Tag Archives: Miguel Santiago

California State Government, Downtown Center BID

In September 2018 — After The Release Of That Damning UC Berkeley Law Report On Nefarious BID Activity — Suzanne Holley Of The Nefariously Active Downtown Center BID Got In Touch With Assemblymember Miguel Santiago’s Office — And Was All Like Obviously This Report Is Wrong — And Biased — And Stupid — And Puerile — And Delusional — But Nevertheless We Are Worried That Some Unhinged Legislator May Try To Enact Legislation Based On It — Therefore Can Your Boss Commit To Helping Us Avoid This Fate — And The Staff Of Miguel Santiago — Who Never Met A Zillionaire Whose Interests He Wouldn’t Bootlickingly Pander To — Was All Like “Sure BIDdies! We Will Protect You From Any Potential Legislation!”

June 28, 2019 Mike Leave a comment

Perhaps you recall that in 2018 a group of dedicated and accomplished students at the UC Berkeley Law School’s Policy Advocacy Clinic released a blockbuster report on the criminalization of homelessness by business improvement districts in California, a copy of which can be obtained here. You should definitely read this. It’s one of the indispensable texts of contemporary radical BIDdology.

One of the report’s major points is that it is probably illegal under existing state law for BIDs, which are publicly funded entities, to use those public funds for lobbying for anti-homeless legislation. And, the report goes on to say, if it’s not illegal now it certainly ought to be, so they call for legislation to regulate BIDs with respect to advocacy.

As you might expect from a report from an institution at the level of UC Berkeley, the arguments are powerful, convincing, and intensely well-supported by extensive evidence¹ and if our local BIDdies had or have any brains at all, or at least any of that sentience-independent primordial reptilian survival sense on which rich dumb mean people rely so heavily, the irrefutable arguments in this report would have, ought to have, made them extremely nervous.

Of course BIDs, like the zillionaires they serve, don’t look to arguments and their refutation to protect their survival, preferring instead to guard themselves with the weaponized raw political power that they’ve gathered around themselves like armor. And that this is an accurate picture is revealed by some recently obtained emails² between Suzanne Holley of the Downtown Center BID and the staff of Downtown Los Angeles Assemblymember Miguel Santiago.

The BIDdies were worried that legislators might actually take the report’s recommendations seriously and start trying to rein them in with laws, so they wrote to Santiago asking for protection from any potential legislation inspired by the report, even though none had yet been introduced. But irrespective of that Santiago, long-time asshole buddy of our Downtown BIDS³ or at least his staff, was all over that. Yes, they said, yes, yes, yes, BIDdies! We will save you from any future legislation!
Continue reading In September 2018 — After The Release Of That Damning UC Berkeley Law Report On Nefarious BID Activity — Suzanne Holley Of The Nefariously Active Downtown Center BID Got In Touch With Assemblymember Miguel Santiago’s Office — And Was All Like Obviously This Report Is Wrong — And Biased — And Stupid — And Puerile — And Delusional — But Nevertheless We Are Worried That Some Unhinged Legislator May Try To Enact Legislation Based On It — Therefore Can Your Boss Commit To Helping Us Avoid This Fate — And The Staff Of Miguel Santiago — Who Never Met A Zillionaire Whose Interests He Wouldn’t Bootlickingly Pander To — Was All Like “Sure BIDdies! We Will Protect You From Any Potential Legislation!” →

Business Improvement Districts, Public Records Act Pragmatics

Los Angeles Business Improvement Districts Held A Seminar In July 2018 To Talk About How To Deal With My Requests For Public Records — The World’s Angriest CPRA Lawyer Carol Humiston Was The Main Speaker — Gave A Bunch Of Bogus Feel-Good Advice That Evidently Didn’t Include Just Complying With The Law Since None Of Her Clients Will Do That — BIDs Reveal That They Want The Law Changed In Their Favor — May Hire A Lobbyist To Facilitate This — Miguel Santiago Is Helping Them Out Yet Again

February 7, 2019 Mike Leave a comment

Around the turn of the century, thanks to brave and successful litigation by property owner Aaron Epstein against the demonic forces of Ms. Kerry Morrison and her Hollywood Entertainment District BID, it is the supreme law of California that business improvement districts are subject to the California Public Records Act. It is this fact that, of course, has made possible the very existence of this blog.

