This alternative would require a number of right-of-way acquisitions and residential 

relocations.

The estimated cost of this alternative ranges from $296 million to $988 million and is 

included in the Appendix A.

Greenfield Alternative - Rainier Route

The Greenfield Alternative – Rainier route would reconstruct an existing route. This 

alternative leaves the BNSF main near Offutt Lake (south of Olympia/Lacey station),

which is not consistent with Amtrak’s service objectives for the rail corridor. This 

alternative then follows the existing Tacoma Rail Mountain Division route through 

Rainier, McKenna, and Roy paralleling State Highway 507, then crossing over State 

Highway 507, and on to Fredrickson. The existing alignment then turns and follows the 

existing Tacoma Rail Mountain Division route north – northwest to the Freighthouse 

Square vicinity.
5

The length of the improved route is approximately 44 miles. The overall route would 

be single track with a four mile-long segment of double track required somewhere 

between Fredrickson and State Highway 512 and another four mile-long segment 

between Rainier and Yelm. The reconstruction includes subballast, ballast, concrete 

ties, and continuously welded rail. Fifteen (15) existing curves, as sharp as six degrees, 

and totaling about 2.9 miles would need to be realigned to two degrees or less. Fortysix (46) public at-grade crossings would be upgraded with new flashing lights and gates. 

This route travels south of Centennial Station in Olympia/Lacey, and would therefore 

require the relocation of this station, possibly to the towns of Rainier or McKenna. The 

effects and costs of this station relocation not analyzed in this option.

Included with the improvements would be new track, rebuilt track, centralized traffic 

control, updated existing grade crossings, and other miscellaneous items.

The estimated cost of this alternative ranges from $205 million to $682 million and is 

included in the Appendix A.

Greenfield Alternative – Lakewood to Tacoma Tunnel Route

The Greenfield Alternative – Lakewood to Tacoma tunnel route would construct a new 

alignment through a new tunnel and reconstruct an existing route. This alternative 

follows the Pt. Defiance bypass route from Nisqually to Lakewood, then leaves the 

BNSF main near Lakewood, travels northeast on a new alignment through a 39’ 

diameter, four-mile-long tunnel to north of Midland, then turns north and follows the 

existing Tacoma Rail Mountain Division route north – northwest to the Freighthouse 

Square vicinity.

The length of the improved route is approximately 20 miles with 4.1 miles of track on a 

new alignment and 15.9 miles of reconstruction of the existing alignment. The overall 

route would be single track with a four mile-long segment of double track required 

through the tunnel. The reconstruction includes subballast, ballast, concrete ties, and 

continuously welded rail. Ten existing curves, as sharp as 6 degrees, and totaling about 

1.7 miles would need to be realigned to two degrees or less. Twenty-four (24) public 

at-grade crossings would be upgraded with new flashing lights and gates.

Included with the improvements would be new track, new connections to the BNSF 

main, rebuilt track, centralized traffic control, upgraded existing grade crossings, new 

tunnel, and other miscellaneous items.

This alternative would require right-of-way acquisitions, residential relocations, and 

commercial relocations.

The estimated cost of this alternative ranges from $2.4 billion to $7.9 billion and is 

included in the Appendix A.
6

I-5 Median Route

The I-5 median route would construct a new alignment in the median of I-5 between 

Tacoma and Nisqually. The route would be approximately 18 miles. The existing 

median width varies between 13 feet and 300 feet, with the majority of the spaces

varying between 20 feet to 40 feet. There is a two mile section in the vicinity of the I5/41st Division Dr. S. interchange that is approximately 60 feet wide. There is also a 2.5 

mile section at the most southern end of the route that varies between 55 feet and 300

feet. An approximate 60 foot median would be required to construct the new alignment

at grade. Due to the limited amount of space within the median, this alternative was not 

analyzed beyond an evaluation of the existing median widths.

Relationship between Point Defiance Bypass Route and Greenfield

Alternatives

The Point Defiance bypass route is located inland in Pierce County, and extends 

roughly 28 miles from the Freighthouse Square vicinity in Tacoma, through Lakewood 

and to Centennial Station in Olympia/Lacey, where it connects with the BNSF main line

(see Figure 1). See Appendix A for a comparison of the Greenfield Alternative routes 

and the Point Defiance Bypass route. Below is a summary of major differences 

between the bypass route and Greenfield Alternatives: 

1) The bypass route from Freighthouse Square to Centralia Station is 

approximately 49.8 miles. The Point Defiance bypass route will decrease travel 

time when compared to the baseline (the baseline is the time it takes for the 

Amtrak Cascades to travel between Nisqually Junction and the Tacoma station 

using the current BNSF mainline along the shoreline (the “Shoreline Route”)) .

The length and travel impact of the Greenfield Alternative routes between 

Freighthouse Square and Centennial Station are as follows:

a. Lakewood South Route – approximately 55.1 miles (5.3 miles longer 

than the bypass route) - decreases travel time when compared to the 

current route

b. Spanaway Route – approximately 56.1 miles (6.3 miles longer than the 

bypass route) - decreases travel time when compared to the current route

c. Fredrickson Route – approximately 58.6 miles (8.8 miles longer than the 

bypass route) - increases travel time when compared to the current route 

(does not meet purpose and need)

d. Rainier Route – approximately 58.3 miles (8.5 miles longer than the 

bypass route) - increases travel time when compared to the current route 

(does not meet purpose and need)

e. Lakewood to Tacoma Tunnel Route – approximately 49.7 miles (0.1

miles shorter than the bypass route) - decreases travel time when 

compared to the current route

2) With the exception of the Rainier Route, the Greenfield Alternative creates new

alignments and the impacts associated with pioneering those new alignments.

The bypass route upgrades an existing line for passenger train use.
7

3) With the exception of the Rainier Route, the Greenfield Alternative requires

purchasing a significant amount of right of way (between 12-200 acres).

Because the bypass route utilizes an existing 100-year-old rail corridor, the 

general right-of-way already exists.

As the Route Locations map makes clear, many different design variations could be 

analyzed. The cumulative impacts of pioneering any new alignment through partially

undisturbed lands and through heavily developed lands cannot be avoided and will be 

costly to mitigate (assuming mitigation is feasible). A new route could adversely affect 

resources protected under Section 4(f) to a much greater magnitude than other 

reasonable and prudent alternatives.

Figure 1

Engineering and Feasibility

The Greenfield Alternative concept was considered for the following reasons: 1) 

efficiency and 2) frequency.
8

Efficiency

Three of the six Greenfield Alternative routes (Lakewood South, Spanaway and 

Lakewood to Tacoma tunnel) analyzed would result in a schedule (travel time) 

reduction when compared to the baseline, while two of the six Greenfield Alternative 

routes (the Fredrickson and the Rainier routes) would result in a schedule increase.

With the new alignment, re-construction of the existing track, and realignment of the 

curves associated with the Lakewood South, Spanaway, and Lakewood to Tacoma 

tunnel routes, the alignment would be able to accommodate 79 mph passenger train 

speeds.

Frequency

Construction of any of the Greenfield Alternative routes would accommodate two

additional daily Amtrak Cascades round-trips.

Geometrics

For this conceptual estimate, the ground was assumed to be fairly flat. Therefore, it was 

assumed that the embankment and/or excavation required would be minimal. The 

required footprint for each route was assumed to be 50 feet each side of the track 

centerline along the entire route.

Structures

The Lakewood South, Spanaway and Fredrickson routes would require a new structure 

across the Nisqually River Valley. The structure would be approximately 1 mile-long

and 50 feet wide.

The Lakewood to Tacoma tunnel route would require a four mile tunnel, approximately

39 feet in diameter. The tunnel would be a two-track tunnel with walkways on each 

side. Boring a new tunnel of this size underneath a neighborhood presents many risks. 

Some of the potential risks include the suitability of the soil, the condition of the 

structures and buildings above the proposed tunnel alignment, acquiring the needed 

right of way and substantial cost. These are only a small portion of the risks included 

with this alternative.

