In March 2020, a coalition of Los Angeles stakeholders filed a lawsuit (LA Alliance for Human Rights, et. al. v. City of Los Angeles, et. al.) that accused the City of Los Angeles (City) and County of Los Angeles (County) of violating State and federal laws in their response to the homelessness crisis. The original lawsuit and subsequent orders by the Court spurred discussions about issues such as structural racism, housing, control of public space, property rights, accessibility rights, mental health, addiction, public health, and use of taxpayer funds. While the underlying causes of the crisis are complex and represent policy failures across multiple levels of government, Angelenos generally agree that the status quo is unacceptable.

Despite years of unprecedented investment and attention, Los Angeles County remains the epicenter of the State’s homelessness crisis. The Los Angeles County Department of Public Health estimated that approximately four unhoused individuals died every day in 2019 and preliminary reporting suggests that the trend has continued during the ensuing period. The most recent point-in-time count (conducted in January 2020) showed that tens of thousands of people were living in the streets without housing or shelter. Several years of data show a deepening crisis and the continued economic impact of the COVID-19 pandemic further threatens vulnerable residents who face housing instability.

A key question posed by the LA Alliance lawsuit is whether the City is doing enough to help unhoused residents while waiting for long-term strategies—primarily development of supportive housing funded by Proposition HHH—to deliver results. Given the increasingly untenable situation in Skid Row and other Los Angeles neighborhoods, U.S. District Court Judge David O. Carter issued an injunction in April 2021 that called for:

• completion of multiple audits/investigations into City and County programs designed to alleviate homelessness (e.g., Proposition HHH and Measure H), as well as funds used for mental health or substance abuse treatment; and
• timelines to offer/provide housing, shelter, or treatment services to unhoused residents of Skid Row.

The injunction also stated, “…City Controller Ron Galperin shall oversee the creation of a report on all land potentially available within each district for housing and sheltering the homeless of each district.” Subsequent discussion with the Court clarified that the scope of the order was limited to properties owned by the City.

The request stemmed from our Office’s previous work on the issue, which included building an inventory of publicly-owned properties and developing recommendations about how the City should strategically manage its real estate assets. We originally launched the Property Panel in 2017 and our 2019 update identified more than 14,000 government owned properties in Los Angeles. Approximately 7,500 of these properties were owned by the City itself. The remaining properties were owned by the federal government, State of California, County of Los Angeles, Los Angeles Unified School District (LAUSD), and Los Angeles County Metropolitan Transportation Authority (Metro).

Discussions surrounding the City’s approach to homelessness have continued to evolve—both inside and outside of the courtroom.

• In May 2021, the United States Court of Appeals for the Ninth Circuit ordered an administrative stay (i.e., hold) on Judge Carter’s injunction and the Court eventually vacated the order. In November 2021, the plaintiffs submitted an amended complaint intended to address some of the procedural and evidentiary concerns highlighted by the Ninth Circuit. Barring a settlement, the legal process will continue to play out over the next several months.
• The City initiated significant changes to its camping laws throughout the summer of 2021. The City now has the authority to prohibit unhoused individuals from sitting, lying, sleeping, or storing their property in the public right-of-way near: (1) sensitive sites such as schools, parks, and libraries; (2) underpasses, overpasses, or ramps; (3) facilities that provide homeless services or shelters opened after January 2018; and (4) portions of the public right-of-way that the City identifies due to threats to public health or safety. To date, the City has designated—or is considering—hundreds of sites under this new framework.

The ultimate outcome of the LA Alliance lawsuit remains unclear, but the growing number of restricted zones established by the City raises questions about where unhoused people can legally sit, lie, and sleep. In addition, the City’s efforts to develop supportive housing using funds from Proposition HHH is beset with high costs, lengthy timelines, and will not produce nearly enough units for everyone in need.

Given these issues, it is critical to identify vacant or underutilized City-owned properties that should be considered for interim shelter or support facilities. This report is intended to fulfill Judge Carter’s original request and provide additional context about the City’s efforts to assess its properties. 

City efforts to develop housing and shelter on City-owned property in recent years  

Developing supportive and affordable housing is a key component of the City’s overall homelessness strategy. As a result, large parcels of City-owned land which are centrally located and do not require extensive site preparation are often designated for construction of housing projects using bond proceeds from Proposition HHH or other funding streams. This approach is intended to leverage existing City assets and lower development costs.

As of June 2021, there were 16 projects in the Proposition HHH pipeline being developed on City-owned property. These properties include Los Angeles Department of Transportation (LADOT) parking lots and properties formerly controlled by the Community Redevelopment Agency of the City of Los Angeles. When completed, these projects will provide approximately 1,074 units of housing for the target population.

But the magnitude of the crisis also requires a mix of short-term strategies to help unhoused residents in need and to ensure that public space such as sidewalks, parks, and streets are safe and clean for all residents. Over the last several years, the City directed multiple teams and working groups (e.g., Interim Housing and Temporary Structures Working Group) to focus on issues such as interim housing and property management. These efforts led to development of new interim housing sites, some of which are located on City-owned property.

