HomeMy WebLinkAboutCOR 04 - Declaration of Leo Flor
COR 4
Declaration of Leo Flor
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DECLARATION OF LEO FLOR - 1
Daniel T. Satterberg, Prosecuting Attorney
CIVIL DIVISION
W400 King County Courthouse
516 Third Avenue
Seattle, Washington 98104
(206) 477-1120/FAX (206) 296-0191
BEFORE THE CITY OF RENTON
COMMUNITY AND ECONOMIC DEVELOPMENT
In re the matter of the Appeal by
Renton Hotel Investors, LLC,
Downtown Emergency Services Center,
King County
Appellants.
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Case No. CODE20-000321
DECLARATION OF LEO FLOR
Leo Flor declares as follows:
1. I am competent to testify and have personal knowledge of the matters herein.
2. I serve as the Director for the King County Department of Community and
Human Services (DCHS).
3. I hold a master’s degree in Infrastructure Planning and Management (2015) and a
JD (2013), both from the University of Washington.
4. DCHS oversees the county’s isolation and quarantine facilities for COVID-19.
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DECLARATION OF LEO FLOR - 2
Daniel T. Satterberg, Prosecuting Attorney
CIVIL DIVISION
W400 King County Courthouse
516 Third Avenue
Seattle, Washington 98104
(206) 477-1120/FAX (206) 296-0191
5. Addition, we at DCHS are responsible for the county’s regular programs to
provide homeless individuals with shelter, affordable housing, behavioral health and other
support services.
6. Under the direction of the Local Health Officer, and following the advice of our
health department, I am responsible for implementing the county’s COVID-19 strategy for
persons who cannot observe public health guidance in a home of their own, including shelter de-
intensification, and isolation and quarantine facilities.
7. The county’s public health strategy to slow the spread of COVID-19 amongst
people without a home of their own is two pronged – whenever possible, keep people healthy in
the first place, and when people are sick or exposed, use isolation and quarantine to interrupt
further transmission of COVID-19.
8. Our premise with the first prong is that the most effective way to slow the spread
of COVID-19, and to prevent the health care system from becoming overwhelmed, is to keep the
most medically vulnerable populations from getting sick in first place.
9. As directed by the Local Health Officer, the county implemented this strategy by
de-intensifying the highest risk congregate shelters in our region, providing shelter residents with
a safer place to stay and stay healthy during the epidemic, and also by providing isolation and
quarantine facilities, so when people do get exposed or sick from COVID-19, but lack a home
where they can safely recover without risking the health of others, they have a safe place to do
so.
10. Persons experiencing homelessness are a medically vulnerable population,
disproportionally less healthy to begin with and with more disabilities than the general public, a
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DECLARATION OF LEO FLOR - 3
Daniel T. Satterberg, Prosecuting Attorney
CIVIL DIVISION
W400 King County Courthouse
516 Third Avenue
Seattle, Washington 98104
(206) 477-1120/FAX (206) 296-0191
trend that is also true of the current county residents who are residing in the hotel in Renton that
is the subject of this matter.
11. The King County homeless population also disproportionately includes persons of
color, a population that because of the effects of long-standing systemic racism, exhibits higher
rates of death due to COVID-19 as well as higher rates of many underlying health conditions that
increase risk of serious health complications of COVID-19.
12. As illness spreads, those indoors in congregate shelters are most vulnerable by
setting, lacking the ability to distance themselves from others. Shelter residents are often unable
to get sufficient sleep, can be malnourished, and tend to live in crowded conditions, perfect
breeding grounds for infectious disease.
13. There are nearly 50 congregate shelters in King County.
14. In partnership with Public Health, we conducted a risk assessment in early March
and identified the highest risk congregate shelters across within our county. Shelters were
designated as high risk if their residents were exceptionally susceptible to COVID-19 by
prevalence of age or disability, if their facilities and conditions were non-compliant with public
health and CDC guidance, or if they were staffed predominantly by volunteers or by persons who
were themselves exceptionally vulnerable to COVID-19.
15. We found the DESC Main Shelter, the Catholic Community Services St. Martins
De Porres Shelter, volunteer-run Catholic Community Services shelters in South King County,
and the Sophia Way, and an Eastside Women’s shelter were among the most vulnerable.
16. DESC’s Main Shelter and the St. Martin De Porres Shelter in particular were
assessed as highly vulnerable because of shelter conditions and the shelter populations. Both
were too crowded, with persons sleeping too close to each other. Neither had sufficient hygiene
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DECLARATION OF LEO FLOR - 4
Daniel T. Satterberg, Prosecuting Attorney
CIVIL DIVISION
W400 King County Courthouse
516 Third Avenue
Seattle, Washington 98104
(206) 477-1120/FAX (206) 296-0191
and bathroom facilities. Both cared for shelter residents who were exceptionally vulnerable by
prevalence of health condition or age of residents.
17. Another important factor in both assessing a shelter’s risk and in identifying ways
to keep shelter residents safe and healthy is that the staff of the shelters was similarly vulnerable
to COVID-19, and none of the shelter operators had the resources or time to hire new and
additional staff, so any solution would require the operator to use the same or fewer staff.
