Tag Archives: Property and Business Improvement District Law of 1994

Already Heavily Rent Burdened Los Angeles Tenants Struggle To Make Payments — While City Council Whines About Its Own Impotence — Refuses To Implement Meaningful Relief — Creates An Inadequate — Overly Complex — Litigation Inducing — Contemptuous — Half-Assed — Relief Program — That’s So Underfunded The Money Will Be Distributed By Lottery — Of All Damn Things — But When It Comes To Commercial Property Owners — Whose Properties Are Located In Business Improvement Districts — Who Therefore Owe Tax Payments To The City — The Situation Is Quite Different — Apparently Without Any Difficulty — Without Any Whining Or Idiotic Reports From Idiotic Deputy City Attorney David Michaelson — The City Is Allowing Them To Pay Late Without Penalty — Without Proving Anything — Without Litigation — Because They Love Zillionaires More Than They Love You And Me — And Because They’re Not Ashamed Of Their Own Hypocrisy

It’s well-known that the economic destruction wrought by the COVID-19 pandemic is putting already severely rent-burdened tenants at even greater risk of eviction and homelessness. Activists have been pleading with Los Angeles City officials for months now to find ways to mitigate this looming crisis while the officials spend their time whining about how they don’t have the power to solve the problem.

The very few measures the City has actually implemented are overly complex, slanted towards landlord interests, half-assed, and very likely to require court intervention as part of the process.1 Not only are the City’s putative solutions entirely insufficient to meet the looming need, but the City only allocated $100 million to the program, which is so inadequate an amount that the City is going to distribute it by lottery.

Our present situation highlights about as clearly as can be the complete contempt, or at least clueless indifference, with which City officials approach the needs of non-zillionaire angelenos. And it’s not just residential tenants that are economically endangered by the pandemic. It’s also been hell on retail businesses, who are also having possibly insurmountable problems covering the rent.

In turn this threatens the income of their zillionaire commercial-property-owning landlords, who are therefore worried about their ability to cover their own expenses, including mortgages and property taxes. But the City government of Los Angeles is neither contemptuous not cluelessly indifferent towards the interests of zillionaires, of course, and their lack of contempt is demonstrated clearly by their attitude toward business improvement district (“BID”) assessments in the City.

The City of Los Angeles has more than forty BIDs. These operations are funded by assessments paid by commercial property owners in the districts. The assessments are not voluntary. They appear on the owners’ county property tax bills and are subject to the same kinds of draconian collection measures used to enforce payment of any tax. But unlike ordinary property taxes, which are paid to and collectable by the County of Los Angeles, these BID assessments belong to the City.

Which I suppose gives City officials some power over how and when they’re collected, or at least that’s the only way I can make sense of a statement made by Dr. Kris Larson, executive director of the Hollywood Property Owners’ Alliance at their recent board meeting. Larson told his board that “while property owners are technically still on the hook to pay their assessments the City is not penalizing those that are late collected.”
Continue reading Already Heavily Rent Burdened Los Angeles Tenants Struggle To Make Payments — While City Council Whines About Its Own Impotence — Refuses To Implement Meaningful Relief — Creates An Inadequate — Overly Complex — Litigation Inducing — Contemptuous — Half-Assed — Relief Program — That’s So Underfunded The Money Will Be Distributed By Lottery — Of All Damn Things — But When It Comes To Commercial Property Owners — Whose Properties Are Located In Business Improvement Districts — Who Therefore Owe Tax Payments To The City — The Situation Is Quite Different — Apparently Without Any Difficulty — Without Any Whining Or Idiotic Reports From Idiotic Deputy City Attorney David Michaelson — The City Is Allowing Them To Pay Late Without Penalty — Without Proving Anything — Without Litigation — Because They Love Zillionaires More Than They Love You And Me — And Because They’re Not Ashamed Of Their Own Hypocrisy