A Bridge Home – In 2018, the City launched the A Bridge Home program, which included installation of modular trailers or membrane structure to provide temporary shelter, storage, and supportive services for unhoused residents. The program was designed to provide participants with short-term transitional housing (typically between three and six months) while they wait for housing to become available.

As of June 2021, the City completed 31 bridge housing facilities—11 of which were developed on properties controlled by City departments. The remaining projects were built on properties owned by other public entities (e.g., Metro, Caltrans) or private entities.

COVID-19 Homelessness Roadmap – The first half of 2020 brought the onset of the COVID-19 pandemic, the influx of emergency funding, and an urgent need to find emergency shelter for high-risk unhoused individuals. The convergence of these factors spurred an increase in the number of planned interim housing projects, along with efforts to identify vacant or underutilized City-owned properties. In addition, concerns about COVID-19 transmission resulted in a greater focus on interim housing in non-congregate settings.

The City and County reached an agreement (Roadmap) in June 2020 to develop 6,700 housing interventions within 18 months to address the COVID-19 emergency. The Roadmap allows for several different types of interventions (e.g., beds in A Bridge Home facilities, safe parking sites, tiny home villages, motel rooms, permanent housing) to count toward the overall goal.

Since the agreement was reached, several City departments—primarily the City Administrative Officer (CAO), Chief Legislative Analyst (CLA), Bureau of Engineering (BOE), and General Services Department (GSD)—have worked with Council Offices and other stakeholders to identify and evaluate potential sites. These efforts, and operating funds from the County, facilitated the development of several interim housing locations, some of which are on property owned by the City.

Further analysis is required to better understand costs associated with developing/operating these types of sites and measuring outcomes for participants. For example, the Safe Sleeping pilot program listed in the table has a projected monthly cost of $2,600 per-person, per-space—which raises questions about the long-term viability of the program, relative to other options. But the City’s alternate approach has typically meant leaving individuals without adequate shelter and sanitation while they wait for housing placements that may take years to materialize.

Processes to determine which City-owned properties are considered for alternate uses

The City’s efforts to identify and assess properties for economic development or other purposes are guided by its Asset Evaluation Framework. The evaluation process is initiated when a proposed re-use of a City-owned property is transmitted to the CAO’s Asset Management Strategic Planning (AMSP) unit. The AMSP unit’s role differs from GSD, which is the City’s property manager, maintains the inventory of properties, and performs real estate transactions on behalf of the City.

The AMSP unit works with City stakeholders to consider a series of factors during its evaluation, including municipal uses currently operating on site and whether those uses are necessary or can be relocated. Recommendations from AMSP are forwarded to the Municipal Facilities Committee (comprised of representatives from the CAO, CLA, and Mayor) for review. Actions recommended by the Municipal Facilities Committee are submitted to the Council for consideration.

The process for identifying viable City-owned sites to develop temporary shelter is mostly consistent with the principles outlined in the Asset Evaluation Framework. But there are additional feasibility considerations and criteria to account for the unique nature of emergency/temporary housing facilities such as bridge shelters, tiny home villages, safe sleeping, and safe parking.

The graphic below summarizes the assessment process for City-owned properties, as reported by the CAO in February 2021. Sites are introduced for feasibility assessments by City Councilmembers or City departments, and corresponding Council Offices provide feedback throughout the process.

Challenges to identifying and repurposing City-owned properties for housing or shelter

The LA Alliance lawsuit spurred discussions about whether the City is doing enough to tackle homelessness using its own properties, which raises larger questions about how the City manages its vast real estate portfolio. The City’s longstanding approach has been fragmented and not optimized to pursue strategic opportunities to revitalize underutilized properties, acquire new land/real estate, or dispose of existing assets. Overall, this limits the City’s economic development potential and prevents reinvestment of real estate revenue into new projects.

To address these—and other real estate management issues—our Office recommended the creation of a new entity called the Los Angeles Municipal Development Corporation (LAMDC). As envisioned, the governance structure of LAMDC would include City officials tasked with advancing public interest goals in partnership with experts from the financial and real estate sectors. The LAMDC is modeled, in part, on leading entities in other jurisdictions, while incorporating features unique to the City of Los Angeles to best serve the needs of the City, stakeholders, and residents.

In the context of the ongoing shelter emergency, potential sites—both publicly- and privately-owned—are being evaluated by the City on a parcel-by-parcel basis. According to a February 2021 CAO report on the City’s efforts to identify properties to contribute to homeless interventions, 100 locations were deemed infeasible for a variety of underlying reasons. Some of the challenges associated with the City-owned properties, as well as other relevant obstacles, are outlined below.

Asset management system – GSD is responsible for maintaining an inventory of the City’s real estate assets. Tracking the status, conditions, and uses of more than 8,000 City-owned properties within Los Angeles County poses challenges. While GSD centrally tracks real estate asset information in its Asset Management System, GSD relies in part on departments to update information about the properties under their control. As a result, real estate asset data can contain errors, and departments sometimes fail to update information in a timely manner.

