How to Get a By-Right Adaptive Reuse Permit from LADBS (No CUP Required)

Most Adaptive Reuse Projects in Los Angeles, including eligible Downtown office-to-residential conversions, can apply directly to the Los Angeles Department of Building and Safety (LADBS) for a building permit without going through a discretionary hearing at LA City Planning. This “by-right” path is the intended default under both the Citywide Adaptive Reuse Ordinance and the 9.4.5/9.4.6 framework, the entire point of these ordinances was to remove Zoning Code barriers that used to force adaptive reuse projects through a Conditional Use Permit process. Whether you qualify for this path depends on three things: building age, historic status, and whether the project is a standalone conversion or a Unified project combining new construction.

What “By-Right” Means Here

The Two Triggers for Administrative Review

Two categories of projects step out of the pure by-right lane into Administrative Review (ADM) by LA City Planning, even though ADM is not treated as a discretionary approval for CEQA purposes (unless the building is determined to be a historical property):

1. Surveyed Historic Resources, buildings assessed as eligible for historic designation through SurveyLA, or listed in HistoricPlacesLA, the city’s historic resources inventory. These applicants are encouraged to schedule a preliminary consultation with the Office of Historic Resources early in the design process.
2. Unified Adaptive Reuse Projects with affordable housing, projects combining an existing building with new construction that include an affordable housing component, in exchange for unlimited density in the new-construction portion or up to two additional residential floors above the existing building.

ADM adds a review step and a referral process but is generally faster than a full Conditional Use Permit hearing.

When You Need a Class 1 or Class 3 Conditional Use Permit

A Conditional Use Permit (CUP) is the most involved path, reserved for:

• Buildings at least 5 but less than 15 years old
• Designated Historic Resources or buildings within a Historic Preservation Overlay Zone (HPOZ)
• Projects requesting incentives or exceptions not included in the adaptive reuse ordinance itself
• Unified Adaptive Reuse projects that do not include an affordable housing component
• Adaptive Reuse projects in Manufacturing Zones within a legacy Adaptive Reuse Subarea

Class 1 CUPs follow the procedures in Section 13B.2.1 of the new Zoning Code, decided by a Zoning Administrator. A Class 3 CUP, following Section 13B.2.3, applies specifically when a non-residential building is being converted to a hotel within an Adaptive Reuse Subarea boundary, worth flagging separately since it’s easy to assume all reuse conversions follow the same CUP class.

Step-by-Step Application Process

• Confirm eligibility and approval track using the checklist in our eligibility guide, this determines whether you go straight to LADBS or route through City Planning first.
• Historic and Unified-project screening, resolve SurveyLA/HistoricPlacesLA status and confirm whether the project involves new construction before finalizing design.
• If by-right: prepare construction documents and submit directly to LADBS for plan check.
• If ADM is triggered: submit the Citywide ARO Administrative Review and Referral Form to LA City Planning, along with required documentation; expect referral to other city departments (including the Office of Historic Resources, if applicable) before clearance to proceed to LADBS.
• If a CUP is triggered: file the case with LA City Planning, complete public notice and hearing requirements before a Zoning Administrator, and obtain a determination letter before applying to LADBS.
• LADBS plan check and permit issuance, applies to all tracks once zoning clearance is obtained; includes standard Building Code, Fire Code, and accessibility review.
• Construction and inspections through to Certificate of Occupancy.

Typical Timeline and Fees

Timelines vary widely by track and project complexity, and LADBS/City Planning fee schedules are updated periodically, always confirm current fees through LADBS’s fee estimator and LA City Planning’s published fee schedule before budgeting. As a general pattern:

• By-right projects move fastest, since plan check is the primary gating step rather than a discretionary hearing.
• ADM projects add a referral and review period on top of plan check, typically measured in weeks rather than months if documentation is complete.
• CUP projects add the most time, since public notice periods and hearing scheduling are required before a determination is issued.

FAQ

Do I need City Planning approval before I can apply for a building permit?

Only if your project triggers Administrative Review or a Conditional Use Permit. Most eligible by-right projects go straight to LADBS.

What is Administrative Review and how is it different from a Conditional Use Permit?

ADM is a staff-level review process, not a discretionary hearing, and is not treated as discretionary for CEQA purposes unless the building is historic. A CUP requires a public hearing and a determination from a Zoning Administrator.

Does a historic building automatically disqualify a project from adaptive reuse?

No. It shifts the project into Administrative Review (if merely a Surveyed Historic Resource) or a Class 1 CUP (if formally designated or in an HPOZ), rather than disqualifying it outright.

Related reading: Historic Resources and HPOZ Rules for Adaptive Reuse Conversions → ·

Adaptive Reuse Timeline: From Feasibility Study to Certificate of Occupancy →

Fees, timelines, and procedural requirements change periodically. Confirm current figures with LADBS and LA City Planning before budgeting a project.

Back to Office-to-Residential Conversion in Downtown LA: The Complete Feasibility Guide →