SMITH & LOWNEY, P.L.L.C.
2317 East John Street
Seattle, Washington 98112
(206) 860-2883, FAX (206) 860-4187

November 15, 2015
Department of Planning and Development
ATTN: Public Resource Center
700 5th Ave., Ste. 2000
PO Box 34019
Seattle, Washington 98124-4019
Re.:

MUP no. 3020285

Introduction.
These comments are being submitted on behalf of End the Prison Industrial Complex Seattle (“EPIC”), a multi-generational and anti-racist community group organizing to end Youth
Incarceration, which is joined in these comments by the following organizations: Seattle-King
County NAACP, Seattle Human Rights Commission, Post-Prison Education Program, Just
Leadership USA, Incarcerated Mothers Advocacy Project, Equity Education Advocate,
Foundation for Healthy Generations, and the National Lawyers Guild, Seattle Chapter. We
request that the City of Seattle deny the master use permit (“MUP”) to the proposed new King
County youth jail project at 1211 E. Alder in Seattle (“youth jail”). The City should defer action
on this application until (1) the City completes a full race and social justice analysis and
environmental review of the impacts of a new youth jail; (2) the City updates the environmental
review; and (3) the City reissues public notice and solicits comments on the specific land use
departures requested by the County, including the extent of and claimed justification for the
departures.
The construction of a new youth jail with a 50-year lifespan would perpetuate a failed
and racist social policy that locks up youths of color in disproportionate numbers. These kids,
more often than not, suffer from trauma, domestic violence, and/or poverty. Locking them up
and severing their relationships with school and family – often for nonviolent offenses – provides
no benefit to them or to society. It exacerbates their trauma and reduces their opportunities.
Indeed, white juvenile offenders have greater chance of success because the system typically
looks the other way, allowing them to grow out of that phase of life without the stigma and
trauma of incarceration.

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We are at an historic moment where all levels of government are waking up to the
injustice of racially disparate incarceration as well the ineffectiveness and social harms of mass
incarceration. Virtually every level of government, from the President to local law enforcement
officials, are calling for a new approach to justice. Our local governments have made specific
commitments with regard to youth incarceration. Our City Council has committed to end youth
incarceration, and King County has committed to reduce the disproportionate detention of youth
of color.
At this moment when our country is turning away from youth detention, how can the City
of Seattle approve a new youth jail with the capacity to lock up two to three times more youth
than we do today? We should not be investing millions of dollars to tear down and rebuild the
existing 23-year-old youth jail, when that money should be spent to support youth and families in
trouble and help them avoid incarceration. The County cannot have it both ways- pledging to
reduce youth incarceration and at the same time insisting that it needs a facility to double or
triple the detention rate.
Seattle can and must stop this misguided project. King County requests that the City
waive critical standards in the land use code based upon its unsupported claim that a new
detention center is needed. As discussed herein, the detention facility is only 23 years old and
there is no need to replace it. Moreover, there is no justification for building a new youth jail
with as many as 150 beds, when the current average population hovers around 60 and all levels
of government have pledged to significantly reduce the number of detained youth in the near
future. City Code gives the Department of Planning and Development the discretion to refuse
these waivers and to prepare a complete race and social justice analysis along with an updated
environmental review.
It is time to close our youth jails, not build another one. We should reinvest our
government's scarce resources into evidence-based approaches to helping kids in trouble. We
should not be constructing a facility to lock kids up for another 50 years.
A.

Our system of youth incarceration is unjust and cruel.
1.

King County disproportionately jails youth of color.

