INTERNAL AUDIT REPORT 
Operational Audit 
Art Program 

January 2017 – March 2021 


Issue Date: June 4, 2021 
Report No. 2021-08

           Art Program 


TABLE OF CONTENTS 

Executive Summary .......................................................................................................................................... 3 
Background ....................................................................................................................................................... 4 
Audit Scope and Methodology .......................................................................................................................... 5 
Schedule of Findings and Recommendations .................................................................................................. 6 
Appendix A: Risk Ratings .................................................................................................................................. 8 












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           Art Program 
Executive Summary 
Internal Audit (IA) completed an audit of the Art Program (program) for the period January 2017 
through March 2021. The audit was performed to determine whether a process was established and
followed to comply with Port Policy, to evaluate governance, and to assess if art assets are maintained
and safeguarded. 
The Port of Seattle (Port) has been an active proponent of art since the late 1960s as the first public
airport to establish a civic art collection. In November 2019, Port Commission approved the Arts and
Cultural Program Policy Directive (Policy). The Policy aspires to position the Port as a national leader
among its peers for art and cultural programming, to promote programming throughout all Port and
Port-related facilities, and to engage the public. The Policy also requires that effective January 1,
2020, one percent of capital construction project costs will be budgeted to art, less allowable 
exclusions. Prior to January 2020, one-half of one percent of design and construction costs were
required to be allocated to the program. 
We concluded that awareness, commitment, and governance over the Port’s Art program was not as
robust as required by Policy guidance. We identified one medium rated issue that is offered to
increase understanding of some of the missed opportunities and to suggest ideas to simplify and
improve how the program is executed. IA recognizes the intrinsic value that art offers and highlights 
the need to balance program expectations with other critical Port functions. This issue is provided
below and discussed in more detail beginning on page six of this report. 
1.  (Medium) – Governance by the Port-Wide Arts and Culture Board (Board) and funding has not
occurred as required by the Cultural Program Policy Directive. Staffing levels and resources 
may also not be sufficient to develop and sustain an art program at both the aviation and
maritime divisions. 



Glenn Fernandes, CPA 
Director, Internal Audit 



Responsible Management Team 
Jeffrey Brown, Chief Operating Officer, Aviation 
Stephanie Jones Stebbins, Managing Director, Maritime 
Lance Lyttle, Managing Director, Aviation 
Dave McFadden, Managing Director, Economic Development 

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           Art Program 
Background 
The Port of Seattle (Port) has been an active proponent of art since the late 1960s as the first public
airport to establish a civic art collection. The Port implemented the Port-Wide Arts and Cultural
Program Policy Directive (Policy), which was approved by Commission on November 19, 2019. The
purpose of the policy is to position the Port as a national leader among its peers for art and cultural
programming, to promote art and cultural programming throughout all Port and Port-related facilities,
and to engage the public. The Policy replaces the Port Art Program Policy and Guidelines, approved
by Commission in December 2009. 
The Policy references an aviation and non-aviation art pool. The pool is funded at one-percent (1%) of 
the budgeted capital construction costs. The Policy identifies the following funding exclusions: 
• Aviation division projects: airfield paving and associated airfield components; fuel hydrant
systems; baggage systems in the bagwell which are not in the public bag claim area; and
underground utilities. 
• Maritime division projects: fishing-related docks; berths; dolphins; piles; electrical; and sewage. 
Oversight is provided by the Port-Wide Arts and Culture Board (Board) for guidance, leadership, and
support to procure, commission and incorporate high-quality art that engages the public. The Board is
comprised of the following nine (9) members: 
• Two (2) commissioners appointed by the Commission President. 
• Three (3) members of the executive leadership team appointed by the Executive Director: 
a. Maritime Managing Director or designee. 
b. Economic Development Managing Director or designee. 
c. Airport Managing Director or designee. 
• Four (4) members of the public, as recommended by the Board and Senior Art Manager, and
appointed by the Commission. 
The Board establishes Port-Wide Arts and Cultural Program Guidelines (Guidelines) and includes the
following guidance: 
• Direct the Port’s art collection and cultural programming to represent the diversity of the people
living in King County, including indigenous and those historically marginalized. 
• Direct the protocol for the procurement, commission, selection, conservation and maintenance,
relocation, deaccession, sale and lease of artwork. 
• Includes protocols for all temporary art exhibits, rotating exhibits and programing. 
• Incorporates Port equity, diversity and inclusion principles throughout the entire program. 
• Includes the following considerations: 
a.  complement the overall aesthetic of the surrounding area 
b.  encapsulate and reflect the spirit of the Pacific Northwest 
c.   coordinate with signage and way-finding when possible 
d.  elevate the Airport’s rating on internationally-recognized airport-rating systems 
e.  adhere to industry practices around conservation and maintenance 
f.   generally  allocate  funds  to  the  project  that  generated  the  specific  funds;  when
recommended 