Right Of Way

Four of the Greenfield Alternative routes – Lakewood South, Spanaway, Fredrickson,

and Lakewood to Tacoma Tunnel require right of way purchases. The acreage required 

is as follows:

Lakewood South Route – approximately 118 acres including 15 acres of 

residential area, Nisqually Indian Reservation land, and Joint Base Lewis 

McChord (JBLM) property. The new alignment between the Olympia/Lacey 

Station and Roy is near an impact zone on JBLM.

Spanaway Route – approximately 217 acres including 88 acres of densely 

populated residential area, Nisqually Indian Reservation land, and JBLM
9

property. The new alignment between the Olympia/Lacey Station and Roy is 

near an impact zone on the JBLM.

Fredrickson Route – approximately 118 acres including 15 acres of residential 

area, Nisqually Indian Reservation land, and JBLM property. The new 

alignment between the Olympia/Lacey Station and Roy is near an impact zone 

on the JBLM.

Lakewood to Tacoma Tunnel Route – requires purchasing approximately 12

acres of densely populated residential and commercial property

As part of the Greenfield Alternative, right of way would be needed from select federal 

agencies including the JBLM and the Nisqually Indian Tribe, requiring substantial time

for compliance with applicable statutes and regulations specific to the agency or the 

tribe. Depending on the agency or tribe, special documentation may be required and the 

right of way may be acquired as an easement rather than in fee.

Conclusion

The Lakewood South, Spanaway, and the Lakewood to Tacoma Tunnel Routes are 

attractive because they result in schedule reductions when compared to the baseline.

The Lakewood South and Spanaway Routes have major disadvantages. Each route’s 

cost is high due to the construction of a new alignment, rebuilding existing alignments, 

a mile-long bridge, and other various items. The disadvantages also include significant 

federal, state, and private right of way purchases.

The Lakewood to Tacoma Tunnel Route also has major disadvantages. The cost of this 

route is high due to the construction of an approximate four mile-long tunnel, rebuilding 

existing alignments, and other miscellaneous items. Without further analysis, it is 

unknown at this time whether this alternative would even be feasible due to soil 

conditions and other factors. 

The Fredrickson Route and the Rainier Route are not viable options since they both 

increase travel times; therefore, not meeting the purpose and need.

The I-5 median route is not a viable option due to the limited median width throughout 

the majority of the route. A limited median would require the rail line to either be 

elevated on structures, or submerged in a tunnel, both of which result in substantially 

increased cost and risk. Due to the limited amount of space, this alternative was not 

analyzed any further than looking at the existing median widths.
10

Environmental Impacts

This portion of the technical memorandum describes the Greenfield Alternative’s likely 

impacts to the built and natural environmental.

Resources

Air Quality

The Greenfield Alternative is within an area that must meet national air quality 

standards for ozone and carbon monoxide, and in proximity to an area that must meet 

standards for particulates.

During construction, dust particles would be released as a result of construction 

vehicles, equipment and wind erosion over exposed earth surfaces. Fugitive dust

releases fine particles in the air, which is linked to respiratory problems, and generally 

constitutes the largest source of air quality concerns during construction. Most of the 

dust particles would settle out immediately adjacent to the construction areas while a 

small fraction would contribute to dust particle levels in the surrounding area. Air 

quality impacts caused by construction equipment emissions are short term and occur 

only when construction activities are taking place. Mitigation measures would be 

implemented to minimize construction emissions and impacts.

Hazardous Materials

Several hazardous material sites are located within 500 feet of all the Greenfield 

Alternative routes. Additional studies would be necessary to avoid these sites or to 

determine if any new sites exist. If any sites were located within an expanded right of 

way, WSDOT would likely be required to remediate the site(s).

Noise/Vibration

Noise: The Greenfield Alternative routes range in length from approximately 30-44

miles. Noise sensitive receptors within 500 feet of the routes include parks, schools, 

and homes. All receptor sites located along the proposed routes would be subject to 

possible noise impacts.

Noise impacts could be reduced by initiating traffic management measures, acquiring 

land to serve as buffer zones, realigning the rail route, insulating public use or nonprofit 

institutional structures (not residential or commercial buildings), or constructing noise 

barriers. 

Vibration: The Greenfield Routes pioneer new alignments in some cases, and travel 

through dense urban areas in others. A General Vibration Assessment would be required 

for the Greenfield routes. If the general assessment determines that there are significant 

adverse vibration impacts, then a Detailed Vibration Assessment would be prepared.
11

Hydrology/Water Quality

The new alignments of the Fredrickson, Lakewood South, and Spanaway Routes would

cross several waterbodies, including the Nisqually River, Muck Creek, and Lacamas 

Creek. Additionally, the Spanaway Route will cross the North Fork Clover Creek, 

which is on the Washington State Department of Ecology’s 303(d) listed waterbodies

for fecal coliform.

The Fredrickson, Lakewood South, and Spanaway Routes would require a new milelong, 50-foot wide structure to cross the Nisqually River Valley, including the Nisqually 

River. The quantity of fill material necessary to build the structure is unknown since 

the details of these routes were not done to the level that they could be quantified. An 

aerial structure built on footings or pilings would reduce the environmental impacts 

associated with placing fill material, but would likely cost several times more than a 

railroad built on embankment.

All six routes are within the Central Pierce County sole source aquifer,6 the Pierce 

County critical aquifer recharge area,7 and are in proximity to wellhead protection 

areas.8 WSDOT would need to work with the appropriate entities regarding appropriate 

protective and mitigation measures. Federal funds may not be expended unless a 

project is designed to avoid any violation of federal or state drinking water regulations.

It is unknown if the Greenfield Alternative would have a substantial impact on water 

quality or water resources at this time. Further study would be necessary to determine 

the extent of these impacts.

Ecosystems

Fish, Wildlife, Vegetation

Property would need to be acquired as right-of-way for the Greenfield Alternative,

some of which is developed. Some of this acreage is likely to be wildlife habitat, which 

would have a direct impact on wildlife.

Route Total ROW Acres Residential Acres Sub-Total

Fredrickson 118 15

Lakewood South 118 15

Rainier 0 0

Spanaway 217 88

Tacoma Tunnel 12 12

6 Designated by the US Environmental Protection Agency

7 Designated by a city or county under the Growth Management Act

8 Group A systems (Washington State Department of Health) serving 15 or more residential connections, or 25 or 

more people per day for 60 days or more per year
12

The US Fish and Wildlife Service (USFWS) has listed the following species in Pierce 

County: bull trout (including designated critical habitat), Canada lynx, gray wolf, 

grizzly bear, marbled murrelet (including designated critical habitat), and northern 

spotted owl (including designated critical habitat). Additionally, there are eight 

candidate species, and 26 species of concern. Further study would be necessary to 

determine the impacts to fish, wildlife, and vegetation.

Endangered Species Act (ESA)

Unavoidable impacts to listed threatened species could occur if the Greenfield 

Alternative routes are constructed, and a Biological Assessment will be required to 

determine this alternative’s impact on those species and their habitats. The timeframe 

for formal consultation under Section 7 of the ESA, for larger projects in the Puget 

Sound area, generally exceeds one year and may take up to two years to complete. 

Mitigating for potential impacts to threatened or endangered species’ habitat would 

require the creation or restoration of equivalent habitat near the project. The regulatory 

requirements and costs of such mitigation would depend on the final alternative 

alignment and the result of consultation with the regulatory agencies.

Wetlands

The preliminary design information available at the time of this analysis suggests that 

wetlands may be impacted by the Greenfield Alternative. Further study would be 

necessary to determine the actual impacts to wetlands. Wetland impacts must be 

mitigated in accordance with federal, state, and local regulations.

Route Total Wetlands Impacted Total Acres Impacted

Fredrickson 19 6.7

Lakewood South 14 5.2

Tacoma Tunnel 3 0.8

Rainier 21 5.9

Spanaway 18 6.6

Wetland impacts would be reduced to the greatest practicable extent by designing and 

implementing minimization and mitigation measures. However, for unavoidable 

impacts, the cost to mitigate is highly variable depending on the rating of the impacted 

wetlands (Categories I-IV), the type of mitigation implemented (preservation, 

enhancement, and/or creation), and the price of real estate. Construction costs and the 

cost to subsequently monitor the mitigation site(s) (up to 10 years or more) are 

somewhat more stable, and therefore can be predicted with a higher level of confidence.
13

Assuming all the wetlands identified during this analysis rated as a Category I (i.e., 

highest-functioning wetlands), the following two cost scenarios9 were developed:

1. The lower cost scenario, which would require a 3:1 creation/restoration ratio10

2. The higher cost scenario, which would require a 6:1 creation/restoration ratio

per 

Class I acre impacted and include a 150-foot buffer. 

