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Home My WebLink AboutCOR 14 - Second Declaration of Vanessa Dolbee COR 14 Second Declaration of Vanessa Dolbee SECOND DECLARATION OF VANESSA DOLBEE IN SUPPORT OF CITY’S FINDING OF VIOLATION – Page 1 Renton City Attorney 1055 S. Grady Way Renton, WA 98057-3232 Phone: 425.430.6480 Fax: 425.430.6498 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 IN PROCEEDINGS BEFORE THE CITY OF RENTON HEARING EXAMINER IN RE THE MATTER OF THE REQUEST FOR HEARING BY RENTON HOTEL INVESTORS, LLC AND KING COUNTY NO. CODE-20-000321 SECOND DECLARATION OF VANESSA DOLBEE IN SUPPORT OF CITY OF RENTON’S FINDING OF VIOLATION REGARDING RED LION DE-INTENSIFICATION SHELTER I, Vanessa Dolbee, declare as follows: 1.I am competent to testify in this matter and have personal knowledge of the facts stated herein. 2.This is my second declaration made in this matter. I reincorporate the following statements regarding my position and my knowledge of this matter: a.I hold the title of Current Planning Manager within the City of Renton’s (the “City’s”) Department of Community & Economic Development (“CED”). I was hired by the City in 2008 as a planner and was subsequently promoted in 2013 to the position SECOND DECLARATION OF VANESSA DOLBEE IN SUPPORT OF CITY’S FINDING OF VIOLATION – Page 2 Renton City Attorney 1055 S. Grady Way Renton, WA 98057-3232 Phone: 425.430.6480 Fax: 425.430.6498 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 of Current Planning Manager. My statements in this declaration are grounded in my personal knowledge and in the skills, training, education, and knowledge that I have gathered as a result of my position and my years with the City of Renton. b.I am familiar with the June 30, 2020 Finding of Violation (“FOV”) that the City issued to King County, the Downtown Emergency Service Center, and Renton Hotel Investors, LLC in this matter. c.The property at issue in the FOV is the former site of a Red Lion Hotel & Conference Center, located at 1 S Grady Way, Renton Washington; King County Parcel No. 3340401630 (the “Property”). 3. In my capacity as Current Planning Manager, I am generally familiar with the properties in the City’s CA zone that are estab lished as “Hotel” land uses, and I searched the City’s online “COR Maps” mapping program to more closely review “Hotels” that are established on CA-zoned properties in the City. 4. In my role as Current Planning Manager, I regularly receive information about how properties throughout the City are being used and operated. To my knowledge, prior to the COVID-19 pandemic curtailing the lodging industry, not one of the Hotels established throughout the City’s CA zoning districts was operating in a manner similar to the Property’s de- intensification shelter. Specifically, to my knowledge, not one of them had a long-term single payor; had restricted access such that the general public could not rent a room; or offered meal service at no cost. SECOND DECLARATION OF VANESSA DOLBEE IN SUPPORT OF CITY’S FINDING OF VIOLATION – Page 3 Renton City Attorney 1055 S. Grady Way Renton, WA 98057-3232 Phone: 425.430.6480 Fax: 425.430.6498 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 5. To my knowledge, because no Hotels in CA zones have operated similarly to the de-intensification shelter at the Property, the City did not take enforcement action against the de-intensification shelter while choosing to not take enforcement action against similarly- operated businesses. 6. As I explained in my previous declaration, the operations of the Red Lion shelter are analogous to the “congregate residence” land use that is recognized in the Renton Municipal Code. A classic example of a “congregate residence” land use is a fraternity or sorority house – operations that are not traditionally associated with providing housing for persons with disability. “Congregate residences” are not allowed in the CA zone. See RMC 4-2- 060 (zoning use table). 7. It is my understanding that more than 200 people are residing at the Red Lion shelter. The CA zone is a non-residential zone; no type of multi-resident use is allowed outright anywhere in the CA zone: “Attached dwellings” (flats and townhomes) are only allowed in the CA zone if part of a mixed-use development. (The de-intensification shelter does not even meet the definition of an “attached dwelling” because its rooms are not “dwelling units” under RMC 4-11-040); “Congregate residences” are not allowed in the CA zone; Temporary multi-resident housing alternatives are not allowed in the CA zone: “Diversion facilities” and “Diversion interim service facilities” are not allowed in the CA zone; and Even medically-related, full-care temporary housing alternatives are not allowed outright in the CA zone: “Convalescent centers” and “medical SECOND DECLARATION OF VANESSA DOLBEE IN SUPPORT OF CITY’S FINDING OF VIOLATION – Page 4 Renton City Attorney 1055 S. Grady Way Renton, WA 98057-3232 Phone: 425.430.6480 Fax: 425.430.6498 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 institutions” are only conditionally allowed in the CA zone.1 8. Since I began employment with the City in 2008, I am aware of no instances in which the City granted a CA-zoned property a rezone to a different zoning designation for the purpose of constructing a standalone residential use on that property. Signed at ___________, Washington this ____ day of August, 2020, under penalty of perjury under the laws of the State of Washington. By: Vanessa Dolbee 1 Sources: RMC 4-2-060 (zoning use table); RMC 4-2-080 (conditions associated with zoning use table). SECOND DECLARATION OF VANESSA DOLBEE IN SUPPORT OF CITY’S FINDING OF VIOLATION – Page 5 Renton City Attorney 1055 S. Grady Way Renton, WA 98057-3232 Phone: 425.430.6480 Fax: 425.430.6498 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 DECLARATION OF SERVICE I declare under penalty of perjury under the laws of the State of Washington that on _______________, a true and correct copy of the foregoing document was served upon the parties listed below via the method indicated: Renton Hotel Investors, LLC: Sumeer Singla Williams, Kastner & Gibbs PLLC ssingla@williamskastner.com [X] E-mail [ ] United States Mail [ ] Legal Messenger [ ] E-Service King County: Howard Schneiderman Senior Deputy Prosecuting Attorney Howard.Schneiderman@kingcounty.gov Youn-Jung Kim Deputy Prosecuting Attorney Jina.Kim@kingcounty.gov Lena Madden Deputy Prosecuting Attorney Lena.Madden@kingcounty.gov [X] E-mail [ ] United States Mail [ ] Legal Messenger [ ] E-Service August 12, 2020 SECOND DECLARATION OF VANESSA DOLBEE IN SUPPORT OF CITY’S FINDING OF VIOLATION – Page 6 Renton City Attorney 1055 S. Grady Way Renton, WA 98057-3232 Phone: 425.430.6480 Fax: 425.430.6498 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 DESC: Daniel Malone Downtown Emergency Service Center (DESC) dmalone@desc.org [X] E-mail [ ] United States Mail [ ] Legal Messenger [ ] E-Service DATED this ________ day of ___________, 2020, at Maple Valley, Washington. /s/ Stephanie Rary Stephanie Rary, Paralegal 12th August With a copy to: Elaine L. Spencer, WSBA #6963 Northwest Resource Law PLLC espencer@nwresourcelaw.com Lisa Chaiet Rahman, WSBA #51531 Northwest Resource Law PLLC lrahman@nwresourcelaw.com [X] E-mail [ ] United States Mail [ ] Legal Messenger [ ] E-Service