Our current system of youth detention disproportionately locks up youth of color. King
County acknowledges that “[w]hile the number of youth in [the County's] juvenile detention has
dropped..., racial disparity has grown.”1

1

Dow Constantine, King County takes action to root out racial disparity in juvenile justice system, King County
Website, March 31, 2015, available at

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Although young people of all ethnicities commit crimes, juvenile prisons are
overwhelmingly filled with black and brown youth.2 In 2013, youth of color accounted for 68%
of youth in residential placement nationally.3 Yet, there is evidence that white youth commit
crimes at the same rate as youth of color.4 Disproportionate incarceration rates can be traced to
implicit bias at every stage of the criminal justice system.5 For example, black youth are
stopped, arrested, detained, and incarcerated at far higher rates than their white counterparts for
the same offenses.6
In King County, black youth make up just 8% of youth, yet represent half of youth
detention admissions.7 Almost three-quarters of incarcerated youth are youth of color.8 This
problem is not getting better. The proportion of black youth who have been incarcerated has
increased in the past decade.9 Just between 2014 and 2015, the number of African Americans
charged with crimes by King County increased by 16.8%, and the number of Asian/Pacific
Islanders charged increased by 52%.10
2.

Most of the kids we lock up suffer from trauma, mental health issues, and/or
abuse.

One of the injustices of youth incarceration is that the kids we lock up are more often
than not coping with trauma, abuse, and/or mental illness. Nine out of ten girls who are
incarcerated have suffered from physical, sexual, or emotional abuse before entering the
juvenile justice system.11 In Washington, 60% of incarcerated youth have mental health issues,
and more face drug or alcohol dependency.12

http://www.kingcounty.gov/elected/executive/constantine/News/release/2015/March/31-juvenile-detentiondiversion.aspx.
2
Juvenile Justice Information Exchange, Racial-Ethnic Fairness, 2015. Available at http://jjie.org/hub/racial-ethnicfairness/.
3
Office of Juvenile Justice and Delinquency Prevention, The Number of Juveniles in Residential Placement
Continued to Decline in 2013. Available at http://www.ojjdp.gov/ojstatbb/snapshots/DataSnapshot_CJRP2013.pdf.
4
Task Force on Race and the Criminal Justice System, Preliminary Report on Race and Washington's Criminal
Justice System, 2011.
5
Id.
6
W. Haywood Burns Institute, Non-Judicial Drivers into the Juvenile Justice System for Youth of Color, 2010.
Available at http://www.indiana.edu/~atlantic/wp-content/uploads/2011/12/Burns-Institute-NonJudicial-drivers.pdf
7
King County, Racial Equity at the Children and Family Justice Center at 1. Available at
http://kcyouthjustice.com/statistics/
8
Id.
9
City of Seattle Resolution 31614, Legislation Details (With Text), Sept. 21, 2015, at 3.
10
Id.
11
Id. at 4.
12
City of Seattle Resolution 31614, Legislation Details (With Text), Sept. 21, 2015, at 4.

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Many of these health and behavioral issues are exacerbated by incarceration due to
victimization by other inmates or prison staff, access to illicit substances in jail, and separation
from social supports.13 These stressors lead to increased rates of suicide idealization and
depression throughout youth jails.14
3.

We are locking up kids for property and status crimes.

Another injustice is that we often are locking these kids up merely for property crimes
and status offenses. Approximately 43% of the King County youth jail population is being
detained for property crimes. Over 10% of King County’s youth jail population is incarcerated
for status offenses such as not attending a follow-up hearing.15 This problem is also getting
worse. Between 2014 and 2015, the length of stay per offender increased by 40% and detention
for property crimes increased by almost 30%.16
Locking kids up merely for a status offense is wrong and contrary to federal policy. In
1994, the Juvenile Justice and Delinquency Prevention Act (JJDPA) called for the
“deinstitutionalization” of status offenders.17 Yet, Washington leads the nation in jailing youth
for non-criminal behaviors, including truancy and running away from home.18 Building a new
jail is likely to make these problems worse, as judges will undoubtedly feel less hesitancy to
detain a child once they have built a new facility that was touted as providing improving
conditions.
4.

Youth incarceration is ineffective and counter-productive.

