City of Los Angeles

20% Building Coverage Threshold

Code Citation
LAMC §12.20.3 · Division 13B.8 (Historic Preservation), Chapter 1A LAMC · Each district’s Preservation Plan

Definition

Exempt Work is the category of work in a Historic Preservation Overlay Zone that is not subject to the design-review process under the citywide HPOZ Ordinance and the procedural framework codified at Division 13B.8 of Chapter 1A. The exemptions are narrow and specific — they exist principally to allow emergency response, certain public-works activity, work performed under approved Mills Act contracts, and interior or below-ground work that does not change the exterior of a structure.

Exempt status must be verified by Department of City Planning staff before the work proceeds. Owners do not self-declare exempt; the determination requires staff confirmation that the proposed work meets the exemption criteria. Because no discretionary decision is issued, exempt determinations are not appealable.

What Flags It

Exempt categories drawn from the citywide framework as restated in the district Preservation Plans reviewed for this entry include:

  • Emergency or hazardous condition correction. Where a City enforcement agency has determined that emergency or hazardous conditions exist and must be corrected in the interest of public health, safety, and welfare. When feasible, City agencies should consult with the Planning Department on how to correct the hazardous conditions consistent with the Preservation Plan.
  • Department of Public Works improvements. Where the Director finds that the certified Historic Resources Survey does not identify any Contributing Elements located within the right-of-way (or the right-of-way is not specifically addressed in the Preservation Plan), and where Public Works has completed a CEQA review determining the work is exempt from CEQA or has no potentially significant environmental impacts. The HPOZ Board is notified and given an opportunity to comment.
  • Mills Act work. Alteration to Historic-Cultural Monument and Mills Act properties under an approved Historical Property (Mills Act) Contract.
  • Foundation maintenance and repair. Maintenance and repair of existing foundations with no physical change to the exterior.
  • Underground utility work in the public right-of-way. Where the work does not affect a historic element and does not involve a new above-ground structure.
  • Interior alterations. Interior alterations that do not result in a change to the exterior of a structure.

Several Preservation Plans add district-specific exempt items tied to visibility — for example, installation of solar modules in some districts, exterior painting with no change in existing paint colors, removal of fences installed outside the period of significance, and re-roofing of flat roofs within parapets where coping is not affected. These item-level exemptions vary by district. The Preservation Plan governs.

Even where confirmed, exempt work does not include items such as installation of decomposed granite or hardscape, installation of artificial turf, installation of fences or hedges, planting of new trees, or the removal of any mature tree or feature identified in the historic resources survey. These are reviewable.

Worked ExampleAn owner of a Contributing 1927 Tudor Revival in Hancock Park has a soils engineer report that the existing foundation has settled and requires repair. The proposed work is in-kind foundation maintenance and repair with no change to the exterior of the structure.

Per the citywide framework as restated in the Hancock Park Preservation Plan, the work qualifies for exemption. The owner brings the proposed scope to OHR for verification of exempt status before construction begins. Once verified, the owner proceeds to the building permit through LADBS without HPOZ design review.

Source: Citywide HPOZ Ordinance (LAMC §12.20.3) and Division 13B.8 (Historic Preservation), Chapter 1A LAMC. District-specific exemption lists set in each adopted Preservation Plan.

Request a Review

Considering a project inside an HPOZ?

Each district has its own preservation plan and its own answer to what is permitted. Design 1 Studio reviews the district-specific framework, character-defining features, and the Certificate of Appropriateness pathway before design begins.

About Design 1 Studio

Building design firm based in Pasadena, California. Over a decade serving Los Angeles County with residential and commercial design, including ADUs, hillside projects, multifamily, and historic-district work. Inspector-led methodology focused on producing drawings that anticipate plan check rather than react to it. Specialty work in HPOZ navigation across LA’s preservation districts. Contact through design1.studio.