The Los Angeles City Council is considering a proposal to eliminate substantial remodels as a reason for no-fault terminations, currently allowed under the California Tenant Protection Act (AB 1482).

These provisions permit landlords to relocate tenants to complete essential upgrades that improve safety and habitability — repairs that cannot be made while tenants remain in the units.

The proposal, presented to the Housing & Homelessness Committee on Oct. 16, 2024, would remove the substantial remodel clause from the city’s “just cause” eviction ordinance. If passed, landlords would need to use the Tenant Habitability Plan (THP) and “primary renovation” program, which requires tenants to be temporarily relocated through the duration of the renovation, continue paying rent and retain tenancy after the remodel.

This proposal has raised concerns from the California Apartment Association, particularly given that 62% of Los Angeles’ housing stock was built before 1970 and needs significant upgrades. Without substantial remodel provisions as outlined in AB 1482, landlords would be limited to the city’s complex Primary Renovation Program.

The Primary Renovation Program involves a two-step process. Landlords must first apply for the THP, overseen by the Code Enforcement Division, before beginning work. Once renovations are completed, they can apply for cost recovery through the Rent Stabilization Division. This process is criticized for its complexity and costs, leading to limited use by landlords.

In a letter to the Housing & Homelessness Committee, CAA highlighted concerns about the Primary Renovation Program and reported delays in processing applications for “just and reasonable” rent increases under the Rent Stabilization Ordinance (RSO), which complicates funding for necessary upgrades.

CAA also requested the department’s forthcoming report include key data: the number of applications filed for substantial remodels, Primary Renovation Program applications and completions, “just and reasonable” rent increases, pending applications, and average processing times. The committee agreed to include these data points in its report.

“Eliminating the substantial remodel provisions, a key aspect of the Tenant Protection Act, without fully understanding the efficacy of the existing processes for RSO properties would be premature,” the letter states. CAA urged the committee to assess the effectiveness of current programs before implementing changes that could hinder efforts to upgrade Los Angeles’ aging housing stock.

CAA continues to engage with city officials to ensure housing providers can maintain and improve their properties without facing unnecessary regulatory barriers.