Five Steps the City of Seattle Should Take to Reduce Trash Around Unsanctioned Encampments

Five Steps the City of Seattle

Should Take to Reduce

Trash

Around Unsanctioned

Encampments

David G. Jones, City Auditor

Seattle Office of City Auditor

February 24, 2020

Five Steps the City of Seattle Should

Take to Reduce Trash Around

Unsanctioned Encampments

Background

The Navigation Team is an approach for addressing the issue of

people living unsheltered in Seattle. The Navigation Team has a dual

mission of constructively engaging people living outdoors in

unsanctioned encampments on public property and mitigating

negative community impacts by removing such encampments as

needed. The City of Seattle has spent millions of dollars removing

millions of pounds of trash from unsanctioned encampments. In 2018,

the Navigation Team removed 2.4 million pounds of trash from

unsanctioned encampments. In the first three quarters of 2019, the

Navigation Team removed over 2.3 million pounds of trash from

unsanctioned encampments.

What We Found

We identified five steps that the City could take to develop a more

strategic approach that would help reduce or prevent unsanctioned

encampment trash from accumulating, and to track whether

encampment trash accumulation is increasing or decreasing: 1) Track

trash accumulation systematically, 2) Develop and implement

strategies for persistent trash “hot spots”, 3) Protect urban streams and

watersheds, 4) Improve needle recovery efforts, and 5) Use best

practices to deter metal theft. We offer five specific recommendations

associated with these steps that are directed at the City as a whole,

rather than the Navigation Team specifically. This recognizes that the

complex issues surrounding unsheltered homelessness require a

systematic, coordinated, multi-pronged response.

Executive Response

Our report incorporates feedback from the Mayor’s Office, the City

Budget Office, Human Services Department, Seattle Police Department,

Public Health – Seattle and King County, Seattle Parks and Recreation,

Seattle Public Utilities, Seattle City Light, and Seattle Office for Civil

Rights. The Executive Response is included as Appendix A.

As part of the 2020 budget, the Seattle City Council passed Proviso

HOM-15-C1 that requires the Executive to provide a written report to

the Council by November 19, 2020 discussing the City’s compliance

with the Office of City Auditor recommendations on Checkpoint 2.3,

Strategies to Prevent Trash Accumulation.

WHY WE DID THIS AUDIT

This audit focuses

specifically on Checkpoint

2.3: Assessment of

Strategies to Prevent

Trash Accumulation from

our

November 2017

Navigation Team Reporting

Plan. Seattle City

Councilmember Lisa

Herbold requested the

Reporting Plan and our

subsequent reports. These

reports promote

continuous improvement in

the City of Seattle’s (City’s)

approach to addressing

unsanctioned

encampments.

HOW WE DID THIS AUDIT

To accomplish the audit’s

objectives, we:

• geocoded, mapped,

and analyzed 2017-18

encampment clean-ups;

• conducted interviews

with City staff and

analyzed reports from

City contractors using

qualitative analysis

software;

• conducted systematic

field surveys using a

mobile application;

• researched best

practices and consulted

with public health and

public safety

researchers.

Seattle Office of City

Auditor

David G. Jones, City Auditor

www.seattle.gov/cityauditor

Five Steps the City of Seattle Should Take to Reduce Trash Around Unsanctioned Encampments

TABLE OF CONTENTS

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

TRACK TRASH ACCUMULATION SYSTEMATICALLY ........................................................................... 4

DEVELOP/IMPLEMENT STRATEGIES FOR PERSISTENT HOT-SPOTS................................................... 9

PROTECT URBAN STREAMS/WATERSHEDS ...................................................................................... 14

IMPROVE NEEDLE RECOVERY EFFORTS ............................................................................................ 17

USE BEST PRACTICES TO DETER METAL THEFT ................................................................................ 21

OBJECTIVES, SCOPE, AND METHODOLOGY ...................................................................................... 24

APPENDIX A ....................................................................................................................................... 26

Executive Response .........................................................................................................................................................26

APPENDIX B ....................................................................................................................................... 27

List of Recommendations ..............................................................................................................................................27

APPENDIX C ....................................................................................................................................... 28

Screenshots of Mobile App for Systematic Site Observations ............................................................................28

APPENDIX D ...................................................................................................................................... 29

Seattle Office of City Auditor Mission, Background, and Quality Assurance ..................................................29

Five Steps the City of Seattle Should Take to Reduce Trash Around Unsanctioned Encampments

Page 1

INTRODUCTION

Audit Overview

This audit focuses on Checkpoint 2.3: Assessment of Strategies to

Prevent Trash Accumulation from our

November 2017 Navigation Team

Reporting Plan. Seattle City Councilmember Lisa Herbold requested the

Reporting Plan and our subsequent reports. These reports are intended to

promote continuous improvement in the City of Seattle’s (City’s) approach

to addressing unsanctioned encampments.

Navigation Team Overview. The Navigation Team is an approach

implemented by former Mayor Murray’s administration for addressing the

issue of people living unsheltered in Seattle. The Navigation Team became

operational in February 2017. The 2020 budget for the Navigation Team is

$8.4 million;

this includes a team of 38 people including 11 police officers, 2

police sergeants, 17 civilian City staff, and 8 contracted outreach workers.

The Executive Branch (Executive) has stated

that the Navigation Team is

meant to accomplish a dual mission: to constructively engage people living

outdoors in unsanctioned encampments (i.e., tents or improvised shelters)

on public property and to mitigate negative community impacts by

removing such encampments as needed.

The Executive has identified four

major responsibilities for the Navigation Team, as stated in the

Executive’s

Quarter 1 2019 Proviso Report:

Engage unsheltered people, conduct needs assessments and make the

appropriate referrals to alternative shelter and offer other services.

Gather data about conditions at unauthorized encampments and in those

circumstances when unsheltered people are asked to vacate a site, assist with

the storage of personal property as is requested and/or practicable.

Remove waste and debris from sites after encampments have been removed.

Enforce lawful orders to vacate an unauthorized encampment site.

The City has spent millions of dollars in removing trash from unsanctioned

encampments. In 2018, the Navigation Team removed 2.4 million pounds of

trash from unsanctioned encampments. In the first three quarters of 2019,

the Navigation Team removed over 2.3 million pounds

of trash from

unsanctioned encampments.