Without actual copies of actual records, what credibility would we have? We would we be but yet another gang of basement-dwelling neckbeards ranting about injustice on the internet?¹ And the fact that their BIDs are subject to the CPRA drives the BIDdies absolutely wild with rage.

They just cannot understand how it is that every law on the books has been carefully crafted to allow zillionaires and their minions to curbstomp anyone who interferes with their interests, and yet this law seems to work against zillionairity by e.g. exposing them to public mockery and contempt.² They just cannot believe that the law says what it says. What, they seem to be muttering, have we been paying all those damn legislators for?

And so they have consistently ganged up to fight any improvement³ to the CPRA and to develop and utilize methods for evading their CPRA-imposed duties. We saw this recently when they hired a lobbyist to thwart, gut, and render meaningless AB-1479, Rob Bonta’s modest 2017 proposal to strengthen the CPRA by making it possible to actually sanction violations, a sinister project in which they were aided by the sleazy backroom machinations of would-be Huizar successor Miguel Santiago.

And newly obtained evidence shows that in July 2018 the BIDdies continued these CPRA-thwarting efforts by holding a seminar on my CPRA requests, convened by Rena Leddy, executive director of the Fashion District BID, currently being sued for egregious CPRA violations, keynoted by Carol Humiston, the world’s angriest CPRA lawyer, and attended by circa 35 BIDdie representatives, many of whom are also being sued for egregious CPRA violations, all there to discuss me and this blog and how not to follow the law!

In particular, the records, obtained, ironically, via the CPRA, include a powerpoint presentation given by Humiston and a set of notes taken by one of the attendees.⁴ The powerpoint thing is tedious nonsense, although it gains some interest from the fact that the South Park BID wouldn’t give me a copy, claiming attorney/client privilege, a stance that’s hard to maintain in the face of the fact that Humiston presented it to 35 people, many of them not her clients. Fortunately not every BID is so moronically mulish.

However, the set of notes is pure gold! It outlines Humiston’s strategies for delaying or obstructing access to records, including suggested bogus fees to impose, when to delete emails to thwart requesters, and so on. Most crucially, though, it reveals that the BIDs have at least discussed changing state law to relieve them from their CPRA duties and hiring a lobbyist to help them do so.

They have also, it states, talked to a legislator, who is obviously that nefarious little twerp Miguel Santiago, who has amplified their wickedness before. This is an essential glimpse into the red, bloody, seething ids of the zillionaire minions who run this City’s BIDs. Turn the page for excerpts, commentary, and finally a transcription of the entire document.
Continue reading Los Angeles Business Improvement Districts Held A Seminar In July 2018 To Talk About How To Deal With My Requests For Public Records — The World’s Angriest CPRA Lawyer Carol Humiston Was The Main Speaker — Gave A Bunch Of Bogus Feel-Good Advice That Evidently Didn’t Include Just Complying With The Law Since None Of Her Clients Will Do That — BIDs Reveal That They Want The Law Changed In Their Favor — May Hire A Lobbyist To Facilitate This — Miguel Santiago Is Helping Them Out Yet Again →

Business Improvement Districts, California State Government

Remember Those Underpass Homeless Encampments Outside The South Park BID Boundaries? — The BID Is Not Only Paying Staff To Photograph Them — Also They Are Paying Staff To Lobby Miguel Santiago’s Office To Get CalTrans And CHP To Clear Them Out — Why Is A Member Of The California State Assembly Ignoring The BID’s Lawless Behavior? — Probably For Money, Doncha Think? — Or Because — With The Recent Fall Of The House Of Huizar — Santiago Feels His Path To CD14 Is Wide Freaking Open

December 20, 2018 Mike Leave a comment

OK, remember how there are these underpasses with a bunch of homeless encampments in them that are not in the South Park BID but the BIDdies wanted to clean them up anyway except Ellen Riotto said they couldn’t cause it was against the law but then she sent her staffies out to gather photographic evidence of the encampments which is clearly also against the law? OK, this is another episode in that story!