10 per 

Class I acre impacted and include a 300-foot buffer.

Based on the above requirements, the following acreages and associated costs would be 

needed for each route:

Route 3:1 Ratio Cost11,12,13 6:1 Ratio Cost11,12,13

Fredrickson 20.1 acres $5.2M 40.2 acres $10.3M

Lakewood South 15.6 acres $4.0M 31.2 acres $8.0M

Tacoma Tunnel 2.4 acres $0.6M 4.8 acres $1.2M

Rainier 17.7 acres $4.5M 35.4 acres $9.1M

Spanaway 19.8 acres $5.1M 39.6 acres $10.2M

These cost scenarios only address the cost of constructing the wetlands; they do not 

address the costs of locating and purchasing the real estate for these sites or their buffer 

acreages.

These estimates would be refined only after accurately identifying wetland boundaries 

and assessing their functions and values. This would be accomplished by delineating

and rating each wetland. It is also possible that additional wetlands could be discovered 

during the fieldwork, which would increase mitigation costs.

Approvals would be required from the following agencies:

US Army Corps of Engineers – Section 404 of the Clean Water Act, which 

also includes determining the Least Environmentally Damaging Practicable 

Alternative (LEDPA); Section 10 of the Rivers and Harbors Appropriation Act

WA State Department of Ecology – Section 401 of the Clean Water Act;

Coastal Zone Management Consistency Certification

WA State Department of Fish and Wildlife – Hydraulic Project Approval

Local jurisdictions – Shorelines; Floodplain Development; Critical Area 

Ordinances

Because of the many jurisdictions involved, acquiring the necessary approvals could 

take a year or longer.

9 Based on 2006 guidance, and input from Geoff Gray, SCR Biologist, on September 9, 2010.

10 Creation/restoration ratios are determined by the US Army Corps of Engineers if a Section 404 Individual Permit is 

issued.

11 A total of $256,784/acre. This total was inflated by 15% from the 2006 guidance of $223,290/acre. The cost has 

been rounded to the nearest $100,000 for the purposes of this analysis.

12 This total does not include real estate acquisition costs. 13 This cost does not include the area required for the buffer.
14

Human Communities

Socioeconomic/Environmental Justice

The Greenfield Alternative could potentially impact private residences, private 

businesses, Joint Base Lewis-McChord, and the Nisqually Indian Reservation. The 

2009 poverty guideline for a family of four is $22,050; within the study area, the 

median income is above the poverty guideline. 

Route Average Median Income Minority Population

Fredrickson $50,374 30%

Lakewood South $39,875 36%

Tacoma Tunnel $46,810 40%

Rainier $51,510 25%

Spanaway $51,811 33%

Further study is necessary in order to determine whether minority or low-income 

populations would be disproportionately affected.

Private residences and businesses would be displaced by the Greenfield Alternative.

Any individuals or businesses that would be displaced as a result of implementing this 

alignment would be provided with relocation assistance under the Uniform Relocation 

Assistance and Real Property Acquisition Policies Act (42 USC 4601).

Recreation/Section 4(f) and Section 6(f)14

The Greenfield Alternative as currently designed would impact several publicly owned 

parks, which are Section 4(f) resources. Impacts could include increased noise levels, 

displacement and/or change in access.

Section 4(f), 49 U.S.C. 303, of the Department of Transportation Act states that the 

Federal Railroad Administration will not approve the use of land from a significant 

publicly owned park, recreation area, or wildlife and waterfowl refuge, or a 

prehistoric/historic site that is on or eligible for the National Register of Historic Places

(NRHP), unless the determination is made:

1) There is no feasible and prudent alternative to the use of land from the 

property

2) The proposed action includes all possible planning to minimize harm to the 

property resulting from such use

Supporting information demonstrates that there is a feasible and prudent alternative that 

would avoid these Section 4(f) resources. Because another alternative exists that does 

14 Property purchased with Land and Water Conservation Act funds
15

not impact Section 4(f) resources, the Greenfield Alternative should be considered and 

rejected.

Historic/Cultural

Preliminary research indicates that the Greenfield Alternative could potentially impact 

the following recorded prehistoric and historic archaeological sites/resources:

Fredrickson Route: 24 sites

Lakewood South Route: 25 sites

Tacoma Tunnel Route: 1 site

Rainier Route: 19 sites

Spanaway Route: 25 sites

Some of these sites/resources could be eligible for listing on the NRHP and could 

trigger a Section 4(f) analysis. Section 4(f) of the Department of Transportation Act

requires an analysis to show that there is no prudent and feasible alternative to using 

such a resource. If there is no prudent and feasible avoidance alternative, then WSDOT 

must demonstrate that the project includes all possible planning to minimize harm to the 

Section 4(f) resource. Historic/cultural sites and resources and their potential 

importance would require extensive study and consultation with agencies with 

jurisdiction and affected Indian tribes. This consultation could play a major role in 

developing or modifying this alternative. Excavations for data recovery and historic 

research would likely be needed for some of these sites/resources.

Section 106 of the National Historic Preservation Act would require any such impact to 

properties on or eligible for the NRHP to complete a 4(f) Evaluation. This process is 

discussed in the preceding Recreation/Section 4(f) and Section 6(f) sub-section.

Conclusion

Because the Greenfield Alternative would build a new rail alignment, it creates more 

impacts compared to either improving the Point Defiance Bypass (the proposed action) 

or the no action alternative. The impacts are as follows:

Section 4(f) resources such as several publicly owned parks 

Wildlife habitat that supports threatened species 

Private residences, private businesses, a portion of JBLM, and the Nisqually 

Indian Reservation

Up to approximately 10.9 acres of wetlands 

Up to 25 cultural/historic resources

Possible disproportionate adverse effects to minority populations

See Appendix A for a summary of the environmental impacts.
16

Technical Memo Summary

The Greenfield Alternative includes three routes (Lakewood South Route, Spanaway 

Route, Lakewood to Tacoma Tunnel Route) that would meet the project purpose and 

need. Although these routes meet the project’s purpose and need, there are many 

challenges and obstacles including the following:

Lakewood South Route, Spanaway Route

o Construction of an approximately one mile-long bridge over the 

Nisqually River Valley

o Require upgrading up to 24 at-grade crossings

o Acquisition of a significant amount of right of way from many different 

types of owners including residential, commercial, Nisqually Indian 

Reservation, JBLM, cities, and other federal, state, and private entities

o The new alignment between the Olympia/Lacey Station and Roy is near 

the artillery impact zone on JBLM

o Potential impacts to endangered species

o Potential significant impacts to socioeconomic resources.

Lakewood to Tacoma Tunnel Route

o High cost and associated risks of constructing a four mile-long tunnel 

o Potential impacts to endangered species

o Potential impacts to socioeconomic resources

Between 0.8 acre (Tacoma tunnel route) and 6.6 acres (Spanaway route) of wetlands 

may be impacted by the Greenfield Alternative. Assuming that all the wetlands rated as 

a Category I (i.e., highest-functioning wetlands), the mitigation cost could range from 

approximately $0.6 million15 to $10.2 million.16 Permits from multiple jurisdictions 

would likely take a year or longer to acquire.

The Greenfield Alternative is within the Central Pierce County sole source aquifer, the 

Pierce County critical aquifer recharge area, and is in proximity to wellhead protection 

areas. If a project violates state or federal drinking water regulations, it cannot receive 

any federal funds.

Staff Recommendation

Staff’s recommendation is that the Greenfield Alternative be eliminated from further 

consideration.

WSDOT staff considers this alternative both impractical and unfeasible from a

technical, economic, and environmental standpoint, and will describe it as such in the 

project Environmental Assessment (EA). Because of the Greenfield Alternative’s 

technical and environmental constraints and its high cost, WSDOT does not intend to 

15 The lower cost scenario at a 3:1 creation/restoration ratio 16 The higher cost scenario at a 6:1 creation/restoration ratio
17

study this alternative in detail within the project’s EA, unless new information becomes 

available that would change these findings.