Unsanctioned Encampments Lack Hygiene and Sanitation. As our office

has previously reported

, hundreds of unsanctioned encampments in Seattle

currently lack hygiene facilities (e.g., showers, hand washing, laundry, toilets)

The 2020 proposed budget for the Navigation Team is $8,387,000; however, this does not include Seattle Public Utilities

costs for solid waste disposal for the Navigation Team clean-ups of unsanctioned encampments.

For more information on the dual mission of the Navigation Team, see the Executive’s Quarter 1 2019 Proviso Report.

For the purposes of this audit, our definition of unauthorized encampments does not include those living in motor

vehicles.

See the City of Seattle’s Homelessness Response performance data for updated information on pounds of garbage

removed from unsanctioned encampments.

Five Steps the City of Seattle Should Take to Reduce Trash Around Unsanctioned Encampments

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and sanitation (e.g., human waste and trash disposal). This is a serious public

health risk

for all Seattle residents and an especially high risk for the

individuals currently experiencing homelessness at these undeveloped sites.

Increasing access to enhanced shelters

is an important strategy that would

prioritize hygiene and could reduce environmental and public health risks. In

our previous reports, we have recommended the City increase its enhanced

shelter capacity. Our November 2017 report and October 2018 report

provided examples from other jurisdictions that have quickly increased the

number of enhanced shelters. In addition, our

February 2019 report

identified additional steps that the City could take to improve the provision

of hygiene services. The Mayor’s budget for 2020 did not include funding to

expand current enhanced shelter capacity. Therefore, to protect public

health, the City should develop and implement a more strategic approach

for addressing trash accumulation associated with unsanctioned

encampments. This report identifies five steps that the City should take in

developing a more strategic approach:

1. Track trash accumulation systematically

2. Develop/implement strategies for persistent hot spots

3. Protect urban streams/watersheds

4. Improve needle recovery efforts

5. Use best practices to deter metal theft.

The following page contains a summary of our key report findings. Our

recommendations are directed at the City as a whole, rather than the

Navigation Team specifically. This recognizes that the complex issues

surrounding unsheltered homelessness require a systematic, coordinated,

multi-pronged response. As part of the 2020 budget, the Seattle City Council

passed Proviso HOM-15-C1

that requires the Executive to provide a written

report to the Council by November 19, 2020 discussing the City’s

compliance with the Office of City Auditor recommendations on Checkpoint

2.3, Strategies to Prevent Trash Accumulation.

The Seattle Times and The Atlantic have recently reported on the spread of infectious diseases from fecal

contamination in unsanctioned encampments. Open defecation poses significant risk for disease transmission. Just one

gram of fresh feces from an infected person can contain around 1 million viral pathogens and 1-100 million bacterial

pathogens. Ending the practice of open defecation by providing adequate sanitation (i.e., the safe disposal of human

excreta) is recognized as the most effective means of preventing the transmission of disease through feces. Source:

Sanitation and Health, Public Library of Science – Medicine, November 2010.

Enhanced shelters provide access to drinking water, heat and electricity, showers, laundry, safe cooking facilities,

storage for belongings, and can accommodate couples and pets. Tiny house villages might also provide these features

(e.g., showers, laundry, storage, etc.). We noted in our October 2018 report

that several jurisdictions received private

funding to cover the start-up costs for the enhanced shelters.

Five Steps the City of Seattle Should Take to Reduce Trash Around Unsanctioned Encampments

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Key Report Findings

Seattle’s current system for identifying

trash accumulation risks underserving

important areas of the city. The City should

use systematic geographic surveys to

ensure full-city coverage and track

progress.

Navigation Team clean-ups are resource-

intensive, and some sites have required

multiple clean-ups. These persistent hot-

spots for encampment trash accumulation

could benefit from site-specific

approaches, including improved Good

Neighbor Agreements.

Seattle has made substantial investments in

protecting urban streams and watersheds.

These environmentally-sensitive areas

require focused efforts to prevent harm

from accumulation of trash and human

waste.

Improperly discarded needles are

concentrated around unsanctioned

encampments. Seattle-funded outreach

organizations could play a larger role in

recovery of needles as they do in other

cities.

Debris from metal scrapping is often found

in and around unsanctioned encampments.

The City should use best practices to deter

metal theft.

Photo Credit: City of Seattle Navigation Team, April 2019

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TRACK TRASH ACCUMULATION

SYSTEMATICALLY

This October 14, 2019 photo shows remnants of a campfire and encampment debris near the flammable peat-bogs at

Roxhill Park. The City’s current system for determining encampment clean-ups may underserve areas of the City where

residents are less likely to contact relevant authorities or where encampment trash accumulation is hidden in

greenspaces. Seattle Parks and Recreation has begun to address encampment trash accumulation by conducting

inspections in known Parks encampment hot spots several times per week. This type of systematic identification of

encampment trash accumulation should be expanded and enhanced.

Photo Credit: Seattle Office of City Auditor, October 2019

A more strategic approach for identifying and mitigating trash accumulation

near unsanctioned encampments could help the City improve its response to

public health risks and provide better tracking of its progress. The City’s

current system for identifying trash accumulation from unsanctioned

encampments relies heavily on reports made to the City. This can result in

underserving certain areas of the city, including greenspaces and areas

where residents might be less likely to report due to barriers including,

language, access to technology, or available time. Unlike the City’s approach

to graffiti and illegal dumping, for which City crews actively monitor all areas

of the city, there is insufficient proactive monitoring/identification of

encampment trash accumulation. Further, jurisdictions including San

Francisco and Los Angeles use systematic geographic tracking of trash

accumulation to ensure equity and measure progress.

Due to potential public health risks, the City’s current approach to trash

accumulation would benefit by adopting a more systematic approach to

identifying encampments that require trash mitigation. Exhibit 1 shows how

reports of encampment trash accumulation are received from residents and

Five Steps the City of Seattle Should Take to Reduce Trash Around Unsanctioned Encampments

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other departments (e.g., Seattle Department of Transportation, Seattle Public

Utilities, etc.) and routed through the City’s Customer Service Bureau to the

Navigation Team. Upon Navigation Team inspection, significant trash

accumulation might result in a scheduled Navigation Team clean, a

Navigation Team Obstruction/Hazard clean (i.e., a clean that does not

require 72 hours notice), or no Navigation Team action. In addition, the

Navigation Team may conduct “litter-picks”

at encampments that aren’t

scheduled for removal, and up to ten encampments at any time may receive

weekly trash pick-up from

Seattle Public Utilities (SPU) Encampment Trash

Program.