Youth incarceration has been proven to be ineffective and counter-productive. Stays in
juvenile detention have been shown not to reduce recidivism. In one particular study, there was
no significant difference in recidivism between youth placed in institutions and youth who

13

Paediatrics and Child Health, Problems with access to adolescent mental health care can lead to dealings with the
criminal justice system, Jan. 2009. Available at http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2661329/.
14
Barry Holman and Jason Ziedenberg, Problems with access to adolescent mental health care can lead to dealings
with the criminal justice system, Justice Policy Institute. Available at
http://www.justicepolicy.org/images/upload/06-11_rep_dangersofdetention_jj.pdf.
15
Id.
16
King County Juvenile Court, King County Juvenile Justice Statistics Comparison of 2014 and 2015 through June
30th, 2015.
17
Id.
18
Gary Gately, New Report Finds Incarceration for ‘Status Offenses’ Still Widespread, Juvenile Justice Information
Exchange, April 10, 2015. Available at http://jjie.org/new-report-finds-incarceration-for-status-offenses-stillwidespread/. In a survey measuring the states who use the valid court order exception from 2010-2012, Washington
state detained more youth through the use of the “valid court order” exception (2,705) than all of the three following
states combined (Kentucky: 1,048; Arkansas: 747; Colorado: 356). Id.

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received probation for similar offenses.19 Other studies show that incarcerating a youth for lowlevel crimes makes them more likely to reoffend than those who were not incarcerated.20
King County’s proposal to build a new youth jail bucks a national trend toward ending
youth incarceration. States such as Ohio, Michigan, Texas, Illinois, California, Alabama, and
New York have passed legislation aimed at ending youth detention.21 Nationally, there is a
movement towards community-led alternatives to incarceration such as diversion and restorative
justice.22 Studies have found that community-led alternatives are more effective at reducing
recidivism than jail.23
In addition, the Washington legislature requires state-funded juvenile justice
interventions and programs to be evidence-based24 and research-proven.25 State policy makers
are demanding that program evaluation and cost-benefit analysis techniques be applied to
spending on juvenile justice and child welfare.26 There is no evidence that youth incarceration
provides any benefit or rehabilitation. In fact, none of the evidence-based programs that have
proven to be effective are found in the detention center or the courtroom.27
19

Id.
Center on Juvenile and Criminal Justice, Study: Long-term Juvenile Incarceration Fails to Decrease Reoffending
Rates, May 3, 2012. Available at http://www.cjcj.org/news/5476.
21
National Council on Crime and Delinquency, Using Bills and Budgets to Further Youth Incarceration, Aug. 28,
2013, Available at http://www.nccdglobal.org/sites/default/files/publication_pdf/bills-and-budgets.pdf.
22
Juvenile Justice Information Exchange, Reform Trends, 2015. Available at http://jjie.org/hub/community-basedalternatives/reform-trends/.
23
Juvenile Justice Information Exchange, Key Issues, 2015. Available at http://jjie.org/hub/community-basedalternatives/key-issues/.
24
See e.g. RCW 43.20C, RCW 13.40.500; Center for Children and Youth, Washington State Models for Change
Work Plan, May 2007. Available at http://ccyj.org/wp-content/uploads/2015/04/Models-for-Change-WorkplanSummary.pdf.
25
Washington State Institute for Public Policy, The Community Juvenile Accountability Act:
Research-Proven Interventions for the Juvenile Courts, Jan. 1999. Available at
http://www.wsipp.wa.gov/ReportFile/1311/Wsipp_The-Community-Juvenile-Accountability-Act-Research-ProvenInterventions-for-the-Juvenile-Courts_Full-Report.pdf.
26
Id.
27
Washington State Institute for Public Policy, Updated Inventory of Evidence-Based, Research-Based, and
Promising Practices For Prevention and Intervention Services for Children and Juveniles in Child Welfare, Juvenile
Justice, and Mental Health Systems, July 2015.Available at
http://www.wsipp.wa.gov/ReportFile/1610/Wsipp_Updated-Inventory-of-Evidence-based-Research-based-andPromising-Practices-For-Prevention-and-Intervention-Services-for-Children-and-Juveniles-in-the-Child-WelfareJuvenile-Justice-and-Mental-Health-Systems_Inventory.pdf.
The inventory also includes evidence based programs for the child welfare system, another system to be housed
in the proposed building. These too are based in the community and delivered to children and families where they
live -- in their homes, neighborhoods and schools. These services do not require judicial intervention, judges,
lawyers or jail cells.
The County has also failed to justify the need for a $210 million expenditure to house judges and courtrooms
for the child welfare and dependency proceedings, which also have a racially disparate impact in decisions about
which children to remove from the home. See Washington State Racial Disproportionality Advisory Committee,
Report on Racial Disproportionality in Washington’s Child Welfare System (2d Edition Committee Report to DSHS
Secretary Robin Arnold-Williams pursuant to SHB 1472, Chapter 465, Laws of 2007). Available at
20