The Greenfield Alternative has more potentially significant impacts compared to the 

bypass alternative. The Point Defiance bypass alternative has fewer potentially 

significant impacts and better fulfills the project’s purpose and need. Project 

characteristics evaluated under the Engineering and Feasibility and Environmental 

Impacts sections of this technical memorandum, make clear the reasons for 

recommending the elimination of this alternative.
18

Appendix A – Comparison of Greenfield Alternative to Point 

Defiance Project
Comparison of Greenfield Alternative to Point Defiance Bypass Project

Fredrickson Lakewood 

South

Tacoma 

Tunnel

Rainier Spanaway Pt. 

Defiance 

Bypass1

Design

Length of the Route to be 

Improved

32.5 miles 29 miles 20 miles 44 miles 30 miles 13 miles

Change in route length 

compared to the water level 

route

2.8 miles longer 0.7 miles 

shorter

6.1 miles 

shorter

2.5 miles 

longer

0.3 miles longer 6 miles 

shorter

New/Reconstructed Track 10.5 miles/22 

miles

10 miles/10 

miles

4.1 miles/28.4

miles

0 miles/44

miles

19 miles/11 

miles

2.5 

miles/11.5 

miles

At-Grade Crossings Upgraded 33 2 24 46 24 10

Construction Cost10 $296M - $988M $238M -

$792M

$2.4B - $7.9B $205M -

$682M

$361M - $1.2B $59.6M

Increase/Decrease Travel 

Time

Increase Decrease Decrease Increase Decrease Decrease

Accommodates 2 Additional 

Amtrak Cascades Daily Trips

Yes Yes Yes Yes Yes Yes

Total ROW Required/ 

Residential ROW

118 acres/15 

acres

118 acres/15 

acres

12 acres/12

acres

0 acres 217 acres/88 

acres

1.3 acres/<1 

acre

Potential Environmental Impacts

Hazardous Materials: Sites 

Within 500’

Yes Yes Yes Yes Yes Yes

ESA2: Species Permanently Yes

Affected

Yes Yes No Yes No

Wetlands: Total Impacted3 6.7 acres 5.2 acres 0.8 acre 5.9 acres 6.6 acres 0 acres

Wetlands: Mitigation Ratio4

(3:15/6:16

20.1 acres/40.2 

) acres

15.6 acres/31.2 

acres

2.4 acres/4.8 

acres

17.7 acres/35.4 

acres

19.8 acres/39.6 

acres

N/A

Wetlands: Mitigation Cost7,8 $5.2M/$10.3M

(3:1/6:1)

$4.0M/$8.0M $0.6M/$1.2M $4.5M/$9.1M $5.1M/$10.2M N/A

Socioeconomic/Environmental 

Justice: % Minority Population

30% 36% 40% 25% 33% 39%

Recreation/Section 4(f) 9 and Yes

6(f): Resources Impacted

Yes Yes Yes Yes No

Historic/Cultural: Resources 

Impacted

24 sites 25 sites 1 site 19 sites 25 sites 0 sites

Note: Since the information was the same for all the routes, no information is being provided in this comparison 

table for Air Quality (Attainment Area), Noise (Sensitive Receptors), Hydrology/Water Quality (Proximity to 

Sensitive Surface or Ground Waterbodies), or Socioeconomic/Environmental Justice (2009 Poverty Guidelines and

Average Median Income). See the sub-section for more information.

 1 Point Defiance Bypass Project Environmental Summary (May 2008), and supporting discipline reports; the Environmental Summary analyzed only to S. 66th Street in 

Tacoma, which was the northern extent of the project at that time

2 The timeframe for formal consultation under Section 7 of the ESA, for larger projects in the Puget Sound area, generally exceeds one year and may take up to two 

years to complete

3 Assumes all the wetlands identified during this analysis rated as a Category I (i.e., highest-functioning wetlands) 4 The US Army Corps of Engineers determines creation/restoration ratios if a Section 404 Individual Permit is issued 5 The lower cost scenario, which would require a 3:1 creation/restoration ratio per Class I acre impacted and include a 150-foot buffer. 6 The higher cost scenario, which would require a 6:1 creation/restoration ratio per Class I acre impacted and include a 300-foot buffer 7 A total of $256,784/acre based on 2006 guidance, and input from Geoff Gray, SCR Biologist, on September 9, 2010; this total was inflated by 15% from the 2006 

guidance of $223,290/acre and has been rounded to the nearest $100,000 for the purposes of this analysis

8 This cost does not include real estate acquisition costs or the area required for the buffer 9 FRA will not approve the use of a Section 4(f) resource unless a determination is made that 1) there is no feasible and prudent alternative to the use of land from 

the property; and 2) the proposed action includes all possible planning to minimize harm to the property resulting from such use; supporting information 

demonstrates that there is a feasible and prudent alternative that would avoid these Section 4(f) resources

10 Per the “Cost Estimating Manual for WSDOT Projects”, an estimate range of -40% to 100% was used for a 1% to 15% project maturity (% of design completed)
20

Appendix B – Route Locations
Point Defiance Bypass Project 

Point Defiance Shoreline Alternative 

Technical Memorandum 

May 2011 
ii 

Executive Summary 

Purpose of the Technical Memorandum 

The intent of a technical memorandum is to capture the reasons why an alternative 

should or should not be carried forward for analysis in a project’s environmental 

documentation. 

The purpose of this technical memorandum is to: 

• Evaluate the Shoreline Alternative’s practicality and feasibility from a technical, 

economic, and environmental standpoint under the Federal Railroad 

Administration’s (FRA) National Environmental Policy Act (NEPA) 

regulations; and 

• Determine whether the Shoreline Alternative will be carried forward for further 

evaluation in the Point Defiance Bypass Project (the project) Environmental 

Assessment. 

WSDOT staff, which consists of a multi-discipline team assigned to the production of 

the project, has attempted to give as thorough of an analysis as required to achieve an 

impartial review. The projected or predicted impacts of this alternative have been 

measured against the baseline (the existing facility and surroundings, assuming the 

project is not built). This technical memorandum summarizes WSDOT’s review. 

Point Defiance Bypass: Purpose and Need 

The purpose of the project is to provide more frequent and reliable high-speed intercity 

passenger rail service between Tacoma and Nisqually. The proposed work addresses a 

number of deficiencies in the existing rail alignment around Point Defiance. The project 

needs are to enhance rail service frequency, reliability, efficiency, and safety. The 

existing alignment, shared with rail traffic, is near capacity and is unable to 

accommodate additional high-speed intercity passenger rail service without substantial 

improvements. In addition, the existing alignment has physical and operational 

constraints adversely affecting both passenger and freight train scheduling and 

reliability. 

Description of Project Alternative

The Shoreline Alternative would make improvements within the 26 mile-long existing 

route between Nisqually and Tacoma. See Appendix B for the route location. 

The Shoreline Alternative consists of adding eight miles of new track and re-aligning 15 

miles of existing track. The Shoreline Alternative adds a third track inland along the 

existing route between milepost 3.22 near Old Town Tacoma and milepost 10 near 

Titlow Park. The third track would also have a parallel access road. All the curves 

between Old Town Tacoma and south of Nisqually will be realigned to accommodate 

79 mph passenger train speeds. 
iii 

Conclusion 

Although the Shoreline Alternative can meet the project purpose and need, it creates the 

following challenges and obstacles: 

• Rail congestion would continue due to passenger and freight sharing the same 

right of way. 

• Substantial amounts of right of way acquisitions from multiple owners and 

businesses would result in additional costs and schedule delays. 

• Significant cost and schedule impacts from elimination or relocation of a boat 

moorage and pleasure boat-related business. 

• Considerable added cost resulting from1.7 million cubic yards of excavation 

including 100 acres of clearing and grubbing. 

• Impact aesthetics along the shoreline due to more than six miles of retaining 

walls and the vast amount of excavation required. 