Exhibit 1: City’s Current System for Encampment Trash Accumulation Relies Heavily on Reports

Source: Seattle Office of City Auditor analysis of the Human Services Department’s business process analysis of

encampment clean-up identification.

The sites addressed in the current system are those that are reported by

residents or noticed and reported by City department staff. This means that

certain areas of the City might not receive Navigation Team inspections or

clean-ups.

In contrast, the City’s graffiti and right-of-way illegal dumping

remediation

programs use a combination of response to complaints and systematic

geographic surveillance to plan its work. SPU crews regularly patrol areas of

the City to pro-actively identify graffiti and illegal dumping in the right of

way. This ensures that all areas of the City receive remediation services,

including those areas in which residents may experience barriers to

reporting.

The Human Services Department reported that the Navigation Team conducted 220 “litter-picks” between January –

September 2019.

SPU’s illegal dumping program does not pick up illegal dumping in unsanctioned encampments; it only addresses

illegal dumping in Seattle’s rights-of-way (e.g., a couch on the sidewalk).

Five Steps the City of Seattle Should Take to Reduce Trash Around Unsanctioned Encampments

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Notably, Seattle Parks and Recreation is taking steps toward systematic

tracking of encampment trash accumulation in its parks. Seattle Parks and

Recreation has begun conducting routine inspections of parks with known

encampment hot spots. These inspections occur two or three times per

week, depending on the location. These parks are monitored for trash

accumulation, and if warranted, Parks and Recreation staff may contact the

Navigation Team to visit the site. Seattle Parks and Recreation is also

considering the use of a software tool to collect information about trash and

track changes in conditions over time, such as the mobile app developed by

the City of San Francisco (Appendix C). These are important steps toward

implementing a more systematic approach for tracking trash accumulation

and are consistent with Recommendation 1 below.

Current police

and outreach

activities do not

involve

systematic

tracking of trash

accumulation

The City currently uses some proactive activities for addressing unsanctioned

encampments, including using homeless outreach contractors and, since

June 2019, Right of Way (ROW) Field Contacts conducted by the Seattle

Police Department (SPD). We could not find evidence that these efforts

involve a systematic tracking of trash accumulation.

From June 1 through November 25, 2019, SPD officers made

a total of 893

ROW Field Contacts to address encampments that were considered

obstructions because of their location (See Exhibit 2). Of that total, 59-

percent (524) of the Field Contacts were conducted by SPD Navigation Team

officers, and 41 percent (369) were conducted by SPD Community Police

Team (CPT) and bike officers from the precincts. The Human Services

Department (HSD) indicated that during a Field Contact: 1) the officer

informs the individuals that they must move their belongings, 2) if requested

by the individual, a Field Coordinator from the Navigation Team can

inventory and store the individual’s belongings, 3) the officer also provides

information about accessing shelter and offers to call a Navigation Team

System Navigator to help the individual secure a shelter referral, and 4) if

needed, Navigation Team trash and biohazard crews will remove debris from

the site. Many addresses are repeat locations for SPD ROW Field Contacts.

The

top ten addresses accounted for 164 (18 percent) of Field Contacts. The

City does not currently track whether encampment trash accumulation is

improving or worsening at these sites over time.

HSD indicated that proactive homeless outreach activities can lead to

reduced encampment trash accumulation. However, we were unable to

confirm that this is occurring in practice. We reviewed the 2019 quarterly

reports provided to HSD by its nine contracted outreach providers. Three of

the outreach providers indicated that the increased SPD ROW Field Contacts

in 2019 have made it more difficult for outreach workers to find some of

their clients and might drive individuals to harder-to-reach areas.

Five Steps the City of Seattle Should Take to Reduce Trash Around Unsanctioned Encampments

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Exhibit 2: Many Addresses are Repeat Locations for Navigation Team Clean-Ups and SPD

Field Contacts

2017-18 Navigation Team Clean-Ups (red dots)

2019 (June 1 – November 25) SPD Field Contacts –

Right of Way Enforcement (Navigation Team

officers = blue dots; Bike and Community Police

Team officers = yellow dots)

Source: Left: Seattle Office of City Auditor analysis of 2017-18 Navigation Team clean-ups (Total of 335 clean-ups with

72-hour notice); and Right: SPD Data-Driven Policing analysis of SPD ROW Field Contacts 06/01/2019-11/25/ 2019 (Total

of 893 SPD Field Contacts).

A key component of a strategic approach to addressing trash accumulation

in unsanctioned encampments is systematic geographic monitoring

throughout the city. Systematic geographic monitoring can also help the

City track its progress in addressing unsanctioned encampment trash

accumulation over time.

Exhibit 2 illustrates that between Navigation Team clean-ups and SPD field

contacts, the City has been active in many of the same locations since 2017.

However, without systematic geographic monitoring, the City cannot

Five Steps the City of Seattle Should Take to Reduce Trash Around Unsanctioned Encampments

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adequately track whether trash accumulation is getting better or worse over

time and demonstrate that there is a sustained, positive benefit from these

activities. Los Angeles and San Francisco are examples of jurisdictions that

are conducting systematic geographic monitoring of trash accumulation.

Systematic

geographic

monitoring is a

key component

of a strategic

approach to

reducing trash

accumulation at

unsanctioned

encampments

In 2016, the City of Los Angeles began implementing CleanStat, a systematic

quarterly assessment of the cleanliness level for each city street and alley.

CleanStat allows the City to track the cleanliness of streets and alleys while

strategically deploying limited sanitation resources to address the cleanup

areas of greatest need. Before CleanStat, the City’s previous “complaint-

driven system missed the areas where no one called in street cleaning

requests. As a result, unreported conditions – often in less affluent parts of

Los Angeles – went unaddressed”

. According to a December 2018 report

funded by the Laura and John Arnold Foundation, since implementing

CleanStat, there has been a citywide 83 percent reduction in miles of streets

considered “not clean,” and improvements in street cleanliness in some of

the city’s historically poorest neighborhoods.

