Rights-of-Way Safety Initiative Final Report to the Legislature (Washington Commerce, October 2024)
Summary
Rights-of-Way Safety Initiative Final Report, a report to the Legislature from the Housing Division of the Washington State Department of Commerce dated October 2024, required under the 2022 supplemental operating budget (ESSB 5693). The report quotes the budget provision of $45,050,000 of the coronavirus state fiscal recovery fund for a targeted grant program to transition persons residing on state-owned rights-of-way to safer housing opportunities. It states that findings and statistics are as of June 30, 2023. The key findings state that the initiative was successful in the percentage of individuals who accepted housing and remain in housing, and that thousands of households would still experience homelessness even if every encampment on state-owned right-of-way were cleared.
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Cite this document
“Rights-of-Way Safety Initiative Final Report to the Legislature (Washington Commerce, October 2024).”
Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2024-commercereports-2023-housing-rights-of-way-final-6f3b6eff-1329-4b-4c6289a67f/
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Rights-of-Way Safety
Initiative
Report required under the 2022 supplemental operating budget (Sec.
128(132)(f), Chapter 297, Laws of 2022, ESSB 5693)
October 2024
RIGHTS-OF-WAY SAFETY
INITIATIVE Report to the Legislature
Director Mike Fong
V3.5
Acknowledgments
An acknowledgment to the leadership and staff of
the following state agencies for their collaboration:
Washington State Department of Commerce
Tedd Kelleher, Housing Division Policy Director
Nathan Peppin, Director of Homelessness on State
Property
Penny Thomas, Media Relations Manager
Department of Transportation
Roger Millar, Secretary of Transportation
Washington State Patrol
Chief John Batiste
Office of the Attorney General
Bob Ferguson, Attorney General
We give special recognition to the cities, counties
and non-profit providers who collaborate with the
Rights-of-Way Initiative team to implement and
deliver the program.
HOUSING DIVISION
1011 Plum St. SE
P.O. Box 42525
Olympia, WA 98504-2525
www.commerce.wa.gov
For people with disabilities, this report is available
on request in other formats. To submit a request,
please call 7-1-1 and ask to be connected to 360-
725-4000.
RIGHTS-OF-WAY SAFETY INITIATIVE FINAL REPORT
Table of Contents
Executive summary .........................................................................................................................................4
Program operation ..........................................................................................................................................6
Key findings ....................................................................................................................................................9
Recommendations ........................................................................................................................................13
Appendix A: Site statuses and data as of June 30, 2023 ...............................................................................14
RIGHTS-OF-WAY SAFETY INITIATIVE FINAL REPORT 3
Executive summary
Authorizing statute
This report provides background, context and data about the Rights-of-Way Safety Initiative program to satisfy
the reporting requirements in the 2022 supplemental operating budget, section 128 (132)(f):
(a) $45,050,000 of the coronavirus state fiscal recovery fund—federal appropriation is provided solely for a targeted
grant program to transition persons residing on state-owned rights-of-way to safer housing opportunities, with an
emphasis on permanent housing solutions. Eligible grant recipients include local governments and nonprofit
organizations operating to provide housing or services. Recipients may use grant funding to provide outreach,
housing, transportation, and other services needed to assist individuals residing on public rights-of-way with moving
into housing.
(b) Prior to awarding grants under (a) of this subsection, the department must work with the department of
transportation, representatives of local governments, and representatives of nonprofit housing and homeless
services providers to determine the process and criteria that will be used to award grants. Grant criteria must include,
but are not limited to:
(i) Whether a site where the grantee will conduct outreach and engagement has been identified by the department of
transportation as a location where individuals residing on the public right-of-way are in specific circumstances or
physical locations that expose them to especially or imminently unsafe conditions, including but not limited to active
construction zones and risks of landslides, or when the location of an individual poses a significant threat to the
safety of others;
(ii) Local government readiness and capacity to enter into and fulfill the grant requirements as applicable; and
(iii) Other criteria as identified by the department.
(c) When awarding grants under (a) of this subsection, the department must prioritize applicants that focus on
permanent housing solutions.
