[co-author: Vicky Tavitian, Principal Planner]

The City of Los Angeles’s Planning Department is proposing an expansion to the City’s innovative adaptive reuse policies. Specifically, the City is proposing to amend Sections 12.03, 12.22 A.26, 12.24 X and 16.05 of the Los Angeles Municipal Code (LAMC) and Adaptive Reuse Incentive Areas Specific Plan (Ordinance No. 175,038) in an attempt to reshape the Los Angeles cityscape from 2023 to 2025 by converting vacant commercial spaces into dwelling units, guest rooms or joint living and work quarters (“Citywide Adaptive Reuse Ordinance[1]”). The amendment is intended to facilitate the reuse of existing buildings to address the City’s housing crisis and revitalize Downtown Los Angeles. The conversion of vacant office space will provide a sustainable response to urban development challenges and impacts of the COVID pandemic on the real estate market.

The Historic Significance of Adaptive Reuse

“Adaptive Reuse” is an established concept in Los Angeles, stemming from the 1999 Adaptive Reuse Ordinance (“ARO”). This initiative triggered the transformation of over 12,000 units in Downtown Los Angeles, turning older, economically distressed, and historically significant buildings into vibrant live/work spaces and visitor-serving facilities.

The Citywide Adaptive Reuse Ordinance is an extension on the prior version, broadening the ARO’s reach from the greater Downtown area to the entire City. This approach is a critical component of the Citywide Housing Incentive Program, designed to meet state Housing Element obligations and address the pressing housing needs of Los Angeles.

Unpacking the Proposed Citywide Adaptive Reuse Ordinance

The draft Citywide Adaptive Reuse Ordinance sets out to accomplish several key goals:

1. Broadening the Scope: Unlike its predecessor, which was focused on Downtown Los Angeles, the new expanded Citywide Adaptive Reuse Ordinance aims to extend adaptive reuse incentives across the entire City, in any commercial zone, parking zone, public facilities zone, or on any lot in the RD1.5 Zone or less restrictive residential zones. The Citywide Adaptive Reuse Ordinance is likely to be implemented through one or more zoning code amendments over a 2-year period (2023-2025).
2. Pandemic Recovery: The Citywide Adaptive Reuse Ordinance attempts to respond to the impact of the COIVD pandemic on retail and office spaces, enabling their transformation into dwelling units or hotel guest rooms without altering the existing building’s volume and envelope.
3. Expanding Incentives & Eligibility: The Citywide Adaptive Reuse Ordinance expands existing incentives to encourage the conversion of underutilized buildings into housing, guest rooms or joint living and work quarters. This includes the attempt to simplify the conversion process for structures that are at least 15 years old, by making the approval process by-right – essentially only requiring Department of Building and Safety review. Buildings between 5 and 15 years old or projects requesting additional relief from development standards will need approval from a Zoning Administrator through a Conditional Use Permit. The Citywide Adaptive Reuse Ordinance reduces minimum unit size requirements, exempts mezzanines and loft spaces from maximum floor area calculations, exempts dwelling units, guest rooms or living and work quarters from density requirements of the underlying zone, eliminates off-street parking requirements and exempts conversion projects from having to provide open space and landscaping. The menu of incentives adaptive reuse projects would be entitled to are set forth in Paragraph (g) (Incentives) of the draft Citywide Adaptive Reuse Ordinance.
4. Protecting Historic Resources: The Citywide Adaptive Reuse Ordinance ensures that buildings identified as “Eligible Historic Resources” must follow the Secretary of Interior’s Standards (“Secretary’s Standards”) for rehabilitation. Currently, all exterior work on an eligible historic resource is subject to review by the City’s Office of Historic Resources (“OHR”) for compliance with the Secretary’s Standards. Administrative review by the Planning Department and OHR would be required for any Eligible Historic Resource participating in the Adaptive Reuse Incentive Program. However, adaptive reuse projects that are Eligible Historic Resources could utilize the more flexible California Historic Building Code as far as structural review, seismic retrofit and building-code compliance is concerned, supporting the preservation of the City’s heritage, while unburdening such projects from having to comply with more rigid City building codes during their conversion process.

Proposed Permit Process

In short, the Citywide Adaptive Reuse Ordinance offers 2 paths to project approval dependent upon on the age of the structure subject to conversion and the incentives being requested. The City has also released a Fact Sheet regarding this initiative, which can be found here.

Currently, applicants looking for guidance through the adaptive reuse process can utilize the Department of Building and Safety’s Guidelines on Obtaining Permits for Adaptive Reuse Projects.

Engaging the Community and Future Developments

The City Planning Department is currently seeking public feedback on the draft Citywide Adaptive Reuse Ordinance. Future public hearings will also help gather input and insight from residents and stakeholders, offering a collaborative approach to shaping this transformative proposal. Stay tuned for more updates on this exciting development.

[1] LAMC references to the Citywide Adaptive Reuse Ordinance are still in draft form and have not been finalized or adopted.