SUBJECT: CF 26-4118-S7: Park’s Last-Minute Submission Confirms Resolution Is Noncompliant
TO: cd10@lacity.org, Councilmember.Yaroslavsky@lacity.org, contactcd4@lacity.org, councilmember.soto-martinez@lacity.org, councilmember.hernandez@lacity.org, Councilmember.Blumenfield@lacity.org, councilmember.rodriguez@lacity.org, councilmember.harris-dawson@lacity.org, councilmember.nazarian@lacity.org, councilmember.mcosker@lacity.org, councilmember.park@lacity.org, Councilmember.Lee@lacity.org, councilmember.padilla@lacity.org, councilmember.price@lacity.org, councilmember.jurado@lacity.org
Dear Councilmembers,
Councilmember Park has now uploaded a last-minute “Findings” document to CF 26-4118-S7, apparently in response to concerns that the resolution lacks the specific documentation and findings required by LAMC § 41.18(c)(4). The new document does not cure those defects. Instead, it underscores them.
The submission claims to summarize LAPD and LAFD “statistics and data,” but contains no statistics or data. It provides no dates, incident numbers, records, counts, descriptions, or other documentation supporting its boilerplate references to “numerous emergency incidents” and “encampment fires.” Nearly identical language is repeated for all seven locations without establishing the particular and ongoing threat required at each one.
Community members who regularly observe these locations and conduct outreach to unhoused neighbors also dispute the submission’s basic factual claims.
At 204 Hampton, outreach volunteers report that no one has been maintaining an encampment on the designated side of the street. People have sometimes stayed across the street, but packed up their belongings every morning. St. Joseph Center security has reportedly prevented anyone from setting up a tent on the designated side and had the sidewalk power-washed daily.
Outreach volunteers likewise report that there has not been an encampment at 720 Rose Avenue. An encampment previously existed across the street, outside the Whole Foods parking lot, but it was cleared in 2024 and has not returned. Recent reporting by L.A. Material corroborates that account: Whole Foods hired Ghost Town Consultants in early 2024, and Ghost Town participated in preventing residents from returning following a March 2024 City cleanup. When the reporter recently visited, there were no tents around the Whole Foods perimeter.
This is directly at odds with the submission’s claim that “numerous individuals have consistently maintained an encampment at 720 Rose Ave” for the past year. The reporting places the former encampment across the street, documents its clearance before Councilmember Park’s stated May 2025 to May 2026 data period even began, and reports that the area remained clear during a recent visit.
If the submission’s basic claims are this inconsistent with readily observable conditions at the first locations community members have examined, Council cannot reasonably accept its remaining assertions on faith. The document provides no underlying records with which to verify any of them. These factual contradictions undermine the credibility of the entire submission and demonstrate exactly why § 41.18(c)(4) requires specific documentation rather than boilerplate representations from a council office.
The submission also applies the wrong legal standard. It repeatedly claims that sleeping “within 500 feet” of each address is “unsafe, unhealthy, or incompatible with safe passage.” That language and geographic framework come from subsection (c)(2), which governs overpasses, bridges, washes, railways, and similar infrastructure. This resolution invokes subsection (c)(4), which does not authorize a 500-foot exclusion zone. It requires Council to designate a particular section of street, sidewalk, or other public right-of-way based on specific documentation of a particular and ongoing threat. Neither the resolution nor the new submission identifies the section of public right-of-way being designated.
The timing is also telling. This last-minute submission is itself an acknowledgment that § 41.18(c)(4) requires documentation in the council file. A review of the City’s other (c)(4) council files shows that they were similarly adopted without the required supporting evidence. Although this submission still does not meet the ordinance’s “specific documentation” standard, its filing confirms the broader defect: the City has been adopting (c)(4) designations without satisfying a mandatory prerequisite imposed by the law. Those prior designations are therefore invalid, and Council should not add another invalid resolution to the list.
Please vote no on CF 26-4118-S7 and request a review of all existing § 41.18(c)(4) designations for compliance with the ordinance.
Thank you.
