SB 8 Replacement Requirements: Eligibility Criteria Checklist

PIN Number: 141B193 661

Site Address: 646 N WESTERN AVE

Tract: LA PALOMA ADDITION

Map Reference: M B 5-163

Block: 1

Lot: FR 1

Arb (Lot Cut Reference): 15

This checklist is intended to be used by City staff to verify the eligibility of a Housing Development Project^[1] to use a SB 8 No Net Loss Declaration form in lieu of obtaining a Replacement Unit Determination (RUD) from the Los Angeles Housing Department (LAHD)^[2] for the purpose of implementing the Housing Crisis Act (HCA). The 2023 Housing Crisis Act Interdepartmental Memorandum and the HCA Replacement and Occupant Protection Matrix may be referenced for additional guidance.

A copy of this checklist must be included on the administrative file of the applicable City Planning application or building permit record.

Checklist 1: Housing Replacement Screening for ALL Housing Development Projects

Environmental Standards

If the response is "No", no further action is required. The replacement provisions and occupant protections of the Housing Crisis Act do not apply to a Housing Development Project on the site.The project is not required to obtain a SB 8 RUD from LAHD nor to submit a No Net Loss Property Owner Declaration.

If the answer is "Yes" and the project is proposing a multi-unit project or a stand-alone subdivision, proceed to Checklist 2^[3]. If the answer is "Yes" and the project is proposing a single unit development, proceed to Checklist 3^[4].

Please note that a site located within a Very High Fire Hazard Severity Zone (VHFHSZ) that is also identified on the City's Housing Element sites inventory may still require replacement units as a condition of any development of the site. Information on whether the site is identified on the City's Housing Element sites inventory may be found on ZIMAS under "Housing Element Sites".

The project requires Housing Crisis Act Replacement Review.

Yes

Checklist 2 - Housing Replacement Screening for Multi-unit Projects and Stand-alone Subdivisions^[3]

Checklist 2: Step 1 - Verify whether the proposed project is located on a site that has/had residential uses

All answers must be "No" to qualify for a No Net Loss Declaration, unless permit record or aerial site photos show units in the past five (5) years. If any of the answers are "Yes", proceed to Step 2.

The project is located on a site where the owner had withdrawn or removed rental units pursuant to the Ellis Act within the past 10 years.

The proposed project is located on a site that had at least one residential unit in the past five years.

This determination is based on historical assessor data. LADBS permit records must be used to substantiate determinations. In addition, ZIMAS with aerial imagery turned on can be used as a visual confirmation.

If the answer is "Yes" but assessor records are potentially inconsistent with building permit records, applicants may obtain a Records Research Request from LADBS and submit a copy to Planning staff, for projects that require a City Planning application. Final determination will be made based on building permit records ^[5].

Checklist 2: Step 2 - Verify whether the proposed project involves the demolition of one or more housing units ^[6]

If any of the answers is "Yes", the project must obtain a Replacement Unit Determination (RUD) letter from LAHD. All answers must be "No" to qualify for a No Net Loss Declaration.

The project is proposing the demolition or removal of one or more Housing Units.

Existing or to-be demolished residential units may be identifiable on the architectural plans.

Verify with the project plans

The proposed project is located on a site that has removed one or more residential units in the past five years.

LADBS permit records must be used to substantiate determinations. In addition, ZIMAS with aerial imagery turned on can be used as a visual confirmation.

Applicants may obtain a Records Research Request from LADBS and submit a copy to Planning staff, for projects that require a City Planning application. Final determination will be made based on building permit records ^[5].

Verify with
LADBS permit records

Checklist 3: Housing Replacement Screening for Single-unit Projects^[4]

Checklist 3: Step 1 - Verify whether the proposed project is located on a site that has/had residential uses

All answers must be "No" to qualify for a No Net Loss Declaration. If any of the answers are "Yes", continue with Step 2.