(d) Grant recipients under (a) of this subsection must enter into a memorandum of understanding with the
department, and other state agencies if applicable, as a condition of receiving funds. Memoranda of understanding
must specify the responsibilities of the grant recipients and the state agencies and must include specific measurable
outcomes for each entity signing the memorandum. The department must publish all signed memoranda on the
department's website and must publish an update on outcomes for each memorandum at least every 60 days. At a
minimum, outcomes must include:
(i) The number of people living on the right-of-way whom the parties engage;
(ii) The demographics of those engaged;
(iii) The type and duration of engagement with individuals living on rights-of-way;
(iv) The types of housing options that were offered;
(v) The number of individuals who accepted offered housing;
(vi) The types of assistance provided to move individuals into offered housing;
(vii) Any services and benefits in which an individual was successfully enrolled; and
(viii) The housing outcomes of individuals who were placed into housing six months and one year after placement.
(e) Grant recipients under (a) of this subsection may not transition individuals from public rights-of-way unless they
in good faith offer individuals a housing option that is safer than their current living situation. The department must
establish criteria regarding the safety, accessibility, and habitability of housing options to be offered by grant
recipients to ensure that such options are a meaningful improvement over an individual's current living situation and
that grant recipients provide options that are well-matched to an individual's assessed needs.
(f) The department must submit a preliminary report to the appropriate policy and fiscal committees of the
legislature by December 15, 2022, and a full report by September 30, 2023. The reports must identify barriers to
housing and gaps in services that prevented or otherwise impacted the housing outcomes of individuals engaged by
the grantees, and policy and budgetary recommendations to improve the transition of individuals residing on public
rights-of-way to permanent housing.
This program was developed and implemented closely with the Washington State Department of
Transportation (WSDOT) and the Washington State Patrol (WSP). Additionally, the legislation directed state
RIGHTS-OF-WAY SAFETY INITIATIVE FINAL REPORT 4
agencies to establish memoranda of understanding with local partners, both governmental and non-profit,
based on program objectives and goals.
This report includes findings and statistics as of June 30, 2023. Current program statistics are available online.
Key findings
The Rights-of-Way Safety Initiative reinforced that we know how to bring people inside and refined the
coordination and processes needed to be successful. It demonstrates that encampments can be resolved in a
way that respects the dignity of encampment residents. However, it also faces challenges.
This initiative simultaneously addresses and supports key areas of the homelessness response system but
puts additional strain on existing housing availability and outreach and service resources. It can be challenging
to implement and maintain the program's focus to the extent that this initiative is seen to compete with or be
out of alignment with, local jurisdictions' and service provider priorities.
This initiative was successful in several ways, particularly in the percentage of individuals who accepted
housing and remain in housing, as shown below and in Appendix A. However, even if every encampment on
state-owned right-of-way were cleared, thousands of households would still experience homelessness in
Washington.
Importance of funding types and levels
The type and level of funding made available by the Legislature and Commerce leadership were critical to the
success of this effort. In particular, the funding to acquire capital assets was crucial in addressing
homelessness from an encampment perspective, compared to the current coordinated entry process. There is
typically no single option that can address an entire encampment of any size due to criminal history, domestic
violence, and substance use disorders, and we know that it is critical to have many rooms available that people
experiencing homelessness will accept. It is essential to have an initial intake facility to address the majority of
encampment residents. Capital assets will continue to be a long-term resource for addressing homelessness
across the state. Commerce continues to evaluate options and funding delivery and makes ongoing
reallocations to support new opportunities when possible.
Capital and operating funding offered together will continue to be significant factors in successfully resolving
encampments. This initiative demonstrated the ability to address homelessness differently than the current
coordinated entry model. Coordinated entry (individual perspective) and this initiative (encampment
perspective) have benefits, and maintaining funding for this approach is critical for addressing homelessness
across the state and beyond state rights-of-way.
Summary of housing outcomes from July 2022 to June 2023:
Sites addressed: 30
Residents as of By-Name List deadline: 1,313
Residents who accepted housing: 821
Residents placed in temporary housing or shelter: 751
Residents placed in permanent supportive housing: 70
Residents still in housing: 676
RIGHTS-OF-WAY SAFETY INITIATIVE FINAL REPORT 5
Program operation
Agency roles and responsibilities
Washington State Department of Commerce
The Washington State Department of Commerce (Commerce) contracts and coordinates with local
jurisdictions and non-profits that deliver outreach, services, and shelter and housing solutions. Commerce also
manages capital acquisition financing for property owned by nonprofit partners.