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Just last year King County published a comprehensive study28 highlighting services that
have been proven effective (that are "evidence-based"29),and none of them require incarceration
or detention.30 If King County has determined that these evidence-based programs are the most
effective methods of handling issues of juvenile delinquency or familial trouble, then the County
should be investing in them rather than a new youth jail.
Local research also finds community-led alternatives to incarceration to be more effective
and beneficial. A recent study by the Washington State Institution for Public Policy showed that
community-led alternatives to juvenile detention were much more cost-effective than detention.31
These alternatives create lower rates of recidivism, as well, according to the National Center for
Children in Poverty.32
Youth incarceration is the problem, not the cure. United States incarcerates a higher
portion of its youth than any other developed nation.33 As of 2011, we had 70,000 youth in
detention.34 Building a new youth jail will only increase this problem.
B.

King County has misrepresented the need for a new youth jail.

King County falsely claims that the people voted for this jail and it is needed. In reality,
voters assented to build a “Children and Family Services Center Capital Levy,”35 but the ballot
title never informed them of the proposed new youth jail. Campaigns for the levy misleadingly
promised to replace decrepit buildings with an inclusive facility where disenfranchised families

https://www.dshs.wa.gov/sites/default/files/CA/acw/documents/RaceDisproCover.pdf. Currently, dependency cases
are being handled at the King County Superior Courthouse downtown as well as at the King County Regional
Justice Center in Kent. These locations are convenient for families who rely on public transportation and services
that may be located in the downtown core or in Kent, closer to their homes in the south county area.
28
King County: Regional Law Safety and Justice Committee, Juvenile Court Programs Overview, July 31, 2014.
Available at:
http://www.kingcounty.gov/~/media/exec/PSB/documents/RLSJC/2014/July/Juvenile_Court_Update.ashx?la=en.
29
These include Aggression Replacement Therapy (ART), Functional Family Therapy (FFT), Multi-Systemic
Therapy (MST), Family Integrated Transition (FIT), and Parent Youth Connections Seminar (PYCS) The overview
also notes some promising programs including restorative justice, Education and Employment Training (EET),
mentoring, diversion, and community outreach.
30
Id.
31
Juvenile Justice Information Exchange, Reform Trends.
32
City of Seattle Resolution 31614, Legislation Details (With Text), at 5.
33
Juvenile Justice Information Exchange, Community-Based Alternatives, 2015, avaiable at
http://jjie.org/hub/community-based-alternatives/.
34
Id.
35
King County, Official Local Voter’s Pamphlet, Primary and Special Election, August 7, 2012, at 10, available at
http://your.kingcounty.gov/elections/2012aug-primary/voterguide/ed1-web.pdf.

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could receive social services and support.36 This was a classic bait-and-switch. The public
supports youth services, but not a jail.
The County and its allies also repeatedly misrepresent that the detention facility is at the
“end of its useful life,”37 when, in fact, the detention facility was constructed in 1992.38 Any
disrepairs at the 23 year old detention center are localized to those areas of the building that are
essentially mothballed, having become unnecessary as the population of the 200 bed detention
center dropped to sixty youth. There is no need to replace this detention center.39
C.
There is no need to build a youth jail that is two to three times today’s average jail
population, especially since the City and County have committed to sharply decrease or
end youth incarceration.
With populations in the current jail averaging sixty youth and poised to sharply decrease,
King County cannot justify building a new youth jail with a capacity of up to 150 beds. Seattle's
land use review must evaluate the need for a 150 bed facility because even though King County
has promised to reduce the bed count to 112, it has not reduced the size of the facility nor made a
binding commitment to reduce the bed count.
The population of the youth jail is only around sixty youth per night.40 There is no
justification for building a facility with two to three times the capacity of today’s average
population.
King County could not even justify building a new 60-bed facility because it is clear that
youth detention will sharply decrease in upcoming years. Every level of government has
committed to reducing the number of youths being incarcerated, virtually guaranteeing that the
population will further decrease.
● On October 13, 2014, the City of Seattle and King County issued a Statement of
Intent to address racial disproportionality in the juvenile justice system. It