In addition, systematic geographic monitoring of street and sidewalk

cleanliness is now being conducted in San Francisco. In July 2019, the City of

San Francisco Controller’s Office initiated a pilot program to conduct

systematic geographic monitoring of street and sidewalk cleanliness for 72

miles of predetermined commercial streets and 75 miles of predetermined

residential streets. The City of San Francisco Controller’s office developed a

mobile app

for collecting data that will be used to assess the cleanliness of

these sites over time to track the City’s progress in keeping these streets and

sidewalks clean.

Recommendation 1

The City should conduct systematic geographic surveillance throughout

Seattle to identify areas of encampment trash accumulation and track

its progress with addressing trash accumulation over time. This should

include green-spaces and areas in which residents may experience

barriers to reporting.

See report: Jachimowicz, M., Headley, M., LaMotte, J., & Bergmann, S. (2018).

How to Clean City Streets? Los Angeles

Begins by Collecting New Data.

Washington, DC: Results for America: Invest in What Works Policy Series. Retrieved from

https://results4america.org/wp-content/uploads/2018/12/LosAngelesCaseStudy_Final.pdf

Ibid.

The City of San Francisco’s Controller’s Office provided its mobile app for systematic site assessments to the City of

Seattle Office of City Auditor at no charge. See Appendix C for screenshots from the mobile app used for our

September/October 2019 site observations.

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DEVELOP/IMPLEMENT STRATEGIES FOR

PERSISTENT HOT-SPOTS

Trash clean-ups conducted by the Navigation Team are resource-intensive, sometimes requiring heavy equipment to

remove contaminated soil. Photo Credit: City of Seattle Navigation Team, May 2, 2019

15 sites

accounted for a

disproportionate

32 percent of

Navigation Team

clean-ups in

2017-18

Navigation Team clean-ups are resource-intensive for the City (staff,

equipment, disposal costs). Budgeted costs for Navigation Team clean-up

crews in 2020 exceed $2.7 million; this does not include coordination and

disposal costs. In 2018, the Navigation Team removed 2.4 million pounds

trash from unsanctioned encampments. In the first three quarters of 2019,

the Navigation Team removed over 2.3 million pounds

of trash from

unsanctioned encampments. Navigation Team clean-ups require significant

resources for staffing, equipment, and disposal costs.

We found that certain sites in Seattle continued to accumulate trash and

required repeated Navigation Team clean-ups. This current system of

repeated clean-ups is inefficient and expensive for the City.

The Navigation Team spends considerable resources cleaning up the same

sites multiple times. Our office analyzed the 335 scheduled Navigation Team

clean-ups (72-hour notice) conducted in 2017-18. These 335 clean-ups

involved 189 sites. Nearly 30 percent of the sites (56 of 189) were cleaned by

the Navigation Team multiple times during that period. Of those, 15 sites

were cleaned by the Navigation Team four or more times. These 15

sites

received a total of 107 clean-ups, accounting for a disproportionate 32

percent of the total 335 clean-ups in 2017-18. We refer to these 15 sites as

“hot-spots” due to the number of Navigation Team clean-ups at these sites.

See the City of Seattle’s Homelessness Response performance data for updated information on pounds of garbage

removed from unsanctioned encampments.

Although, the Navigation Team has changed its practices in 2019, and is conducting fewer scheduled clean-ups, six of

these 15 sites have had scheduled clean-ups (Sources: Office of City Auditor analysis of Navigation Team Site journals for

January – July 2019).

Five Steps the City of Seattle Should Take to Reduce Trash Around Unsanctioned Encampments

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Exhibit 3: 15 Locations with more than four Navigation Team Clean-ups in 2017-18

Source: Seattle Office of City Auditor site assessments, September-October 2019; and Seattle Office of City Auditor

analysis of 2017-19 Navigation Team clean-ups (72-hour notice).

*Located within a City of Seattle emphasis area

In September and October 2019, we conducted systematic site assessments

at these 15 sites. We used a mobile app for systematic site assessments

developed by the City of San Francisco’s Controller’s Office,

that they

provided to the City of Seattle at no charge. See Appendix C for screenshots

from the mobile app.

For some of the sites we observed, physical changes to the environment —

such as fencing and construction—may have contributed to keeping them

clean. Six of the 15 hot spot locations did not have observable trash

accumulation. For two of those sites (Alaskan Way Waterfront and

Bell/Western), construction activities had considerably altered the

conditions, such that it would make camping difficult or impossible. For

example, the removal of the Alaskan Way Viaduct means that much of the

space beneath the former roadway was being used to stage construction

equipment or was covered in rubble. At the Airport Way/East Duwamish

Greenbelt, we observed sturdy perimeter fencing and visible signage

The City of San Francisco Controller’s Office developed a mobile app to conduct periodic street and sidewalk

cleanliness evaluations. In 2019-20, the City of San Francisco plans to evaluate about 72 miles of predetermined

commercial streets five times throughout the year and about 75 miles of randomly selected residential streets once over

the course of the year. See Appendix C for screenshots from the mobile app.

Five Steps the City of Seattle Should Take to Reduce Trash Around Unsanctioned Encampments

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indicating that this is one of the City’s emphasis areas; we did not observe

trash accumulation at this site.

However, at nine of the 15 sites, we observed unsanctioned encampment

trash accumulation. In some cases, such as the Dearborn Corridor, we found

significant trash accumulation despite recent clean-ups by the Navigation

Team.

Use of City’s

existing

encampment

trash program

and emphasis

areas could be

optimized

The City has some tools that it could use to address unsanctioned

encampments where trash accumulation is a chronic problem:

• Optimize use of SPU encampment trash program. The City

currently provides weekly trash collection through SPU’s

encampment trash program

(commonly known as the purple bag

program) at eight sites. From January 1 – September 10, 2019, SPU

collected 948,030 pounds of trash through the program. To the

extent that sites are suitable candidates for the encampment trash

program

, the City could expand beyond the eight sites.

• Optimize use of emphasis areas. Section 13 of

Finance and

Administrative Services (FAS) Rule 17-01 allows the City to identify

up to ten emphasis areas, defined as “an identifiable area where the

City has removed an encampment and has designated an

encampment-prohibited area by installing signage.” The City will

post signage at an emphasis area, stating that: camping is

prohibited, and any material found in that area may be removed

without further notice. Additionally, the signs state where personal

property removed from the site is stored and how the owner can

retrieve their belongings. City rules currently permit up to ten

emphasis areas; and there are currently

eight. Therefore, the City has

capacity to add two additional emphasis areas.

