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Home My WebLink AboutItem 31 - 08-14-2020 - Hearing Exhibit - COR 08 - Declaration of Vanessa DolbeeITEM NO. 31 HEX-000304 COR 8 Declaration of Vanessa Dolbee HEX-000305 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 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.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 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 HEX-000306 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 position and my years with the City of Renton. 3. 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. 4. 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”). 5. In my capacity as Current Planning Manager, I am familiar with the Property due to its prominent location in the City. The City zoned the Property and surrounding properties with a Commercial Arterial (“CA”) zoning district designation. Attached hereto as Exhibit A is a true and correct copy of a portion of the City’s online zoning map in the vicinity of the Property, showing that the Property is zoned CA. 6. Consistent with the Red Lion’s CA zoning and with its development as a Red Lion Hotel & Conference Center, the Property has been designated by the City as a “Hotel” land use. 7. While the Property was operated as the Red Lion Hotel & Conference Center , it was in compliance with the land use provisions of RMC 4 -2-060 which allow a Hotel land use on CA-zoned properties. 8. In my capacity as Current Planning Manager, I have access to information about all land use and building permit applications submitted to the City during 2020. Here, the de- intensification shelter that has been operating at the Property since April 2020 began operating HEX-000307 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 without its representatives engaging in any City permitting process. 9. When a property owner or representative proposes to change from one land use allowed outright in the zone to another land use allowed outright in the zone, a change of use SEPA Environment Review permit from the City may be required. An example of such a change of use in the CA zone is a proposed change in use from a Hotel over 4,000 square feet (a use allowed outright in the CA zone under RMC 4-2-060) to an Eating and Drinking Establishment of the same size (another use allowed outright in the CA zone under RMC 4-2-060). 10. I have reviewed the information that is available to the City to date regarding how the de-intensification shelter is being operated at the Property. From that review, I conclude that of all of the land uses recognized in the Renton Municipal Code, the de - intensification shelter is most similar to a “congregate residence,” “diversion facility,” or a diversion interim service facility” as those uses are defined in chapter 4-11 of the Renton Municipal Code. 11. In my capacity as the City’s Current Planning Manager, I am familiar with the Unclassified Use process that is codified in RMC 4-2-050.C.6. Based on my above conclusion that the de-intensification shelter at the Property is most similar to a “congregate residence,” diversion facility,” or a “diversion interim service facility,” I conclude that the outcome of the Unclassified Use process would be to categorize the de-intensification shelter as one of those three uses: congregate residence, diversion facility, or diversion interim service facility. None of those three land uses are allowed in the CA zone. HEX-000308 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 Signed at ___________, Washington this ____ day of August, 2020, under penalty of perjury under the laws of the State of Washington. By: Vanessa Dolbee HEX-000309 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 5, 2020 HEX-000310 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 5th August HEX-000311 EXHIBIT A HEX-000312 4,514 376 Red Lion Zoning Map This map is a user generated static output from an Internet mapping site and is for reference only. Data layers that appear on this map may or may not be accurate, current, or otherwise reliable. None 8/4/2020 Legend 2560128 THIS MAP IS NOT TO BE USED FOR NAVIGATION Feet Notes 256 WGS_1984_Web_Mercator_Auxiliary_Sphere Information Technology - GIS RentonMapSupport@Rentonwa.gov City and County Labels City and County Boundary Addresses Parcels Zoning RC-Resource Conservation R1-Residential 1 du/ac R4-Residential 4 du/ac R6-Residential - 6 DU/AC R8-Residential 8 du/ac R10-Residential 10 du/ac R14-Residential 14 du/ac RMF-Residential Multi-Family RMH-Residential Manufactured Homes CN-Commercial Neighborhood CV-Center Village CA-Commercial Arterial UC-Urban Center CD-Center Downtown COR-Commercial Office/Residential CO-Commercial Office IL-Industrial - Light IM-Industrial - Medium IH-Industrial - Heavy Overlay Districts Auto Mall A HEX-000313