Don’t be fooled: King County’s proposed justice center for families and children is still a jail, Real Change, Aug.
28, 2013. Available at
http://realchangenews.org/2013/08/28/don-t-be-fooled-king-county-s-proposed-justice-center-families-and-childrenstill-jail.
37
King County Ordinance 17304, enacted April 16, 2012.
38
MUP Appendix A Report, Oct. 29, 2013. Available at
http://kingcounty.gov/~/media/operations/FacilitiesManagement/documents/CFJC/SEPAAppendixF.ashx?la=en.
39
Id.
40
King County Department of Adult & Juvenile Detention, Scorecard Highlights, 2015. Available at
http://www.kingcounty.gov/~/media/courts/detention/documents/KC_DAR_Scorecard_Highlights_09_2015.ashx?la
=en.
36

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committed to taking action to reduce youth incarceration, including reducing the
youth incarcerated due to failure to appear in court.41
● On September 17, 2015, City of Seattle council members unanimously passed
Resolution 31614 to end youth detention in the city. 42 Through that resolution, the
City committed to pursue policies to eliminate the need to detain or incarcerate
youth, and it has begun developing an action plan to accomplish this.43 The City
has committed funds for this effort and is on the verge of committing more.
● King County has also stated an intention to “fight for a world where detention for
young people is no longer needed,” committing to decrease youth incarceration
rates sharply through reducing disproportionate incarceration of youth of color.44
If these visions and commitments to ending youth incarceration are to be anything more
than lip-service to a serious issue, a new facility to imprison as many as 150 kids for the next 50
years must not be approved.
D.
The City and County both failed to comply with their requirement to analyze race
and social justice and environmental impacts prior to making a decision on the project.
1. The City should undertake a complete race and social justice analysis.
The City should undertake a complete race and social justice analysis before acting on
this project application. Both the City and County have legally committed to completing race
and social justice reviews before taking significant actions. Transitioning away from youth
incarceration will be among the most important race and justice issues the City and County will
face. Yet neither have complied with their laws and policies requiring race and social justice
review of building a new youth jail.

Statement of Shared Commitment, “Statement of intent between King County and the City of Seattle to continue
to address racial disproportionality in the juvenile justice system.” October 13, 2014. Seattle City Clerk File
Number: 314116. Available at http://clerk.seattle.gov/~CFS/CF_314116.pdf.
42
Seattle City Council Resolution 31614, “A RESOLUTION endorsing a vision for The City of Seattle to become a
city with zero use of detention for youth, and establishing a path forward to develop policies that eliminate the need
for youth detention.” September 17, 2015. Available at
http://clerk.seattle.gov/~archives/Resolutions/Resn_31614.pdf.
43
Id.
44
King County Race and Social Justice Assessment and Action Plan, published March 31, 2015. Available at
http://www.kingcounty.gov/~/media/operations/FacilitiesManagement/documents/CFJC/CoSReport033115.ashx?la
=en.
41