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The City Of Los Angeles Shells Out More Than $2.2M Per Year To Business Improvement Districts — Add In Other Local Public Money — Like LAUSD — And Metro — And LA County — The Total Is More Than $3.7M Per Year To The BIDdies — Not Sure How Many People That Could Put In How Many Hotel Rooms For How Many Nights — But It’s A Lot — Not Sure How Many City Employee Furloughs That Money Could Prevent — But It’s A Lot More Than Zero Of Them — Remember That When They Tell You They Can’t Afford Something — They’re Choosing Not To Afford It

Spend some time hanging around business improvement districts and you’ll certainly hear a bunch of entitled zillionaires whining, bragging, or lying about how they voluntarily agree to spend their own damn money to provide services that the City of Los Angeles is too incompetent, too broke, or too both of these to provide. They just love explaining this to everyone. And the City of Los Angeles is also thrilled with that narrative. This City-produced BID FAQ explains it quite clearly:

[A] majority of business owners of commercial property owners in a given area decide to acquire special benefits and to pay for those benefits themselves.

The story serves everyone’s interests. The BIDdies get to imagine themselves as heroes of putative private sector efficiency and the City gets a bunch of useful idiots to carry out policies that would be incredibly illegal if the City did them directly. Everybody wins but the citizens of Los Angeles. The part you don’t hear too much about, though, the part that none of them really like to discuss, is that when property owned by the City or by other public agencies is included in a BID then the City or the other public agency is also subject to these assessments.

This is specifically authorized by the Property and Business Improvement District Law under which BIDs are established in California.1 This means that when the City Council approves a business improvement district it’s often also approving an ongoing annual payment to the BIDdies. Which, by the way, can be substantial. Over the last few days I looked at various public records involved in BID formation in LA and learned that the City of Los Angeles is on the hook for annual payments to BIDs of at least $2,278,604.2

If LAUSD, Metro, and the County are included the total is $3,710,281 and property owned by the State of California brings the total amount of public money paid annually to LA BIDs to $4,203,276.3 These days, with the City of Los Angeles furloughing employees and moaning about the price of hotel rooms to protect unhoused residents from the ongoing pandemic, there are much, much better uses that that money could be put to.4
Continue reading The City Of Los Angeles Shells Out More Than $2.2M Per Year To Business Improvement Districts — Add In Other Local Public Money — Like LAUSD — And Metro — And LA County — The Total Is More Than $3.7M Per Year To The BIDdies — Not Sure How Many People That Could Put In How Many Hotel Rooms For How Many Nights — But It’s A Lot — Not Sure How Many City Employee Furloughs That Money Could Prevent — But It’s A Lot More Than Zero Of Them — Remember That When They Tell You They Can’t Afford Something — They’re Choosing Not To Afford It

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The West Adams BID Formation Process Has Officially Begun — The Council File Is Opened — And The Draft Ordinance Of Intention Is Published — Largely Promoted By Supervillain Developers CIM Group — The Petitions Are In And Property Owners Holding 50.4% Of The Assessed Value Approve — The Management District Plan Proves That The BID’s Main Purpose Is To Support The Ongoing Tornado-Force Gentrification Of This Vulnerable Neighborhood — Almost Certainly This BID Can’t Be Stopped And Will Start Its Wicked Work On January 1, 2021

A business improvement district that has been in the works in rapidly gentrifying West Adams at least since the Summer of 2018 is finally moving forward and is very likely to be created by the City later this year and begin operations on January 1, 2021. The formation effort is largely backed by supervillainesque developer CIM group, which owns a huge plurality of the commercial property in the proposed district, slated to run along Adams from La Brea to Hauser.1 The formation materials are currently contained in Council File 20-0020.

Recall that a BID is a geographical area within which commercial property owners2 pay extra taxes3 to fund various services. The formal BID creation process begins with a group of property owners4 petitioning the City to allow a BID to be formed. It’s required by the Property and Business Improvement District Act of 1994, which is the authority under which BIDs are created and administered in California, that these petitions represent property owners “who will pay more than 50 percent of the assessments proposed to be levied”5

According to the report placed in the Council File by the City Clerk they received petitions representing $106,034.65 out of a total assessed value in the proposed district of $210,388.90, which is 50.4%. The report doesn’t say how many distinct owners signed petitions nor who they were, but I’m working on finding out. The next stage in the formal process is for City Council to pass a so-called Ordinance of Intention, the draft of which is available here.