Transferring shelter residents to multiple separate locations from one location would not be
feasible because there would not be enough staff available to care for the residents in multiple
locations.
18. We initially housed St. Martin Do Porres clients in a larger congregate setting
within the King County International Airport (Boeing Field).
19. Even though clients slept more than six feet apart at the King County Airport,
COVID-19 still spread amongst the exceptionally vulnerable population. In consultation with
Public Health, we recognized that even a more spread out congregate setting could have the virus
spread within it, especially amongst exceptionally vulnerable clients, so the county began
looking for hotels and motels, which could provide sufficient separation, similar to what is
available for persons who have a home of their own in which to isolate or quarantine, for the
most vulnerable homeless persons to effectively quarantine. While we knew we could not get
every resident into hotels, we could get more residents into hotels, which would then allow even
further deintensification of the remaining high-risk congregate shelters.
20. Because of the DESC Main Shelter’s cramped conditions, higher-risk population
within it, and DESC’s staffing constraints, we recognized that we would need to identify a single
hotel or motel in which to house the shelter guests if we were going to keep them safe. At the
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DECLARATION OF LEO FLOR - 5
Daniel T. Satterberg, Prosecuting Attorney
CIVIL DIVISION
W400 King County Courthouse
516 Third Avenue
Seattle, Washington 98104
(206) 477-1120/FAX (206) 296-0191
time, we were acting with extreme urgency, recognizing that if we did not move the shelter
residents before COVID-19 was introduced into the congregate shelter, we risked the health and
lives of the shelter’s hundreds of residents.
21. In addition to DESC’s own staff, the DESC population required the support of
Harborview doctors, nurses, and mental health staff. It would have been highly impracticable to
split up those clients and require service providers to continually travel from hotel to hotel.
22. We also needed a hotel which was affordable. Any hotel to keep the DESC
residents safe would be only one of multiple new facilities or locations that we were
simultaneously pursuing for deintensification and isolation and quarantine.
23. More critically, we needed a hotel that was willing to accept homeless shelter
residents, and this was the most significant limitation. We identified multiple hotels willing to
host first responders, but very few that would allow homeless individuals while also being
affordable.
24. The Red Lion in Renton was the only available hotel with sufficient space, within
the price range we could afford, with owners willing to host persons experiencing homelessness.
25. Residents of the DESC main shelter moved into the Red Lion on April 9th.
26. Between March and May, we created a network of new county-wide COVID-19
facilities in most regions.
27. In addition to the Red Lion, we have also provided for shelter de-intensification
hotels or motels, sometimes by leasing entire hotels and other times by funding hotel vouchers,
in Sea-Tac, Bellevue, Redmond, two in Seattle, plus four de-intensified congregate shelters, all
in Seattle.
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DECLARATION OF LEO FLOR - 6
Daniel T. Satterberg, Prosecuting Attorney
CIVIL DIVISION
W400 King County Courthouse
516 Third Avenue
Seattle, Washington 98104
(206) 477-1120/FAX (206) 296-0191
28. We have also constructed isolation and quarantine facilities -- in White Center,
Seattle (two facilities), Bellevue, Issaquah, Kent, and a now de-commissioned site in Shoreline.
Four of these facilities are individual room settings, and three are congregate isolation settings
(including the now-decommissioned Shoreline site).
29. The City of Seattle is hosting the bulk of COVID-19 facilities.
30. Seattle established facilities of their own, in additional to the county’s facilities.
31. DESC is both a provider of shelters, permanent housing, crisis, outreach, and
ongoing behavioral health, and provides all of those services except for permanent housing at the
Red Lion.
32. Harborview Medical Center continues to provide integrated physical healthcare
for Red Lion clients.
33. At the Red Lion, we added security services (which we do not typically provide at
shelters we fund) and supplemented the security at the request of the City of Renton.
34. We also added fencing.
35. We at King County strive to continually improve the level of services we can
provide and are ready and willing to support the shelter operator to make any reasonable or
innovative operational changes we can to help during this epidemic and to minimize impacts on
the community.
36. The county’s two-prong strategy has so far been very successful at keeping the
spread of COVID-19 among the homeless low.
37. To best of my knowledge, there have been no COVID-19 deaths so far among
King County shelter residents.
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DECLARATION OF LEO FLOR - 7
Daniel T. Satterberg, Prosecuting Attorney
CIVIL DIVISION
W400 King County Courthouse
516 Third Avenue
Seattle, Washington 98104
(206) 477-1120/FAX (206) 296-0191
38. There were two deaths among formerly homeless persons living in permanent
supportive housing.
39. Other regions of the U.S. and nations have not fared as well.
40. Further, at the Red Lion, there have been no cases of COVID-19, despite more
than 300 tests now having been administered.
41. The COVID-19 epidemic reminds us that we are interconnected. If we fail to take
care of the most vulnerable, the community as a whole will suffer greater rates of illness and loss
from COVID-19.
I declare under penalty of perjury under the laws of the State of Washington that the
foregoing is true and correct.
Respectfully submitted this 15th day of July at Seattle, WA.
\s\ Leo Flor________________________
Leo Flor