Washington State Department of Transportation
The Washington State Department of Transportation (WSDOT) works with local jurisdictions and non-profits
to identify high-priority sites and establish an understanding of the boundaries of those sites. WSDOT provides
maintenance, including trash removal, landscaping, site modifications, security, etc., to sites before and after
the relocation of people living on state rights-of-way. WSDOT provides ongoing staff time to identify any
repopulation of sites, coordinate with partners, and reinforce that the sites are closed. WSDOT continues to
work on repairing any ongoing damage and/or cleaning resolved areas. This ongoing work is not resolved once
the initial encampment is closed.
Washington State Patrol
The Washington State Patrol (WSP) partners with local law enforcement to support outreach workers as
needed while they engage people living on priority sites. WSP also supports WSDOT staff as they clean sites
that people have left. After encampments are cleared, WSP supports outreach workers to prevent people from
re-occupying a site.
How the program resolves encampments
This encampment resolution model is time-intensive, as efforts are made to offer each resident housing
options appropriate to their needs. The broadly defined steps taken are summarized below:
1. Outreach: To build trust, outreach workers frequently engage with residents. This includes connecting
people to services and resources, including health care, food, clothing and other immediate needs.
2. By-Name List: Develop a "By-Name List" of residents and their individual housing needs so residents can
be moved into housing as soon as it is available.
3. Site stabilization: Work with local jurisdictions and WSDOT to install temporary sanitation facilities, remove
vegetation, install fencing, and, in certain situations, hire security. This may include working with local law
enforcement and WSP on public safety issues.
4. Connecting people to housing and shelter: As housing and shelter opportunities that meet residents'
needs become available, the By-Name List is used to move them into temporary shelter, transitional
housing, permanent housing, and permanent supportive housing.
5. Site restoration: After the encampment residents are placed in housing, WSDOT crews and/or contractors
remove trash, remove vegetation to improve visibility, install more fencing as needed, and place passive
measures to prevent re-occupation of the sites. WSDOT also monitors and repairs cleared sites as needed
— an ongoing need, even after the encampment is cleared.
RIGHTS-OF-WAY SAFETY INITIATIVE FINAL REPORT 6
Program funding
To provide additional housing solutions, services, and outreach support, Commerce directed an additional $60
million of Rapid Capital Acquisition funding and $36 million of Home Security Account funding to the Rights-of-
Way Safety Initiative (ROW). WSDOT and WSP also work to support the initiative but do not have specific
funding for their portion of the work. WSDOT must allocate overall encampment funding dollars for this work;
WSP bills WSDOT out of those overall encampment dollars for its overtime charges supporting initiative work.
Funding levels to support the full range of work that all three agencies perform to address encampments is
necessary to continue ongoing encampment resolutions and, perhaps more importantly, maintain the areas
that have been cleared of encampments. Maintaining cleared areas of rights-of-way requires a significant
monitoring and engagement staff presence.
In June 2022, the Commerce released a request for proposals (RFP) to local governments within King, Pierce,
Snohomish, Spokane, and Thurston counties. The RFP required each of these counties to submit a
collaborative, multi-jurisdictional proposal. Table 1 outlines the funding allocated for this RFP, categorized by
county.
Table 1: Initial funding allocation by county, July 2022 to June 2023
County Total funding
King $46,927,584
Pierce $30,255,489
Snohomish $22,910,681
Spokane $24,304,192
Thurston $19,602,054
Total $144,000,000
Commerce received a response from every county except Snohomish County. After review and discussion,
Commerce accepted the submitted proposals either in whole or in part. Staff gave priority to proposals or
components of proposals that:
Delivered a mix of shelter and housing options that could be available quickly and would likely result in
people moving inside instead of relocating to another unsheltered location.
Included providers that had a proven record of serving the local homeless population in their counties.
Commerce reallocated all but $4 million of the funds originally designated for Snohomish County when
Snohomish County and the City of Everett declined the opportunity to apply for funding. Commerce then
initiated a new, open RFP for non-profit housing providers to address rights-of-way in Snohomish County. Table
2 shows the revised distribution of funding, which included a slight increase to the Snohomish allocation from
$4 million to just under $6 million. The increase to $6 million was because two providers responded to the
Snohomish RFP, and, after review, Commerce accepted both proposals.
