A business improvement district (BID) in Los Angeles1 is a geographical area in which the owners of commercial property are assessed an additional fee for various services that aren’t provided by the City. These fees are collected either by the City of L.A. via direct billing2 or, more usually, by the County of Los Angeles as an add-on to property tax bills.
The state law authorizing BIDs requires each BID to be administered by a property owners’ association (POA).3 In the normal course of things these organizations are conjured up by the City at the time the BID is established, although sometimes previously existing nonprofits will end up as a POA. One example of this is the Hollywood Chamber of Commerce, which serves as POA for the East Hollywood BID, although it predates its existence.
This chain of emails from December 2015 reveals that the Pacific Palisades Business Improvement District paid Urban Place Consulting $21,000 for guiding the establishment process and an additional $4,000 to the consulting engineer.5 This is yet another piece of the BID consultancy puzzle that I’ve been trying to decipher since it became clear that almost certainly BID consulting qualified as lobbying under the Municipal Lobbying Ordinance and that almost all of the qualified consultants were breaking the law by not being registered with the City Ethics Commission like, e.g., Tara Devine.6
And this small piece of evidence is especially valuable given the fact that by now it’s essentially impossible to coax records out of the Palisades BID. They’ve even hired a lawyer specifically to thwart my requests, as if the bred-in-the-bone intransigence7 of PPBID ED Laurie Sale, which presumably they’ve already paid for, weren’t enough in itself.
Larry Kosmont handled the Gateway to LA BID’s 2014-5 renewal and was, very properly, registered as a lobbyist while doing so.You may recall that the Los Angeles Municipal Lobbying Ordinance requires qualified lobbyists to register with the City Ethics Commission and also disclose a bunch of interesting information about their clients and their income. Also, the process of establishing or renewing a BID is fairly complex, and most property owners’ associations8 hire a consultant to guide them through the process. These consultants are regulated and recommended by the City Clerk’s office.
The process of getting a BID established or renewed, it turns out, looks an awful lot like the definition of lobbying activity to be found at LAMC §48.02, which is essentially preparing information and discussing it with City officials as part of influencing the passage of municipal legislation. The law requires anyone who’s paid for thirty or more hours of this over three consecutive months to register as a lobbyist, and it’s generally extremely hard to prove that someone’s met this criterion. You may, e.g., recall that earlier this year, in order to make a reasonably convincing case that Venice Beach BID consultant Tara Devine had passed this threshold, I spent months piecing together more than a hundred pages of evidence regarding her BID consultancy work.
But recently it’s occurred to me that these consultants have contracts with the BIDs they service, and that at least in the case of BID renewals, the contracts will be accessible via the Public Records Act.9 The contracts will contain some information about how much time the consultants spend on the project, and thus should be useful as evidence in reporting consultants to the Ethics Commission for lobbying without a license.
Here’s a brief summary of the background: 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.12 Since then I’ve been tracking the progress of this massive project via various CPRA requests. In November 2016 the Police Commission informed all BIDs of the registration requirement. In December 2017 the Police Commission told the BIDs to quit whining and comply with the law.
Meanwhile, the latest piece of evidence in the ongoing saga of the registration of BID Patrols with the Police Commission comes from a huge release of emails by the Fashion District BID13 These span the time from July 1, 2016 through January 31, 2017 and are mostly between BID staff and the City of Los Angeles.14
There is an awful lot to write about here, but today I just want to highlight this interesting December 2016 email from FDBID operations director Randall Tampa to Eugene Shin, who’s the Police Commission investigator who’s handling the registration project. Randall Tampa sees the bigger picture here. It’s not a loss for BIDs who want to be free of any kind of oversight by the City, but a win for higher quality governance for everyone in Los Angeles:
I totally agree and support the police commission (and you) in your efforts to assure that only qualified personnel are patrolling the streets of Los Angeles.
In his email, Randall Tampa explicitly relates this opinion to his own experience as a police officer, proving yet again that people with experience in matters usually are much saner and have much more robust insights into how to regulate them. Most of the BIDs in our fair City are run by a bunch of cop-loving wannabes15 who are essentially see City governance as some kind of bizarre role-playing game, like Zillionaires versus Homeless, or whatever, rather than as an arena where wisdom and experience are far more essential than zillionaire-itude.
