Ah, friends, just another desultory announcement of yet another batch of public records obtained from our friends at the BIDs, the meaning of none of which is yet clear, but we don’t let that worry us here in MK-dot-Org-landia. Everything happens for a reason, as they say, and I’m sure all this junk is no exception and some day it will prove to comprise crucially important pieces in puzzles whose very existence is as yet undiscerned. But for now I’m just announcing its existence, and do with it what you will. Anyway, here’s what I got:
Emails between the East Hollywood BID and the City of LA — March 2017 through July 2017. There are 110 emails here, attachments are attached to the emails, it’s amazing how empty of content this batch is. About 84% of them consist of Nicole Shahenian trying to get people to use her new email at ehbid.org. I don’t know for sure but I’d bet money that she made this switch because of my CPRA requests. Also, Aram Taslagyan’s replacement as CD13 East Hollywood field deputy introduces himself herein, but I already forgot his name.
East Hollywood BID quarterly reports 2012-2016 — BIDs are required by their contracts with the City to submit quarterly reports with updates on how they’ve been spending their money.3 These are useful to have on hand for reference. There’s nothing in these that stands out right now, but I haven’t read them carefully yet nor even looked at all of them.
Media District emails with the City of LA — And also a few from the Hollywood Property Owners Alliance folks, although nothing substantial. Again, it’s essential to have this material on hand for reference. There doesn’t seem to be much of special interest here, although there’s a lot more evidence of Rita Moreno’s uncharacteristically activist style as a BID analyst with the Clerk’s office, which is abstractly a good thing, although certainly she’s not going to be an activist if it upsets the BIDs too much.
Media District emails about Andrews International Security contract — The Media District BID is in the process of hiring infamous private security monolith Andrews International as its security provider, to begin July 1. These are some emails about the process. The most interesting things here are the attachments, which include A/I’s standard contract as well as proposed pricing matrices and so on. Andrews International famously runs the infernal Hollywood BID Patrol for the even-more-infernal Hollwood Property Owners Alliance just North of the Media District, so everything about them is interesting. There is much more material to come regarding this matter, and I will write about it in detail as it comes in, but it’s essential enough that I thought I’d better publish what I had immediately.
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 entity6 whereas the amended version had January 1, 2017 as the day of qualifying.
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.7 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.
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.
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.