Other cities use

“Good Neighbor

Agreements”

with homeless

service providers

to help address

nearby trash

accumulation

We found that trash is accumulating at chronic hot spots near City-funded

homeless service facilities. Other cities use “Good Neighbor Agreements”

with their contracted agencies to address trash accumulation in the areas

around their facilities. HSD does not currently address trash accumulation in

their Good Neighbor Agreements with homeless service agencies.

During our September 2019 observations, we found encampment trash

accumulation at two persistent hot spot locations (Dearborn Corridor and

Cascade) that were adjacent to two City-funded homeless services facilities.

HSD contracts require homeless services facilities (e.g., shelters, permanent

supportive housing) to maintain a Good Neighbor Plan

. HSD’s contract

language states that Good Neighbor Plans will include a process for

Trash collection services are delivered by way of outreach workers distributing bags. Persons living in encampments

voluntarily fill the bags and place trash 20 feet from encampment for collection.

SPU indicates that the encampment trash program depends on the identification of established, self-organized

encampments that are able to collect their own trash within the spaces they occupy and deliver them to a specified

drop-off point for contractor pick-up. Not all encampments fit these criteria.

Five Steps the City of Seattle Should Take to Reduce Trash Around Unsanctioned Encampments

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communicating with neighboring businesses and residents, policy/

procedure to address neighborhood concerns, written policy concerning the

rights and responsibilities of clients, program rules and restrictions, and

opportunities for providers, clients and community members to participate

in supporting program and client success in healthy and safe

neighborhoods.

HSD’s 2019 Good Neighbor agreements ask for a “commitment to

neighborhood health and safety standards,” but they do not specifically

mention trash or litter mitigation. Further, HSD does not currently require its

contractors to address trash accumulation adjacent to its facilities. In

contrast, in other cities, including Portland, Vancouver BC, and San Francisco,

Good Neighbor Agreements with homeless services providers include

expectations about maintaining cleanliness in the area surrounding the

facility. For example, a

‘Good Neighbor Agreement’ between a homeless

shelter and Portland’s Joint Office for Homeless Services includes “all spaces

within 1000 feet of the shelter site.”

We obtained HSD’s

2019 ‘Good Neighbor Plan’ for the DESC Navigation

Center. This facility is adjacent to the “Dearborn Corridor” site. This hot spot

for trash accumulation was cleaned 10 times by the Navigation Team in

2017-18; Navigation Team site journals for 2019 indicate that it had been

cleaned twice between January and July 2019, and the site is on SPU’s litter

route. In addition, two of SPD’s top ten ROW Field Contact addresses

(accounting for 30 SPD ROW Field Contacts) are near the Navigation Center

(See Exhibit 4). Despite these efforts, during our September 2019 field

observation, we noted significant trash accumulation at the site, including

directly adjacent to the Navigation Center facility.

Exhibit 4: Two of SPD’s Top Ten ROW Field Contact Locations are

Near the DESC Navigation Center

Source: SPD Analysis of the top ten addresses for SPD ROW Field Contacts, June 1-

November 25, 2019

Five Steps the City of Seattle Should Take to Reduce Trash Around Unsanctioned Encampments

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Exhibit 5 provides a cross-walk between the Portland Good Neighbor

Agreement example and the Seattle’s (HSD) Good Neighbor Plan for the

Navigation Center. Unlike Portland’s Good Neighbor Agreements, Seattle’s

agreements are not very robust. For example, they do not require signatures

from stakeholders, and they do not address trash accumulation.

Exhibit 5: Portland’s Good Neighbor Provisions are More Extensive Than Seattle’s

Agency City of Seattle Human Services

Department

Portland Joint Office for Homeless

Services (JOHS)

Signatories None JOHS, Shelter Provider, Neighborhood

Association, Police Department, Local

Businesses, Local School, Local Business

Association

Physical Area Covered

Not stated

All spaces within 1000 feet of the shelter

Provisions for Litter Not stated Voluntary litter patrols; staff pick up litter

around perimeter

Community Meetings Homeless shelter staff attend community

meetings

Homeless shelter staff attend community

meetings; Homeless shelter hosts

quarterly community meetings

Mediation Resources

Not stated

JOHS will provide mediation

Legal Status of Agreement

Non-binding

Source: Seattle Office of City Auditor analysis of the Human Services Department’s 2019 ‘Good Neighbor Plan’ for the

DESC Navigation Center and ‘Good Neighbor Agreement’ between a homeless shelter and Portland’s Joint Office for

Homeless Services.

Recommendation 2 The City should apply specific strategies to address persistent hot spots

of encampment trash accumulation in Seattle that may include, but are

not limited to: 1) expanding and increasing the frequency of the Seattle

Public Utilities encampment trash program, 2) designating more

emphasis areas,

and 3) requiring specific litter mitigation activities in

a designated area around the facilities as part of Good Neighbor

Agreements with City-funded agencies.

Designating more than ten emphasis areas would require amending the FAS Encampment Rule 17-01, section 13.6.

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PROTECT URBAN STREAMS/WATERSHEDS

During this clean-up of unsanctioned encampments at the Thornton Creek Natural Area, the Navigation Team removed

corrosive materials and human waste.

Photo Credit: City of Seattle Navigation Team, July 23, 2018

The City has made significant long-term investments in protecting creeks,

watersheds, receiving waters, and habitat. Therefore, it will be important to

ensure that these dollars are not undercut by the City’s actions or inactions

related to encampment trash accumulation and fecal contamination.

Seattle contains several urban creek watersheds, as well as two large regional

watersheds. Preserving and improving the health of the urban watersheds is

essential for providing healthy and livable communities. Urban creek

watersheds not only are home to fish and wildlife, but help to filter stormwater

before it enters lakes, the Duwamish River, and Puget Sound. For certain

environmentally sensitive sites, exposure to chronic litter, dumping, and human

waste contamination associated with unsanctioned encampments could slow

gains from long-term City investments. Therefore, the City should consider

whether its actions or inactions related to encampment trash clean up undercut

other City efforts to keep the water clean.

