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27 February 2026

Citywide Adaptive Reuse: A Potential Solution To Vacancy And Housing

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Greenberg Glusker Fields Claman & Machtinger

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As 2026 unfolds, Los Angeles is confronting two significant challenges. According to a Greater Los Angeles Office Report by Cushman & Wakefield, office vacancy is towering...
United States Real Estate and Construction
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As 2026 unfolds, Los Angeles is confronting two significant challenges. According to a Greater Los Angeles Office Report by Cushman & Wakefield, office vacancy is towering at 23%, with roughly 50 million square feet of direct and sublet office space sitting empty. Moreover, the city struggles with a severe housing shortage and increasing pressure to meet state housing production mandates. A single policy shift may now offer a way to address both challenges at once.

Effective February 1, 2026, Los Angeles adopted the Citywide Adaptive Reuse Ordinance, giving the green light for large-scale conversion of non-residential buildings into multifamily housing units. For the business community, including owners, lenders, developers, and investors, the new ordinance presents an opportunity to derive value from outdated or unused office, retail, and hotel space by converting it into new residential projects that can compete in today's market and add much-needed housing to the city.

Adaptive reuse is not a foreign concept to Los Angeles. In fact, in 1999, the city enacted its original Adaptive Reuse Ordinance, focused primarily on the downtown area. With zoning incentives and a more streamlined approval process, the ordinance allowed more than 12,000 units to be constructed, as office and retail buildings were converted into lofts, apartments, and mixed-use developments. Later, in 2002, the city expanded those incentives to select neighborhoods, including Hollywood and Chinatown, through the Adaptive Reuse Incentive Areas Specific Plan.

The new Citywide Adaptive Reuse Ordinance builds on that foundation in several important ways.

First, building eligibility is expanded. Under the prior framework, qualifying buildings had to be constructed before 1974. The new ordinance allows buildings that are at least fifteen years old at the time of permit application and construction to convert to residential use. Buildings between five and fifteen years old remain eligible, subject to approval from a Zoning Administrator through a Conditional Use Permit. Even parking structures at least five years old and hotels with fewer than 300 units may be given new life under the new ordinance.

Second, geographic limitations have been eliminated. The Adaptive Reuse Areas Specific Plan, which confined adaptive reuse to designated areas such as downtown, Hollywood, Koreatown, and Chinatown, was repealed concurrently with the new ordinance. Thus, adaptive reuse is now permitted citywide, allowing conversion projects in areas that were previously excluded under the program.

Third, the entitlement process has been further streamlined. Eligible buildings that are at least fifteen years old, and parking structures at least five years old, are entitled to a building permit as of right now as long as they comply with applicable requirements under the ordinance. Buildings five to fifteen years old may be approved by the Director of Planning under an administrative review process. These procedural shifts reduce uncertainty in project approval and shorten project timelines, addressing some obstacles that have historically complicated adaptive reuse projects and made them more difficult to finance.

Finally, the ordinance creates new incentives. Adaptive reuse projects are exempt from any minimum unit size zoning requirements. Existing floor area and building height may be retained, even if they exceed current zoning standards. Parking requirements are locked in at existing levels, and surplus parking can be converted into units or amenities. Developers are also permitted to introduce interior courtyards, light wells, and mezzanines without incurring new floor area penalties.

Together, these changes represent a notable shift in Los Angeles land use policy. With office occupancy unlikely to return to pre-pandemic levels in the near future, the Citywide Adaptive Reuse Ordinance may provide a practical path forward in addressing the housing crisis while simultaneously allowing owners and investors to unlock value in assets that are no longer needed for their original functions.

This article was originally published by the Los Angeles Business Journal.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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