Tag Archives: Larry Kosmont

The Hollywood Chamber Of Commerce Amended Its Lobbying Registration Form in April 2017 And The Only Change Was The Date They Qualified — More Interesting, Though, Is The Fact That They Consider Their Pro-Establishment Advocacy For Jeff Zarrinnam’s Inchoate Hollywood-Western And Route 66 BIDs To Be Lobbying Activity

It’s well-known that the Municipal Lobbying Ordinance requires lobbyists of all stripes to register with the City Ethics Commission. The Hollywood Chamber of Commerce is no exception to the rule.1 They are also required to amend their registration forms if there are any material changes in the information provided.2

And as you know if you follow this blog, I find everything to do with lobbyists in Los Angeles fascinating, and thus I haunt the Ethics Commission’s lobbying pages, poring over the alphabetical lists of individual lobbyists and of lobbyist firms and employers to see if anything’s changed or if something is newly interesting.

And lo! Last night I noticed that our old friends, the Hollywood Chamber of Commerce, had amended their registration form on April 28. Here are the two forms:

Well, I stared and stared and stared at those two forms just trying to figure out what had changed. Eventually I noticed that the original form had January 31, 2017 as the date they’d qualified as a lobbying entity3 whereas the amended version had January 1, 2017 as the day of qualifying.

One of the Hollywood Chamber’s registration forms superimposed on the other with 38% opacity so that it’s clear that the only difference is in the qualifying date. Click to enlarge, of course.

There’s a lot of information on the forms, though, and I didn’t feel confident that the difference I’d noticed was in fact the only difference. I wasn’t sure what do to until this morning, when it occurred to me that if I put both pages into the GIMP, superimposed one on top of the other, and then faded the opacity up and down I’d be able to notice what changed.4 And it turns out that in fact, it’s correct that the only change was the date of the Hollywood Chamber’s qualifying as a lobbyist.

Which leads irresistibly to the question of why Leron Gubler and/or Nicole Shahenian, who are the Hollywood Chamber’s two registered lobbyists, felt the need to make this tiny change. Read on for speculations and some other chit-chat about the fact that Leron Gubler lists the establishment of the Hollywood Western and the Route 66 BIDs as issues the Chamber is lobbying for this year.
Continue reading The Hollywood Chamber Of Commerce Amended Its Lobbying Registration Form in April 2017 And The Only Change Was The Date They Qualified — More Interesting, Though, Is The Fact That They Consider Their Pro-Establishment Advocacy For Jeff Zarrinnam’s Inchoate Hollywood-Western And Route 66 BIDs To Be Lobbying Activity

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The Fascinating Story Of How It Took Three Months And A Demand Letter From An Attorney To Get Rena Leddy To Disclose That The Fashion District BID Is Paying Steve Gibson Of Urban Place Consulting $215 Per Hour For BID Renewal Consulting, Which Is Less Than Larry Kosmont Gets But More Than Ed Henning

Late last year it occurred to me that BID consultants, who help BIDs with the City processes necessary to establish or renew a BID, are essentially engaging in lobbying activity as defined in the Municipal Lobbying Ordinance at LAMC §48.02 and yet none of them1 seemed to be registered with the Ethics Commission as required by LAMC §48.07(A).

I then spent months piecing together over 100 pages of evidence to show that BID consultant Tara Devine had violated this law. Subsequently it occurred to me that the contracts that the consultants sign with BIDs would provide essential evidence that they’d been acting as lobbyists, so I determined to request these from many renewing BIDs. This led me to the discovery, thanks to the incomparable Laurie Hughes of the Gateway to LA BID, that GTLA’s BID consultant, Larry Kosmont, actually was registered as a lobbyist and had disclosed his BID consultancy as lobbying in his required reporting. The San Pedro BID is also up for renewal, and has recently released a fairly complete set of BID renewal records.

This brings us to the Fashion District. On February 21, 2017 I emailed Rena Leddy to request, among other material:

… all records associated with the renewal process, including but not limited to communications between the BID and the consultant and/or the engineer, contracts with and invoices from the consultant or the engineer, materials prepared by the consultant or the engineer for the renewal process, databases and mailing lists prepared or used by the consultant or the engineer, and also any communications between the consultant and the engineer that aren’t already responsive to the first part of this request.

The story of what happened after that stretched out over three months and generated many many megabytes of discussion. Read on for a (far too) detailed and exceedingly well-documented narrative recounting, complete with a happy, happy ending!
Continue reading The Fascinating Story Of How It Took Three Months And A Demand Letter From An Attorney To Get Rena Leddy To Disclose That The Fashion District BID Is Paying Steve Gibson Of Urban Place Consulting $215 Per Hour For BID Renewal Consulting, Which Is Less Than Larry Kosmont Gets But More Than Ed Henning

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Urban Place Consulting Charged Palisades BID 62% Less For Establishment Than They Are Charging Fashion District For Renewal, $21K vs. $55K. The Resulting Linear Model Suggests That Each Additional Parcel Adds Around $18 To The Price Of BID Consultancy, But Comparison With San Pedro Casts Some Doubt On Accuracy

This chain of emails from December 2015 reveals that the Pacific Palisades Business Improvement District paid Urban Place Consulting $21,000 for guiding the establishment process and an additional $4,000 to the consulting engineer.1 This is yet another piece of the BID consultancy puzzle that I’ve been trying to decipher since it became clear that almost certainly BID consulting qualified as lobbying under the Municipal Lobbying Ordinance and that almost all of the qualified consultants were breaking the law by not being registered with the City Ethics Commission like, e.g., Tara Devine.2

And this small piece of evidence is especially valuable given the fact that by now it’s essentially impossible to coax records out of the Palisades BID. They’ve even hired a lawyer specifically to thwart my requests, as if the bred-in-the-bone intransigence3 of PPBID ED Laurie Sale, which presumably they’ve already paid for, weren’t enough in itself.

