BURNHAM CIVIC

⚖ TBC Intelligence

This document is available to TBC Intelligence members.

Dear Mr. Vice President,

I am writing on behalf of The Burnham Civic (TBC), a civic accountability organization based in Seattle, Washington. We are requesting that the Task Force to Eliminate Fraud examine the King County Regional Homelessness Authority (KCRHA) as a case study in systemic fraud, waste, and abuse of federal housing and homelessness funds.

The problem is documented.

The Washington State Auditor's Office flagged $37 million in accounting errors at KCRHA. The agency has cycled through three CEOs in four years. Homelessness outcomes have worsened every year since KCRHA's formation in 2021, despite annual Continuum of Care (CoC) funding exceeding $60 million. The Seattle Housing Authority, which receives $458.5 million annually and operates under a Moving to Work waiver extended through 2038, carries $154.5 million in "Program Operations & Administration" that has never been subject to meaningful disclosure.

TBC has the evidence.

Over the past year, our organization has built a comprehensive accountability package:

• A data inventory of 60+ datasets across KCRHA, SHA, HSD, SPD, SFD, and King County
• Seven agency accountability briefs with over 70 targeted Public Records Act requests
• Documented governance failures across 10 city commissions ($3.4 million in annual waste)
• A federal funding roadmap identifying 11 streams and $3.8 million in Year 1 recoverable or redirectable funds

What we are requesting:

1. That the Task Force receive a briefing from TBC on KCRHA and SHA as a priority case study
2. That Seattle/King County be included in any initial audit or investigation cycle under the Executive Order
3. That TBC serve as a local execution partner for Task Force operations in the Pacific Northwest. Our organization has the data infrastructure, public records expertise, and ground-level intelligence to support investigations from intake through resolution.

TBC is not writing to observe from the sidelines. We built this organization to solve exactly this problem and are prepared to commit fully to the Task Force's mission in whatever capacity is most useful. This work is on behalf of every Seattle citizen who has watched hundreds of millions in federal funds produce worsening outcomes for the people they were meant to serve.

A version of this letter was also sent to Chairman Andrew N. Ferguson, Vice Chairman of the Task Force to Eliminate Fraud, Federal Trade Commission, 600 Pennsylvania Avenue NW, Washington, DC 20580.

WASHINGTON STATE COMPANION FINDINGS

The federal pattern runs all the way down. While the Task Force targets HUD and HHS programs at the federal level, the state of Washington has its own documented record of opaque grant disbursement, procurement waste, and policy capture. TBC has been compiling these in parallel. A selection:

• Childcare provider grants administered through the office of Bob Ferguson. State funds were distributed to childcare providers without public disclosure of the recipient names. A public dollar that does not name its destination cannot be audited by the public, and the structure makes pattern detection across recipients impossible. Companion record: Washington Department of Revenue.
• Catholic Community Services (CCS) IT spend. Approximately $2.5 million paid for internal software with no published outcome metric, no implementation milestone disclosure, and no public RFP record reachable through ordinary records request. CCS is a federally and state subsidized service provider; this is the procurement pattern the Task Force was built to interrupt. Full record: Catholic Community Services.
• Downtown Emergency Service Center (DESC). Behavioral health and supportive housing operator running on the same federal Continuum of Care pass-through that feeds KCRHA. Same structural risk profile: large operator, large federal subsidy, weak outcome reporting reachable through ordinary public records process. Full record: DESC.
• Sound Transit shortfalls, bonus structure, and capital opacity. The agency runs chronic capital shortfalls (now seeking new voter revenue to cover ST3 commitments already paid for once) while paying out executive bonuses across the same fiscal cycles in which milestones slip. There is no public claw-back mechanism. The capital program has absorbed repeated scope cuts and timeline slips without commensurate senior accountability. The board is appointed, not elected. Procurement for stations, alignments, and prime contractors moves through a structure that is functionally invisible to ordinary public records review. TBC treats Sound Transit as an active accountability case in parallel to this submission.
• Cascade Bicycle Club and the capture of transportation policy. A single advocacy organization has exercised outsized influence over Seattle and Washington transportation policy, repeatedly tilting outcomes against transit, freight, and emergency access while operating with the institutional access of a public agency. The mechanism by which a 501(c)(3) acquires policy-setting power in this way is itself a fraud-and-abuse vector and warrants disclosure of donor flows, contracts, lobbyist filings, and revolving-door employment with WSDOT and SDOT. Companion record: SDOT Accountability Package.
• Translation and interpretation services contracts. Washington state, King County, and the City of Seattle each spend large recurring sums on translation and interpretation services across health, courts, schools, and social services. Contracts run through a small concentrated set of vendors. Per-language cost structures, vendor selection, billable-hour audit trails, and aggregate annual spend are not routinely published in a form a citizen or auditor can use. This is a procurement category where simple disclosure of vendor, language pair, hourly rate, and total annual spend per agency would let the public see where the money actually goes. TBC has opened a documentation file on this category.
• The Choe Show accountability series. Independent reporting by Jonathan Choe documenting SDCI permitting opacity, KCRHA spending failures, and related state and county dysfunction. Nine PRA requests filed and tracked, with companion documentation available to the Task Force on request. Active series targets include Sound Transit, Cascade Bicycle Club, translation services contracts, the Bob Ferguson childcare grants, DESC, and CCS. This is the local journalism layer the federal investigation needs.

The remedies described in the body of this letter, namely forensic audit, asset freeze, and claw-back of bonuses paid during milestone slippage, translate cleanly to the state and county contexts above. TBC's accountability package addresses both layers.

TBC ACCOUNTABILITY SERIES - RELATED COVERAGE

The submission above sits inside a longer body of TBC accountability work. Each linked page is part of the public record; companion files, primary documents, and PRA logs are available to the Task Force on request.

Civic standard - international benchmarks

• Seattle Police and the World's Fair Standard - Washington has ranked last in the country in police staffing for fifteen straight years. The benchmark is what Tokyo, Singapore, Dubai, Seoul, and Krakow actually do, and what it would cost Seattle to get there. The accountability frame is the gap between cities that decided to be world-class and cities that did not.

Homelessness response - KCRHA orbit

• KCRHA - the federal Continuum of Care pass-through and the agency that absorbs it.
• DESC - Downtown Emergency Service Center, parallel federally funded operator.
• Catholic Community Services - federally subsidized provider with IT and procurement opacity.
• Housing Development Consortium - the trade group through which large operator interests are coordinated.
• 47 Shifts Operations Map - the live unsheltered response operation, the alternative to the existing KCRHA structure.

Transportation - Sound Transit, Cascade, SDOT

• SDOT Accountability Package - Seattle Department of Transportation policy capture, including Cascade Bicycle Club's institutional access.

Permitting and building - SDCI

• The Permit Machine - SDCI permitting as a structural vector.
• Who's Building What - live permit data on who is actually building in Seattle.
• Economic Taking Tracker - how regulation moves value across the city without compensation.

State agencies and federal levers

• Washington Department of Revenue - state tax collection structure and the Ferguson AG-era record.
• Washington Department of Ecology - state environmental enforcement structure.
• Federal Levers - the federal infrastructure consent-decree mechanism for forcing state and local accountability.

Infrastructure and public service

• 87 Times a Year - Seattle's combined sewer overflows, the parallel infrastructure failure.
• 311 Service Requests - the public-complaint pipeline and what it reveals about service delivery.