UCLA

I. PURPOSE & SCOPE

UCLA is committed to free speech as a fundamental feature of our democracy and a crucial dimension of UCLA’s institutional and academic culture. UCLA is also committed to enabling student organizations and other groups to host events on campus that supplement and enrich students’ educational experience.  Toward that end, UCLA makes certain facilities and outdoor areas available to student organizations and other groups for events with written permission, when all terms and conditions are met. However, such events can raise significant security concerns and interfere with other University functions and activities.  To protect the First Amendment rights of those who wish to participate in events hosted on University Property while safeguarding UCLA’s other vital interests, UCLA will enforce the rules as outlined in this Policy.

This Policy sets forth the conditions under which a Registered Campus Organization (RCO) or Non-Registered Campus Organization (Non-RCO), as defined below (Non-RCO) may be permitted to use University Property for extracurricular uses designated as a Major Event and outlines the procedures for requesting and approving a Major Event. This Policy is intended to support the ability of Event Organizers to host Major Events on University Property regardless of the viewpoints anticipated to be expressed during the event.

This Policy does not apply to events sponsored by a University Unit or for events held on grounds designated as being generally open to the public by the UCLA Regulations on Activities, Registered Campus Organizations & Use of Properties or any policy adopted to supersede those Regulations.  This means that this Policy does not apply to outdoor events without a gated or otherwise monitored entrance and exit.

This interim Policy will remain in effect from the effective date above until it is superseded by a final policy that has been approved in accordance with UCLA Policy 100, Administrative Policies and Procedures.

II. DEFINITIONS

For the purposes of this Policy:

Event Organizers are individuals or groups who sponsor or organize a Major Event. The Event Organizer can be either an RCO Event Organizer or a Non-RCO Event Organizer. A Major Event organized jointly by an RCO Event Organizer and a Non-RCO Event Organizer will be treated as an event organized by an RCO Event Organizer.

Guarantor is a University Unit that agrees to (a) be identified as a co-sponsor of the Major Event on publicity materials, (b) certify in writing to the Review and Oversight Entity that it approves the major event security assessment form when it is submitted, (c) send a representative to the Security Assessment Meeting and at least one meeting with the assigned University Advisor, (d) be responsible for all costs that the Non-RCO Event Organizer is required to pay the University under this Policy but fails to pay, and (e) be responsible for all contractual obligations to the University that the Non-RCO Event Organizer is required to satisfy but does not. 

Major Event is any planned gathering, including but not limited to celebrations, dances, lectures, forums, performances, rallies, social gatherings, concerts, speaker presentations, and conferences on University Property at which one or more of the following conditions apply:

1. Over 350 persons are anticipated to attend;
    
2. The Chancellor or the Chancellor’s designee determines based on the safety and security criteria (see section III.C) and the assessment of the UCLA Police Department (UCLAPD) (see section IV.A.4) that the event is likely to significantly affect campus safety and or significantly affect campus services (including kiosk guards, service roads, or parking);
    
3. The Chancellor or the Chancellor’s designee determines based on the interference criteria (see section III.C) that the event has a substantial likelihood of significantly interfering with other campus functions or activities; or
    
4. Over 50 persons are anticipated to attend and alcohol is intended to be served.

Non-Registered Campus Organization is an organization other than a University Unit that is not a Registered Campus Organization.

Registered Campus Organization is an organization that is registered through the UCLA Office of Student Organizations, Leadership & Engagement (SOLE).

Review and Oversight Entity is the entity responsible for reviewing and approving a requested Major Event. SOLE is the Review and Oversight Entity for Major Events organized by RCO Event Organizers and the Events Office is the Review and Oversight Entity for Major Events organized by Non-RCO Event Organizers.

Security Assessment Meeting is a meeting between the Event Organizer and UCLAPD, as well as any other necessary participants, to discuss security concerns and recommendations for the Major Event and options for addressing security needs, such a meeting is required if UCLAPD determines that the Major Event has substantial security needs.

University Advisor is the assigned advisor for a Major Event. The University Advisor for RCO Major Events is the SOLE advisor assigned to the RCO and the University Advisor for Non-RCO Major Events will be assigned by the Events Office.