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City resolution 31164 directs City agencies to “use available tools to work to eliminate
racial and social disparities across key indicators of success, including health, education [and]
criminal justice … Efforts by City departments should include: … Implementation of racial
equity tools in budget, program and policy decisions, including review of existing programs and
policies.”45 The Mayor’s executive order 2o14-02 requires “City departments [to] expand their
use of the Racial Equity Toolkit as part of all program and policy planning processes.”46 The
City's policy decision about whether the new detention center is "needed" - thereby justifying a
waiver of critical land use codes - is certainly subject to these requirements.
The City’s race and social justice review to date has been untimely and inadequate. A
more rigorous analysis of the immediate and collateral impacts of this project on communities of
color and working class communities needs to be done to ensure that the City, the County, and
the public are informed about the effects of this project. The analysis to date treats the
construction of the jail as a fait accompli, when in fact the City should analyze the race and
social justice impacts of its discretionary land use decisions. Without the City’s discretionary
waivers and permits, the project cannot move forward.
King County should also comply with its laws and complete an analysis before making a
final decision on this project. It should also complete a cost-benefit analysis similar to that
which the State has done for evidence-based, research-proven programs. Such an analysis would
prove that the project is not evidence-based and is a waste of government resources.
2. The City should require a comprehensive environmental review.
The County and City have failed to comply with the State Environmental Policy Act
(SEPA) because they fail to consider negative public health and safety impacts of youth
incarceration, as required by WAC 197-11-330(3)(e)(iv), they inadequately address other
environmental issues, and they fail to provide adequate mitigation. For example, they contain no
or inadequate information as to the phasing of the project, toxins on the property site, and the
social and economic impacts of the project. There also have been significant changes in
circumstances since the environmental assessment was completed, including development that
has been completed or approved in the area, resulting in increased traffic. For example, the
City’s closure of 14th Avenue to northbound traffic just south of the project site has caused
significant changes in traffic patterns in the vicinity of the project site, rendering the previous
traffic analysis obsolete. The City should require the preparation of an environmental impact
statement or should exercise its substantive SEPA authority to deny the project.
45

Seattle City Council Resolution 31164, Adopted November 30, 2009. Available at
http://clerk.seattle.gov/~archives/Resolutions/Resn_31164.pdf.
46
Office of the Mayor, City of Seattle Executive Order 2014-02: Race and Social Justice Initiative. April 3, 2014.
Available at http://murray.seattle.gov/wp-content/uploads/2014/04/RSJI-Executive-Order.pdf.

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E.

The project does not comply with the City’s land use code.

The project fails to meet numerous requirements of the City’s land use code, including
but not limited to: (1) failure to provide required setback; (2) failure to comply with maximum
building width; (3) failure to comply with maximum building depth; (4) placing off-site parking
in an L3 Zone; (5) failure to comply with height requirements; (6) failure to comply with
landscaping and screening requirements; (7) failure to comply with parking requirements; (8)
failure to comply with FAR requirements.
This project does not qualify for a waiver of any of the land use code’s standards. The
County cannot circumvent the City's land use code simply because it desires to build a new
courthouse and detention center and house them in a single building. The County's application
has not described or justified the requested departures and it must do so in writing and subject to
public review. The City must reissue the notice to provide a comment period on the County's
justification for the departures. The current application contains no identification of the specific
departure request, including which departures are requested, the extent of the departures (how far
out of compliance the proposal is), and the justification for the departure.
The City cannot justify the requested departures because it cannot prove a need or public
benefit from the detention facility as proposed. Indeed, the County admits this since it has
committed to reducing the bed count but has not redesigned the facility to bring it into
compliance with the land use code. The County's desire to retain the option of incarcerating up to
150 youth in the future cannot qualify as a "need," in light of the its pledge to detain no more
than 112 kids. As discussed above, the County could not even justify that a 112-bed facility
given that the average population is sixty and this number is expected to sharply decrease in
coming years.
The County also cannot play numbers games to justify building a mega-facility in this
neighborhood zone. For example, it cannot claim compliance with building depth requirements
by measuring only half of the building's depth. The law requires the entire building depth to be
measured.
This mega-facility is simply inconsistent with the codes and the neighborhood. The
county proposed to ignore requirements for setbacks, building width, building depth and building
height simply based upon its desire to build a giant facility. However, even if there was the need
for the proposed square footage, there is no need for these code departures because the County
has countless options to redesign the building to meet the land use code.