Environmentally

sensitive areas

are at risk of

contamination

A recent SPU analysis describes the kind of contamination that can be

caused by unsanctioned encampments. For example, there are encampments

in the Thornton Creek watershed, and a 2018 SPU analysis

showed elevated

levels of human-source fecal bacteria in Thornton Creek near Matthews

Beach. Exhibit 6 identifies environmentally sensitive areas in Seattle that

could be contaminated by trash and human waste, including urban streams,

wetlands, public beaches, and shoreline. These areas highlighted on the map

have the highest likelihood of surface water contamination from

unsanctioned sites.

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Until a comprehensive solution is implemented to help those experiencing

homelessness, or to provide these individuals with access to appropriate

sanitary facilities, the risks associated with the uncontrolled inputs of human

waste at environmentally sensitive areas need to be mitigated. One method

to reduce these risks is to not allow camping in locations that have the

highest likelihood of moving trash and feces generated at these sites into

the surface waters.

It will also be important for the City to continue to investigate and fund

effective interventions for addressing human waste generation from

unhoused populations. For example, in 2020, the Seattle City Council funded

a short-term pilot project in SPU to test innovative solutions to manage and

dispose of wastewater generated from unauthorized homeless

encampments. SPU’s pilot program’s charter indicates that “unmanaged

waste from unhoused populations represent a significant risk to public

health and the environment.”

The pilot will include field testing of potential

wastewater service delivery models, and SPU is coordinating with various

stakeholders including SPD, the Navigation Team, Department of

Neighborhoods, Public Health - Seattle & King County (PHSKC), and

community stakeholders.

Recommendation 3 We recommend that the City prohibit camping in Water Quality and

Public Health Protection Areas, and systematically monitor these

locations to ensure that unsanctioned camping is not occurring.

The SPU Wastewater for Unhoused Populations Pilot Program Charter indicates “Using a conservative estimate of

human waste generation; the unhoused population in the City of Seattle is producing approximately 1280 gallons of

highly concentrated human waste every day. No data exists on the proportion of this waste which is being disposed of

onto streets or into storm-drains. Based on the rate of incidents being referred to SPU’s Spill Response team, it appears

that a significant portion of this waste is being improperly managed. SPU Spill Response responded to 142 sewage spills

with 117 requiring cleaning due to human waste from unhoused populations in drains or on the public right of way from

1/1/2018 to 8/1/2019.”

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Exhibit 6: Environmentally Sensitive Areas Risk Greater Harms from Trash and Human Waste

Accumulation

Source: Seattle Public Utilities, Environmental Science and Technology Section

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IMPROVE NEEDLE RECOVERY EFFORTS

86 percent of Navigation Team clean-ups from January – July 2019 involved the recovery and disposal of needle waste.

Photo Credit: City of Seattle Navigation Team, June 12, 2019

Hypodermic needles (needles) are improperly disposed in Seattle’s public

areas by housed individuals as well as individuals who are experiencing

homelessness. Discarded needles and syringes are a common component of

the trash that accumulates at unsanctioned encampments. City-funded

outreach workers currently bring clean needles to unsanctioned

encampments but do not have any responsibility for recovery and disposal

of those needles. Consequently, improperly discarded needles pose health

risks for the general population and require significant City resources to

clean up.

It is important for people who inject drugs to have adequate access to clean

needles. Using clean needles significantly reduces the risks of transmitting

infections including, HIV, Hepatitis B, and Hepatitis C. There are

four needle

exchange locations

in Seattle. In addition, at least three

of HSD’s

homeless outreach providers deliver clean needles to unsanctioned

encampments. However, these HSD-funded homeless outreach providers do

not accept or collect used needles.

This results in a burden for the City to

According to Public Health Seattle and King County each needle exchange provides sharps containers and receives

both sharps containers and individually discarded needles.

HSD indicated that three of its funded homeless outreach providers provide needles to unsheltered individuals: REACH

(Navigation Team), REACH (Neighborhood Outreach), and YouthCare Street Outreach. None of these three outreach

providers provide needle recovery and disposal of used needles. HSD indicated that three of its funded outreach

providers do not provide clean needles or recover used needles: Mary’s Place, Chief Seattle Club, Urban League Street

Team. HSD was unable to provide information about needle exchange for the following funded homeless providers:

Seattle Indian Center, DESC HOST, Seattle Indian Health Board, Mother Nation.

In contrast, as part of their encampment trash program, SPU’s three contracted hepatitis education outreach workers

(15 hours per week total) provide needle distribution and collection to eight unsanctioned encampments.

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find, recover, and dispose of the used needles around unsanctioned

encampments.

Currently, the City advises

people to report used needles to 1) the Customer

Service Bureau or, 2) Seattle Parks and Recreation, or 3) SPU’s Illegal

Dumping hotline.

SPU removes needles from public property within 24

hours and provides advice regarding safe clean-up and disposal of needles

from private property. From August 2016 through December 2019, SPU staff

have collected 30,905 needles in response to 9,333 community reports.

People disposed since February 2017 a total of 253,050 syringes in boxes

located in City public rights-of-way and small bathroom needle disposal

units.

In addition to the SPU staff who clean up needles based on complaints, the

Downtown Seattle Association’s (DSA) Metropolitan Improvement District

(MID) staff routinely pick up needles in the DSA service area. From January

through November 2019, MID staff cleaned up 10,797 needles.

Further, the

Navigation Team often cleans up needles during its clean-ups of

unsanctioned encampments. Exhibit 7 maps the 335 Navigation Team

encampment clean-ups in 2017-18 and the 4,473 (unduplicated) reports of

needles to SPU for that same period. The map shows geographic clusters of

concentration of needles and encampment clean-ups.

Further, our analysis

of Navigation Team site journals from January through July 2019 indicates

that 86 percent of these clean-ups involved the recovery of needles.

SPU also advises people to safely dispose of needles at any of the secure public disposal boxes located in the right of

way, public parks, and public libraries. SPU’s sharps collection website

provides an interactive map of sharps disposal

locations.

The total of 10,797 needles collected by the DSA MID from January – November 2019 represents a 15 percent increase

over the same period in 2018.

The Office of City Auditor did not correlate the locations of needles with other features including transit corridors,

proximity to service providers, etc.

