Tag Archives: San Pedro Historic Waterfront BID

Business Improvement Districts, Municipal Ethics

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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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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Announcements, Business Improvement Districts

More Than A Gigabyte Of Emails Between The San Pedro BID, The Port Of Los Angeles, And Some Other Random Seeming Parties!

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This is just a short note to announce the availability of 1.3 GB of emails between the San Pedro BID and the Port of LA. Because the Port has a seat on the BID’s Board of Directors this request picked up a ton of intra-Board emails, which are fascinating. Here’s a link to the goodies on Archive.Org:

This is a rich, rich release, and you’ll be hearing about details of it for many posts to come. But for now, turn the page to read some inconsequential silliness about the nonsense in Board President Jonathan Williams’s mouth in the cartoon at the head of this post.
Continue reading More Than A Gigabyte Of Emails Between The San Pedro BID, The Port Of Los Angeles, And Some Other Random Seeming Parties! →

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Business Improvement Districts

Business Improvement Districts Are Not Small Businesses According To The Small Business Administration, So Why Did Executive Directrix Lorena Parker Swear Under Penalty Of Perjury That The San Pedro BID Meets The Criteria?

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So it seems that the Port of Los Angeles has something called a small business enterprise program, in which they “provide additional opportunities for small businesses to participate in professional service and construction contracts … in a manner that reflects the diversity of the City of Los Angeles.” (see this PDF for details).

And it also seems that the San Pedro BID contracts with the Port every summer to run trolleys around downtown San Pedro. And as part of the contract, the Port requires the BID to complete an Affadavit of Company Status. And part of the status is whether the contractor is a small business or not. As you can see from the PDF or from the image that appears somewhere near this sentence, the San Pedro BID1 claims to be a “Very Small Business Enterprise” (“VSBE”) which is an extra-small form of Small Business Enterprise (“SBE”).

Screenshot of the San Pedro BID’s contractor status affadavit showing their claim to be a “very small business enterprise.”
Of course, with all such programs it’s important to have clear definitions, and the Port of LA has laid theirs out for all to see in the cover sheet of this certification form, which all contractors are required to fill out and submit with a notarized signature under penalty of perjury. The relevant bit for our purposes is:

The Harbor Department defines a SBE as an independently owned and operated business that is not dominant in its field and meets criteria set forth by the Small Business Administration in Title 13, Code of Federal Regulations, Part 121.

Continue reading Business Improvement Districts Are Not Small Businesses According To The Small Business Administration, So Why Did Executive Directrix Lorena Parker Swear Under Penalty Of Perjury That The San Pedro BID Meets The Criteria? →

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Business Improvement Districts, Los Angeles City Government

In August 2016 Lorena Parker Of The San Pedro Historic Waterfront BID Interceded With Joe Buscaino’s Staff To Try To Fix Pending Criminal Charges Against Property Owners, Probably Including BID Board President Eric Eisenberg, Stemming From Ongoing Unsanitary Dumpster Conditions, Which Seems Not Only Unethical, But Also Like An Illegal Use Of Assessment Funds

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In July 2016, San Pedro Historic Waterfront BID executive directrix Lorena Parker contacted CD15 staffers Ryan Ferguson and Jacob Haik2 apparently in an attempt to have them fix pending citations and criminal charges against local property owners, possibly including BID board president Eric Eisenberg, stemming from sanitation violations involving dumpsters. You can read the details in this email chain (as always, there’s a transcription after the break).3 This episode quite possibly involves the dumpster next to the Cabrillo Hotel, the filthy state of which has been obsessively4 chronicled by Bruce Ecker at The Renaissance Dump website.

We here at MK.Org have discussed at length the much-violated requirement that business improvement districts only spend their money on activities that are approved by the City Council at the time the BIDs are established.5 These preapproved activities are enshrined in the so-called Management District Plan. The San Pedro BID’s MDP can be found here (Careful — huge PDF download). You can read it over and over again and you will find no mention whatsoever of paying Lorena Parker a salary so that she can try to get Joe Buscaino’s staff to try to make criminal charges go away.

And why would anyone think this is OK? Aside from the fact that having Lorena Parker act as a fixer isn’t listed in the MDP, there’s the simple fact that if people have criminal charges pending against them based on the unsanitary state of their dumpsters, they ought not to be seeking intercession to halt the proceedings. Instead, they ought to clean up their damn dumpsters. This is citizenship 101.6 And the elected officials of the City ought to be enforcing the City’s laws for the benefit of its citizens, rather than meeting with zillionaires in an attempt to subvert them.
Continue reading In August 2016 Lorena Parker Of The San Pedro Historic Waterfront BID Interceded With Joe Buscaino’s Staff To Try To Fix Pending Criminal Charges Against Property Owners, Probably Including BID Board President Eric Eisenberg, Stemming From Ongoing Unsanitary Dumpster Conditions, Which Seems Not Only Unethical, But Also Like An Illegal Use Of Assessment Funds →

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Business Improvement Districts, The Race Card

First The San Pedro BID Hated The Car Show. Then The San Pedro BID Loved The Car Show. Then The San Pedro BID Lobbied The City On The Car Show’s Behalf. But To Keep The BID’s Love The Car Show Had To Agree To Typically Coded Typically Racist Cultural Conditions: No Hip Hop. No Rap Music.

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Once upon a time in 2016 an organization called Hot Import Nights was going to host a car show in Downtown San Pedro. This would seem to be a natural fit, since San Pedro is nestled between such motorhead meccas as Torrance and Gardena and Carson and Long Beach, famed hot spots of both formal and informal Southern California car culture due not in small part to the feverish and innovative automotive, aerospace, and marine manufacturing activities centered in the subregion for more than a century at this point.

