Quick answer: In the City of Los Angeles, a landlord planning Primary Renovation Work in an occupied, rent-stabilized (RSO) building — replacing plumbing or gas lines, rewiring or replacing the electrical panel, HVAC or elevator work, structural work that exposes the building frame, or lead or asbestos abatement — must have a Tenant Habitability Plan (THP) accepted by the Los Angeles Housing Department (LAHD) before the building permit is cleared. Tenants must then be served at least 60 days before work starts, and the landlord must relocate them and pay the costs whenever their units cannot be lived in outside weekday working hours. Mandatory soft-story and concrete seismic retrofits in RSO buildings need a THP too. APLA Construction (CA Lic #1136359) plans renovation, retrofit and balcony repair work in occupied buildings around these rules.
A THP is a document the landlord submits to LAHD describing how planned construction will affect tenants and how those impacts will be mitigated. It comes from the City’s Tenant Habitability Program (Los Angeles Municipal Code Chapter XV, Article 2, §§ 152.00–152.08), part of the Rent Stabilization Ordinance. The code explains why it exists: Primary Renovation Work “generally makes rental units untenantable, as defined by California Civil Code Section 1941.1, on a temporary basis.” LAHD describes the program’s intent as protecting tenants “from untenantable housing conditions and/or forced permanent displacement.”
The THP applies to buildings under the Rent Stabilization Ordinance. LAHD’s checklist summarizes RSO coverage as rental housing in a structure with a certificate of occupancy first issued on or before October 1, 1978. And it only matters if people live there: the checklist’s first question is whether any unit is occupied — “If you answered NO, stop here, sign and obtain your permit.”
The RSO defines Primary Renovation Work as work that improves the property by prolonging its useful life or adding value and that involves replacing or substantially modifying a structural, electrical, plumbing or mechanical system that needs a permit, or abating hazardous materials such as lead-based paint and asbestos. LAHD’s program lists the categories:
| Category | Examples |
| Plumbing | Replacing water, gas or drain lines (a whole-building repipe) |
| Electrical | Rewiring or replacing the electrical panel (a rewire) |
| Mechanical | Heating, ventilation, air conditioning or elevator work |
| Structural | Additions or modifications to the foundation or structure, including the roof, that expose the building frame or compromise security — LAHD’s checklist names seismic improvements, stairs, walkways, patios and balconies |
| Hazardous materials | Lead-based paint or asbestos abatement |
In practice, the Primary Renovation Work Identification Checklist (revised February 25, 2025) is attached to the permit application. If any unit is occupied and the answer is yes to any one of its other three questions — major electrical, plumbing, mechanical or structural work; hazardous-material abatement; or work that will cut into walls or ceilings, shut off gas, power or water, make a kitchen or bathroom unusable, or affect weatherproofing, structural soundness or security — the checklist says: “YOU MUST FILE A TENANT HABITABILITY PLAN” with LAHD before a permit will be issued. Note that in all pre-1978 construction, the checklist says lead-based paint is assumed to be present and safe work practices are required.
Mandatory seismic retrofits. For soft-story and non-ductile concrete retrofits under the City’s mandatory retrofit programs (see our seismic retrofit guide), the Building Code requires the owner of an RSO building to submit a Tenant Habitability Plan to LAHD. LADBS’s soft-story THP guide is direct: LADBS will not issue a retrofit permit, and retrofit work may not start, until the THP is accepted. Seismic work has its own notice rule: LAHD’s summary of tenant rights for seismic work says the work may begin no sooner than 20 days after the landlord serves the THP and a Notice of Seismic Retrofit Work, and that a tenant appeal stays the work until the hearing officer decides.
SB721 balcony and stair repairs. LAHD’s balcony-inspection materials do not mention the THP. But the checklist lists stairs, walkways, patios and balconies under structural work, so a permitted structural repair to those elements in an occupied RSO building can require a THP under the checklist’s own terms. Answer the checklist before you schedule the repair — the 60-day notice can matter more than the construction schedule. See our SB721 balcony inspection guide.
A note if you read LAHD’s web pages: some describe the permit being issued before THP clearance. The Municipal Code, the LAHD checklist and the LADBS seismic guide all put LAHD acceptance first, and that is the safe order to plan around.
Under § 152.07, a landlord who does not comply can be denied rent adjustments for the work, gives the tenant a defense in an eviction case, and can be sued for actual damages plus special damages of up to twice the actual damages or $5,000, whichever is greater, with three times actual damages for willful violations; any waiver of these rights by a tenant is void. Certain violations, including false statements, are misdemeanors punishable by a fine of up to $1,000 and up to six months in jail. Cost-recovery rent increases for renovation or seismic work also depend on an accepted THP.
Searches for this topic often surface a different program. LA County Public Health’s Rental Housing Habitability Program (RHHP), created in 2024, is a routine inspection program — inspections once every four years — for rental units in unincorporated LA County, and it does not apply in incorporated cities such as Los Angeles. The City’s THP is not an inspection program at all: it is the plan a landlord files before renovating.
The landlord files the THP, with help from LAHD’s Tenant Habitability Program staff. What the plan needs from the contractor is a clear scope, cost and schedule for each unit, and a construction plan that keeps tenants in place wherever possible — utility shutoffs only during weekday working hours, dust and noise control, and lead-safe practices in pre-1978 buildings. APLA Construction provides that information for repipes, rewires, seismic retrofits and balcony repairs in occupied buildings, and builds the work to it. See our Los Angeles building permit guide.
Yes, if the building is occupied and the work is Primary Renovation Work — replacing plumbing or gas lines, rewiring or replacing the electrical panel, HVAC or elevator work, structural work that exposes the frame, or lead or asbestos abatement. LAHD must accept the THP before the building permit is cleared. If no unit is occupied, LAHD’s checklist says no THP is needed.
Yes, for buildings subject to the Rent Stabilization Ordinance. The Building Code requires the owner to submit a THP to LAHD, and LADBS will not issue the retrofit permit until it is accepted. Seismic work may begin no sooner than 20 days after the THP and notice are served on tenants.
At least 60 days for Primary Renovation Work under LAMC § 152.04, with the accepted THP and a Notice of Primary Renovation Work in the language of the lease. For mandatory seismic retrofit work, LAHD’s rules allow work to begin 20 days after service.
Often, yes. Tenants must be relocated only if their unit becomes untenantable outside 8:00 a.m. to 5:00 p.m., Monday through Friday, or if they would be exposed to toxic or hazardous materials. When relocation is required, the landlord pays for comparable temporary housing and all relocation costs, and the tenant keeps the right to return.
No. The County’s RHHP is a routine inspection program for rental units in unincorporated LA County and does not apply in the City of Los Angeles. The City’s Tenant Habitability Plan is a mitigation plan a landlord files before renovating an occupied rent-stabilized building.
Call (818) 818-4419 or email info@aplaconstruction.com. CA License #1136359.
Sources, read 15 October 2026: Los Angeles Municipal Code §§ 152.00–152.03, §§ 152.04–152.08 and § 151.09; LAHD Tenant Habitability Program, THP online application and Primary Renovation Work Identification Checklist (rev. 2-25-2025); LADBS Soft Story Retrofit Program THP guide; LAHD Summary of Tenant Rights for Seismic Retrofit Work; LA County Department of Public Health Rental Housing Habitability Program. Relocation amounts are adjusted annually — confirm current figures with LAHD. General information, not legal advice.