Major Issues of Concern

After analyzing the Project as proposed in the DEIR, BHA came to the following conclusion:

Any objectives of the proposed Project for this educational institution, together with any possible Overriding Considerations, are grossly outweighed by the significant and unavoidable environmental impacts on the surrounding residential community, including impacts relating to the circulation system, intersection congestion, air quality, noise, and neighborhood intrusion. The DEIR fails to include substantial evidence that would support a different conclusion.

Among the issues identified by BHA in the DEIR are the following:

  • The Project descriptions fails to provide the required information and analysis of the true nature of the Project, which is a facility for events benefiting external groups not affiliated with the University.
  • The DEIR fails to capture the full range of potential traffic or to offer effective mitigations.
  • The DEIR misstates the allowed maximum enrollment, and then fails to provide a traffic analysis based on its claimed enrollment number.
  • Alternative 4 (“Reduced Event Alternative”) is insufficient to mitigate the traffic impacts generated by the Project.
  • The DEIR fails to validate the parking demand for events or to demonstrate that the amount of parking on campus is adequate during construction or when the project is operational.
  • The DEIR is inadequate because it attempts to address only the Project Site, yet it is impossible to separate the development of the Project Site from its impact on the overall operations of the School.
  • The DEIR is inadequate because it incorporates many unauthorized uses of the campus as if they were approved and then tries to expand them.
  • The issuance of the FEIR must be deferred until it can incorporate the results of the Department of City Planning compliance with the Los Angeles City Council directives in the Motion relative to evacuation routes in Very High Fire Hazard Severity Zones (“Motion”) adopted by unanimous vote on November 10, 2020 (Council File No. 20-1213).

The FEIR responds to all comments submitted to the DEIR (you can read them here).  BHA will review these responses and the new proposed project of Alternative 5 to see if our concerns have been adequately addressed.  BHA will be submitting a letter of issues with the FEIR and with Alternative 5 and will attend the hearing July 14. It is important that you take the survey in order for BHA to be able to represent your views.