The Shoreline Alternative proposes to fill in nearly three miles of shoreline, and would 

impact approximately 1.9 acres of wetlands. If these wetlands rated as a Category I (i.e., 

highest-functioning wetlands), mitigation costs could reach into the millions, and it 

would likely take a year or longer to acquire permits from multiple governmental 

jurisdictions. 

The Shoreline Alternative is located within the Central Pierce County sole source 

aquifer, and the Pierce County critical aquifer recharge area. The recharge area is in 

close proximity to wellhead protection areas. If a project violates state or federal 

drinking water regulations, it cannot receive any federal funds. 

The Shoreline Alternative impacts portions of the Nisqually National Wildlife Refuge 

along with several publicly owned parks, and prehistoric and historic archaeological 

sites/resources, some of which could be eligible for the National Register of Historic 

Places. These resources are protected under Section 4(f), 49 U.S.C. 303, of the 

Department of Transportation Act. Section 4(f) resources cannot be impacted if a 

feasible and prudent alternative exists that would avoid Section 4(f) resources. 

Recommendation 

Staff’s recommendation is that the Shoreline Alternative be eliminated from further 

analysis. 

WSDOT staff considers this alternative both impractical and unfeasible from a technical 

and economic standpoint, and will describe it as such in the project Environmental 

Assessment (EA). Because of the Shoreline Alternative’s technical and environmental 

constraints and its high cost ($1.42 billion to $1.64 billion), WSDOT does not intend to 

study this alternative in detail within the project’s EA, unless new information becomes 

available that would change these findings. 
iv 

The Shoreline Alternative has more potentially significant impacts than the bypass 

alternative, while the bypass alternative has fewer potentially significant impacts, and 

better fulfills the project’s purpose and need. Project characteristics evaluated under the 

Engineering and Feasibility and Environmental Impacts sections of this technical 

memorandum explain the reasons for recommending the elimination of this alternative. 
v 

Contents

EXECUTIVE SUMMARY ........................................................................................ II

PURPOSE OF THE TECHNICAL MEMORANDUM ............................................................. II

POINT DEFIANCE BYPASS: PURPOSE AND NEED .......................................................... II

DESCRIPTION OF PROJECT ALTERNATIVE .................................................................... II

CONCLUSION ............................................................................................................ III

RECOMMENDATION................................................................................................... III

INTRODUCTION ...................................................................................................... 5

PURPOSE OF THE TECHNICAL MEMORANDUM ............................................................. 5

POINT DEFIANCE BYPASS: PURPOSE AND NEED .......................................................... 5

DESCRIPTION OF SHORELINE ALTERNATIVE ............................................... 6

RELATIONSHIP BETWEEN BYPASS ROUTE AND SHORELINE ALTERNATIVES .................. 6

ENGINEERING AND FEASIBILITY ...................................................................... 8

EFFICIENCY ............................................................................................................... 8

FREQUENCY ............................................................................................................... 8

GEOMETRICS ............................................................................................................. 8

STRUCTURES ............................................................................................................. 9

RIGHT OF WAY ......................................................................................................... 9

MAINTENANCE ........................................................................................................ 10

CONCLUSION ........................................................................................................... 11

ENVIRONMENTAL IMPACTS ............................................................................. 11

RESOURCES ............................................................................................................. 11

Air Quality .......................................................................................................... 11

Hazardous Materials ........................................................................................... 11

Noise/Vibration ................................................................................................... 12

Hydrology/Water Quality .................................................................................... 12

ECOSYSTEMS ........................................................................................................... 13

Fish, Wildlife, Vegetation .................................................................................... 13

Endangered Species Act (ESA) ............................................................................ 13

Wetlands and Shorelines ..................................................................................... 13

HUMAN COMMUNITIES ............................................................................................ 15

Socioeconomic/Environmental Justice ................................................................. 15

Recreation/Section 4(f) and Section 6(f) .............................................................. 15

Historic/Cultural ................................................................................................. 16

CONCLUSION ........................................................................................................... 16

TECHNICAL MEMO SUMMARY ......................................................................... 16

STAFF RECOMMENDATION ............................................................................... 17

APPENDIX A – COMPARISON OF SHORELINE ALTERNATIVE TO POINT 

DEFIANCE BYPASS PROJECT ............................................................................ 18
vi 

APPENDIX B – ROUTE LOCATION .................................................................... 19
5 

Introduction 

Purpose of the Technical Memorandum 

The intent of a technical memorandum is to capture the reasons why an alternative 

should or should not be carried forward for analysis in a project’s environmental 

documentation. 

The Federal Railroad Administration’s (FRA) National Environmental Policy Act 

(NEPA) regulations state that the process of considering environmental impacts “should 

begin by identifying all reasonable alternatives to the proposed action, including ‘no 

action’ and including mitigation measures not incorporated into the design of the 

proposed action.” 

The Council on Environmental Quality describes “reasonable” alternatives as those that 

are practical or feasible from the technical or economic standpoint and use common 

sense rather than simply desirable from the standpoint of the applicant.1

NEPA regulations go on to state “It is entirely proper that the number of alternatives 

being considered should decrease as the environmental consideration process proceeds 

and as analysis reveals that certain alternatives would in fact be unreasonable.” For 

alternatives eliminated from further study, a project’s environmental documentation 

must “briefly discuss the reasons for their having been eliminated”2

. Accordingly, this 

technical memorandum will be appended to the Point Defiance Bypass Project’s 

Environmental Assessment (EA) and become a part of the permanent project record. 

The purpose of this technical memorandum is to: 

• Evaluate the Shoreline Alternative’s practicality and feasibility from a technical, 

economic, and environmental standpoint under NEPA regulations 

• Determine whether the Shoreline Alternative will be carried forward for further 

evaluation in the project EA 

WSDOT staff, consisting of a multi-discipline team assigned to deliver this project, has 

attempted to provide the required level of analysis to achieve an impartial review. The 

projected or predicted impacts of this alternative have been measured against the 

baseline (the existing facility and surroundings, assuming the project is not built). The 

following information summarizes this review. 

Point Defiance Bypass: Purpose and Need 

The purpose of the project is to provide more frequent and reliable high-speed intercity 

passenger rail service between Tacoma and Nisqually. This project addresses the 

deficiencies in the existing rail alignment around Point Defiance. The project needs are 

 

1 Forty Most Asked Questions Concerning CEQ’s NEPA Regulations

2 Council on Environmental Quality Regulations, Sec 1502.14(a)
6 

to enhance rail service frequency, reliability, efficiency and safety. The existing 

alignment, 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 and freight train scheduling 

and reliability. 

Specific elements of the project needs include: 

• Enhanced frequency: Increase Amtrak Cascades round-trips from four to six by 

2017 in order to meet projected service demands. 

• Enhanced efficiency: Enhance the efficient movement of people by reducing the 

amount of time passenger and freight trains spend yielding to other freight 

movements. 

• Improved reliability: Reduce or eliminate passenger rail service interruptions 

caused by natural factors (e.g., landslides) or operational limitations (e.g., 

drawbridge closures). 

• Improved safety: Construct at-grade crossings with upgraded safety features 

including wayside horns, median barriers, advanced warning signals, and traffic 

signal improvements. 

Description of Shoreline Alternative 

The Shoreline Alternative would make improvements to the existing route between 

Nisqually and Tacoma. It consists of adding 8 miles of new track and re-aligning 15 

miles of existing track. The Shoreline Alternative adds a third track inland along the 

existing route from Harbor (MP 3.22) to Titlow (MP 10.0). The third track will be 

located 25 feet center to center from the adjacent track and would have a 13-foot access 

road along side of it. All the curves between Harbor (MP 3.22) and south of Nisqually 

(MP 25.11) will be realigned to be 1 degree and 50 minute curves or broader to 

accommodate 79 mph passenger train speeds. 

Figure 1 shows the location of both the Shoreline Alternative (shown in green) and the 

bypass route (shown in blue). 

Included with the improvements would be clearing and grubbing, excavation, 

embankment, new track, new turnouts, bridge replacements, culvert extensions, 

retaining walls, a 1mile-long tunnel, and other miscellaneous items. 

The Shoreline Alternative would also involve right of way acquisition, residential 

relocations, commercial business impacts, and local road relocations. 