Once this is passed the City Clerk will mail out ballots to all the property owners and if enough of them, again weighted by assessment amounts, vote in favor of the BID City Council will pass another ordinance creating the BID. Before this can happen the owners have to know what services their extra taxes are going to fund, which is laid out in great detail in the so-called Management District Plan.6 When a BID is created this document7 is incorporated into the law establishing it and then they can’t spend money for anything not enumerated in the plan. The proposed West Adams BID’s MDP is here.

The West Adams BID’s proposed activities are limited in the MDP to “Sidewalk Operations, District Identity and Placemaking, and Administration Services.” The MDP makes it very clear that the BID is being formed to support gentrification, though, stating that its “services would be needed to accommodate hundreds of new apartments and businesses opening in 2019 and 2020, and these services would be needed by the beginning of 2021.” The surprise omission here is funding for security guards. During the pre-formation process CIM Group’s support-building outreach focused to a great extent on property owners’ perceptions of safety in the area.
Continue reading The West Adams BID Formation Process Has Officially Begun — The Council File Is Opened — And The Draft Ordinance Of Intention Is Published — Largely Promoted By Supervillain Developers CIM Group — The Petitions Are In And Property Owners Holding 50.4% Of The Assessed Value Approve — The Management District Plan Proves That The BID’s Main Purpose Is To Support The Ongoing Tornado-Force Gentrification Of This Vulnerable Neighborhood — Almost Certainly This BID Can’t Be Stopped And Will Start Its Wicked Work On January 1, 2021

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Katherine McNenny And I Prevail Against Chinatown BID In Our California Public Records Act Lawsuit — George Yu Didn’t Participate At All — From Start To Finish No One From The BID Showed Up — Which Is Not Enough To Win This Kind Of Petition — We Still Had To Prove Our Case — Which We Did Of Course — But Yu’s Ostrichism Also Led The Judge To Deem That All Our Requests For Admission Were Admitted To — Which May Have Drastic Long-Term Consequences For The BID — Far Beyond Those Directly Associated With Our Victory — Its Very Existence May Be Threatened — Let’s Freaking Hope So, Eh?

As you probably know, last year Katherine McNenny and I were forced by the unhinged intransigent refusal of psychopathic rageball George Yu to comply with the California Public Records Act to file a lawsuit against his Chinatown Business Improvement District. For reasons known only to himself, George Yu not only refused to comply with the statute, he refused to participate in the lawsuit at all.

We were seeking a writ of mandate from the judge ordering Yu to hand over the documents. It turns out that, in California at least, courts are not allowed to issue such orders merely because the respondents don’t show up.1 It’s still required that the petitioners prove their case. Which, of course, we were able to do, because it was righteous. So last Wednesday, July 24, 2019, the trial was held, before which the judge issued a tentative ruling granting us our every wish.

The whole trial lasted about 30 seconds and consisted of the judge asking our lawyer if he wished to be heard on the tentative. He said that he did not. The judge adopted the tentative as final and told the lawyer we could have our notebook back. You can get a copy of the tentative ruling here and a copy of the minute order showing that it was adopted as final here.

There are a bunch more steps before everything’s done. We have to serve the final ruling on the BID, the judge has to sign the order, we have to file a motion to get paid, probably will have to file more stuff to enforce all that stuff. These wheels have been turning very slowly since August 2018 when we filed, and they continue to turn slowly, but they’re crushing everything in their path as they turn.
Continue reading Katherine McNenny And I Prevail Against Chinatown BID In Our California Public Records Act Lawsuit — George Yu Didn’t Participate At All — From Start To Finish No One From The BID Showed Up — Which Is Not Enough To Win This Kind Of Petition — We Still Had To Prove Our Case — Which We Did Of Course — But Yu’s Ostrichism Also Led The Judge To Deem That All Our Requests For Admission Were Admitted To — Which May Have Drastic Long-Term Consequences For The BID — Far Beyond Those Directly Associated With Our Victory — Its Very Existence May Be Threatened — Let’s Freaking Hope So, Eh?