But if there’s a BID in the woodpile they’re going to have an opinion, either puritanical, stupid, or both, on any proposed activities within their jurisdiction, whether it’s any of their concern or not. And it’s well-known to those who know it well that Downtown San Pedro is cursed by being chronically subject to the tender mercies of the San Pedro Historic Waterfront BID. And thus it is no surprise that the BID weighed in on the car show. And it’s no surprise that they hated it. It’s exactly the kind of thing that knee-jerk puritanical real estate minions will hate.

But what is a surprise is that they changed their little minds and came to love it. They loved it so darn much that they signed an MOU with it and agreed to lobby the City on its behalf. But there’s no such thing as a free lunch and white supremacy will exact payment for any favors it bestows. In exchange for the BID’s aid and comfort, the car show had to agree not to play any rap music or hip hop at their event, and a bunch of other, as weird but possibly less racist, conditions as well.

This unreasoned, or at least publicly unreasoned, hatred for all things insufficiently caucasian, is for whatever reason, a signature element of BIDolatry in the City of Los Angeles. Over the years we’ve uncovered, e.g., the fact that the Hollywood Property Owners Alliance really, really hates Chicano-associated art genres as well as music that attracts dark-skinned patrons. The freaking HPOA even hates Peruvians if they seem like they’re getting too comfy in Hollywood.

These weird, crypto-racist attitudes are not just the province of our frenemies at the HPOA. They are evidently shared by BIDs all over the City. Thus it’s really no surprise to find that the San Pedro BIDdies are a bunch of cultural crypto-racists as well. But, as always, it’s still surprising, still disconcerting, to see the details figured plain as though upon a lighted screen. Turn the page for the story in detail with extensive documentation!
Continue reading First The San Pedro BID Hated The Car Show. Then The San Pedro BID Loved The Car Show. Then The San Pedro BID Lobbied The City On The Car Show’s Behalf. But To Keep The BID’s Love The Car Show Had To Agree To Typically Coded Typically Racist Cultural Conditions: No Hip Hop. No Rap Music. →

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Business Improvement Districts, Fashion District BID

Newly Obtained Documents Reveal That The Hollywood Media District BID Is Paying Urban Place Consulting $1,550.35 More Than The Fashion District BID Is Paying For Renewal Services Because UPC Is Billing Assistants At 20% More! Jeff Briggs Supplies Unredacted UPC Labor Matrix Without Requiring A Freaking Demand Letter! Aaron Aulenta Isn’t As Much Of A “Tech Dinosaur” As Previously Claimed!

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You may recall that as part of my long term project to turn as many BID consultants as possible in to the City Ethics Commission for unregistered lobbying, I’ve been trying to track down consulting contracts and other such evidence. I obtained a lot of excellent information from the San Pedro Historic Waterfront BID and, after a prolonged struggle, chronicled in excessive detail here, I obtained an unredacted copy of Urban Place Consulting’s contract with the Fashion District BID.

In the course of that whole mishegoss I had to overcome FDBID executive directrix Rena Leddy’s ultimately untenable position that the so-called “labor matrix,” a chart which detailed how much time UPC meant to spend on each aspect of the BID renewal process and how much they were to be paid for it,7 was a trade secret. Among the many cogent arguments we used8 was the evident fact that labor costs couldn’t possibly be trade secrets because UPC would of necessity have to share them with prospective clients before a contract was signed. This was a purely logical argument, but now, thanks to a huge trove of records shared with me this evening by the Media District BID and relating to their renewal process, also being handled by UPC, I have definitive proof.
Continue reading Newly Obtained Documents Reveal That The Hollywood Media District BID Is Paying Urban Place Consulting $1,550.35 More Than The Fashion District BID Is Paying For Renewal Services Because UPC Is Billing Assistants At 20% More! Jeff Briggs Supplies Unredacted UPC Labor Matrix Without Requiring A Freaking Demand Letter! Aaron Aulenta Isn’t As Much Of A “Tech Dinosaur” As Previously Claimed! →

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Business Improvement Districts, Municipal Ethics

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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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.9 They are also required to amend their registration forms if there are any material changes in the information provided.10

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 entity11 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.12 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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Fashion District BID, Public Records Act Pragmatics

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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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 them13 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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Business Improvement Districts, Municipal Ethics

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

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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.”14 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.15 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,16 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 lulz17 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 →

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Business Improvement Districts, Fashion District BID

Urban Place Consulting Charged Palisades BID 62% Less For Establishment Than They Are Charging Fashion District For Renewal, $21K vs. $55K. The Resulting Linear Model Suggests That Each Additional Parcel Adds Around $18 To The Price Of BID Consultancy, But Comparison With San Pedro Casts Some Doubt On Accuracy

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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.18 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.19

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 intransigence20 of PPBID ED Laurie Sale, which presumably they’ve already paid for, weren’t enough in itself.

In particular, because we already knew that Urban Place was charging the Fashion District $55,000 for renewal consulting and because it’s the first time we’ve known the rates that a single consultant is charging two different BIDs, it’s possible for the first time to attempt to model UPC’s fee structure. The gory details are available after the break, but the upshot it’s possible to estimate that UPC’s baseline fee for establishing/renewing an ideal BID with zero parcels in it is about $19,583 and that each additional parcel adds a little more than $18 to the cost of establishing/renewing the BID.
Continue reading Urban Place Consulting Charged Palisades BID 62% Less For Establishment Than They Are Charging Fashion District For Renewal, $21K vs. $55K. The Resulting Linear Model Suggests That Each Additional Parcel Adds Around $18 To The Price Of BID Consultancy, But Comparison With San Pedro Casts Some Doubt On Accuracy →

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