Tag Archives: South Park BID

Video Of First Interested Persons Meeting Now Available — See John Howland And Bill Delvac Discuss Whether Neighborhood Council Assent Is Necessary For Development Projects (TL,DR: Yes). This Revelation Makes BID Control Of DLANC Seem Even More Unsavory Than It Already Did

Yesterday afternoon the Ethics Commission held the first in a series of three meetings to gather even more input from interested parties concerning proposed revisions to the Municipal Lobbying Ordinance. I recorded the whole thing for posterity and you can watch it here:

I’ll be commenting on this and the next meeting1 from time to time, and today I just want to point out an interesting response from seasoned Los Angeles lobbyists John Howland and Bill Delvac2 to an interesting question from Ethics Commission ED Heather Holt. One of the proposals on the table is a requirement that lobbyists report attempts to influence neighborhood councils in addition to the other City agencies they’re already required to disclose information about. In the context of this discussion, Holt asked the lobbyists:

Just out of curiosity, for development projects, is there a general sense that you need a neighborhood council buy-in for it to go anywhere?

In response to this, über-düber lobbyist John Howland smirked and emitted an inarticulate snort, seemingly in disbelief that the boss of the Ethics Commission could ask such a silly question, before saying “yes.” This response was echoed by Bill Delvac, with Howland interjecting the occasional assent:

BD: We’re happy when we get to neutral.
JH: Yeah. Well, yeah.
BD:
[Unintelligible] … the Charter and the Code, they’re really not binding. But it matters more to some Councilmen [sic] than it does to others and often [unintelligible] you wanna get their support. I wouldn’t have written the Charter that way, but …

This interchange certainly supports the Ethics Commission’s proposal to subject lobbying directed at neighborhood councils to disclosure, and, interestingly, there didn’t seem to be any actual opposition to this proposal from the lobbyists. So maybe, no matter what gets compromised out of the rest of the proposals, this one will make it through the gauntlet, which is a good thing.3

And turn the page for a discussion of some potential implications, possibly as-yet unconsidered, of this proposal having to do with the fact that, probably uniquely among NCs, the DLANC has a ton of BID staffers on its board of directors.
Continue reading Video Of First Interested Persons Meeting Now Available — See John Howland And Bill Delvac Discuss Whether Neighborhood Council Assent Is Necessary For Development Projects (TL,DR: Yes). This Revelation Makes BID Control Of DLANC Seem Even More Unsavory Than It Already Did

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How I Reported Shadowy BID Consultant Tara Devine To The City Ethics Commission For Failing To Register As A Lobbyist Based On Her Work For The South Park BID In 2017

So you may recall that I’ve been working on establishing the fact that BID consulting constitutes lobbying as defined in the Municipal Lobbying Ordinance. I kicked off this project in February with shadowy BID consultant Tara Devine, whom I reported to the Ethics Commission for working as a lobbyist but failing to register as a lobbyist. Meanwhile, if you have no idea what I’m talking about, here is a reasonable introduction to the concepts of both BID consultancy and why it’s almost certainly the kind of thing for which registration with the Ethics Commission is required.

My theory gained some credibility with the discovery that some BID consultants in Los Angeles do register as lobbyists. Since February I’ve been collecting evidence against Ed Henning for his work with the San Pedro BID and also against Urban Place Consulting for their work on Fashion District BID renewal and also Media District BID renewal.

And, of course, against Tara Devine for her ongoing work with the South Park BID. Finally, a few weeks ago I completed a generic argument1 that BID consultancy constitutes lobbying. And this morning I’m pleased to announce that, despite the twisted CPRA-defying machinations of South Park BID director of operations2 Katie Kiefer and her less-than-competent lawyers,3 I have submitted yet another complaint to the Ethics Commission against Tara Devine, this time for her BID consulting for South Park. You can read the whole complaint here.