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Exhibit 7: Navigation Team encampment clean-ups (red) and reported needle waste (blue) are

geographically clustered.

Source: Map by Seattle Public Utilities, Environmental Science and Technology Section based on SPU needle data and

Navigation Team clean-up data (72-hour notice), 2017-18.

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In other cities

outreach

agencies conduct

proactive “needle

sweeps” to

recover used

needles

In Boston, the City’s needle exchange and harm reduction services provider,

AHOPE

, has a four-person team that picks up used needles 12 hours per day,

seven days a week. In addition to the dedicated sharps team, 10 to 15

AHOPE outreach workers collect used needles as they are doing outreach in

the community. “We are in the midst of a crisis, and we have to work

together,” said Sarah Mackin, director of AHOPE, in a

recent interview. “The

reality is that we are not only taking responsibility for the syringes that we

give out, we’re taking responsibility for any syringes found in a public way.”

The San Francisco Department of Public Health considers syringe recovery

and disposal to be an important part of their collective impact approach

Each of San

Francisco’s 13

syringe sites has a

written disposal plan

that includes syringe

recovery, street area

“sweeps,” and

targeted clean-ups

throughout the city.

In addition, the San

Francisco

Department of Public

Health funds a ten-

person clean-up

crew that picks up

discarded syringes

seven days per week.

Recommendation 4

The City should engage outreach agencies in needle recovery and track

its progress in reducing improperly discarded needle waste.

Ottawa’s “Needle Hunter” Program

Creates Jobs and Protects Public from

Discarded Needles

The City of Ottawa partners with the Causeway Work

Centre to hire, train, and supervise up to forty men and

women who are at risk of homelessness due to recovery

from addiction and/or some form of mental illness. They

call themselves “Needle Hunters,” and they work seven

days a week to recover discarded needles and other drug

paraphernalia from public spaces. In 2018, the Needle

Hunters recovered about 20,000 needles. Needle Hunters

are paid employees who have had difficulty integrating

into the traditional workforce.

Above: Needle Hunter Theresa, photo by Nicholas

Galipeau. For the full video produced by Nicholas

Galipeau about the Needle Hunters click here:

https://www.youtube.com/watch?v=PcICu7_9kE8

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USE BEST PRACTICES TO DETER METAL

THEFT

58 percent of Navigation Team clean-ups from January – July 2019 involved the recovery and disposal of debris from

metal scrapping.

Photo Credit: City of Seattle Navigation Team, January 8, 2019

Deterring metal

theft can reduce

related trash

accumulation

While metal scrapping in public places in Seattle may be carried out by

housed individuals as well as individuals experiencing homelessness, metal

scrapping activities around unsanctioned encampments can contribute to

trash accumulation at these sites. For example, piles of insulation and

coating are left behind when copper wire is stripped, and tires and trash

accumulate when bikes and other metal objects are dismantled. We found

evidence of debris from metal scrapping at 58 percent of Navigation Team

clean-up sites between January and July 2019. The metal scrapping at

unsanctioned encampments may not be related to metal theft. However, to

the extent that these scrapping activities are theft-related, any progress that

the City can make in deterring metal theft could also reduce the amount of

related trash accumulation.

One proven approach for cities in deterring metal theft is working with metal

recycling businesses to reduce the incentives for metal theft. The Problem-

Oriented Policing Guide to Theft of Scrap Metal, states that “the scrap metal

theft problem is driven entirely by the ability to sell stolen goods to

recyclers.” Our analysis indicated that there are eight scrap metal recycling

businesses in Seattle, and it is important for the City to ensure that these

scrap metal dealers are operating responsible

recycling businesses. In the

past year, SPD has conducted preliminary compliance checks with three of

the eight recycling businesses and found one business out of compliance.

However, SPD indicated that it has not been able to dedicate resources to

RCW Chapter 19.290 describes the requirements for scrap metal businesses in Washington state including record-

keeping and reporting to law enforcement.

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conduct follow-up compliance checks or to look at the five remaining

businesses.

Use Proven Practices. It is important that the City approach metal theft

deterrence by using practices that are effective, procedurally just, and fair to

the affected parties. The U.S. Department of Justice, Office of Community

Oriented Policing Services has developed guidebooks for police agencies

that identify proven practices for reducing bicycle theft and metal theft

. In

addition, the Institute of Scrap Recycling Industries, Inc. provides free

technical assistance to law enforcement agencies on strategies for working

with scrap metal recycling businesses to deter metal theft.

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Recommendation 5 The City should use proven strategies for deterring metal theft to

reduce the accumulation of trash accumulation from metal scrapping

around unsanctioned encampments.

Recent Street Light Wire Thefts Put Certain

Seattle Communities at Risk

In addition to contributing to trash accumulation, metal

theft can also reduce community safety. In 2019, Seattle

City Light has experienced an increase in wire thefts in its

street light system. City Light officials are aware of 25 wire

thefts that year that disrupted street light service in the

affected areas. At least four of the 25 thefts disrupted

street light services near low-income housing complexes.

Disruption of street light services is dangerous for

pedestrians and drivers. Lack of street lighting can also

increase risk for and fear of crime and may cause

residents to curtail normal activities.

Addressing wire theft is costly and complicated for Seattle

City Light. Thieves generally remove the wires from street

light poles by breaking into the access covers at the base

of the poles and handholes in the street. Four wires, at

about 100 feet each, can be removed from a single pole.

Seattle City Light has taken preventative measures

including installing tamper-proof screws and replacing

copper wires with steel (which has no monetary value),

but these measures have not deterred the theft. Now, City

Light crews are welding handholes shut and blocking

access with heavy environmental blocks. These measures,

while they may prevent theft, make maintenance more

difficult and costly for Seattle City Light.

Seattle City Light Street Light Wire Thefts,

January – November 2019

Source: Office of City Auditor analysis of

Seattle City Light street light wire theft report

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OBJECTIVES, SCOPE, AND METHODOLOGY

Audit Scope and

Methodology

This audit was conducted at the request of Councilmember Lisa Herbold for

our office to assess the Executive’s

Quarter 2 response to the Navigation

Team reporting plan, which responded to 5 of the 14 reporting checkpoints

from the Office of City Auditor’s November 2017 Navigation Team Reporting

Plan. This audit focuses specifically on Checkpoint 2.3: Assessment of

Strategies to Prevent Trash Accumulation.