Relationship between Bypass Route and Shoreline Alternative 

In 2010, WSDOT evaluated the Shoreline Alternative because of comments from key 

stakeholders and municipalities within the project area.
7 

The bypass route and Shoreline Alternative are similar in that they enhance frequency, 

improve reliability, and enhance efficiency. The alternatives differ in the location of the 

improvements. The bypass route is located inland in Pierce County, and extends 

roughly 20 miles from Freighthouse Square vicinity in Tacoma, through Lakewood and 

past DuPont to just east of I-5, where it connects with the BNSF main line (see Figure 

1). Below is a summary of additional major differences between the two alternatives: 

1) Currently, passenger trains are often delayed because they share tracks with 

freight trains. Even though the Shoreline Alternative proposes to add capacity, 

passenger trains will still share tracks with nearly all freight trains in the area. 

For the bypass route alternative, the traffic volume is light and consists almost 

exclusively of passenger trains. Unlike typical freight trains, passenger trains 

operate on detailed schedules that permit conflict-free on-time operation on 

single-track segments. 

2) The bypass route reduces the rail distance between Seattle and Portland by 5.9 

miles compared to the existing/Shoreline Alternative. 

3) The Shoreline Alternative, including the proposed build out improvements will 

decrease travel time for passenger trains by 2-3 minutes and the bypass route 

will decrease it by approximately 6-10 minutes within this segment. 

4) The Shoreline Alternative constructs a new third track for approximately seven 

miles. The bypass route upgrades an existing line for passenger train use. 

5) The Shoreline Alternative will require the acquisition of a significant amount of 

right of way. Because the bypass route is in an existing track corridor, the right 

of way in general already exists. 

6) The Shoreline Alternative extends along the shore of Puget Sound at the base of 

steep, heavily wooded hillsides, which are subject to mudslides, and fallen trees 

during the rain and windstorms that regularly occur from late fall through early 

spring. The bypass route is not generally subject to these problems since it is not 

located at the base of steep, heavily wooded hillsides. 

Many different design variations could be analyzed. The substantial cumulative impacts 

of pioneering any new alignment through partially undisturbed lands and through 

heavily developed lands cannot be avoided. A new route adversely affects resources 

protected under Section 4(f) to a much greater magnitude than do other reasonable and 

prudent alternatives. 
8 

Figure 1 

Engineering and Feasibility 

The Shoreline Alternative concept was considered for the following reasons: 1) 

efficiency and 2) frequency. 

Efficiency 

With the construction of the third track and realignment of the curves associated with 

this alternative, the alignment would be able to accommodate 79 mph passenger train 

speeds. This would amount to a schedule reduction of 2-3 minutes within this segment. 

Frequency 

Construction of the third track and curve realignments will accommodate two additional 

daily Amtrak Cascades round-trips. 

Geometrics 

The proposed alignment of this alternative would follow the existing Point Defiance 

main line from Tacoma to Nisqually. This alternative would require removal of 
9 

approximately 1.7 million cubic yards of material and placing approximately 135,000 

cubic yards of embankment. Excavation would require clearing and grubbing of 

approximately 100 acres. Because the existing cut slopes have localized instability 

issues, 2:1 slopes are used. 

The required earthwork will increase the impacts to the project vicinity. An estimated 

216 acres of land are displaced by the new footprint. The width of the footprint varies, 

and may be up to 420 feet across at the widest point. 

Construction of the third track in Tacoma would require relocating Waterview Street 

from MP 3.22 to MP 5.07. This is due to the steep terrain between the existing two 

tracks and the street. Waterview St. provides access to multiple water view homes. An 

alternate access would need to be identified and evaluated. 

Lemon Beach Road West (located to the south of Titlow Park from MP 10.61 to MP 

11.09) requires relocation as well due to the curve realignment. This is due to the steep 

terrain in the area. An alternate access would need to be identified and evaluated. 

Structures 

This alternative would construct approximately 300 linear feet of bridge, 71.5 feet wide 

(three tracks) over Alderway St, N 40th St, and N 49th S. It will also construct 

approximately 800 linear feet of bridge, 46.5 feet wide (two tracks) over Chambers Cr. 

Waterway, a boat launch, 5th St. Waterway, and I-5(Northbound and Southbound). 

One tunnel approximately 1 mile-long with a diameter of 39 feet would be required to 

the south of the existing Nelson Bennett Tunnel. The tunnel would be a two-track 

tunnel with walkways on each side. Boring a new tunnel of this size underneath a 

neighborhood presents many risks. Some of the potential structural risks include the 

suitability of the soil, the condition of the structures and buildings above the proposed 

tunnel alignment, acquiring the right of way needed, and cost. 

This alternative would also require approximately 6.6 miles of retaining walls, ranging 

in height from 20-35 feet. 

Right Of Way 

This alternative would require right of way purchase of approximately 48 acres. This 

includes a 30 acre section of developed land costing approximately $1,089,000 per acre. 

The required right of way includes the following types of purchases: 

• Approximately 60 residential relocations including homes with Puget Sound 

views. 

• A portion of Joint Base Lewis-McChord (JBLM). 

• Chambers Creek Boat Owners Association. This would include the elimination 

of the moorage and pleasure boat-related business due to replacement of the 

bridge over the Chambers Creek Waterway. The moveable span would be 

eliminated with the bridge replacement to reduce delays to the trains. 

• A portion of Chambers Bay Golf Club. 
10 

• Parcels owned by the City of Tacoma. 

• City of Ruston – Ruston Playfield. 

• A portion of the Nisqually National Wildlife Refuge 

• Forest and parkland. 

As part of the Shoreline Alternative right of way would be needed from select federal 

agencies including JBLM. Substantial time would be needed for compliance with 

applicable statutes and regulations specific to the agency before right of way would be 

granted. Depending on the agency, special documentation may be required and the right 

of way may be acquired as an easement rather than in fee (actually purchasing the land). 

Beyond the areas identified as potentially affected by construction work, there may be 

other affected properties. Moving the railroad closer to homes or businesses could cause 

increased noise and vibration impacts. Steep slopes could cause instabilities in the slope 

as well. Geotechnical investigations would be needed to further analyze all of these 

effects. 

Two areas that have the greatest potential impact to established neighborhoods are 

located just to the north and to the south of Steilacoom. One option to minimize this 

effect on the neighborhoods is to realign the rail alignment over the water. This would 

involve a structure (bridge) over Puget Sound that could be more than two miles long. 

There are many obstacles and issues involved with this option including but not limited 

to the following: 

• Extensive and potentially lengthy permitting process including multiple permits 

from multiple jurisdictions. 

• Extensive environmental impacts 

• Extensive mitigation for environmental impacts 

• Maritime impacts due to the presence of a ferry dock at Steilacoom 

• Risks involved with the construction of a structure over the water 

• Cost 

These are just a few of the concerns involved with constructing a new structure over 

Puget Sound. The feasibility of this option is unknown, without further analysis. The 

risks involved with an undertaking of this kind are vast and could have a profound 

effect on the cost of this alternative. 

Maintenance 

The existing alignment extends along the Puget Sound shoreline at the base of steep, 

heavily wooded hillsides. Even with the required improvements, cut slopes and trees 

will still exist along the route. These hillsides are subject to mudslides and fallen trees 

during the rain and windstorms that regularly occur from late fall through early spring. 

Current required maintenance on the existing route will continue to some extent with 

the additional third track, even with the anticipated slope stability improvements. 
11 

Conclusion 

The track improvements built as part of the Shoreline Alternative could result in a 2-3 

minute schedule reduction within this segment, and would add capacity to the existing 

route. 

However, this alternative also has major disadvantages. The cost of this alternative is 

extremely high ($1.42 billion to $1.64 billion) due to the vast amount of excavation 

needed on the steep slopes along the Puget Sound shoreline, as well as the construction 

of retaining walls, bridges, a tunnel, and other various items. The disadvantages also 

include significant federal, state, and private right of way purchases and continued 

maintenance concerns on the existing route. Without conducting a geotechnical 

investigation, it is impossible to determine whether this alternative is feasible due to the 

vast amount of ground disturbance associated with the earthwork, tunnel and potential 

new structure(s) over Puget Sound. 