In particular, because we already knew that Urban Place was charging the Fashion District $55,000 for renewal consulting and because it’s the first time we’ve known the rates that a single consultant is charging two different BIDs, it’s possible for the first time to attempt to model UPC’s fee structure. The gory details are available after the break, but the upshot it’s possible to estimate that UPC’s baseline fee for establishing/renewing an ideal BID with zero parcels in it is about $19,583 and that each additional parcel adds a little more than $18 to the cost of establishing/renewing the BID.
Continue reading Urban Place Consulting Charged Palisades BID 62% Less For Establishment Than They Are Charging Fashion District For Renewal, $21K vs. $55K. The Resulting Linear Model Suggests That Each Additional Parcel Adds Around $18 To The Price Of BID Consultancy, But Comparison With San Pedro Casts Some Doubt On Accuracy

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Kosmont Invoices For Gateway To LA BID Reveal How Much Time It Takes To Get A BID Renewed, And It Doesn’t Look Good For BID Consultants, Like Tara Devine, Like Urban Place Consulting, That Are Not Registered As Lobbyists With The City

Larry Kosmont handled the Gateway to LA BID’s 2014-5 renewal and was, very properly, registered as a lobbyist while doing so.
You may recall that the Los Angeles Municipal Lobbying Ordinance requires qualified lobbyists to register with the City Ethics Commission and also disclose a bunch of interesting information about their clients and their income. Also, the process of establishing or renewing a BID is fairly complex, and most property owners’ associations1 hire a consultant to guide them through the process. These consultants are regulated and recommended by the City Clerk’s office.

The process of getting a BID established or renewed, it turns out, looks an awful lot like the definition of lobbying activity to be found at LAMC §48.02, which is essentially preparing information and discussing it with City officials as part of influencing the passage of municipal legislation. The law requires anyone who’s paid for thirty or more hours of this over three consecutive months to register as a lobbyist, and it’s generally extremely hard to prove that someone’s met this criterion. You may, e.g., recall that earlier this year, in order to make a reasonably convincing case that Venice Beach BID consultant Tara Devine had passed this threshold, I spent months piecing together more than a hundred pages of evidence regarding her BID consultancy work.

But recently it’s occurred to me that these consultants have contracts with the BIDs they service, and that at least in the case of BID renewals, the contracts will be accessible via the Public Records Act.2 The contracts will contain some information about how much time the consultants spend on the project, and thus should be useful as evidence in reporting consultants to the Ethics Commission for lobbying without a license.

The project started to produce results at the end of February, when the incomparable Laurie Hughes of the Gateway to LA BID supplied me with her BID’s contracts with Larry Kosmont, who was handling the renewal process.3 Well, late last week, Laurie Hughes gave me an absolutely essential set of documents, consisting of detailed monthly invoices from Kosmont to the BID during the 15+ month renewal process. These are fascinating,4 containing as they do detailed inventories of every individual task involved in the renewal process broken down into fifteen minute billing increments. Turn the page for more descriptions, discussion, and speculations.
Continue reading Kosmont Invoices For Gateway To LA BID Reveal How Much Time It Takes To Get A BID Renewed, And It Doesn’t Look Good For BID Consultants, Like Tara Devine, Like Urban Place Consulting, That Are Not Registered As Lobbyists With The City

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New Documents: January 2017 Emails Between East Hollywood BID and City of LA, Also Gateway To LA BID By-Vendor Reports

Just a brief note to announce a couple more sets of documents:

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Is There Such A Thing As An Honest Lobbyist? Probably Not, But Nevertheless, Larry Kosmont Handled The Gateway To LA BID’s Recent Renewal And Registered With The Ethics Commission To Do So, Casting Further Doubt On Any Theory That Implies That Shadowy BID Consultant Tara Devine Was Not Also Required To Register

We’ve been discussing BID consultants a lot recently because of shadowy BID consultant Tara Devine and the fact that it looks so much like BID consultancy satisfies the LAMC’s definition of lobbying that it’s very likely that she broke the laws requiring registration, causing me, in the throes of a well-developed sense of civic duty, to report her transgressions to the Ethics Commission and then again to report some associated transgressions to Mike Feuer. What will come of these matters no one can now know, of course, but one aspect that troubled me slightly is the apparent novelty of the charges. That is, all the BID consultants I knew of at the time weren’t registered. This doesn’t mean they don’t have to register. After all, consider what happened with BID security and the Police Commission as a result of our reporting. But nevertheless, one never wants to be the first to make an argument if it’s possible to avoid it.

So imagine my pleasure in discovering that, first, the famous Gateway to LA BID, one of Mike Bonin’s babies out there by the Airport in CD11, renewed for 10 years in 2015, and they used a BID consultant named Larry Kosmont to handle the process for them. And second, that Larry Kosmont was not only registered as a lobbyist during this process, but that he specifically, explicitly, disclosed his work for the Gateway BID to the City and specifically, explicitly listed the City Clerk as one of the City offices he’d lobbied in furtherance of the renewal project. This is going to make it a lot harder for Tara Devine and her defenders, if any she has by now, to argue that it never occurred to anyone that BID consultants were lobbyists and therefore subject to registration. Turn the page for links to all relevant documents!
Continue reading Is There Such A Thing As An Honest Lobbyist? Probably Not, But Nevertheless, Larry Kosmont Handled The Gateway To LA BID’s Recent Renewal And Registered With The Ethics Commission To Do So, Casting Further Doubt On Any Theory That Implies That Shadowy BID Consultant Tara Devine Was Not Also Required To Register

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