This report was written by Claudia Gross Shader with input from Megumi

Sumitani, Melissa Alderson, and Sean DeBlieck.

The Office of City Auditor would like to extend its appreciation to the GIS

staff in SPU and Seattle Information Technology for their assistance in

creating the maps included in this report as well as their assistance in

supporting our pilot use of the Survey 123 mobile app developed by the City

of San Francisco.

We would also like to thank the following researchers for their review and

comment on our draft report: Dr. Karen Snedker from Seattle Pacific

University, Dr. Cody Telep and Katherine Brown from Arizona State

University, and Dr. Benjamin Bearnot, Division of General Internal Medicine,

Department of Medicine, Massachusetts General Hospital, Boston, and

Department of Medicine, Harvard Medical School.

A preliminary draft of this report was shared with staff from HSD, SPD, SPU,

Parks, PHSKC, Seattle Office for Civil Rights, the City Budget Office, and the

Mayor’s Office. We made changes to the final report based on their input.

We conducted this audit using various methodologies, as follows:

• We reviewed the Executive’s August 10, 2018 Quarter 2 Response to

Statement of Legislative Intent 242-1-A-1;

• We interviewed officials from several City departments: HSD, SPU, SPD,

PHSKC;

• With data we obtained from the Navigation Team and assistance from

SPU GIS staff, we geocoded, mapped, and analyzed 2017-18

encampment clean-ups;

• With assistance from the Seattle Information Technology GIS staff and

SPU GIS staff we loaded the Survey 123 mobile app developed by the

City of San Francisco;

• We made site visits to the 15 locations with the most frequent

Navigation Team clean-ups from 2017-18 and evaluated the conditions

at these sites with the Survey 123 mobile app;

• We made site visits to locations for the SPU encampment trash program;

Five Steps the City of Seattle Should Take to Reduce Trash Around Unsanctioned Encampments

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• We researched the processes of how the City is notified of new

encampments;

• We analyzed data provided by SPD on its Right of Way Field Contacts;

• We used NVivo, a qualitative analysis software tool, to analyze key

themes from the 2019 quarterly reports of HSD’s contracted outreach

providers;

• We researched examples of systematic geographic tracking of trash

accumulation, needle recovery, and good neighbor agreements from

other jurisdictions.

Per our standard practice, we conducted a process based on the City’s

Racial

Equity Toolkit for our work on this report. Further, we intentionally sought

opportunities to incorporate into our analysis the experience of people living

unsheltered. This included our site observations of the 15 sites most

frequently cleaned by the Navigation Team in 2017-18.

We conducted this performance audit in accordance with generally accepted

government auditing standards. Those standards require that we plan and

perform the audit to obtain sufficient appropriate evidence to provide a

reasonable bass for our finding and conclusions based on our audit

objectives. We believe that the evidence obtained provides a reasonable

basis for our finding and conclusions based on our audit objectives.

NOTE: RATS IN UNSANCTIONED ENCAMPMENTS

During our audit, officials from Public Health Seattle & King County (PHSKC) noted that unsecured food,

human waste, and solid waste accumulations at unsanctioned encampments provide food and harborage

for rats. Individuals living in unsanctioned encampments are at risk of exposure to rat bites, urine, and

feces that can carry diseases. Further, when a rat infestation becomes established at an unsanctioned

encampment, the rodents will migrate to neighboring properties increasing the risk of damage caused by

rats to neighboring homes and businesses.

We did not conduct fieldwork for this audit to assess Seattle’s public health risks related to rats.

In July 2018, PHSKC developed a flyer

about rodents in response to outreach workers reporting rats and

rat bites that were affecting people who were living outside.

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APPENDIX A

Executive Response

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APPENDIX B

List of Recommendations

• Recommendation 1: The City should conduct systematic geographic surveillance throughout

Seattle to identify areas of encampment trash accumulation and track its progress with addressing

trash accumulation over time. This should include green-spaces and areas in which residents may

experience barriers to reporting.

• Recommendation 2: The City should apply specific strategies to address persistent hot spots of

encampment trash accumulation in Seattle that may include, but are not limited to: 1) expanding

and increasing the frequency of the SPU encampment trash program, 2) designating more

emphasis areas, and 3) requiring specific litter mitigation activities in a designated area around the

facilities as part of Good Neighbor Agreements with City-funded agencies.

• Recommendation 3: We recommend that the City prohibit camping in Water Quality and Public

Health Protection Areas, and systematically monitor these locations to ensure that unsanctioned

camping is not occurring.

• Recommendation 4: The City should engage outreach agencies in needle recovery and track its

progress in reducing improperly discarded needle waste.

• Recommendation 5: The City should use proven strategies for deterring metal theft to reduce the

accumulation of trash accumulation from metal scrapping around unsanctioned encampments.

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APPENDIX C

Screenshots of Mobile App for Systematic Site Observations

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APPENDIX D

Seattle Office of City Auditor Mission, Background, and Quality

Assurance

Our Mission:

To help the City of Seattle achieve honest, efficient management and full accountability throughout City

government. We serve the public interest by providing the City Council, Mayor and City department

heads with accurate information, unbiased analysis, and objective recommendations on how best to use

public resources in support of the well-being of Seattle residents.

Background:

Seattle voters established our office by a 1991 amendment to the City Charter. The office is an

independent department within the legislative branch of City government. The City Auditor reports to

the City Council and has a four-year term to ensure her/his independence in deciding what work the

office should perform and reporting the results of this work.

The Office of City Auditor conducts

performance audits and non-audit projects covering City of Seattle programs, departments, grants, and

contracts. The City Auditor’s goal is to ensure that the City of Seattle is run as effectively, efficiently, and

equitably as possible in compliance with applicable laws and regulations.

How We Ensure Quality:

The office’s work is performed in accordance with the Government Auditing Standards issued by the

Comptroller General of the United States. These standards provide guidelines for audit planning,

fieldwork, quality control systems, staff training, and reporting of results. In addition, the standards

require that external auditors periodically review our office’s policies, procedures, and activities to

ensure that we adhere to these professional standards.

Seattle Office of City Auditor

700 Fifth Avenue, Suite 2410

Seattle WA 98124-4729

Ph: 206-233-3801