Environmental Impacts 

This portion of the technical memorandum describes the Shoreline Alternative’s likely 

impacts to the built and natural environment. 

Resources 

Air Quality 

The Shoreline Alternative is within an area that must meet national air quality standards 

for ozone and carbon monoxide, and in proximity to an area that must meet standards 

for particulates. 

During construction, dust particles would be released as a result of construction 

vehicles, equipment and wind erosion over exposed earth surfaces. Fugitive dust 

releases fine particles in the air, which is linked to respiratory problems, and generally 

constitutes the largest source of air quality concerns during construction. Most of the 

dust particles would settle out immediately adjacent to the construction areas while a 

small fraction would contribute to dust particle levels in the surrounding area. Air 

quality impacts caused by construction equipment emissions are short term and occur 

only when construction activities are taking place. Mitigation measures would be 

implemented to minimize construction emissions and impacts. 

Hazardous Materials 

Several hazardous material sites are located within 500 feet of the Shoreline 

Alternative. Additional studies would be necessary to avoid these sites or to determine 
12 

if any new sites exist. If any sites were located within an expanded right of way, 

WSDOT would likely be required to remediate the site(s). 

Noise/Vibration 

Noise: The Shoreline Alternative is approximately 25 miles long. Noise sensitive 

receptors within 500 feet of the route include the Nisqually National Wildlife Refuge, 

several publicly owned parks, schools, and homes. All receptor sites located along the 

proposed alignment would be subject to possible noise impacts. 

Noise impacts could be reduced by initiating traffic management measures, acquiring 

land as buffer zones, realigning the rail route, insulating public use or nonprofit 

institutional structures (not residential or commercial buildings), or constructing noise 

barriers. Long-term noise impacts could negatively affect the Nisqually National 

Wildlife Refuge which would constitute a constructive use under Section 4(f) of the US 

Department of Transportation Act of 1966. The subsequent Recreation/Section 4(f) and 

Section 6(f) sub-section has additional information on how FRA is required to handle 

impacts to Section 4(f) resources. 

Vibration: Because the Shoreline Alternative would travel through dense urban areas, a 

General Vibration Assessment would be required. If the general assessment determines 

that there are significant adverse vibration impacts, then a Detailed Vibration 

Assessment would be prepared. 

Hydrology/Water Quality 

The Shoreline Alternative will fill approximately 2.5 miles of Puget Sound shoreline 

and cross several unnamed waterbodies. One of these unnamed waterbodies is within 1⁄4 

mile of listed Washington State Department of Ecology 303(d) waterbodies (Balch and 

Cormorant Passages). 

The Shoreline Alternative is within the Central Pierce County sole source aquifer,3

 the 

Pierce County critical aquifer recharge area,4 and is in proximity to wellhead protection 

areas.5 WSDOT will need to work with the appropriate entities regarding appropriate 

protective and mitigation measures. Federal funds may not be expended unless a project 

is designed to avoid any violation of federal or state drinking water regulations. 

It is unknown if the Shoreline Alternative would have a substantial impact on water 

quality or water resources at this time. Further study would be necessary to determine 

the extent of these impacts. The permitting process for approving shoreline fill is 

discussed in the following Wetlands sub-section. 

 

3 Designated by the US Environmental Protection Agency

4 Designated by a city or county under the Growth Management Act

5 Group A systems (Washington State Department of Health) serving 15 or more residential connections, or 25 or 

more people per day for 60 days or more per year
13 

Ecosystems 

Fish, Wildlife, Vegetation 

Approximately 48 acres (of which 30 acres are developed) would need to be acquired as 

right of way for the Shoreline Alternative, and approximately 100 acres would be 

cleared and grubbed. Some of this acreage is likely to be wildlife habitat, which would 

have a direct impact on wildlife. 

Marbled murrelet has been documented within the corridor and is listed as a threatened 

species. Additionally, eight species of concern (bald eagle, osprey, pileated 

woodpecker, purple martin, reticulate sculpin, riffle sculpin, Vaux’s swift, and western 

bluebird) have been documented within the corridor. Further study would be necessary 

to determine the impacts to fish, wildlife, and vegetation. 

Endangered Species Act (ESA) 

Unavoidable impacts to listed threatened species could occur if the Shoreline 

Alternative is constructed, and a Biological Assessment will be required to determine 

this alternative’s impact on those species and their habitats. The timeframe for formal 

consultation under Section 7 of the ESA, for larger projects in the Puget Sound area, 

generally exceeds one year and may take up to two years to complete. 

Mitigating for potential impacts to threatened or endangered species’ habitat would 

require the creation or restoration of equivalent habitat near the project. The regulatory 

requirements and costs of such mitigation would depend on the final alternative 

alignment and the result of consultation with the regulatory agencies. 

Wetlands and Shorelines 

The preliminary design information available at the time of this analysis suggests that 

nine wetlands totaling approximately 1.9 acres may be impacted by the Shoreline 

Alternative. Further study would be necessary to determine the actual impacts to 

wetlands. Wetland impacts must be mitigated in accordance with federal, state, and 

local regulations. 

Wetland impacts would be reduced to the greatest practicable extent by designing and 

implementing minimization and mitigation measures. However, for unavoidable 

impacts, the cost to mitigate is highly variable depending on the rating of the impacted 

wetlands (Categories I-IV), the type of mitigation implemented (preservation, 

enhancement, and/or creation), and the price of real estate. Construction costs and the 
14 

cost to subsequently monitor the mitigation site(s) (up to 10 years or more), are 

somewhat more stable and therefore can be predicted with a higher level of confidence. 

Assuming all the wetlands identified during this analysis rated as a Category I (i.e., 

highest-functioning wetlands), the following two cost scenarios6

 were developed: 

1. The lower cost scenario, which would require a 3:1 creation/restoration ratio7

 per 

Class I acre impacted and include a 150-foot buffer. Based on these requirements, a 

total of 5.7 acres would need to be constructed or restored at a cost of 

approximately $1,464,000;8,9,10 

2. The higher cost scenario, which would require a 6:1 creation/restoration ratio7

 per 

Class I acre impacted and include a 300-foot buffer. Based on these requirements, a 

total of 11.4 acres would need to be constructed or restored at a cost of 

approximately $2,927,000. 

These cost scenarios only address the cost of constructing the wetlands; they do not 

address the costs of locating and purchasing the real estate for these sites or their 

associated buffer areas. 

These estimates would be refined only after accurately identifying wetland boundaries 

and assessing their functions and values. This would be accomplished by delineating 

and rating each wetland. It is also possible that additional wetlands could be discovered 

during the fieldwork, which would likely increase mitigation costs. 

Approvals would be required from the following agencies: 

• US Army Corps of Engineers – Section 404 of the Clean Water Act, which 

includes determining the Least Environmentally Damaging Practicable 

Alternative (LEDPA); Section 10 of the Rivers and Harbors Appropriation Act 

• WA State Department of Ecology – Section 401 of the Clean Water Act; 

Coastal Zone Management Consistency Certification 

• WA State Department of Fish and Wildlife – Hydraulic Project Approval 

• Local jurisdictions – Shorelines; Floodplain Development; Critical Area 

Ordinances 

Because of the many jurisdictions involved and the extent of shoreline impacts, 

acquiring the necessary approvals could take a year or longer. 

 

6

 Based on 2006 guidance, and input from Geoff Gray, SCR Biologist, on September 9, 2010. 

7

 The US Army Corps of Engineers determines creation/restoration ratios if a Section 404 Individual Permit is 

issued. 

8

 A total of $256,784/acre. This total was inflated by 15% from the 2006 guidance of $223,290/acre. The cost has 

been rounded to the nearest $100,000 for the purposes of this analysis 

9

 This total does not include real estate acquisition costs 

10 This cost does not include the area required for the buffer 
15 

Human Communities 

Socioeconomic/Environmental Justice 

The Shoreline Alternative could potentially impact approximately 60 private residences, 

private businesses, the Fort Lewis Military Reservation, and a municipal wastewater 

treatment plant. The 2009 poverty guideline for a family of four is $22,050; within the 

study area, the median income is above the poverty guideline. 