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The South Park BID Solicited — Or Extorted — Donations Totalling $80,000 From Developers To Pay For Some Studies They Wanted Done — In Return The BID Sent Staffers To City Council Committee Meetings To Give Public Comment In Favor Of The Developers’ Projects — Using Talking Points Supplied By The Developers — Money Well Spent For The Developers I’m Guessing Since Councilmembers Probably Won’t Approve Projects BIDs Oppose — This Is One Way In Which The Illusion Of Community Buy-In Is Created And Maintained In Los Angeles — One Of The Developers Involved Was Lightstone Group — Whose Lobbyists Are Also Being Investigated In Relation To José Huizar — Because Of Course They Are

Here’s the short version. In 2017 the South Park BID wanted to lobby Metro concerning some transportation issues. To do this they needed some reports prepared by professionals who were going to charge them around $80,000. For whatever reason they didn’t want to pay out of the BID budget, so they hit up local developers for $5,000 contributions. In exchange the BID supported the developers’ various projects before City Council committees and commissions using talking points prepped by the developers to inform their public comments.

First, let’s talk about the two issues the BID was, and is, lobbying for. One is to establish an enhanced infrastructure financing district (EIFD)1 to fund transit improvements in the BID, in particular moving Pico Station underground.2 The BID’s “one pager”3 on the benefits to be gained from the EIFD can be read by clicking here and their presentation on “undergrounding” Pico Station is available here. The other issue has to do with improving connections between various presently disconnected-by-public-transit points Downtown. The BID’s presentation on that can be read here.

And of course before one goes a-lobbying one needs reports! Written by experts! And experts don’t come cheap, but they will provide proposals with estimates of the costs, and here are the two the BID obtained:

And based on these estimates, the South Park BID determined that it needed $80,000 to begin the report-making process. And for whatever reason, they also determined that they were only going to pay $5,000 themselves. The rest, saith the BID, they were going to raise from developers and maybe some other BIDs Downtown. And the story of this whole mess, told, as usual, in excruciating detail via transcriptions of emails, can be found after the break!
Continue reading The South Park BID Solicited — Or Extorted — Donations Totalling $80,000 From Developers To Pay For Some Studies They Wanted Done — In Return The BID Sent Staffers To City Council Committee Meetings To Give Public Comment In Favor Of The Developers’ Projects — Using Talking Points Supplied By The Developers — Money Well Spent For The Developers I’m Guessing Since Councilmembers Probably Won’t Approve Projects BIDs Oppose — This Is One Way In Which The Illusion Of Community Buy-In Is Created And Maintained In Los Angeles — One Of The Developers Involved Was Lightstone Group — Whose Lobbyists Are Also Being Investigated In Relation To José Huizar — Because Of Course They Are

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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

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

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How I Reported BID Engineer Ed Henning To The California Board For Professional Engineers For Incompetence, Negligence, Self-Plagiarism, And All-Round Not Doing His Damn Job

Here’s a quick summary of the background. BID formations are required by the Property and Business Improvement District Law of 1994 to be supported by a report prepared by a licensed engineer.1 Engineer Ed Henning wrote the report for the ill-born Venice Beach BID.2 The California Board for Professional Engineers regulates the engineering profession and can investigate allegations of incompetence or negligence. Ed Henning wrote the engineer’s report for the Venice Beach BID and did an awful, negligent, incompetent job of it.

A complaint was made against Henning but was rejected by the Board without being read because they claimed that writing BID reports didn’t constitute the practice of engineering. After a great deal of discussion with BPELSG executive officer Ric Moore, he agreed that in the future his office would not dismiss such complaints unread.