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           Art Program 
Audit Scope and Methodology 
We conducted the engagement in accordance with  Generally Accepted Government Auditing
Standards and the International Standards for the Professional Practice of Internal Auditing. Those
standards require that we plan and conduct an engagement to obtain sufficient, appropriate evidence
to provide a reasonable basis for our findings and conclusions based on our engagement objectives.
We believe that the evidence obtained provides a reasonable basis for our findings and conclusions
based on our engagement objectives. 
The period audited was January 2017 through March 2021 and included the following procedures: 
Validate that a process to comply with Port policy was established and followed. 
• Gained an understanding of the history and status of the art program through discussions with
management. 
• Interviewed key process personnel on process procedures and requested documentation to
support processes. 
• Reviewed project memo documents to confirm timing of art transfers. 
• Obtained general ledger detail to assess transfers into and out of the art program fund. 
Evaluate governance over the art program. 
• Interviewed key personnel regarding Board meetings. 
• Obtained and reviewed Board meeting agendas and content of minutes. 
• Reviewed Commission documents to determine if Commissioners were aware of art purchases
and status of the program. 
• Reviewed the report prepared by the Lumiere Group, dated March 6, 2020, outlining the Port’s 
five-year strategic art and cultural program. 
Assess if art assets are maintained to preserve value and are properly safeguarded. 
• Interviewed art program management to gain an understanding of the conservation and
maintenance procedures for art collections. 
• Obtained documentation of previous collection assessments to verify assessments are
occurring. 
• Selected 15 art pieces from the asset inventory list and validated their existence by physical
observation at SEA. 
• Observed 15 art pieces at SEA and traced them to the asset inventory list. 







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           Art Program 
Schedule of Findings and Recommendations 
Rating: Medium 

Governance by the Port-Wide Arts and Culture Board (Board) and funding has not occurred as
required by the Port-Wide Arts and Cultural Program Policy Directive (Policy). Staffing levels
and resources may also be insufficient to develop and sustain an art program at both the
aviation and maritime divisions. 
We identified three critical elements where compliance with the Policy wasn’t always followed. We also
evaluated the Policy and observed that requirements could  be  streamlined so that program
expectations are more achievable and realistic. 
Governance 
The Port-Wide Arts and Culture Board (Board) provides guidance, leadership, and support in its
acquisition  and  integration  of  art throughout  the Port and Port-related  facilities.  The  Board  is
comprised of nine members (two commissioners, four public members, and three Executive
Leadership Team (ELT) members or designee from Aviation, Economic Development, and Maritime
divisions). Due to complex scheduling requirements, governance meetings have not been occurring
consistently, as scheduled. 
Funding 
One percent (1%) of all capital construction project costs in the authorized capital improvement plan is 
required to be allocated to the art pool; one for Aviation and one for Maritime. The Policy also lists 
funding exemptions including underground utilities, fuel hydrant systems, fishing related docks,
dolphins, piles, electrical and sewage. However, from 2017 to 2021 an art pool was not used to
procure art. 
For Aviation, a one-time increase of $1.223 million was made as a retroactive adjustment in January
2021. This adjustment was for projects with an effective date of January 2017. In 2021, a $1.453
million decrease occurred and represents a reconciling adjustment for a 2014 decrease to the art
budget (no funds were spent for art aquisitions1). For the International Arrivals Facility and North
Satellite construction projects, the Aviation group procured art purchases directly out of the project
budgets and did not use the art pool. 
Year                      Transfers In              Transfers Out 
2017                        $10,000                         - 
2018                               -                         - 
2019                               -                         - 
2020                               -                         - 
2021                      $1,223,000               $1,453,0341 
Maritime and Economic Development did not fund an art pool or make art purchases between 2017
and 2021. 
Staffing and Resources 
According to the March 2020 report titled Five-Year Strategic Plan for the Port-Wide Arts and Cultural
Program, a minimum of five full time art staff were recommended. The report states “The Port-Wide
Arts and Cultural Program requires a robust staff to support existing and future commitments. Caring
for the existing artwork, researching and acquiring new artwork, and implementing and installing
temporary exhibitions are key components of the new staffing model.” Although internal resources and 