RIGHTS-OF-WAY SAFETY INITIATIVE FINAL REPORT 7
Table 2: First revised funding allocation, by county and fund source
County Flexible Proviso Rapid Capital Acquisition Home Security Fund Total
King $16,620,344 $19,000,000 $13,594,206 $49,214,550
Spokane $8,607,817 $6,500,000 $10,322,000 $25,429,817
Pierce $9,715,588 $19,668,070 $5,517,007 $34,900,665
Thurston $5,803,333 $14,831,930 $7,168,070 $27,803,333
Snohomish $4,000,000 Reallocated Reallocated $4,000,000
Total $44,747,082 $60,000,000 $36,601,283 $141,348,365
Table 3 shows the final revisions to the county-level allocation of funds to support all the accepted projects.
Table 3: Second revised funding allocation, by county and fund source
County Flexible proviso Rapid capital Acquisition Home Security Fund Total
King $16,620,344 $19,000,000 $13,594,206 $49,214,550
Spokane $8,607,817 $6,500,000 $10,322,000 $25,429,817
Pierce $9,715,588 $19,668,070 $5,517,007 $34,900,665
Thurston $5,803,333 $14,831,930 $7,168,070 $27,803,333
Snohomish $4,000,000 Reallocated $1,945,894 $5,945,894
Total $44,747,082 $60,000,000 $38,547,177 $143,294,259
Revisions to the funding allocations continue to maximize the options available to address the needs of those
experiencing homelessness on state rights-of-way. Commerce will continue to collaborate with its partners to
identify needs and refine program delivery.
RIGHTS-OF-WAY SAFETY INITIATIVE FINAL REPORT 8
Key findings
This has offered a variety of shelter and housing options and allowed enough time to engage individuals. As a
result, most people (80%) living in an addressed rights-of-way encampment has moved indoors as of June 30,
2023. The initiative demonstrated that it is feasible to clear encampments while providing dignified living
conditions. However, it also showed that even high-quality congregate shelters, which offer limited privacy,
attracted only a small number of people, and even fewer remained in these shelters long-term.
What success looked like
Local jurisdictions, communities, non-profits, state partners, and advocates have a wide range of metrics of
what constitutes success for a program addressing homelessness. Factors specific to this initiative include:
Scope and scale of the encampment
Needs of the people residing there
Health and safety hazards present
Damage to or improper use of public and private property
Availability of local available temporary and permanent housing resources
Quality of the collaborative homeless crisis response
Table 4: Summary of resident outcomes
Accepted housing
# of residents as of (Temp + Permanent Permanent
Sites Temp/shelter Still in housing
by-name deadline Initial Housing supportive housing
Placements)
30 1,313 821 751 70 676
Perceived quality of housing options
One common measure of success is the subjective quality of the housing offered, as seen by the individuals
and families living outside, unsheltered. That subjective quality has a significant impact on long-term
temporary and permanent housing outcomes and the ability to have the offer of housing accepted. During the
initial site engagement process, Commerce and its partners reported higher participation when the program or
housing offered matched a prospective client with their preferred temporary or permanent housing type.
Outreach engagement builds trust with residents and improves
outcomes
The ability to match available program and housing options to the people living on initiative sites was achieved
with outreach engagement occurring over a matter of weeks to assess needs and build trust. That
engagement strategy resulted in more than 80% of people moving inside when offered accessible non-
congregate temporary housing or permanent supportive housing. This is in stark contrast with the much lower
rates of success seen in typical encampment clearing efforts, which rely on brief outreach and, often, offers of
congregate shelter beds that people won’t move into.
RIGHTS-OF-WAY SAFETY INITIATIVE FINAL REPORT 9
Non-congregate shelter is more successful than congregate shelter
While a spectrum of temporary and permanent housing interventions are necessary to address the immediate
impacts to state rights-of-way, Commerce and its partners have seen the least success placing those
experiencing homelessness in congregate shelters,1 which are usually large facilities with little to no privacy.
As a short-term emergency option, congregate shelter has a significant role in addressing housing stability.
However, when used as a long-term housing option, perhaps due to limited alternatives in that locality, many
individuals experiencing homelessness simply choose to remain outside or leave the shelter within days or
weeks of entering it.
Other elements of success:
Creating a site list of people's names ("by-name list"), using a good faith effort to identify people living at
the site for at least a week, balanced with closing the list as soon as is practical to prevent new
migration.