Well, given this assurance it seemed worthwhile to me to spend time writing another complaint against Henning, whose work is universally acknowledged to be ultra-shabby,3 And that’s just what I did! You can grab a copy of the whole thing right here on Archive.Org, and turn the page for selections and little bit of discussion!
Continue reading How I Reported BID Engineer Ed Henning To The California Board For Professional Engineers For Incompetence, Negligence, Self-Plagiarism, And All-Round Not Doing His Damn Job

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Open Rebellion In The Melrose BID! Duckworth On The Defensive!! Refuses To Give Board Email Addresses To Property Owners!!! Even Though He Already Gave Them To Me!!!! And Don’t Forget He And He Alone Got The Damn BID Sued!!!!! And For This They Are Paying Him $72,000 Per Year To Work 20 Hours Per Week???!?

Sadly, for he is one of the most satirogenic figures in all of BIDlandia, we have not heard much from pirate king Donald Duckworth around these parts lately except, of course, for the fact that he, complacently steeped in his outlaw ways, forced me to file a pair of writ petitions against two of his baby BIDs because he, complacently steeped in his unhinged arrogance, flat-out and unaccountably refuses to comply with his statutory obligations under the California Public Records Act1 even though, if the past is prologue,2 it’s very likely to cost his BIDs a lot of damn money that they can probably ill afford to waste.

But regardless of Cap’n Donald’s law-flouting noncompliance it is occasionally possible to obtain records, or at least emails, involving him by the simple expedient of getting them from the other side of the correspondence.3 And recently a friend of this blog got a small pile of emails between Mr. Don Duckworth and Los Angeles City Clerk staff, and you can read the whole set here on Archive.Org.4 And there’s pretty much interesting stuff in there, but tonight I’m focusing on just three items.

June 9, 2018 email from Don Duckworth to Laura Aflalo about record inspection — Melrose property owners Laura Aflalo and Richard Jebejian want to come inspect records. Don Duckworth says sure you can but why would you want to, isn’t it a waste of your time?

June 9, 2018 emails between Duckworth and Aflalo about her questions about BID operation — Like why do the BID bylaws violate the Brown Act? And why can’t she have the Board members’ email addresses? And why won’t Don Duckworth just answer the damn questions?!

June 9, 2018 Duckworth to Aflalo with a detailed breakdown of how he spends the BID’s money — It’s detailed and evasive at the same time, a Duckworthian superpower, evidently.

And turn the page for some commentary, some mockery, and some highly selected transcriptions of at least the first two items. The third is going to have to wait till another time because it’s getting late around here!
Continue reading Open Rebellion In The Melrose BID! Duckworth On The Defensive!! Refuses To Give Board Email Addresses To Property Owners!!! Even Though He Already Gave Them To Me!!!! And Don’t Forget He And He Alone Got The Damn BID Sued!!!!! And For This They Are Paying Him $72,000 Per Year To Work 20 Hours Per Week???!?

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Psychopathic Rageball George Yu Of The Chinatown BID Admits On Camera That He Broke The Law By Using BID Personnel To Preemptively Displace Homeless People Outside His BID Boundaries — Less Importantly Years Later He’s Still Whining About The Chinatown Walmart Fiasco As He Lambastes Outsiders From Alhambra For Daring To Have An Opinion — And In More Aggro Yu-ian Weirdness, Admonishes Public Commenters To Keep It Short And Cut The “Bullshit”

I’m sure you read about my big adventure yesterday when I went up north to film the Chinatown BID’s meeting and criminal ringleader George Yu got so salty that I wouldn’t tell him who I was that he flipped out to an extraordinary degree, screamed at me and then banned me for life from his weirdo fiefdom, the Far East Plaza.

But that’s not all that happened at the meeting. It turns out that George Yu is not merely a psychopathic rageball but he also runs his meetings like some kind of free association fest, like he’s on the couch and the audience is his analyst. And the most revealing, peculiar, unbelievable stuff came pouring forth from George Yu, self-betrayal oozing from his every pore, as they say.