University Property includes any University owned, operated, leased, or maintained property, including all of the buildings and grounds of the UCLA campus or any building or ground otherwise within the direction and control of UCLA. 

University Unit is any academic or nonacademic department or division or any other official University entity, including any official department, school, or institute of the University, the University Extension, or any officially recognized part thereof, or any authorized student government.  For avoidance of doubt, this definition includes the Center for the Art of Performance at UCLA (“CAP”) and the UCLA Alumni Association. 

Venue Scheduler is the UCLA department that schedules event locations and initiates the Events Online (EOL) Application for Event Organizers.

III. POLICY STATEMENT

This Policy operates in conjunction with other applicable University policies and facility regulations, including but not limited to UCLA Policy 860: Extracurricular Use of University Facilities and UCLA Regulations on Activities, Registered Campus Organizations & Use of Properties. In the event of a conflict between the provisions of another policy and this Policy, the provisions of this Policy will govern the use of University Property for Major Events.

The following provisions apply to Major Events on University Property:

A. UCLA will evaluate each proposed Major Event in a viewpoint-neutral manner.

B. Priority for the use of University Property will be given to academic and administrative departments of UCLA. The use of University Property is subject to availability and any existing facility operating policies, the impact on the UCLA campus and community environment, the ability of campus agencies to control traffic and security, applicable health and safety regulations, and related federal, state and local laws.

C. Any determination by the Chancellor or the Chancellor’s designee that an event constitutes a Major Event will be based on their assessment of audience size, provision of alcohol, and the factors detailed below regardless of the viewpoints anticipated to be expressed during the event:

Safety and Security Criteria. Permissible criteria to be used to determine whether an event is likely to significantly affect campus safety and security or significantly affects campus services are the following: (a) the proposed location of the event, (b) the estimated number of participants, (c) the time of the day that the event is to take place, (d) the date and day of the week of the event, (e) the proximity of the event to other activities or locations that may interfere, obstruct, or lessen the effectiveness of the security measures being implemented, (f) the resources needed to secure the event, (g) the anticipated weather conditions, (h) the estimated duration of the event, (i) any objective and credible evidence regarding actual threats to campus safety or security, and (j) any similar viewpoint- and content-neutral considerations relevant to assessment of campus safety, security, and services. 

Interference Criteria. Permissible criteria to be used to determine whether an event has a substantial likelihood of significantly interfering with other campus functions or activities are the following: (a) the proposed location of the event, (b) the estimated number of participants, (c) the time of the day the event is to take place, (d) the expected duration of the activity; (e) the activity’s timing in relation to the academic calendar (for example, proposed scheduling during the first week of classes or during final examination week);  (f) the expected noise level to be generated by the activity; (g) the need for and/or availability of University resources and personnel to facilitate, oversee or control the activity; and (h) any similar viewpoint- and content-neutral considerations relevant to assessment of potential disruption to campus functions or activities. 

D. Event Organizers are encouraged to consult with their assigned University Advisor at the earliest possible time if they have any questions whether their event may be classified as a Major Event.

E. For avoidance of doubt, a residential or day camp organized on the UCLA campus with the permission of a University Unit where the majority of attendees are 18 years old or younger will not be classified as a Major Event. Also for avoidance of doubt, an academic or professional conference organized through a University Unit will not be classified as a Major Event.

IV. PROCEDURES

All Event Organizers must follow the following procedures to request and host a Major Event:

A. Procedures for Requesting a Major Event

1. Summary of Procedural Requirements

1. comply with the specific requirements and scheduling procedures of the requested University Property;
    
2. complete and submit the event registration via the Events Online (EOL) Application preferably four weeks, but at least three weeks prior to the event; 
    
3. complete and submit a Major Event security assessment form at least three weeks prior to the event;
    
4. meet with the assigned University Advisor to review event details at least two weeks prior to the event, and at other intervals prior to the event, as requested by the University Advisor;
    
5. schedule a Security Assessment Meeting with UCLAPD no later than two weeks prior to the event,  if UCLAPD determines the event has substantial security needs;
    
6. designate a representative who is responsible for media relations at least two weeks prior to the event; 
    
7. submit proof of event insurance at least one week prior to the event;
    
8. require advance ticketing for entrance to the event; and
    
9. comply with all pre-event requirements as established in other applicable policies.