Average Median Income Minority Population 

$44,482 27% 

Further study is necessary in order to determine whether minority or low-income 

populations would be disproportionately affected. 

Private residences and businesses would be displaced by the Shoreline Alternative. Any 

individuals or businesses that would be displaced as a result of implementing this 

alignment would be provided with relocation assistance under the Uniform Relocation 

Assistance and Real Property Acquisition Policies Act (42 USC 4601). 

Recreation/Section 4(f) and Section 6(f)11

The Shoreline Alternative as currently designed would impact portions of the Nisqually 

National Wildlife Refuge and several publicly owned parks, which are Section 4(f) 

resources. Impacts could include increased noise levels, displacement and/or change in 

access. 

Section 4(f), 49 U.S.C. 303, of the Department of Transportation Act states that the 

Federal Railroad Administration will not approve the use of land from a significant 

publicly owned park, recreation area, or wildlife and waterfowl refuge, or a 

prehistoric/historic site that is on or eligible for the National Register of Historic Places 

(NRHP), unless the determination is made that: 

1) There is no feasible and prudent alternative to the use of land from the property; 

and 

2) The proposed action includes all possible planning to minimize harm to the 

property resulting from such use. 

Supporting information demonstrates that there is a feasible and prudent alternative that 

would avoid these Section 4(f) resources. Because another alternative exists that does 

not impact Section 4(f) resources, the Shoreline Alternative should be considered and 

rejected. 

 

11 Property purchased with Land and Water Conservation Act funds 
16 

Historic/Cultural 

Preliminary research indicates that the Shoreline Alternative would potentially impact 

24 recorded prehistoric and historic archaeological sites/resources. Some of these 

sites/resources could be eligible for listing on the NRHP and could trigger a Section 4(f) 

analysis. Additionally, due to its age, the Washington Department of Archaeology and 

Historic Preservation may require that the rail line be evaluated as a historic property in 

order to determine its eligibility for the NRHP. 

Section 4(f) of the Department of Transportation Act requires an analysis to show that 

there is no prudent and feasible alternative to using such a resource. If there is no 

prudent and feasible avoidance alternative, then WSDOT must demonstrate that the 

project includes all possible planning to minimize harm to the Section 4(f) resource. 

Historic/cultural sites and resources and their potential importance would require 

extensive study and consultation with agencies with jurisdiction and affected Indian 

tribes. This consultation could play a major role in developing or modifying this 

alternative. Excavations for data recovery and historic research would likely be needed 

for some of these sites/resources. 

Section 106 of the National Historic Preservation Act would require any such impact to 

properties on or eligible for the NRHP to complete a 4(f) Evaluation. This process is 

discussed in the preceding Recreation/Section 4(f) and Section 6(f) sub-section. 

Conclusion 

Widening the existing BNSF rail corridor to include a third track would potentially 

impact the following: 

• Section 4(f) resources such as the Nisqually National Wildlife Refuge and 

several publicly owned parks; 

• Approximately 2.5 miles of Puget Sound shoreline; 

• Wildlife habitat that supports threatened species; 

• Approximately 60 private residences, private businesses, and a portion of Joint 

Base Lewis-McChord; 

• Approximately 1.9 acres of wetlands; 

• 24 cultural/historic resources; 

See Appendix A for a summary of the environmental impacts. 

Technical Memo Summary 

The Shoreline Alternative meets the project purpose and need; however, there are many 

challenges and obstacles including the following: 
17 

• Rail congestion would continue due to passenger and freight sharing the same 

right of way. 

• Substantial amounts of right of way acquisitions from multiple owners and 

businesses would result in additional costs and schedule delays. 

• Significant cost and schedule impacts from elimination or relocation of a boat 

moorage and pleasure boat-related business. 

• Considerable added cost resulting from1.7 million cubic yards of excavation 

including 100 acres of clearing and grubbing. 

• Impacts to aesthetics along the shoreline due to more than six miles of retaining 

walls and the vast amount of excavation required. 

The Shoreline Alternative proposes to fill in nearly 2.5 miles of shoreline, and would 

impact approximately 1.9 acres of wetlands. If these wetlands rated as a Category I (i.e., 

highest-functioning wetlands), mitigation costs could reach into the millions, and it 

would likely take a year or longer to acquire permits from multiple governmental 

jurisdictions. 

The Shoreline Alternative is within the Central Pierce County sole source aquifer, the 

Pierce County critical aquifer recharge area, and is in proximity to wellhead protection 

areas. If a project violates state or federal drinking water regulations, it cannot receive 

any federal funds. 

Staff Recommendation 

Staff’s recommendation is that the Shoreline Alternative be eliminated from further 

consideration. 

WSDOT staff considers this alternative both impractical and unfeasible from a technical 

and economic standpoint, and will describe it as such in the project Environmental 

Assessment (EA). Because of the Shoreline Alternative’s technical and environmental 

constraints and its high cost, WSDOT does not intend to study this alternative in detail 

within the project’s EA, unless new information becomes available that would change 

these findings. 

The Shoreline Alternative has more potentially significant impacts compared to the 

bypass alternative. The Point Defiance bypass alternative has fewer potentially 

significant impacts, and better fulfills the project’s purpose and need. Project 

characteristics evaluated under the Engineering and Feasibility and Environmental 

Impacts sections of this technical memorandum explain the reasons for recommending 

the elimination of this alternative. 
Appendix A – Comparison of Shoreline Alternative to 

Point Defiance Bypass Project

18

Shoreline Pt. Defiance Bypass1

Design

Route Length between Freighthouse Square 

past DuPont to just east of I-5, where it 

connects with the BNSF main line

25.9 miles 20 miles

New/Reconstructed Track 8.0 miles/15 miles 2.5 miles/11.5 miles

Construction Cost10 $1.42B - $1.64B $59.6M

Total ROW Required/ Residential ROW 48 acres/30 acres 1.3 acres/<1 acre

Potential Environmental Impacts

Wetlands: Total Impacted2 1.9 acres 0 acres

Wetlands: Mitigation Ratio3 (3:14/6:15) 5.7 acres/11.4 acres N/A

Wetlands: Mitigation Cost6,7 (3:1/6:1) $1.5M/$2.9M N/A

Socioeconomic/Environmental Justice: % 

Minority Population

27% 39%

Recreation/Section 4(f) 8 and 6(f): Resources Yes

Impacted

No

Historic/Cultural: Resources Impacted 24 sites 0 sites

Note: Since the information was the same for both alternatives, no information is being provided in this 

comparison table for Air Quality (Attainment Area), Hazardous Materials (Sites Within 500 Feet), Noise (Sensitive 

Receptors), Hydrology/Water Quality (Proximity to Sensitive Surface or Ground Waterbodies), or ESA (Impacts to 

Threatened Species). See the sub-section for more information.

 1 Point Defiance Bypass Project Environmental Summary (May 2008), and supporting discipline reports; the Environmental Summary analyzed only to S. 66th Street in 

Tacoma, which was the northern extent of the project at that time

2 Assumes all the wetlands identified during this analysis rated as a Category I (i.e., highest-functioning wetlands) 3 The US Army Corps of Engineers determines creation/restoration ratios if a Section 404 Individual Permit is issued 4 The lower cost scenario, which would require a 3:1 creation/restoration ratio per Class I acre impacted and include a 150-foot buffer. 5 The higher cost scenario, which would require a 6:1 creation/restoration ratio per Class I acre impacted and include a 300-foot buffer 6 A total of $256,784/acre based on 2006 guidance, and input from Geoff Gray, SCR Biologist, on September 9, 2010; this total was inflated by 15% from the 2006 

guidance of $223,290/acre and has been rounded to the nearest $100,000 for the purposes of this analysis

7 This cost does not include real estate acquisition costs or the area required for the buffer 8 FRA will not approve the use of a Section 4(f) resource unless a determination is made that 1) there is no feasible and prudent alternative to the use of land from 

the property; and 2) the proposed action includes all possible planning to minimize harm to the property resulting from such use; supporting information 

demonstrates that there is a feasible and prudent alternative that would avoid these Section 4(f) resources

10 The Risk Self-Modeling Spreadsheet was used to perform risk-based estimating.
19 

Appendix B – Route Location