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           Art Program 

a contractor have recently been assigned, only one full time aviation employee manages the art
function. 
Recommendations: 
Governance 
The collective insights of commissioners, Executive Leadership Team (ELT), and public members
bring valuable insight and offer a diverse perspective. However, the ability to coordinate meetings so
that all nine members can attend might be unreasonable. To assure meetings occur as scheduled, the
Board should consider revising the requirements of who needs to be present for a meeting to proceed
as scheduled. This may include reducing membership to a more manageable number. 
Funding 
We believe the number of qualified and dedicated employees are critical to maintain and advance the
art  program.  Therefore,  funding  allocations  should  be  determined  after  staffing  levels  and/or 
appropriate  resources,  have been agreed upon.  We  also  recommend  simplifying  the  funding
requirements based on the needs of the art program purchases. The Policy requires determining
whether a project is eligible, determining the amount, and recording the entry on an individual and
ongoing basis. Instead, a one-time annual allocation could be established based on a percentage of
the capital budget. The allocation could also include a minimum (floor) and maximum (cap), as per the
current policy. Having an annual allocation could also reduce administrative burden and simplify
accounting transactions. 
Staffing and Resources 
We recommend the Board review the Five-Year Strategic Plan including the resource assessment, 
performed by the Lumiere Group. Adjustments to the plan might be necessary based on committed
resources. In 2016, a third-party appraised the value of 36 articles at approximately $15 million. With a
collection of over 200 pieces, the ability to catalogue, maintain, and build the art program is dependent
upon the number of qualified and dedicated employees, as well as inventory systems and resources to
meet the objectives and intent of the art program. 
Management Response/Action Plan: 
Aviation Response 
The Aviation Division agrees with the recommendations and will work with the Executive Director and
the Port-Wide Arts and Culture Board on the changes to the governance, funding and staffing
resources necessary to implement the recommendations. 
The Aviation Division supports the recommended once a year art budget allocation to the Aviation Art
Pool rather than percent (%) allocation for each project when the construction budget is authorized. 
Maritime and Economic Development Response 
The Maritime and Economic Development Divisions agree with the finding and recommendation
related  to  the  governance. With  respect  to  funding,  the  Maritime  Division  agrees  with  the
recommendation that funding and staffing/resources be aligned as well as simplified, however, we do
not believe the same solutions will make sense to all divisions across the Port. We will work with the
Executive Director and the Port-Wide Arts and Culture Board on the changes to the governance,
funding and staffing resources necessary to address the findings in ways appropriate to our facilities. 

DUE DATE: 12/31/2021 

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           Art Program 
Appendix A: Risk Ratings 
Findings identified during the audit are assigned a risk rating, as outlined in the table below. Only one
of the criteria needs to be met for a finding to be rated High, Medium, or Low. Findings rated Low will
be evaluated and may or may not be reflected in the final report. 
Financial      Internal                                               Commission/
Rating                                   Compliance      Public 
Stewardship  Controls                                         Management 
High probability
Non-compliance
Missing or not                       for external audit   Requires
with Laws, Port
High       Significant     followed                          issues and / or     immediate
Policies, 
negative public     attention 
Contracts 
perception 
Partial              Potential for
Partial controls 
compliance with   external audit
Requires
Medium   Moderate                  Laws, Port       issues and / or
Not functioning                                          attention 
Policies             negative public
effectively 
Contracts          perception 
Functioning as
Low probability
intended but     Mostly complies                       Does not
for external audit
could be        with Laws, Port                       require
Low      Minimal                                   issues and/or
enhanced to    Policies,                            immediate
negative public
improve        Contracts                           attention 
perception 
efficiency 











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