And it’s worth taking a moment to review just why the BID can’t spend money on stuff going on outside its boundaries, never forgetting for a moment that dedicating staff time to a matter is spending money on it, which is to say the money paid the staff member. It’s all due to the Property and Business Improvement District Act at §36625(a)(6), which states unequivocally that:

The revenue from the levy of assessments within a district shall not be used to provide improvements, maintenance, or activities outside the district or for any purpose other than the purposes specified in the resolution of intention

Oh, also, keep in mind that the problem, from the BID’s point of view, with these underpasses is that the City of LA seems not to be allowed to evict homeless people from under them, evidently because it’s state property under there. Thus Caltrans and the Highway Patrol somehow have to do it, and the BID just doesn’t have the influence with them that they do with the City, I guess, which apparently makes it a separate and ongoing problem for the BID.

So the other day I received a big pile of emails from the Parkies comprising correspondence between them and any email address at ca.gov or its subdomains. You can gaze lovingly upon the whole steaming heap of them here on Archive.Org. And amongst these are email after email after email between South Park BID staff and staffers in the office of Assemblymember Miguel Santiago, in whose district the BID situates, having to do with those damn underpasses.

That is to say there is plenty of evidence in there of repeated violations of §36625(a)(6). But who does one complain to about it? We’ve already seen that the Los Angeles City Clerk, which putatively oversees our BIDs, will take complaints about insufficient brutality towards the homeless, but not, it seems, about violations of the law by the BIDs themselves. And it’s disconcerting to say the least to see an actual Assemblymember conspiring to violate the laws which he and his colleagues have sworn to defend.¹

Although I suppose it’s not surprising that Miguel Santiago would be involved in such a scheme, given his demonstrated proclivity for selling the best interests of the people of California down the river just cause some BIDs asked him to. As I’ve said many times, I wasn’t cynical at all before I started learning about BIDs, but the BIDdies have made me so. Turn the page, if you will, for as much of the chronology as I have, links to the emails, and a few select transcriptions.
Continue reading Remember Those Underpass Homeless Encampments Outside The South Park BID Boundaries? — The BID Is Not Only Paying Staff To Photograph Them — Also They Are Paying Staff To Lobby Miguel Santiago’s Office To Get CalTrans And CHP To Clear Them Out — Why Is A Member Of The California State Assembly Ignoring The BID’s Lawless Behavior? — Probably For Money, Doncha Think? — Or Because — With The Recent Fall Of The House Of Huizar — Santiago Feels His Path To CD14 Is Wide Freaking Open →

Business Improvement Districts

What Passes For Wit Among Zillionaires — South Park BID Board Members Paul Keller And Bob Buente Mockingly Refer To Downtown Homeless Encampments As “Bombay” And “Calcutta” — Super-Genius Paul Keller Proposes Illegally Using BID Staff Outside BID Borders To Clean Encampments — Has To Be Talked Down Off That Particular Ledge By BID Zeck Dreck Ellen Salome Riotto Who — Despite Her Devotion To Her Satanic DTLA Masters — At Least Has Some Goddamn Sense — Also Riotto Reveals Hitherto Unknown Illegal Downtown BID Anti-Homeless Intelligence Gathering Conspiracy

November 3, 2018 Mike Leave a comment

Last Thursday morning off I went to the concrete canyons of Downtown Los Angeles to sit through yet another interminable gathering of the Board of Directors of the South Park BID and, just for you, dear reader, I have posted video of the whole damn thing both here on YouTube and here on Archive.org. And it was mostly more of the same old bad BIDness, but without a quorum, so no action was taken.

There were a few interesting episodes though, and I’ll be writing about one or more of them soon enough, but the text for today’s sermon is this little hissy fit, pitched by none other than the finest legal mind of his generation, that is to say self-proclaimed schmuck Paul Keller, accompanied by the narcissistic back-up harmony vocal stylings of the BID’s own Uncle Fester,¹ which is to say Bob Freaking Buente. There is, of course, a transcription of the whole damn thing after the break, and juicy quotes interspersed throughout the article here.

Paul Keller wants to talk about … underpasses. The ones he drives under when he gets off the freeway in the morning. They’re filled with homeless people. Paul Keller doesn’t like this. Bob Buente reminds him that in zillionairese underpasses are referred to as “Bombay” and/or “Calcutta.”² What he really seems to hate about them is that (a) they are offensive to his finely honed zillionaire aesthetics and (b) he can’t ignore them because there’s a traffic signal there: “But unfortunately the light causes you to be in Bombay if it’s red.” The problem evidently is that CalTrans has jurisdiction over underpasses so the usual zillionaire methods of getting shit done, like e.g. giving José Huizar another 700 bucks, aren’t effective.

