When I asked at the Naches RD on July 26, 2013, I was told the Hell's Crossing trailhead to Goat Peak does NOT require a NW Trail Pass and indeed there was no requirement sign posted at the trailhead either.
Thanks for the update! Actually, I believe it is now illegal for the Forest Service to require people to pay to park anywhere just as long as you don't use any provided facilities. I never buy one. I will update the page.