Use clear communication and signage to prevent a sudden expansion of the site by people seeking
housing, by stating the by-name list is closed and people will have to leave when the site closes.
Prioritize at-risk individuals (parents with young children, the elderly, or those with significant
hardships) for immediate housing before site resolution, when possible.
Assistance moving possessions that can be accommodated in the shelter or housing offered, and
assistance over at least a week to clean up and dispose of possessions that cannot be moved.
Skilled outreach workers lead engagement and handle all interactions in almost all cases.
Availability of commissioned law enforcement officers who can promptly respond to rare emergent
situations as identified by outreach staff, and who are available to provide security for workers cleaning
and modifying a site once it is closed.
Use maintained fencing and other barriers as appropriate for each site to clearly communicate the area
is not a public place. This includes ongoing work, and funding, to repair fencing and other modifications
that experience continued damage after a site is closed.
At least weekly monitoring of sites that have been closed, and a plan to promptly engage people who
show up on the site, clearly communicating that they cannot remain on the site.
When measured against similar efforts around the nation, including the well-known encampment remediation
work in Houston, Texas, the outcomes our initiative has achieved represent a tremendous success.
1 Congregate Shelter - a place where many people are housed together in a large space, typically with bunk beds or cots with limited if
any walls or partitions to separate space.
RIGHTS-OF-WAY SAFETY INITIATIVE FINAL REPORT 10
There is more to do and learn going forward, including:
Where do the almost 20% of people who do not take the offers of housing go, and how can we ensure
they, too, move inside?
What is the appropriate mix of permanent destinations for people moving into temporary housing?
Many existing Permanent Supportive Housing operators report that some of the people we are serving
are too high acuity to be successful in their housing. What combination of more intensive services in
PSH and new facility types are needed?
How do we expand behavioral health services to proactively engage people to prevent encampments?
Many people living on state rights-of-way are eligible for behavioral health services; will earlier outreach
lead to prevention?
Expanding the program to other counties: This initial work focused on five counties, but homelessness
is an issue across the state and determining how to replicate and fund this work in those locations is a
long-term need.
Barriers and challenges
Even when flexible funding is available, it is difficult to quickly set up new housing and services in a local or
regional system that is already overburdened. Although some additional temporary and permanent housing
opened promptly after awarded funds, most took at least a year from funding to the date of occupancy.
Barriers to prompt opening:
Opposition from local governments to leasing or purchasing existing hotels and apartments to house
people. The vast differences in each community indicate a need for creating a clear and prompt process
that ensures responsive siting fairly throughout the state.
Existing housing development and service providers are already understaffed, leaving them unable to
take on additional responsibilities. Solutions include adequate pay, necessary training, and support for
staff working in traumatizing environments.
Limited WSP staff and WSDOT funding used to support outreach and cleanup work because of limited
support from local law enforcement. Although direct engagement by law enforcement is rarely
necessary, it is critical that outreach workers can rely on law enforcement to respond to requests for
assistance addressing critical situations. Clarifying the division or responsibilities between state and
local law enforcement is needed, and ensuring adequate law enforcement availability is supported.
Setting realistic expectations regarding how long it takes to set up new housing and services. New
capacity can be promptly opened at the margins, but at least a year is needed, in most cases, for almost
any new capacity procured from the public or private sector.
Many existing Permanent Supportive Housing operators report that they cannot successfully house
some of the people living outside who have significant behavioral health needs. Although existing PSH
models can successfully house most people living outside, some people need PSH with more intensive
services or other facility types. Identifying the types and proportions of additional options needed is a
critical next step.
RIGHTS-OF-WAY SAFETY INITIATIVE FINAL REPORT 11
Additional challenges:
Homeless services and housing providers report being overwhelmed by the depth and breadth of the
need for emergency and permanent housing. There are extremely limited existing housing and bed
options to dedicate to the State Rights-of-Way Initiative. This priority also experiences local resistance,
where coordinated entry systems have a significant wait list.
Local political processes and philosophies that differ from the state initiative.
Lack of housing and behavioral health resources for individuals with high acuity needs.
Lack of housing options to reasonably segregate individuals with violent and/or sexual offense
histories from other populations, particularly women and children.
Lack of facilities for youth and young adults, particularly minors who are pregnant.