And turn the page for a technical discussion of an interesting issue which came up while I was putting this complaint together. Note that I discussed this same issue the other day, so if you read that post, you might want to just skip the rest of this one.
Continue reading How I Reported Shadowy BID Consultant Tara Devine To The City Ethics Commission For Failing To Register As A Lobbyist Based On Her Work For The South Park BID In 2017

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In Defense Of A Change To A Compensation-Based Threshold For Lobbying Registration In Los Angeles

I wrote yesterday about a troubling meeting of the Ethics Commission concerning revisions to the Municipal Lobbying Ordinance. The proposals are still very much in flux, and timely public comments are not only essential for swaying the wavering commissioners in the right direction, but the commissioners, no matter their other flaws, do seem to read them, so they’re likely to be effective if submitted over the next couple of months.1

I had planned to write a letter to the Commission about all the issues together and publish it here as well, but the more I think about it the more I have to say. Thus I thought it would be much easier for everyone if I wrote about one issue at a time and then edited the posts down into a single letter to the Commission. Also, maybe you’ll find some of my ideas useful in framing your own letters, which should be sent to ethics.policy@lacity.org.

This post, then, is the first installment of that project, and the subject is the proposed change from a time-based registration requirement to a compensation-based requirement. If you have no idea what I’m talking about, you’re surely not alone. Turn the page for an introduction to the issue and arguments in favor of making the change.
Continue reading In Defense Of A Change To A Compensation-Based Threshold For Lobbying Registration In Los Angeles

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Apparently The City Attorney Of Los Angeles Has Opined That Business Improvement Districts Can’t Spend Money On Things That Aren’t In Their Management District Plans Unless The Plans Are Amended — At Least That’s What Shadowy BID Consultant Tara Devine Said In 2012 And Why Would She Lie About That?

When business improvement districts in California are created, it’s required by the Property and Business Improvement District Act of 1994 at §36622 to file a so-called management district plan (MDP) with the City. This is meant to describe exactly what the BID is going to spend its money on, and it’s incorporated into the City’s Ordinance of Establishment, by which means the BID is created. It must be approved by the City Council, and the City has the power to revise it at will. The law makes it pretty clear that BIDs are actually forbidden from spending money on activities that aren’t in the MDP, although this facet of the law is generally ignored by the City.

And I’m presently working on a project that requires a close reading of invoices submitted by Tara Devine1 to the South Park BID over the years, which I obtained last month as the fruit of a CPRA request.2 Although 2012 is outside the timeline I’m working on, I was fascinated to note that Tara Devine seems to have been engaged by the South Park BID to actually write that year’s annual planning report3 for them. One of the things that she billed for in the course of performing her contract to do so Tara Devine billed for was a conversation with accounting firm RBZ, since merged with Armanino, and the subject of that conversation was wholly new to me:
Continue reading Apparently The City Attorney Of Los Angeles Has Opined That Business Improvement Districts Can’t Spend Money On Things That Aren’t In Their Management District Plans Unless The Plans Are Amended — At Least That’s What Shadowy BID Consultant Tara Devine Said In 2012 And Why Would She Lie About That?

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In Which I Present A General Argument That BID Consultancy Is Lobbying Activity In Order To Simplify And Regularize The Process Of Reporting BID Consultants To The Ethics Commission For Failure To Register

It’s a long term project of mine to turn in as many BID consultants as possible to the City Ethics Commission for failing to register as lobbyists. So far, though, I’ve only managed to report Tara Devine for her work on the Venice Beach BID because the work is so involved. Such a report has two essential components:

  1. An argument that BID consultancy satisfies the definition of lobbying activity found in the the Municipal Lobbying Ordinance at LAMC §48.02.
  2. An argument that a specific BID consultant was paid for sufficiently many hours over sufficiently few months to trigger the registration requirement found in the MLO at LAMC §48.07(A).

It occurred to me recently that the first argument will be the same for all BID consultants, and that therefore it would be possible to streamline the reporting process by writing it up in a generic format that would apply to any given BID consultant. So that’s what I did, and you can read the result here. I will be using this to make a number of complaints against BID consultants in the near future, which I will report on here.

