Occasionally people in my position find that actual factual matters are weirder than we could have even imagined. It’s hard to make fun of people whose publicly revealed antics are not only stranger than fiction but stranger even than satire. The great Mark Russell used to call this kind of material “rip and read.”1
So yesterday, courtesy of the ever-courtly but but not always ever lawful Nicole Shahenian, EHBID ED, all the materials for this afternoon’s East Hollywood BID meeting arrived via email. And there to my wondering eyes did appear the following greasy little slabs of marketitation:2
EHBID Strategy Report Final — Result of a lot of brainstorming and so forth, prepared for the BID by Counterintuity, who, I hope, have substantial qualifications beyond the fact that they seem to come from Burbank.
You may recall that late last year, on the basis of my complaint to the Police Commission, the City of LA resumed enforcement of LAMC 52.34 against BID security forces.1 Since then it’s been possible to track the progress of this massive project via various CPRA requests. So in November 2016 the Police Commission informed all BIDs of the registration requirement and, at the same time, told them that their BID patrollies would be subject to arrest if they didn’t submit. In December 2017 the Police Commission told the BIDs to quit whining about it because the law is the law.
This is just a short note to announce three new sets of documents for your entertainment, your edification, and, if you’re interested, a little puzzle for you to solve.
First we have a couple of monthly sets of emails between BIDs and the City of Los Angeles. This turns out to be a useful request for keeping finger on pulse, often leading to unexpected discoveries, so I make it every month of all my favorite BIDs.1 Perhaps there are some lurking here:
Bylaws of the Palisades BID — Given how damned much trouble it is to coax thing one out of the PPBID and given that they’re evidently willing to spend thousands of dollars fighting my requests rather than just complying with them, it’s always a pleasant surprise to get anything at all out of these people. Of course, these are really the bylaws of the property owners’ association which administers the Palisades BID. Unlike seemingly every other BID in Los Angeles, these people named their POA the same thing as their BID, which makes the confusion even more complete than it usually is. This is probably because something else was already called the Pacific Palisades Property Owners Association.
One requirement that the Property and Business Improvement District Law places on BIDs, found at §36650, is the submission of annual planning reports (“APRs”) to the City Council:
The owners’ association shall cause to be prepared a report for each fiscal year, except the first year, for which assessments are to be levied and collected to pay the costs of the improvements, maintenance, and activities described in the report. … The report shall be filed with the clerk … The city council may approve the report as filed by the owners’ association or may modify any particular contained in the report and approve it as modified.
And it seems that the BID isn’t allowed to spend money on stuff that’s not discussed in the APR, so it’s not a trivial matter.
The way this piece of code plays out in Los Angeles is that, first, a BID director submits the APR to the Clerk along with a formulaic cover letter. For instance, here is the one submitted by Nicole Shahenian on December 30, 2014 to accompany the East Hollywood BID’s APR for 2015. This is essentially the same letter submitted by all BIDs:
Dear Ms. Wolcott:
As required by the Property and Business Improvement District Law of 1994, California Streets and Highways Code Section 36650, the Board of Directors of the East Hollywood Business Improvement District has caused this East Hollywood Business Improvement District Annual Planning Report to be prepared at its meeting of December 29, 2014.
And don’t forget that state law requires the City Council to adopt the report either with or without modifications. In Los Angeles this part of the process is initiated by the Clerk sending another form letter to City Council, recommending that they adopt the BID’s APR. It’s my impression that the Clerk doesn’t recommend modifications to the report at this stage. These seem to be handled by Miranda Paster before the APR is submitted to Council, as in this example involving the Media District BID. Anyway, take a look at Holly Wolcott’s January 14, 2015 recommendation to City Council with respect to the East Hollywood BID’s APR. Like every such document, this states:
The attached Annual Planning Report, which was approved by the District’s Board at their meeting on December 29, 2014, complies with the requirements of the State Law and reports that programs will continue, as outlined in the Management District Plan adopted by the District property owners.
And it goes on from there to recommend:
That the City Council:
FIND that the attached Annual Planning Report for the East Hollywood Property Business Improvement District’s 2015 fiscal year complies with the requirements of the State Law.
ADOPT the attached Annual Planning Report for the East Hollywood Property Business Improvement District’s 2015 fiscal year, pursuant to the State Law.
Tonight I had the pleasure of receiving from self-proclaimed active member of the revitalized Hollywood community1 Jeffrey Charles Briggs almost 200 emails between the East Hollywood Business Improvement District and various far-too-friendly folks at the City of Los Angeles. For now these are available here on Archive.Org. They’re PDFs, but they’re that super-PDF-format that one can make with genuine Adobe software that embeds attachments right in there with clickable links.2 I have only been able to give these a cursory look-over, but I can already see a few crucial items. I’ll be writing on these matters as soon as I possibly can, but if you want a preview of one of them take a look at this juicy little number.
I’m just announcing a few new documents today. When I requested them it was almost an afterthought. I didn’t expect much of them. But one has turned out to be really interesting and potentially really important.
These are just routine Contractor Responsibility Ordinance pledges of compliance. Today I have three: