Last month I learned that the San Pedro BID was paying Edward Henning $20,000 to handle their BID renewal process. This discovery was independently interesting, but also important for my ongoing research project of learning everything possible about BID consultancy with the ultimate goal of shopping as many BID consultants to the City Ethics Commission as possible, mostly for violations of LAMC §48.07, which requires that “[a]n individual who qualifies as a lobbyist shall register with the City Ethics Commission within 10 days after the end of the calendar month in which the individual qualifies as a lobbyist.”
In this clause, someone “qualifies as a lobbyist” when they, according to LAMC §48.02 are “compensated to spend 30 or more hours in any consecutive three-month period engaged in lobbying activities.”1 Note that today I’m mostly skipping the argument that BID consultancy qualifies as lobbying activities, but you can read about it in excruciating detail here.
Part of the evidence that I obtained last month were these two invoices from Edward Henning to the SPHWBID. As you can see, they span the time period from March 2016 through December 12, 2016 and bill for a total of 75 hours. That’s roughly 7.5 hours per month if distributed evenly across the billing period. This is not enough evidence to show that Edward Henning was required to register. In fact, if he did work about 7.5 hours a month he would not have been so required.
It’s precisely that issue that today’s document release shines some light on. The other day, San Pedro BID executive directrix Lorena Parker was kind enough to send me over 100 emails to and from Edward Henning.2 At first I thought I’d be able to pick out 3 consecutive months in which Edward Henning was compensated for 30 hours by assuming that the number of emails in a month was proportional to the number of hours worked. This didn’t pan out for a number of reasons, not least because I don’t yet have emails between Edward Henning and the City of LA that weren’t CC-ed to Lorena Parker. I can tell from internal evidence that there are some of these,3 and I have a pending CPRA request for them, but they’re not yet in hand.
Read on for more detail on the unregistered lobbying case as well as a new theory that I thought at first might actually get the BID itself in some trouble rather than just the consultant. I don’t think it’ll work out in this particular case, but it has interesting implications for the future. Bad scene for the BIDdies and lulz4 all round for humanity!
Continue reading Relatively Complete Set Of Records Pertaining To Ongoing San Pedro Historic Waterfront BID Renewal Process Reveals Hitherto Unknown Details About Costs, Hours, Contract Terms, Etc. Heralding Plausible Case Against Edward Henning For Failure To Register As A Lobbyist But Not, Unfortunately, Against The BID Because They’re Not Paying Him Enough