Save Westwood Village A B u s i n e s s - C o m m u n i t y A l l i a n c e D e d i c a t e d t o Q u a li t y R e v i t a l i z a t io n
explanation as required by CEQA and also UC BUS-55 Section IV.A.8.d: “Prices, rates or fees currently charged in the off-campus community for comparable goods and services such as those planned for the new project.” UCLA has failed to disclose “any past failure to meet net revenue assessments or other debt repayment schedules on time” (UC BUS-55, Section IV.A.8.g). The Westchester Bluff’s project was sold at a considerable loss. The Colina Glen Townhouses have had severe financial problems. UCLA has failed to disclose “Any atypical assumptions used in the financial feasibility analysis and explanation for their application....” (UC BUS-55, Section IV.A.8.f). Save Westwood Village has submitted extensive analysis by an independent expert, HVS, that the project is not economically feasible. Furthermore, the Regents have refused to vote on this project and requested more analysis and information. In the absence of this information, the DEIR is premature. UCLA has failed to “disclose “any non-University use of space that will occupy a portion of the project (e.g., retail, restaurant or any other third-party use that may not qualify for tax-exempt interest treatment)” (UC BUS-55, Section IV.A.8.h). Page 1-5 of the DEIR arbitrarily rejects scoping comments requesting analysis of the socioeconomic impacts of this project as they impact the local economy of Westwood, causing urban decay and indirect physical impacts on the environment (more vacant storefronts, businesses closing, more homeless persons congregating in Westwood). 1.
UCLA has failed to uphold its duty to prevent environmental damage when feasible alternatives exist and thus violates CEQA Section 15021 (see discussion of Alternatives later). Also, CEQA Section 15021(b) makes it clear that this analysis is required: “In deciding whether changes in a project are feasible, an agency may consider specific economic, environmental, legal, social, and technological factors.” The list of economic issues rejected on DEIR page 1-5 must be analyzed in order to determine if changes in the project are economically feasible. Thus a new DEIR is required to be prepared that provides this analysis and then it must be recirculated.
2.
No basis for occupancy assumption. There is no evidence in the record that suggests demand for academic conference facilities will make up 66% of the room nights for the Luskin Hotel. Based on our research this is an unreasonably high number that throws into question the Project’s financial feasibility. Page 5 of 40