The project is located on a site where the owner had withdrawn or removed rental units pursuant to the Ellis Act within the past 10 years.

Checklist 3: Step 2 - Verify whether the site has more than one dwelling unit

All answers must be "No" to qualify for a No Net Loss Declaration. If any of the answers are "Yes", proceed to Step 3.

The project is located on a site that has units subject to the Rent Stabilization Ordinance (RSO).

Yes

More than one dwelling unit was on the site within the past 5 years.

This determination is based on historical assessor data. LADBS permit records must be used to substantiate determinations. In addition, ZIMAS with aerial imagery turned on can be used as a visual confirmation.

If the answer is "Yes" but assessor records are potentially inconsistent with building permit records, applicants may obtain a Records Research Request from LADBS and submit a copy to Planning staff, for projects that require a City Planning application. Final determination will be made based on building permit records ^[5].

Checklist 3: Step 3 - Verify whether the proposed project involves the demolition of two or more housing units ^[6]

If the response is "Yes", the project must obtain a Replacement Unit Determination (RUD) letter from LAHD and must replace all units removed or proposed to be removed. If the response is "No", the project qualifies for a No Net Loss Declaration^[7]^[8]

The project is proposing the demolition or removal of two or more Housing Units. Existing or to-be demolished residential units may be identifiable on the architectural plans.^[4]

Verify with the project plans

Demolition permit records show that more than one unit was removed in the past five years.

LADBS permit records must be used to substantiate determinations. In addition, ZIMAS with aerial imagery turned on can be used as a visual confirmation.

Applicants may obtain a Records Research Request from LADBS and submit a copy to Planning staff, for projects that require a City Planning application. Final determination will be made based on building permit records ^[5]

Verify with
LADBS permit records

6/12/2025

Footnotes:

^[1]Information on whether the development type is a "Housing Development Project" for the purpose of implementing the HCA and when the PZA, RUD, No Net Loss, and optional vesting procedures may apply can be found on the Housing Development Project Applicability Matrix.

^[2]Information on submitting for the SB 8 Replacement Unit Determination from LAHD can be found here: SB 8 Determinations – LAHD

^[3]A Housing Development Project that does not involve the removal of any number of units, is not on a site that has removed any housing units within five years, and where no units were subject to an Ellis Act withdrawal within the past 10 years may be eligible to use a SB 8 No Net Loss Declaration form in lieu of obtaining a Replacement Unit Determination (RUD) from the Los Angeles Housing Department (LAHD).

^[4]A project proposing only one residential unit that does not involve the removal of more than one unit, is not on a site that has removed any housing units within five years, and where no units were subject to an Ellis Act withdrawal within the past 10 years may be eligible to use a SB 8 No Net Loss Declaration form in lieu of obtaining a Replacement Unit Determination (RUD) from the Los Angeles Housing Department (LAHD).

^[5]In order to obtain a Record Research Request, applicants may fill out a records research request form and submit it online to records.ladbs@lacity.org.

^[6]Housing Development Projects requiring the demolition or removal of one or more residential units must replace at least as many residential units as will be demolished. The removal of a housing unit can be done under various permit types. For example, the conversion of a duplex to a single-family dwelling is a Housing Development Project that results in the removal of units. Housing Development Projects consisting of a single unit may require additional replacement units if demolishing more than one unit. For example, a duplex must be replaced by at least two units.

^[7]When only one single unit replaces one single unit, the replacement unit may be of any size and income level consistent with State and City rules and regulations. The 2023 Housing Crisis Act Interdepartmental Memorandum and the HCA Replacement and Occupant Protection Matrix may be referenced for additional guidance.

^[8]A proposed single-family project located on a site identified on the City's Housing Element sites inventory and that had an existing housing unit occupied by a lower-income tenant within the past five years may require replacement units. Information on whether the site is identified on the City's Housing Element sites inventory may be found on ZIMAS under "Housing Element Sites".