Turn the page to learn what the other problem is, how Ellen Salome Riotto schooled Paul Keller a little bit but he just won’t listen and wants her to break the law anyway, and the big reveal! All the Downtown BIDs are compiling anti-homeless intelligence which they’re evidently going to pass on to Miguel Santiago, possibly in anticipation of his becoming CD14 repster in 2020 because José Huizar’s rapey incontinence has effectively torpedoed the political ambitions of the other Huizar, his hand-picked successor, that is, of course, Richelle.
Continue reading What Passes For Wit Among Zillionaires — South Park BID Board Members Paul Keller And Bob Buente Mockingly Refer To Downtown Homeless Encampments As “Bombay” And “Calcutta” — Super-Genius Paul Keller Proposes Illegally Using BID Staff Outside BID Borders To Clean Encampments — Has To Be Talked Down Off That Particular Ledge By BID Zeck Dreck Ellen Salome Riotto Who — Despite Her Devotion To Her Satanic DTLA Masters — At Least Has Some Goddamn Sense — Also Riotto Reveals Hitherto Unknown Illegal Downtown BID Anti-Homeless Intelligence Gathering Conspiracy →

Homeless Issues

Miguel Santiago’s BID-Inspired Horror-Show Anti-Homeless Bill Is Dead For This Year — It Would Have Made It Far Easier To Intern Homeless People In Los Angeles County — Placed On Inactive File Yesterday As Legislature Adjourns For The Year

September 1, 2018 Mike Leave a comment

In January of this year Assemblymember Miguel Santiago introduced AB-1971, which was meant to expand the legal definition of a gravely disabled person essentially to allow at-will internment of homeless human beings. This pernicious nonsense was eagerly supported by Los Angeles City Councillors and their BIDdie co-conspirators. The bill met vigorous opposition from homeless people, their advocates, civil rights supporters, people who see how such a law could be weaponized against the elderly, and so on. A coalition of the sane, that is.

Last month, in a particularly cynical move, the bill was amended to only apply in Los Angeles County. However, even that concession to the opposition evidently wasn’t enough to save it. Yesterday, on the last day of the 2018 legislative session, the bill was placed on the inactive file. I don’t pretend to understand much about the arcane workings of the legislature, but it seems that this means it’s not dead, it could come back for further politicking next year, but that it’s not going to pass into law in 2018 and therefore will not take effect in 2019.¹

Of course the bill’s supporters presented it publicly as a compassionate measure to save homeless people who would otherwise die on the street. Regardless of their stated intentions, though, it’s clear that, if passed, this bill would have given police and BIDs a powerful tool for clearing homeless people off the streets and into carceral institutions, the better to effectuate their goal of cleansing the streets of Los Angeles of people who they see as no better than trash.

This perspective is supported by the lists of opposers and supporters, consisting of mostly governments, police, and Kerry Morrison’s wholly-controlled subsidiaries, which you will find after the break.
Continue reading Miguel Santiago’s BID-Inspired Horror-Show Anti-Homeless Bill Is Dead For This Year — It Would Have Made It Far Easier To Intern Homeless People In Los Angeles County — Placed On Inactive File Yesterday As Legislature Adjourns For The Year →

Street Vending

Ricardo Lara’s Street Vending Bill SB-946 Passed By Assembly — Now Back To Senate For Approval Of Amendments — Then On To The Governor’s Office

August 21, 2018 Mike Leave a comment

For background take a look at this fine article in the Times by Emily Alpert Reyes.

Ricardo Lara’s monumental street vending regulation bill, SB-946, was read in the Assembly for the third time yesterday and passed 56 to 17 on a straight party-line vote.¹ Because it was amended in the Assembly, notably here and here, it has to go back to the Senate for one more vote before heading to the Governor’s office.

The bill is universally opposed by Los Angeles BIDdies. Led by Carol Schatz of the Central City Association, they have been opposing it vigorously since its introduction in January 2018. Their overwrought terror of this bill is a natural consequence of their unhinged, years-long opposition to street vending in Los Angeles despite the essential role it plays in the social and cultural life of this City.

