Tag Archives: Open Letters

Open Letter To The Los Angeles Ethics Commission Asking Them To Consider Adopting A Policy On Disclosure Of Ex Parte Communications

I reported last week that Serena Oberstein, Vice President of the Los Angeles City Ethics Commission, had engaged in undisclosed ex parte communications with a couple of (unregistered) lobbyists regarding a proposal to revise the Municipal Lobbying Ordinance. Of course, at present, there’s no requirement for any City commissioners, except Harbor Commissioners, to disclose such communication.

However, the example of the Board of Harbor Commissioners shows that it is possible for City commissions to adopt more stringent requirements than the rest of City government is subject to. Given the role of the Ethics Commission in defending the public interest in transparency and disclosure, it seems like a natural candidate for such a policy.

Hence, as promised, I’ve written a letter to the Commission asking them to put an item on the agenda for December 19 asking the staff to draft a policy proposal for such a requirement. Here’s a copy of the letter, and you can read a transcription after the break. If you’re moved to write about this yourself, you can, as far as I know, send communications to the Commission at ethics.commission@lacity.org.
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My Letter To The Ethics Commission On Proposed Revisions To The Municipal Lobbying Ordinance

As you may already know, the City Ethics Commission is in the process of proposing revisions to the Municipal Lobbying Ordinance. The full proposal is here. They’ve been holding meetings to solicit input and, given the anti-regulatory stance adopted by a significant number of the Commissioners recently, it’s essential that right-minded people get their comments in to ethics.policy@lacity.org soonest.

I’ve been working on a letter for a few weeks now,1 and yesterday I finally finished it. You can get a copy of the PDF or read a transcription after the break. Please feel free to use any part of this to guide or inspire your own letters, which, as I said, I really hope you will send in as soon as possible.

The next Commission meeting is on October 17, and I’m told by staff that all comments received by a few days before then will be distributed to the Commissioners. If you can get your comments in pretty soon, though, they’ll also be discussed by staff prior to finalizing the proposals, which may be a good thing.
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Open Letter To Holly Wolcott And Miranda Paster Regarding Nicole Shahenian’s Violation Of LAMC 48.04(B) In 2014

Here’s a letter I sent this morning to Holly Wolcott and Miranda Paster about the fact that East Hollywood BID Director Nicole Shahenian appears to have violated LAMC 48.04(B) by stating that the EHBID’s 2015 Annual Planning Report had been prepared at a Board meeting on December 29, 2014, when in reality no such meeting took place. Also maybe look at the actual complaint I filed with the Ethics Commission.

The main points are that the Clerk ought to institute some kind of oversight to make sure that this nonsense stops happening. The Ethics Commission will rule on Nicole Shahenian’s violation of the Municipal Lobbying Ordinance, but that only applies because she was coincidentally registered as a lobbyist in 2014. Most BID directors are not registered lobbyists,1 but many of them apparently lie about the APR approval process. This could potentially create dire consequences due to the fact that, e.g., BIDs can actually be disestablished for such transgressions, whether or not the Municipal Lobbying Ordinance is involved. Anyway, as I said, here is the letter as a PDF, and turn the page for a transcription.
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Open Letter To Holly Wolcott and Miranda Paster Concerning Tara Devine’s Misleading Everyone With Her Discredited “Zoning Not Use” Theory

Holly Wolcott in her bully pulpit, explaining it all to you!
Here’s a letter I sent this morning to Holly Wolcott and Miranda Paster about Tara Devine misleading everyone with respect to the question of whether commercial properties were necessarily included in the Venice Beach BID. There’s a transcription after the break, as always, for the PDF averse.

This is a fairly serious matter, and actually illegal if it turns out to be the case that Tara Devine was required to register as a lobbyist last year, as I have alleged that she was. The point is that since the Clerk’s office is supposed to oversee BIDs, they ought to oversee BID consultants as well, and since both honesty and integrity are explicit criteria for qualifying as a BID consultant perhaps these two ought to look into whether Tara Devine is actually qualified. Turn the page for a transcription.
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Open Letter To Holly Wolcott And Miranda Paster Concerning The Question Of Whether BID Consultants Qualify As Lobbyists And What The Proper Course Of Action Might Be If They Do

A pseudo-artistic computer-modified image of Los Angeles City Clerk Holly Wolcott.
Here’s a letter I sent this morning to Holly Wolcott and Miranda Paster concerning the question of whether BID consultants qualify as lobbyists for the purposes of complying with the Municipal Lobbying Ordinance. My feeling, of course, is that they do qualify, they ought to register with the City, they should be punished for the fact that they have not done so, and the City staff who work with them without insisting that they register ought to be busted for aiding and abetting. But since evidently this has never occurred to anyone before, I thought it would be decent to give everyone involved a chance to assess their own risk in choosing a course of action. Hence this letter. There’s a transcription with live links after the break if you don’t want to deal with a PDF.
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Open Letter to City Council Asking For Postponement of Venice Beach BID And A Moratorium On New BID Formation


Honorable Los Angeles City Councilmembers,

I’m writing to urge you to postpone consideration of the proposed Venice Beach business improvement district and to think about placing a moratorium on the formation of new BIDs until we as a City can have a much-needed, long-delayed conversation about their proper role. A major problem is that as they’re now constituted, there is no way for anyone not on their Boards of Directors to have any influence over property-based BIDs in Los Angeles. They have effectively isolated themselves from every one of the City’s means of contractor oversight. People who live in or near BIDs are directly impacted by their activities in many ways but have no effective means of influencing them. Since the property owners associations that administer the BIDs are mostly controlled by self-perpetuating Boards there aren’t even effective ways for the property owners in BIDs to influence their policies. Property-based BIDs also covertly and perhaps inadvertently perpetuate racist policies from the past in unexpected ways.
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An Open Letter to Mitch O’Farrell Regarding Signal Box Art in the Hollywood Entertainment District

Thus it’s hard to understand why it’s not good enough to appear on the signal boxes of Hollywood.
Thus it’s hard to understand why it’s not good enough to appear on the signal boxes of Hollywood.

See here and here for the background to this post.

Dear Councilmember O’Farrell,

As you may already be aware, the Hollywood Property Owners Alliance is presently holding a competition to choose artwork to adorn signal boxes in the Hollywood Entertainment District, which they contract with the City of Los Angeles to administer. As you know, the L.A. Department of Transportation requires your approval for this project to move forward. I am writing to ask you to withhold your consent from the HPOA’s plan pending a revision of their stated rules which, regardless of the intent, have the effect of significantly lowering the chance that Latino artists working in some of our most vibrant local traditions will be chosen for this honor.

The problem is that the BID’s stated requirements for submissions include the proviso that “NO Cartoon Images or Graffiti work of any kind will be considered.”1 Graffiti art and cartoon styles are associated in L.A. with Latino, especially Mexican-American artists. Work by Los Angeles artists in these genres has brought world renown, not just to the artists themselves, but to our City. Thus it’s hard to understand why it’s not good enough to appear on the signal boxes of Hollywood. The mystery only deepens when one considers that the HPOA’s requirements also state that “Text Art” will be given full consideration, as if Graffiti art were not also “Text Art.”
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