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:

• Original form — filed on January 31, 2017
• Amended form — filed on April 28, 2017

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.

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.

Personally, I’d like to think that they are feeling the heat of constant scrutiny emanating from these pages, manifested most recently in our stunning discovery that Nicole Shahenian seems to have lied to everyone about some pretty important matters, quite likely in violation of her solemn oath as a lobbyist.⁵ But, sadly, as with so many such things, we’re probably never going to know.⁶

And the long list of issues that they’re lobbying over is fascinating in itself. Among them we find several old friends, obsessions of the famous Ms. Kerry Morrison one and all, like e.g. street performers, or street vending, and so on. But also interesting, and not surprising in retrospect, are the listings for two inchoate BIDs, the Hollywood-Western BID and the Hollywood Route 66 BID, both of them projects of the infamous Mr. Jeff Zarrinnam, kingpin shot-caller of the also infamous East Hollywood BID.

And it’s not the fact that the Hollywood Chamber is behind these two projects that’s a surprise. Obviously, like every other real estate oriented zillionaire or zillionaire-adjacent entity in the City they’re in favor of BIDs and more BIDs, especially, for whatever reason, ones run by Jeff Zarrinnam, whose EaHo⁷ BID is already administered by the Hollywood Chamber of Commerce, and why would these new BIDs be any different?

What’s surprising, although clearly not wrong, is that the Hollywood Chamber openly admits that its advocacy on behalf of BID formation is lobbying activity under the meaning of the Municipal Lobbying Ordinance. This seems to be a fairly controversial idea in some circles. For instance, shadowy BID consultant Tara Devine fairly notoriously failed to register as a lobbyist based on her work in establishing the Venice Beach BID.

The situation is even more complex with BID renewal efforts.⁸ It turns out that registered lobbyist Larry Kosmont considered his renewal work for the Gateway to LA BID to be disclosable lobbying but that no other renewal consultant seems to agree, at least if their failure to register with the Ethics Commission is any indication. I’m presently in the process of building cases against renewal consultants Ed Henning for his work with the San Pedro Historic Waterfront BID, against Urban Place Consulting for their work with the Fashion District BID, and a couple others that are too incipient to discuss.⁹

In any case, for whatever reason, the BID establishment and BID renewal mafias seems generally quite resistant to the idea that what they’re doing is lobbying activity and that they might be required under the law to register. That’s why it not only surprised me to find that at least Leron Gubler and Nicole Shahenian agree with me against their zillionaire compatriots on the issue, but also cheered me up to an unreasonable degree. And that’s all I have for you today!

Image of Leron Gubler is originally from here but I chipped, tipped, gripped, and flipped it to the point where it is now, it seems, ©2017 MichaelKohlhaas.org.

1. Actually I’m glossing over some interesting technicalities here, or at least putting them in a footnote so that non-ethics-nerds can skip over easily. There are three kinds of “lobbying entities” recognized by the MLO: individual lobbyists, lobbying firms, and lobbyist employers. Lobbying firms are companies that take money from third parties to lobby the City on behalf of their projects. On the other hand, lobbyist employers are firms that hire their own in-house lobbyists to lobby on behalf of their own projects. Some of these are companies that actually engage in business, like e.g. AirBnB is a lobbyist employer, as is Cisco Systems. But others don’t do much besides lobbying, like e.g. both the Hollywood Chamber of Commerce and the Los Angeles Chamber of Commerce are lobbyist employers. This means that they lobby the City but they don’t take money from clients to lobby. They just lobby on whatever they want to. All three of these kinds of things are collectively called “lobbying entities” in the MLO. The weird technicality is that LAMC §48.07(A) requires individual lobbyists and lobbying firms to register, but is silent with respect to lobbyist employers. They must actually be required to register, because they do register, and obviously they wouldn’t register without being required to, but I’ll be damned if I can figure out exactly why they’re required to register. My guess is that in the Charter or somewhere there’s a section allowing the Ethics Commission to make administrative rules based on the laws it’s responsible for, and there’s a rule requiring lobbyist employers to register, but I’m too lazy to check right now. Drop me a line or leave a comment if you know the answer to this conundrum.
2. The question in the previous footnote is a question here too. LAMC §48.07(F) requires amendments, but as far as I can see it applies only to individual lobbyists and lobbying firms, not to lobbyist employers. As the question is the same, I suppose that the answer will also turn out to be the same.
3. Qualifying is a technical thing as well, that’s far too involved for me to go into here. It’s roughly based on the definition of “lobbyist” found in LAMC §48.02 but for lobbying firms, and probably lobbyist employers as well, there are additional layers. It’s got to be a topic for another day, though, or I’m never going to finish this damn post.
4. Like a freaking blink comparator or something. Like discovering Pluto or standing silent on a peak in freaking Darien, but with a City Ethics Commission registration form! If I were more clever than I am I’d have written a script to animate the fading, but you’ll have to make do with the static image that appears somewhere near the sentence to which this footnote is appended.
5. That, my friends, is sarcasm. Lobbyists don’t really take oaths. They are, however, forbidden by LAMC §48.04(B) from lying about certain matters under certain circumstances.
6. Listen, though, if you work for Leron Gubler or, heck, if you ARE Leron Gubler and you just want to, you know, try being honest for just one time, see how it feels or whatever, why not try out our resources for whistleblowers and let us know in confidence what happened? Come on! What could it hurt, friends?
7. Not kidding, they actually want to rename East Hollywood to EaHo, which, as far as I can see, might as well stand for something like “ethnic antisepsis for Hollywood,” given their covert if not explicit dedication to running every last Latino out of the area.
8. Property-based BIDs are required by law to renew every five to ten years. This process is complex enough that they seem to universally hire consultants to assist them with it.
9. OK, it’s Tara Devine again and South Park, this time for renewal. South Park’s twisted little pipsqueak of an operations director, the infamous Katie Kiefer, is all lawyered up and not responding adequately to CPRA requests, so the complaint is on hold while the lawyers duke it out in the alley. Stay tuned for updates. Similarly with the freaking Palisades BID (and Urban Place again, this time for establishment rather than renewal). This one is complicated beyond human comprehension by the unearthly obstructionism of Laurie Sale, executive director and walking CPRA-dead-zone. Seriously, I often wonder if the unreasonable success of this woman’s blockheaded bloody-mindedness makes people like Rena Leddy, who tends to suffer in the short run for her dedicated attempts to actually comply with the law, long for a lobotomy. But it can only work for so long, friends, and all will turn up right in the end, for both me and for Rena Leddy, I imagine.