When last we peeked into the Minutes of the Board of Directors of the Pacific Palisades BID, we learned that they were all sitting around up there in Northwest Zillionaireville quaking in their super-pricy boots over the influx of gang members from urban Santa Monica. Today, well, there’s the serious matter of street vending to discuss, of course, but first, take a look at the minutes from January 4, 2017, where we learn about this:
Homeless issue – One person is a problem on Via de la Paz lately. He is a 300 lb., male black man with a nasty temper. Officer Moore recommends signing a “Trespass Arrest Authorization” form which was handed out.
Got it? He weights three hundred pounds.16 He’s black. And not only that, he is both male and a man. This is a truly frightening situation! I’m wondering if their trespass authorization form has a place to put the weight of trespassers that the cops are authorized to arrest? The standard form does not, but the LAPD is famous for deploying multiple helicopters to fly against the homeless in the Palisades. Are they going to refuse them a custom anti-homeless trespass form? Especially if they’re being overrun by a horde of three hundred distinct pounds of angry homeless black male man?
I mean, I know you can never be too rich or too thin, but that the Palisadesians are extra-scared of this man because “he is a 300 lb., male black man…” is somewhat unexpected, even though 300 lb. people can certainly “pose to be dangerous.” I would have thought that fear of the homeless would be measured more by the individual than by the pound, but I’m wrong again. Certainly this is why I can’t afford to live in the Palisades amongst the jittery little psychopathic self-interested zillionaire theorists of homelessness. My priorities are obviously really confused.
Another Rick in the wall, part 97: Rick Lemmo, who is Rick Caruso’s senior VP for some kind of nonsensical crap, explains the zillionaire’s view of law-abiding high finance.For a brief moment this morning, I was worried that it’s a bad thing that my coverage of the Pacific Palisades BID, initiated mainly because of a confluence of my interest in CD11 and the fact that the criminal intransigence of Mike Bonin’s staff has made it essentially impossible for me to get records directly from them, is tending fairly unexpectedly towards the navel-gaze, self-reference, point-is-to-understand-the-world, nerdview rather than towards the outward-looking, the-point-is-to-change-it focus which is somewhat of an ideal around here. That anxiety took me about 35 seconds to get over, so we’re going meta again this morning sans apologia.18
In any case, whatever her manifold faults as a CPRA client may be, Laurie Sale, executive directrix of the Palisades BID, is at least a reliable source of minutes and agendas. You may recall that she was previously kind enough to send me the PPBID’s 2016 minutes and agendas, and this weekend she sent me the 2017 minutes and agendas through February. There’s some interesting stuff in there, primarily about street vending, which I will write on quite soon. The minutes also suggest that CD11 field deputy Sharon Shapiro19 is an actual member of the PPBID’s Board of Directors. I’ll be looking into this, not least because it’s reminiscent of Debbie Dyner Harris’s ill-fated attempt to nab a voting seat for CD11 on the Board of the Venice Beach Property Owners Association, which was slapped down ignominiously by City Attorney Mike Feuer as a conflict of interest.
But never mind that for now. The text for today’s sermon is this little slab of nonsense, found in the BID’s minutes for February 1, 2017:
BID received requests for public records – copies of meeting minutes, agenda, emails back and forth within the City, etc. from a gentleman who is requesting this from many BIDs. Elliot made a motion to retain attorney not to exceed $4,000. Rick seconded, all approved, motion carried. In the event that this person wants copies made, then we need to request payment. Rick motioned: “we don’t want to make it difficult for him, but to rather provide him every access to public records according to the strictest rules of law so that it doesn’t provide any financial detriment to the property owners of our business improvement district.” Susan seconded. Unanimously approved, motion carries.
Laurie Sale is a sympathetic character, no doubt, but if we start letting our personal feelings towards people stand in the way of enforcing the law then anarchy will follow as surely as the night follows the day, so we’re not gonna do that! Plus even sympathetic characters, if they’re lawless, can still pose to be dangerous!Here’s the short version of this post: Laurie Sale of the Palisades BID has been telling me for months that she is too busy to work on my CPRA requests. Yesterday she turns out to be too busy to send copies of emails in a reasonable format. She continues to be too busy to provide an estimated date of production even though CPRA requires it. She keeps telling me she only works half-time. BIDs sign a contract with the City which requires them to maintain staffing adequate for the completion of required work in a timely manner. CPRA compliance is required work. Being too busy to do it is not doing it in a timely manner. Too busy for CPRA, BIDs?? Breach of freaking contract!!