So for instance, he admitted that he sent his BID crew to clean up something to do with homeless people at Sunset and Beaudry which, it seems, is not in his BID. Watch and listen here: You’ll see background photos on the screen. We worked with [unintelligible]. Yes, it’s at Sunset and Beaudry. No, it’s technically not Chinatown. But if those… If the [unintelligible] people there are staying at Sunset and Beaudry and then venture into Chinatown it’s a whole nother story. Our residents walk past this site daily. We couldn’t stand it. We cleaned it up.

Of course, it’s explicitly against state law for BIDs to spend money, which includes expending labor, on anything outside their boundaries. Just take a look at the Property and Business Improvement District Law 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 …1
Continue reading Psychopathic Rageball George Yu Of The Chinatown BID Admits On Camera That He Broke The Law By Using BID Personnel To Preemptively Displace Homeless People Outside His BID Boundaries — Less Importantly Years Later He’s Still Whining About The Chinatown Walmart Fiasco As He Lambastes Outsiders From Alhambra For Daring To Have An Opinion — And In More Aggro Yu-ian Weirdness, Admonishes Public Commenters To Keep It Short And Cut The “Bullshit”

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Rita Moreno Thinks The “Boundaries Of A BID Must Be Contiguous” — Misty Iwatsu Agrees!! — No! Wait! Rita Moreno Thinks “There’s No Legal Requirement That The Boundaries Be Contiguous”! — Whichever It Is, We Think That Rita Moreno (A) Is Practicing Law Without A License And Ought To Stop It Right Now Cause It’s Illegal And She’s Confusing Everybody And (B) Does Not Know What The Word “Contiguous” Means

OK, I’m sorry, this post is on kind of a technical subject, but I think it’s important and also it reveals a kind of weird off-handed incompetence amongst the City Clerk’s BID analyst staff that I think is worth memorializing. The central issue is whether the Property and Business Improvement District Act of 1994 requires a BID to be in one piece. I’m going to use the technical term “connected” here.1

It’s not just an idle question, either. You may recall that the proposed Hollywood Route 66 BID runs up Santa Monica Blvd. from Vine Street to Hoover Street. The problem is that Vermont Avenue crosses Santa Monica right in the middle of that stretch, and every building that touches Vermont is already included in the East Hollywood BID.

Regardless of what the PBID law has to say about connectedness of BIDs, it’s very, very clear on the fact that BIDs can’t overlap.2 Hence commercial buildings on both Santa Monica and Vermont must be excluded from the Hollywood Route 66 BID, which leaves its territory disconnected. Plausibly, also, the EHBID could cede those buildings to the Route 66 BID, but, interestingly, doing so would leave the EHBID disconnected, so nothing would be gained. Here’s a copy of the map if it’ll be useful.

Thus a correct understanding of what the law allows is essential for the formation of at least that BID, and probably others in the future. And I’m not a lawyer, but I read the whole damn PBID law about a zillion times and the connectivity of a BID is not mentioned in there at all. It’s my not-a-lawyer understanding that if a law doesn’t explicitly forbid something then that something is allowed.

But the famous Rita Moreno of the City Clerk’s Neighborhood and Business Improvement District division didn’t agree with me in 2017! Then she did agree with me in 2018! And Misty Iwatsu spent some time in 2016 babbling on about the matter and thought 2017 Rita Moreno was right! And Rita Moreno didn’t just think, she advised! And it strikes me that her advice looked an awful lot like practicing law without a license, which is illegal in California!3

And of course you want to see details! And primary sources! Turn the page and there they are!!
Continue reading Rita Moreno Thinks The “Boundaries Of A BID Must Be Contiguous” — Misty Iwatsu Agrees!! — No! Wait! Rita Moreno Thinks “There’s No Legal Requirement That The Boundaries Be Contiguous”! — Whichever It Is, We Think That Rita Moreno (A) Is Practicing Law Without A License And Ought To Stop It Right Now Cause It’s Illegal And She’s Confusing Everybody And (B) Does Not Know What The Word “Contiguous” Means

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