Part 1: Navigating Change of Use in Los Angeles

What is Change of Use Permitting?

Are you looking for a warehouse that you can turn into a fitness studio? Or maybe you’re hoping to build a restaurant in a retail space that was previously a bespoke clothing shop? In either case, it’s likely that you’ll need to apply for a Change of Use Permit. Tracking change of use is an important part of maintaining dynamic and diverse neighborhoods, especially in a dense urban environment like Los Angeles. This process can be daunting, but with a partner like Letter Four, Inc. engaged in your project early, the load can feel much lighter. We can help to determine whether a Change of Use Permit will be a necessary piece of the puzzle in your upcoming project — a critical first step to finding the ideal space for your business and to ensure as smooth of a permitting process as possible.

To change the use of a commercial space that falls within LA’s city limits, extensive investigation and reporting must be conducted. Some of these investigations can include environmental impact reports, building code compliance research, permissions from local planning authorities, inspections, and more. Even though change of use permitting can take time and involves a complex process, it’s very possible with Letter Four, Inc. in your corner. We have completed many projects that were only made possible after clearing the change of use permitting hurdle.

We encourage businesses to understand basic zoning regulations and whether your intended use aligns with the permitted uses of the spaces you want to consider. One effective way to do this exploration is through feasibility studies. A feasibility study is a comprehensive analysis that empowers you to determine the suitability of a specific location or building for your business. Choosing the right spot for your business is crucial for your business's success. It evaluates whether a business of your type can operate in the proposed location, taking into account any restrictions like proximity to certain establishments such as schools. Its main goal is to confirm the viability of your project before committing significant resources, ensuring that potential risks are minimized. If a Change of Use Permit is required, this will help you to have a grasp of both the timeline and cost implications as both can have a major impact on your business’ bottom line.

How Do I Apply for Change Of Use?

When you’ve gathered all of your documents, completed your due diligence through feasibility studies, have engaged your team in evaluating your options, and feel confidently ready to move forward, it will finally be time to submit your application for a Change of Use Permit.

What goes into the application? You’ll need to submit a plan that includes comprehensive details about your upcoming project. The plan should include:

1. Site plan that includes details like number of stories, streets, use type, lot size, alleys, loading zones, and parking areas
2. Floor plan that shows existing and proposed remodels
3. Equipment and fixtures
4. ADA accessibility, including access ramps, path of travel, restrooms, parking, and more
5. Parking layout and parking analysis
6. Previous building permits and certificate of occupancy
7. Construction details
8. Additional notes that may be required by the Health Department or others

Why is Change of Use Permitting so challenging in Los Angeles?

In recent years, Los Angeles has seen a surge in adaptive reuse, an alternative term to change of use, where a building’s purpose is redefined and designed to take on a new life to serve an entirely new purpose. A city often referred to as sprawling, much of LA’s surface area has been developed. As much as people think of LA as a newer city, there are many existing buildings that are more than 100 years old. This makes adaptive reuse projects critical to keeping buildings functional and up to code as they become safer over time. Letter Four, Inc. specializes in these types of projects that investigate spaces, for example an office space, evaluate its past life, and envision a new function through thoughtful interior design and interior architecture.

Los Angeles has particularly complex regulations and codes — our high population leads to high demand, and thus, intense competition over the same coveted spaces. Our experience has shown us that two of the biggest challenges with adaptive reuse projects in Los Angeles are parking and accessibility (ADA or Disabled Access). Building systems updates and Landlord negotiations are next in line.

The Disabled Access requirements came into effect well after older buildings were initially constructed. When applying for a building permit, it’s necessary to get disabled access approval for entry to the space, restrooms, circulation, and other facilities. Because this can get quite expensive, LA accommodates applications for financial hardship. We then put a certain percentage of the total construction cost to disabled access updates. While this helps with securing more cost effective permits, it also opens the space owner/operator up to potential lawsuits for areas that are not fully compliant.