Meanwhile, if you have no idea what I’m talking about, you can find explanations of everything after the break, along with a fairly detailed summary of the argument that BID consultancy qualifies as lobbying under the MLO.
Continue reading In Which I Present A General Argument That BID Consultancy Is Lobbying Activity In Order To Simplify And Regularize The Process Of Reporting BID Consultants To The Ethics Commission For Failure To Register

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Massive Document Dump Concerning Shadowy BID Consultant Tara Devine — What Has She Been Up To Since Destroying Venice Beach And How She Is Probably In Way More Trouble Than Anyone Thought With Respect To Not Having Registered As A Lobbyist

Yesterday I took a little trip South on Flower Street to the dark horse Death Star of downtown, the South Park BID, to look over some public records that they’ve been holding out on since January 2017 and only coughed up because my lawyer can beat up their lawyer.1 I found a hot mess of, among many, many problems, bizarrely damaged emails printed to PDF in random order with unintelligible OCR, missing attachments, purposely scrambled pages, and misnamed and poorly divided files. It’s going to take quite a while to put this nonsense into any kind of useful state,2 but I know a lot of my readers are wondering what’s up with shadowy BID consultant Tara Devine,3 so I thought I’d get the information concerning her up as fast as possible, even though it’s not yet in an ideal format.

That’s the big news, and you can turn the page if you’re in the mood for more detail and discussion. Note, though, that I’ll be posting about this material again once I get it revised into a more useful form.
Continue reading Massive Document Dump Concerning Shadowy BID Consultant Tara Devine — What Has She Been Up To Since Destroying Venice Beach And How She Is Probably In Way More Trouble Than Anyone Thought With Respect To Not Having Registered As A Lobbyist

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A Potential Solution To A Perennial Problem At The Nexus Of Los Angeles Business Improvement Districts, The Municipal Lobbying Ordinance, And A Few Widely Abused Exemptions To The California Public Records Act

The life-cycle of a request for documents under the California Public Records Act goes like this: A member of the public asks to see records held by some agency. The agency has ten days1 to respond with a determination which states whether the agency has any such records and, if so, when the agency will be ready to hand them over.2 In general agencies are required to produce all requested records.

However, CPRA lists certain classes of records which are exempt from production. Some of these so-called exemptions are weirdly specific, e.g. at §6253.5 we read:

…statewide, county, city, and district initiative, referendum, and recall petitions … and all memoranda prepared by the county elections officials in the examination of the petitions indicating which registered voters have signed particular petitions shall not be deemed to be public records…

One of the two most important sections of CPRA with respect to exemptions is found at §6254, which consists of innumerable sections, each listing an exemption or a broad class of exemptions. And as completely in favor of absolute government transparency as I am, it’s clear that at least some of these are absolutely justified. For instance, §6254(r) exempts:

Records of Native American graves, cemeteries, and sacred places and records of Native American places, features, and objects … maintained by, or in the possession of, the Native American Heritage Commission, another state agency, or a local agency.

And there are sections which exempt such things as reports on vulnerabilities to terrorism, library circulation records, certain financial data that people are required by law to submit, and so on. These are mostly noncontroversial. Others, however, are much less defensible, at least as applied.
Continue reading A Potential Solution To A Perennial Problem At The Nexus Of Los Angeles Business Improvement Districts, The Municipal Lobbying Ordinance, And A Few Widely Abused Exemptions To The California Public Records Act

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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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The San Pedro BID Is Paying BID Consultant Edward Henning Only $20,000 To Handle Their Impending Renewal. This Is 64% Less Than The Fashion District Will Pay Urban Place Consulting And 75% Less Than The South Park BID Will Pay Tara Devine. Why The Huge Variation In Compensation For A Job Whose Elements Are Delineated By The City?

You may recall that Edward Henning is an engineer who works with a number of BID consultants on BID establishment and renewal, writing the engineer’s reports required by Streets and Highways Code §36622(n). I’ve previously reported, e.g., that he seems to get paid about $9,000 for writing these things.1 Well, TIL that Ed Henning is also a BID consultant his own self!

The story begins with Lorena Parker, executive director of the San Pedro Historic Waterfront BID, sending me the contract that Ed Henning and her BID signed for consulting services, along with some ancillary information:

These materials are also available on the Archive, which is useful because of OCR and so forth. And that’s today’s goodies. Turn the page for discussion!
Continue reading The San Pedro BID Is Paying BID Consultant Edward Henning Only $20,000 To Handle Their Impending Renewal. This Is 64% Less Than The Fashion District Will Pay Urban Place Consulting And 75% Less Than The South Park BID Will Pay Tara Devine. Why The Huge Variation In Compensation For A Job Whose Elements Are Delineated By The City?

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