And here is a quick recap of how we got to this place. About 80% of the staff of this website grew up in Venice, so we all got really interested in the Venice Beach BID. Unfortunately, CD11 staffie Chad Molnar took offense at the use I made of the fruits of a couple CPRA requests and stopped complying with the law altogether, forcing me to turn him in to the City Ethics Commission. That’s going to take forever to resolve, though.
Thus thwarted in my attempts to learn about the inner workings of Mike Bonin’s weirdo little empire directly, I have turned to requesting materials of all the BIDs in his district, which are Westchester Town Center, Brentwood Village, Gateway to LA, and last, but never ever least, the Pacific Palisades BID,20 which was explicitly called out by Mike Bonin himself on the floor of the Council Chambers as one of the good BIDs. I have received some material from these halfwits-by-the-sea, which provided raw material for our most popular post in the month of January, but mostly their executive directrix, Laurie Sale, keeps telling me that she’s too damned busy to send stuff in a timely manner.
And finally, yesterday, she condescended to transmit a bunch of emails to me by forwarding them, with her own typed annotations prepended. I had asked for them in native format,21 and providing them in native format is required by CPRA.22 It’s important to get emails this way because it preserves the integrity of the headers and also it ensures that attachments arrive in precisely their native formats as well.23 I habitually request emails in native formats and most BIDs have figured out how to comply with this requirement. So I told Laurie Sale that her forwarded emails weren’t acceptable and could she please figure out how to send them in the right format. I can tell from her headers that she uses Outlook, so I sent her a link to Microsoft Support which explains how to export emails to a PST file. It’s not hard.
You probably thought that this place was nothing more than a colony of self-satisfied zillionaires and their floofly little dogs, just strolling around on the bluffs in their $1,400 Jimmy Choos, but it turns out that it’s a seething urban hell, generating crime wave after crime wave in the Palisades. Build that wall, Mr. Bonin!OK, remember after the Venice Beach BID was approved for the second time and Mike Bonin gave a meandering, semi-sensical, victory speech, pronouncing definitively that he
…acknowledge[d] that there have been issues and problems with BIDs in other areas. But there have also been BIDs that have been very successful and have been great partners in solving homelessness. In Pacific Palisades we have a BID that has actually worked with the Pacific Palisades Task Force on Homelessness and has helped get people housed.
Combine this statement, just begging to be fact-checked, with the fact that Mike Bonin’s weirdo staff is engaged in a criminal conspiracy to violate the California Public Records Act, thereby bringing the legally authorized investigations of brave citizen journalists into the shady shenanigans of CD11 to a grinding halt, and how could I resist asking Mike Bonin’s darling Pacific Palisades BID for a bunch of public records?
Well, last night, PPBID executive directrix Laurie Sale, in addition to coming at me all salty with a bunch of copypasta lawyerese about how she wasn’t handing over anything unless God and the FBI told her she had to,24 also provided me with a year’s worth of agendas and minutes from her according-to-Mike-Bonin-exemplary little BID out there to the northwest of reality in zillionaireville. Of course I put it up on Archive.Org immediately. And there’s some fine craziness in there, friends. Greetings homeless neighbors! On behalf of the Palisades BID I would like to announce that we are from the LAPD and we are here to help the old amongst you, especially those whose health has deteriorated!
First of all, with respect to the homeless population of the Palisades, which according to Mike Bonin this BID’s handling of is a pattern of enlightened BIDolatry, take a look here at the Minutes from February 3, 2016, where we read, in the words of Laurie Sale her own self, that:
Older homeless are receptive to services as their health deteriorates. On the enforcement front, Michael Moore will be here soon to attest to the fact that they’ve gotten a lot more support from LAPD. Have provided more air support and foot support and they’ve mapped out all of the encampments. The signage has helped and allowed them to go in and get people off of the bluffs. Currently have a count of approximately eighty (80) homeless in the area but no market [sic] increase.
A business improvement district (BID) in Los Angeles1 is a geographical area in which the owners of commercial property are assessed an additional fee for various services that aren’t provided by the City. These fees are collected either by the City of L.A. via direct billing2 or, more usually, by the County of Los Angeles as an add-on to property tax bills. 