2. University Property Scheduling and Policies

In addition to obtaining the approval from the designated Review and Oversight Entity, all Event Organizers must comply with the specific requirements and scheduling procedures of the requested University Property. The policies and scheduling procedures for each specific University Property may vary. For information regarding programmable outdoor areas, Event Organizers may contact the Events Office. For direction to the appropriate department regarding the scheduling of indoor facilities, Event Organizers may contact their University Advisor.

Event Organizers may be charged fees for use of the venue in accordance with standard rate tables of the administrative bodies involved.  Event Organizers requiring special facility arrangements, equipment or staffing for their event may be charged fees in accordance with standard rate tables of the administrative bodies involved.  In such cases, deposits and financial accountability may be required (see UCLA Policy 860: Extracurricular Use of University Facilities).

3. Event Registration Form

At least three weeks, but preferably four weeks, prior to the Major Event, an Event Organizer must complete and submit an Events Online (EOL) Application. Because the EOL Application is sent to the Event Organizer by the Venue Scheduler after the Event Organizer has tentatively registered for a venue, the Event Organizer should identify and tentatively register for a venue  at the earliest possible time and in sufficient time to receive the EOL Application, complete it, and submit it within the timeframe noted above.  No registration for use of a venue is final until event arrangements have been approved under the terms of this Policy.

EOL is the University’s official system for registering all extracurricular activities including Major Events. The completed EOL Application will be automatically forwarded to SOLE for all RCO Major Events for review and approval. An RCO will be permitted to plan for a Major Event only if the RCO is in good standing with SOLE and has been registered by SOLE for at least one full academic quarter immediately preceding the event.

Non-RCO Event Organizers may plan a Major Event only when a University Unit agrees to serve as Guarantor for the event. Non-RCO Event Organizers must have a Guarantor complete and submit the EOL Application, which will then be automatically sent to the Events Office for review and approval.  In addition to the review and approval process, submitting the EOL Application also provides notice to applicable campus service providers and administrators who may be involved in planning for an event.  Submitting an EOL Application does not constitute approval of the use of the venue at the proposed date and time. 

4. Major Event Security Assessment Form

All Event Organizers must complete and submit a Major Event security assessment form following the instructions at least three weeks prior to the Major Event. Contact UCLAPD Special Events at 310-825-6543 or at SpecialEvents@ucpd.ucla.edu to request the Major Event security assessment form. Event Organizers are encouraged to submit the form at the earliest possible time. 

If UCLAPD determines the event has substantial security needs, the Event Organizer must schedule a Security Assessment Meeting with UCLAPD no later than two weeks prior to the event date. The meeting will include, as necessary, the following: the University Advisor or the University Advisor’s designee; the facility manager or designee; and one or more representatives from the Event Organizer (including, in the case of an RCO, at least one signatory). The representatives of the Event Organizer serving as first contacts will be made known to UCLAPD at this time and will be present at meetings and available for consultation throughout the event-planning period. UCLAPD will discuss security concerns and recommendations at the Security Assessment Meeting, and meeting participants will discuss options for addressing security needs that UCLAPD has identified.

The UCLAPD police chief or a designee may inform others, including but not limited to representatives from the UCLA Police Department, Los Angeles Police Department, Mayor’s office, City Council District Office, Westwood Village Improvement Association, and the Neighborhood Associations/Councils, or their designees, about the event.  UCLA Government and Community Relations may be included in these communications as a liaison to elected officials and/or surrounding community groups. The UCLAPD police chief or any member of this group may request additional meetings in advance of the event to discuss concerns.

5. Meet with the Assigned University Advisor

All Event Organizers must meet with the assigned University Advisor to review event details at least two weeks prior to the Major Event. The University Advisor will schedule an event coordination meeting with Event Organizers to exchange information about the event and discuss logistical expectations. The University Advisor may request an additional meeting to ensure that all instructions given to the Event Organizer (e.g., at the event coordination meeting) have been carried out.