Surprisingly, the political juice of the BIDdies has availed them not in this particular struggle. We’ve seen how they’re able to reach out even all the way to Sacramento to kill off bills that threaten their plutocratic reign over almost every aspect of our daily life. But here, it’s not working. Even Miguel Freaking Santiago, their flunky in every possible situation, voted for SB-946.

A veto from Jerry Brown is their last hope. And maybe they’ll get it, who knows? You can bet what passes for good money in these latter days of the economy that they’re working on him right now. And if they manage to talk him around to their point of view, it’s the end of the matter, since our esteemed legislature is never ever going to override him. Anyway, I don’t know how long it’ll take for this to come up before the Senate, but you’ll hear about it here when it does!
Continue reading Ricardo Lara’s Street Vending Bill SB-946 Passed By Assembly — Now Back To Senate For Approval Of Amendments — Then On To The Governor’s Office →

Homeless Issues

Miguel Santiago’s BID-Inspired Bill Redefining Grave Disability Amended Yesterday To Expire In 2024, Apply Only In Los Angeles County — Revealing With Even More Clarity That This Is Nothing But Cynical Pandering To The Anti-Homeless, Anti-Human Zillionaires Of Los Angeles

July 4, 2018 Mike Leave a comment

You may recall that Assemblymember Miguel Santiago, a through-and-through creature of the BIDs of Downtown Los Angeles, has been pushing a bill, AB-1971, to redefine grave disability in California in order to allow cities to lock up homeless people on even more superficial pretexts than are currently available to them.

The prospect of this, of course, has BIDs all over the City messing their jeans in joy, and therefore has our esteemed councilbabies messing theirs at the thought of the copious contributions soon to swell their officeholder accounts.¹ So much did this unconstitutional jive mean to our Council that they memorialized their support in Council File 18-0002-S11 and also went about the place giving dog-whistle-filled speeches to their BIDdie constituencies.

But despite Santiago and the BIDs and the LA City Council dressing the proposal up as somehow related to compassion or other human emotions, it was pretty clear to everyone that it was nothing more than another tool to facilitate the detention and removal of homeless human beings from our streets. Thus did opposition begin to build, even to the point where, last week, the Los Angeles Times Editorial Board, in no way known for its leftie firebrandism, came out against the bill for precisely the right reasons:

… it’s odd that so much attention is devoted instead to making it easier for authorities to force mentally ill homeless people into involuntary treatment even if they are not an immediate danger to themselves or to others. Once we grab them — and remove them from whatever comfort or support structure they have managed to create — where do we put them? If we force them into hospitals for medical treatment they say they don’t want, then what?

Well, evidently the opposition grew strong enough that yesterday Miguel Santiago felt forced to amend his cynical creation. Amazingly, though, he didn’t change its substance, but only its scope. The new version, if adopted, would expire on January 1, 2024 and, most bizarrely, would apply only in Los Angeles County. Turn the page for some more commentary and a red-lined summary version of yesterday’s changes.
Continue reading Miguel Santiago’s BID-Inspired Bill Redefining Grave Disability Amended Yesterday To Expire In 2024, Apply Only In Los Angeles County — Revealing With Even More Clarity That This Is Nothing But Cynical Pandering To The Anti-Homeless, Anti-Human Zillionaires Of Los Angeles →

Street Vending

SB-946, Ricardo Lara’s Sanity In Street Vending Bill, Was Amended Yesterday In The Assembly To Allow Cities To Prohibit Vending Near Farmers’ Markets, Swap Meets, A Little More In Parks Than Before, And On Sidewalks Where There Is A Valid Temporary Use Permit — But Its Heart Is Intact And It’s Scheduled For The Assembly’s Local Government Committee On June 20

June 12, 2018 Mike Leave a comment

You probably recall that I’m tracking Ricardo Lara’s street vending regulation bill, SB-946. In short, the bill would prohibit local jurisdictions in California from regulating street vending except in a very minimal, sane way. Obviously this bill faces tons of exceedingly high-powered opposition from Los Angeles zillionaires.

For reasons known only to themselves and their 90210-based therapists, these powerful political players hate sidewalk vendors to the point where it seems acceptable to arrest them, chain them, confiscate and waste their wares and equipment, and so on. They compare them to drug dealers and prostitutes and are seemingly unable to comprehend the economic value brought to our City by these entrepreneurs, let alone the social value.