The Importance of Understanding Hurdles

By understanding the hurdles of the Change of Use permitting process, you will have a better sense of what kinds of questions to ask and which parts of the process can lead to headaches, like extended timelines or additional paperwork. Most challenges will have options for workarounds. Many of them will come as a result of a comprehensive, extended investigation and reporting through a proper feasibility study.

If you are feeling unsure of whether your plan is complete, a pre-application that goes through a preliminary review can be submitted by your architect or design team. The feedback from this preliminary review will inform your design team about gaps or additional needs that haven’t been addressed yet, and better prepare the project for the application step. This preliminary review process can go even more smoothly when you work with a design-build team like Letter Four, Inc. that includes both your architect and contractor under one roof. We have gone through this process many times before, and have established relationships with land use consultants and city departments that conduct the review.

LETTER FOUR’s Done It Before

Explore some case studies with us that investigate how we’ve addressed Change of Use scenarios for previous projects.

1. Bespoke Cycling
Basic Retail Shop Turned Cycling Gym

Bespoke Cycling came to us shortly after they’d decided on a new central location for their growing business. Focused on downtown LA, the goal was to appeal to in-office professionals working in the area. They landed on a space in the FIGat7th mall, in a raw shell of a space that gets a lot of foot traffic as it sits on the main foot-access route to the parking garage.

The location that was selected sits below a Target, which meant that sound-proofing and vibration isolation would be required. The new location also did not have sufficient HVAC, and needed plumbing upgrades to meet the demands of a gym environment. While the project was a success, we may have been able to offer our client even more support if given the option to help with lease negotiations. When we are involved early, we can help to get an LOI in place. This can be an avenue to clearly identify unexpected costs and potential risks that could have resulted in tenant improvement credits or possibly even free rent to reduce overall project cost.

Letter Four, Inc. was the design architect, project manager, and architect of record. We had the opportunity to exercise our creative muscles in the sawtooth wall as part of the overall design. The design is not only eye-catching, but it also helps to insulate the acoustics within the main studio room from the entrance which sits along the shared pedestrian passage between the mall and parking garage. Other challenges included amplifications to energy supply, HVAC provisions, and plumbing, where the MEP team became key players. We needed to make sure that we could add to the building’s plumbing fixture count for the new bathrooms and showers, which required locating the right equipment and ensuring sufficient power supply.

2. Letter Four Headquarters
Classic Speedwash Laundromat, turned bustling Design-Build office HQ.

Since starting Letter Four, Inc. back in 2010, it has always been a goal to own, design, and build our own office, which reflects the spirit of our business with a timeless, fun, and functional aesthetic. We wanted to continue operating in Culver City or Mar Vista, and needed enough space to allow our business to grow, while still feeling right-sized to accommodate our team. In addition, we needed to include storage space for a materials library that houses a variety of finishes and fixtures that we order for all of our projects. We targeted a walkable neighborhood that felt accessible to our staff and to our clients.

The original laundromat was divided into two spaces. The first included coin-operated machines, and the second contained a drop-off area for full-service laundry. The space had attractive high ceilings, but came with the caveat that we would need to remove a lot of the plumbing that was in-place for the machines. The existing linoleum flooring was dated and worn, but the sub-surface was concrete which offered the potential to be polished and repurposed to add a modern touch.

We deliberated over how much of the space to use, whether we only needed half to address basic functional needs or whether we would want to occupy the entire space to grow into over time. Deciding on the larger space required additional, supplemental permits that caused delays in the process.

Operationally, we moved the building from a gas supply for heating to an all-electric building, a change which required additional coordination. The laundromat historically had a large annual sewer fee that the city accidentally continued to charge, despite the change of use permitting, so we worked with them to refund those charges. The additional coordination, opportunity for delays, and accidental additional charges all represent potential obstacles that can come with change of use permitting despite meticulous planning. These also represent knowledge building and perspective that we can bring to your interior tenant improvement project; having gone through it ourselves, we are in a position to better advise our clients in their own processes.