Lack of housing across income levels, pushing more affordable housing options out of reach for those
at the lowest income levels.
Staffing and resource challenges that reduce the number and types of services that are available locally.
Staffing and resource challenges within other agencies (WSDOT and WSP) not directly or fully funded in
the proviso for their roles in this process, while facing other encampment needs and costs in
jurisdictions and regions not covered by the program.
RVs on streets, lots and rest areas, which present different challenges than the street and/or lot parking.
RIGHTS-OF-WAY SAFETY INITIATIVE FINAL REPORT 12
Recommendations
There are diverse challenges to housing people experiencing homelessness. No single solution exists to
address every barrier to housing stability. Although the Rights-of-Way Safety Initiative focuses on a very
specific portion of public land, the population residing on these rights-of-way present many of the same
challenges that the overall homeless population presents. These recommendations focus on achieving the
legislated goals of the Rights-of-Way Safety Initiative, and may not represent a widely applicable approach to
the urgent issue of homelessness in general.
Operating funding
Additional operating funding investment from the Legislature will be necessary to maintain the levels of
success in the five initial participating counties supporting state agencies, local governments, and non-profit
providers. In addition, more operating funding will be needed for Commerce to expand the Initiative into
additional counties. Likewise, WSDOT and WSP will need additional funding to be able to continue their roles in
the Initiative.
Capital funding
Further capital investment to acquire additional housing options will be needed if the Legislature wants the
Initiative to expand. Currently, there is inadequate capacity to house people experiencing homelessness on
state rights-of-way. During the Initiative's first year, the lack of housing solutions was the most significant
hurdle to relocating households experiencing homelessness on state rights-of-way.
Flexible funding
Flexibility in funding authorization would be helpful to address encampments located on property abutting
local jurisdictional land. Commerce and its partners have faced challenges closing an encampment and
preventing its relocation to a neighboring parcel, or its later re-establishment.
RIGHTS-OF-WAY SAFETY INITIATIVE FINAL REPORT 13
Appendix A: Site statuses and data as of June 30, 2023
# of residents Permanent
Accepted Temporary Still in
Site County Status as of by-name supportive
housing shelter housing
deadline housing
SR-520 King Closed 5 5 5 0 5
Olive Way King Closed 10 10 10 0 9
Dearborn King Closed 64 57 55 2 48
Northgate King Closed 27 24 21 3 19
Eastlake King Closed 7 6 6 0 5
South Park* King Closed 33 30 20 10 30
Pasadena Ave (I-5 North at Ship Canal) King Closed 14 14 14 0 14
CID* King Closed 167 146 142 4 124
Myers Way King Active TBD 0 0 0 0
McDougall Avenue Snohomish Closed 13 13 3 10 10
112th Street Snohomish Closed 9 9 4 5 7
Smokey Point Rest Area Snohomish Active 126 60 60 0 59
Silverlake Trail Snohomish Closed 26 25 20 5 19
Everett Ave I-5 Overpass Snohomish Closed 2 2 2 0 2
19th Ave WinCo Snohomish Closed 6 5 4 1 5
I-5 S & SR 104 Snohomish Closed 1 1 1 0 1
164th South on-ramp to I-5 Snohomish Closed 5 2 2 0 2
Swamp Creek Snohomish Active 31 25 25 0 25
Lilly Road Thurston Closed 3 1 1 0 0
Pacific Avenue Thurston Active 16 4 4 0 1
City Center Thurston Active 36 13 13 0 8
Wheeler Avenue Thurston Active 54 24 24 0 16
Sleater Kinney Road Thurston Active TBD 18 18 0 18
Camp Hope Spokane Closed 467 184 157 27 154
84th & Hosmer Pierce Closed 78 46 46 0 20
Bay Street Pierce Active 46 35 32 3 21
74th & Tacoma Mall Blvd Pierce Closed 39 37 37 0 29
Bridgeport Pierce Closed 5 5 5 0 5
SR-7 & 38th Pierce Closed 21 18 18 0 18
Off-site (Hwy 16 Park & Ride) Pierce Closed 2 2 2 0 2
Total 30 1,313 821 751 70 676
*These sites may include funding and housing from other partners due to the right of way being multi-jurisdictional.
RIGHTS-OF-WAY SAFETY INITIATIVE FINAL REPORT 14
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