And it’s often the case that what makes the zillionaires unhappy makes the state legislature unhappy. These people have essentially endless political juice. We saw a heartbreaking example of this last year with the saintly Rob Bonta‘s AB-1479. This bill proposed much-needed improvements to the California Public Records Act and was curbstomped and gutted by our local zillionaires and their satanic minions with the assistance of slimy little BIDdie-boy Miguel Santiago, who will be running for Jose Huizar’s seat in 2020 and thus has every incentive to please the Downtown power elite at the expense of the human population of California.

So watching Lara’s essential bill make its way through the legislature since it was introduced at the end of January has been an anxiety-inducing process. It passed the Senate intact in early May and made its way to the Assembly. It’s been hovering around the edges of the Local Government Committee without any action until yesterday, when it was amended by Lara and put on the committee’s schedule for Wednesday, June 20.

And thankfully the amendments were exceedingly minimal. You can compare the new language here, and there’s a transcription after the break. All that happened, though, is that the current version will allow cities to prohibit vending near certified farmers’ markets, near permitted swap meets, in parks for a few new reasons, and on sidewalks with a valid temporary use permit. The most important facets of the bill are still blessedly intact, including the amnesty provisions. Fingers crossed for the 20th, friends! You can find your reps here and write to them about it.
Continue reading SB-946, Ricardo Lara’s Sanity In Street Vending Bill, Was Amended Yesterday In The Assembly To Allow Cities To Prohibit Vending Near Farmers’ Markets, Swap Meets, A Little More In Parks Than Before, And On Sidewalks Where There Is A Valid Temporary Use Permit — But Its Heart Is Intact And It’s Scheduled For The Assembly’s Local Government Committee On June 20 →

Fashion District BID, Los Angeles City Council

Video Of Fashion District BID May 24, 2018 Annual Meeting Now Available Featuring Special Guest Stars Miguel Santiago, José Huizar, And Bryan Eck — Introduced By Chunk-Headed Yobbo Zillionaire And Em Freaking Cee Mark Chatoff — The Crap These People Say When They Think They’re Surrounded By Friends Is — Well, Just Watch It If You Have The Stomach

May 24, 2018 Mike Leave a comment

Look, kids, I know you appreciate what I do to provide you all with the freshest possible news about our fair City’s business improvement districts, but I don’t think anyone who doesn’t go to meetings with me really truly understands the pain involved.¹ Or at least that’s how I felt after sixty freaking five minutes² of the Fashion District BID‘s annual stakeholder extravaganza this morning. But I made it out alive and now you can watch the whole thing on YouTube or here on Archive.Org if you prefer.

José Huizar was the headliner, but there was a surprise appearance by Assemblymember Miguel Santiago which was very revealing, and a long spiel from City planner Bryan Eck, which was too technical for me to follow, but I am sure is of great interest to those who’re interested in that stuff. Huizar’s talk was loaded with his usual weirdo revelations, and I’m going to have to wait till Saturday to write about it because I surely don’t have time right now.

Miguel Santiago had a lot to say about the legislature’s current BID-endorsed effort to gut protections against the abuse of conservatorship, which BIDdies all over the state are salivating over as it will make it so everybody with a uniform, up to and including parking enforcement officers, will be able to take homeless people into custody and lock them up somewhere far, far away from here, for e.g. smelling funny or scaring the nice shiny customers or whatever. Of course, the City Council is all over this issue as well.

He had the nerve to thank the freaking Fashion District BID for their “advocacy around the issue of homelessness..”³ He also mentioned offhandedly that, as part of last year’s BID-induced gutting of AB-1479, which would have amended the California Public Records Act in a number of excellent ways, the Fashion District BID had phoned his office for help and he had helped them. Which is despicable in any number of ways, although not surprising.

As I said, I don’t have time to do justice to most of this material tonight, but if you turn the page, you’ll find links to the various speakers and a transcription of Miguel Santiago’s reprehensible little spiel.
Continue reading Video Of Fashion District BID May 24, 2018 Annual Meeting Now Available Featuring Special Guest Stars Miguel Santiago, José Huizar, And Bryan Eck — Introduced By Chunk-Headed Yobbo Zillionaire And Em Freaking Cee Mark Chatoff — The Crap These People Say When They Think They’re Surrounded By Friends Is — Well, Just Watch It If You Have The Stomach →