3. The Boy & The Bear
Retail shell transformed into a buzzing coffee house.

Our client came to us after leasing their space, looking for help with the interior build out for the new location of The Boy & The Bear. Located in the main Culver City Corridor, the coffee shop planned to make and sell both food and beverages. The client’s original approach was to get a permit for the space as food retail, however this would have limited their food options to pre-packaged foods and beverages only. The permit for that was restricted to storefronts up to 750 SF and did not make sense with the 1,500 SF footprint of the space. When we got involved, we identified this discrepancy and submitted a change of use permit that changed the designation for the space from retail to restaurant. This allowed the occupant load to increase in addition to the associated parking allowances.

By changing the use to Restaurant, the coffee shop owner was able to make full use of their allowable square footage while also leveraging the general corridor reduced parking incentives. The design of the space was centered around the Colombian origins of the coffee the shop serves, focused on an environment reminiscent of the cool Colombian mountains. Each of the client’s shops is based on a color, and this storefront is the Grey Store. Using grey concrete as a primary material, exotic greenery brings softer texture to offer engaging contrast in the space. Pops of copper accents throughout create warmth within the otherwise neutral palette and provide visual interest. The final design of the shop’s interior offers a serene and productive place of respite where locals can work, rest, or create while they sip on their coffee.

Key Considerations for a Smooth Change of Use Permitting Process

● Build Your Team Early: By getting the right team together early, you’ll have early exposure to all of the possible risks that could come with taking on your project. Your team may include architects, engineers, or land use consultants. You may also want to consider engaging city planning staff early to call out any specifics that may put a snag in your plan.

● Include Us In Lease Negotiations: It's essential to engage with reputable professionals who understand how to balance cost, speed, and quality effectively. A detailed approach to planning and communication lays the foundation for a successful project that aligns with your priorities. By engaging LETTER FOUR before you sign your lease, we may be able to help you identify potential risks or delays in your construction timeline or budget, and help to build any necessary accommodations into your lease negotiations.

● Lean Into the Zoning Laws: Any space in which you want to build your business will inevitably fall under specific zoning. Understanding all of the zoning limitations can help to determine whether you’ll need to go through the process of a zoning amendment, which could impact your construction schedule and final delivery date. As in the example above, different uses include different allowances — and you’ll want to make sure that given your square footage and the goals of your business, you are applying for the right end-use.

‍● Occupancy Changes: If you are considering a change of use, you will need to provide calculations for how many people will occupy your newly designed space. For example, the occupancy calculations for a 1,500 SF retail shop will account for a handful of people milling around to look at products and perhaps try on clothing. If repurposed as a restaurant, the headcount increases dramatically with many people seated at tables for extended periods at the same time, in addition to necessary staffing to keep things running. With this increase, you’ll need to consider ingress and egress — how people enter and exit the space — and whether your plans and build-out would be sufficient to keep everyone safe in an emergency.

● Building Restrictions: Let’s say that you want to add a second floor to a space that has a high ceiling. Thinking about how people will access that second floor on a stairwell or in an elevator will impact where you can place other items throughout the space, like an entryway or exit, because these items cannot be constructed in any position that would obstruct the flow of foot traffic.

Another example to consider may be the age of the building. Some older buildings will not be able to accommodate retrofitting for important elements for accessibility, like installing a ramp. There is typically a workaround, in this case you may want to use a mechanical lift as an alternative solution; a hardship that would need to be defined and laid out in your permit application.

Changing the use of a space provides ample opportunity to explore new visions and elevate interior tenant improvements. Designing a gym into a space that was previously a stationery store, or a pilates studio where there was previously a restaurant, will inevitably come with challenges. Letter Four, Inc. has a plethora of interior tenant improvement projects in our portfolio, making us the right partner to help you assess your needs and options, and to make plans for your project’s path forward. With a simple introductory call, you’ll quickly learn the high level of service and expertise that we can bring to your project’s design, budget, schedule, and overall project process, protecting your bottom line. As soon as you are ready to start investigating your options, book a call to see how we can help bring your dream to reality!