6. Publicity Materials and Media

At least two weeks prior to the Major Event, all Event Organizers must designate to their University Advisor a representative who is responsible for media relations, so that UCLA Communications and Public Outreach knows with whom to coordinate regarding logistical matters involving media organizations. 

Any publicity materials for the Major Event must comply with UCLA Policy 110: Use of the University’s Names, Seals, and Trademarks. 

7. Event Insurance

In compliance with UC Business and Finance Bulletin BUS-63, all Event Organizers must submit proof of event insurance at least one week prior to the Major Event. Event Organizers are encouraged to apply for insurance coverage at the earliest possible time to allow for processing of their insurance application and for underwriting. Please note that submission of an application does not guarantee coverage.

RCO Event Organizers should follow the RCO Event Liability procedures to arrange for insurance through the approved University provider (at the time of Policy enactment, Mercer was the approved insurance carrier). If insurance through the approved University provider is not approved for the event by the insurance carrier, the event cannot proceed unless the Event Organizer is able to obtain identical insurance coverage to that provided through the approved University provider.

Non-RCO Event Organizers must submit to the Events Office a Certificate of Insurance naming “THE REGENTS OF THE UNIVERSITY OF CALIFORNIA” as an additional insured and including an additional insured endorsement with General Liability coverage defined by the UCLA Office of Risk Management, but not less than one million dollars ($1,000,000) per occurrence. The event cannot proceed unless the Certificate is provided to the Events Office at least one week prior to the event. If the Non-RCO Event Organizer does not have event insurance, the organizer may purchase coverage by going to http://ucla.campusconnexionsuc.com/Constituency/Other-Constituents. Depending on the risks associated with the event, Non-RCO Event Organizers may be required to provide higher amounts of general liability coverage, additional types of insurance, or both.

8. Advance Ticketing

Advance ticketing is required for all Major Events.  Advance ticketing for all Major Events organized by Non-RCO Event Organizers and all Major Events organized by RCO Event Organizers where tickets will be sold to attendees must be conducted by utilizing the UCLA Central Ticket Office (CTO). Advance ticketing for events organized by RCO Event Organizers where tickets are complimentary to attendees may be conducted by the RCO Event Organizer through the CTO or an online vendor approved by the CTO.

An official college-, university- or state-issued identification is required for ticket pickup at the event.  The number of tickets held, reserved, sold, and/or issued cannot exceed the event capacity. No standby line will be allowed and no standby tickets may be created or offered. For Major Events where UCLAPD has determined as part of the security assessment described below that the event has substantial security needs, all event tickets issued must be generated by the CTO or its designee and have a unique identifier that can be electronically validated to ensure authenticity of the ticket. For more information about the ticketing process, contact CTO at 310-825-2101 or cto@tickets.ucla.edu.

9. Pre-Event Requirements

Event Organizers must comply with all pre-event requirements as established in other policies administered by SOLE, the Events Office, UCLAPD, Insurance and Risk Management, Registrar’s Office, and the facility manager. A variety of permits and/or waivers may be required, for example, to distribute food or drinks or to film the event. The designated Review and Oversight Entity is responsible for determining whether an Event Organizer has complied with all relevant policies and obtained the necessary permits and/or waivers.

B. Event Regulations and Approval

1. Security Assessment

UCLAPD will conduct a security assessment based on information provided on the Major Event security assessment form and other information UCLAPD may obtain.

UCLAPD will assess security needs using the safety and security criteria (see section III.C) based on objective and credible evidence of specific risks. 

UCLAPD will make security recommendations that, in UCLAPD’s professional judgment, will address security threats identified as a result of the evaluation conducted pursuant to the paragraph above.  The goals of UCLAPD’s security recommendations will be to:

1. Minimize risks to the health and safety of the event participants and audience;
    
2. Minimize risks to the campus and surrounding community;
    
3. Support the ability of the Event Organizers to successfully hold the event; and
    
4. Respect the exercise of rights of free expression by the Event Organizer, participants, and the    community, including lawful protestors.

Recommended security measures may include adjusting the venue, date, and/or time of the event; providing additional law enforcement; imposing controls or security checkpoints; requiring increased ticketing measures as described above; and creating buffer zones around the venue.