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F.

The project undermines non-detention alternatives.

King County Superior Court Presiding Judge Susan Craighead recently said, “Sadly, we
often put youth in detention because we don’t have another safe place to put them. We
desperately need alternatives.”47 After acknowledging the problems of youth detention, King
County Council members approved $4 million for programs dedicated to keeping youth in
schools and out of incarceration.48 This is a paltry contribution towards alternatives compared to
the $210 million proposed for the new jail complex. Scarce tax dollars should be spent
providing those alternatives, not creating shinier courtrooms and jail cells.
Building this project will provide no incentives for local governments to invest in these
alternatives, and it will likely have the opposite effect. Local officials will have a political need
to fill jail cells to justify their $210 million expenditure. The project would further undermine
alternatives if it goes over-budget and cannibalizes the County’s scarce resources for nondetention alternatives. In Michigan, Wayne County’s new jail was similarly supposed to cost
$200 million, but the cost overruns ballooned the budget to almost $390 million before the
project was put on hold.49
Currently, it costs $95,805 to detain each youth per year in detention.50 According to US
Census data, the city of Seattle is spending $9,483 per youth per year for education.51 This raises
the question: Is it in the public’s best interest to build a detention center so that we can spend ten
times as much to keep youth incarcerated as we do to keep them educated?
G.

The facility’s location increases hardship for out-of-city families.

Many of the youth who are arrested in King County reside in the South End of the
county. Building a new youth jail in Central Seattle creates burdens on the very communities
the project is supposed to serve. Rather than creating a centralized location in Seattle to
52

47

Lynn Thompson, New Juvenile Jail: Fewer Beds, More Help Keeping Kids Out, Seattle Times, March 31, 2015.
Available at http://www.seattletimes.com/seattle-news/new-juvenile-jail-fewer-beds-more-emphasis-on-how-tostay-out/.
48
Id.
49
Sarah Cwiek, Wayne County Halts Construction on New Jail Amidst Massive Cost Overruns, Michigan Radio,
June 6, 2013, available at http://michiganradio.org/post/wayne-county-halts-construction-new-jail-amidst-massivecost-overruns#stream/0.
50
City of Seattle Resolution 31614, Summary and Fiscal Report, August 2015, at 4, available at
https://seattle.legistar.com/LegislationDetail.aspx?ID=2458519&GUID=93E5F1D7-42A7-4899-BB7803150F043416&Options=&Search.
51
U.S. Census Bureau, Public Education Finances: 2013, Issued 2015, at 8, available at
http://www2.census.gov/govs/school/13f33pub.pdf.
52
Dep’t of Social and Health Services, 2011 Juvenile Arrests by Law Enforcement Agency/Department and by
County, 2012,available at https://www.dshs.wa.gov/sites/default/files/JJRA/pcjj/documents/annualreport2013/Table.64.pdf.

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accommodate judges and lawyers, direct services and resources should be allocated to the
communities most affected by King County’s juvenile justice system.
On behalf of EPIC and the other organizations signing on to this comment letter, we
respectfully request that the City deny the master use permit. This proposal perpetuates a broken
system and would harm not only the youth who are placed within its walls, but also the
communities that are supposedly to be protected. Rather than spending millions to replace a
relatively new jail, we should focus our funds on alternatives that bring us closer to the City's
goal of ending youth incarceration altogether.

Yours very truly,
SMITH & LOWNEY, P.L.L.C.
By: _/KL/________________
Knoll Lowney, WSBA no. 23457
Claire Tonry, WSBA no. 44497
Meredith Crafton, WSBA no. 46558
Attorneys for End the Prison Industrial Complex –
Seattle (EPIC)

Cc:
Seattle City Council
King County Council
Seattle Mayor Ed Murray
King County Executive Dow Constantine
EPIC
Seattle-King County NAACP
Seattle Human Rights Commission
IMAP
Post-Prison Education Program
JustLeadershipUSA
Equity Education Advocate
Foundation for Healthy Generations
National Lawyers Guild, Seattle Chapter