2. Approval by SOLE or the Events Office

Each proposed Major Event must be approved by the designated Review and Oversight Entity.  The designated Review and Oversight Entity will base its review and approval on the Event Organizer’s compliance with this Policy. The designated Review and Oversight Entity’s determination regarding the time, place, and manner of the proposed Major Event will depend on UCLAPD’s security assessment and recommendations described in the preceding section as well as the interference criteria and the safety and security criteria (see section III.C).

The designated Review and Oversight Entity will endeavor to approve the date; time; venue; estimated number of guests; parking; provision of alcohol (if any); special facility arrangements, equipment, or staffing; security measures; fees; and any other like restrictions of Major Events within two weeks of the Event Organizer’s submission of the applicable event registration form and Major Event security assessment form, assuming all other procedures within the stated timeline have been met. Major Events may not proceed unless and until all such details have been expressly approved in writing (email notification will suffice) by the designated Review and Oversight Entity.

3. New Information or Changing Circumstances

If UCLAPD or the designated Review and Oversight Entity determines that, because of new information it has received or changing circumstances, its assessment must be modified, it will schedule additional meetings or communications with Event Organizers and other appropriate stakeholders to discuss its revised recommendations.

4. Appeal Process

Should the Event Organizer not agree with UCLAPD or the designated Review and Oversight Entity on the implementation of security measures or approvals required under this Policy, the Event Organizer may submit a written appeal to the appeals officer. The appeals officer is an individual designated by the Chancellor who was not involved in the planning, review, or implementation of this Policy with respect to the Major Event at issue and has the authority to make a final determination.

The appeals officer may decide, without owing any deference to the Review and Oversight Entity’s decision (i.e. de novo),  whether the restrictions imposed, security measures adopted, and/or costs imposed are viewpoint-neutral and, if appropriate, content-neutral. On all other issues, the appeals officer will review for abuse of discretion based on the safety and security criteria and/or the interference criteria. 

The appeals officer will provide the Event Organizer, the designated Review and Oversight Entity, the Office of the Administrative Vice Chancellor, and the Office of the Vice Chancellor for Student Affairs, with a written explanation of the reasons for his or her final decision.

5. Termination of a Major Event

If during an event an imminent threat to safety or property arises, avoidance or minimization of which requires termination of the event, authority to terminate the event rests with the senior civilian administrator designated to oversee law enforcement operations that is present and available. If no such person is present or available, authority is delegated to the highest-ranking UCLAPD officer or UCLA Fire Marshall at the event.

6. Security Costs

RCO Event Organizers will not be charged by UCLA for security costs deemed necessary by UCLA to ensure safety and security in connection with a Major Event. This includes any costs incurred to provide UCLAPD personnel, any costs incurred to employ private security personnel, and any costs incurred to supply police or security equipment. This also includes any costs incurred to respond to potential disturbances or protests in connection with the event.

However, the University reserves the right to charge to the RCO Event Organizer “house costs,” which are not security costs, as identified in Attachment A. In addition, if an RCO Event Organizer or speaker requests further security beyond what UCLA determines is needed, UCLA will not pay the costs for such further security.

A Non-RCO Event Organizer will be charged based on standard recharge rates for any security costs associated with their Major Event, except that UCLA will pay for security costs attributable to potential disturbances or protests in connection with any such event. In addition, in order to properly balance UCLA’s interest in making its venues available with the need for fiscal responsibility and other important educational and public service priorities of the University, UCLA will not spend more than $100,000 per academic year on security costs for Major Events hosted by Non-RCO Event Organizers. Once the $100,000 cap has been reached, no Major Events organized by Non-RCO Event Organizers will be permitted for the remainder of the academic year, except that any Major Event hosted by a Non-RCO Event Organizer that is already scheduled and approved pursuant to this Policy will be permitted to proceed and UCLA will pay for security costs attributable to potential disturbances or protests in connection with such event notwithstanding the cap.

V. REFERENCES

1. UCLA Policy 860: Extracurricular Use of University Facilities;
    
2. UCLA Regulations on Activities, Registered Campus Organizations & Use of Properties;
    
3. UCLA Student Organizations, Leadership & Engagement (SOLE) Policies.

VI. ATTACHMENTS