Departmental operations – Decisions about the feasibility of repurposing vacant or surplus City-owned land depend on factors such as lot size, nearby amenities, and infrastructure conditions. If the minimum criteria are met and requisite approvals are obtained, the site can be prepared for conversion to bridge housing, safe parking, safe sleeping, or tiny home village.

But the task becomes markedly more challenging when the location is tied to departmental operations. For example, a lightly used maintenance yard may be a viable location for interim housing, but the affected department would need to modify its operations to account for the repurposing of the location.

Community opposition – The City’s ability to identify and convert vacant or underutilized property for supportive housing or interim housing interventions is further complicated by residents, businesses, or local organizations who oppose those efforts. Opposition can come from stakeholders who contend that these projects should be developed in other areas, or others who contend that resources allocated to interim housing impedes long-term solutions like supportive housing.

Whether through formal appeals of land use decisions or less formal means like social media, residents, businesses, and local organizations wield significant influence about which locations are considered. Ultimately, the pushback can shrink the number of projects that are selected for initial feasibility assessments or prevent viable projects from moving forward.

Site characteristics – There are a variety of reasons why a vacant or underutilized City property may be deemed infeasible. Because larger and centrally located sites are typically set aside for affordable/supportive housing development, many of the remaining properties present their own site-specific challenges such as inadequate size, irregular layout, wildfire risks, pollution risks, ADA issues, or other regulatory hurdles. Sites that do not have easy access to essential infrastructure such as power, water, and sewer will typically require site preparation that makes the project cost prohibitive.

Proprietary departments – Management of property asset data is particularly challenging for the City’s proprietary departments. These entities own or control thousands of parcels of land, much of which supports their management of critical infrastructure and transportation systems.

Given the scope and nature of capital improvement projects and upgrades taking place at the LAX, the Port of LA, and across the City’s power and water systems, it can be difficult to ensure information about properties such as their condition, and future plans for sites, is up to date and accurate. In addition, these properties are typically subject to a greater number of regulatory constraints compared to properties controlled by Council-controlled departments.

The information in the subsections below is intended to provide a point-in-time assessment on properties that should be considered for homeless housing interventions or support facilities. Our analysis was limited to properties within the City’s direct control, but properties owned/controlled by other public entities (e.g., LAUSD, Metro, Caltrans) should also be considered as part of a comprehensive approach to the issue.

It is critical to note that our process was limited to potential site identification. Actual determinations about habitability and feasibility cannot be made until subject matter experts in departments such as the Bureau of Engineering conduct formal assessments. A series of factors such as site layout, access to infrastructure, contamination/liability risks, impact on surrounding communities, and site preparation time/costs need to be considered.

In addition, it should be noted that we used minimum lot size criteria established by the City to identify potential sites. Other types of interim housing interventions may allow for greater density or smaller lot sizes.

Vacant City-owned properties – Judge Carter’s April 2021 injunction included City-owned properties that could be used for supportive/affordable housing. However, we primarily focused our efforts on City-owned sites that can be used to develop interim shelter because of the emergency nature of the situation and the relative speed at which interventions like tiny home villages, safe sleeping villages, and safe parking could be deployed.

We targeted approximately 6,000 City-owned properties which were flagged as vacant or did not have any known structures based on the database maintained by GSD. We focused on these locations because they are more likely to be available, and repurposing them would be less likely to disrupt ongoing City operations. Our methodology for identifying sites is outlined in the Appendix of this report and was based on the City’s process from the February 2021 CAO report. But there are some key issues that should be noted.

• The City’s initial feasibility screening sets a minimum three-year threshold for site availability, with a preference for sites available for up to five years. Given the urgency of the situation, we reduced this threshold to one-year and provided controlling departments with an opportunity to provide feedback.
• Some of the sites we recommended for consideration have already been formally assessed by the City. We recommended that these sites get a second look based on information provided by controlling departments or different facility types that have emerged since the original assessment was completed. For example, sites previously ruled out for bridge housing may be suitable for safe parking or tiny home villages.

Overall, we identified 26 City-owned sites which met our minimum criteria, may be habitable, and warrant formal assessment. Combined, these properties have potential to provide approximately 1.7 million square feet of space for interim housing or other types of facilities. Site profiles can be found in the Appendix of this report.

It is important to note that our Office evaluated properties based on data contained in the City’s property database, Los Angeles County Assessor records, and information about properties provided by City departments. Only properties meeting our minimum suitability criteria were considered, and our analysis did not consider the locations of the City’s potentially suitable properties. As a result, the properties identified during our research are not distributed evenly based on geographic parameters, such as Council Districts. Potentially feasible sites tend to be located in areas where the City owns large properties.

Additional analysis will be required to determine whether these potential sites are distributed equitably and overlap with areas where unhoused Angelenos are located.

Parker Center – The sheer magnitude of the homelessness crisis affects nearly every neighborhood in Los Angeles, but Skid Row has been ground zero for several decades. The most recent point-in-time count (conducted in January 2020) estimated that there were 4,662 unhoused people living in the area—more than 11% of the citywide homeless population. The conditions on Skid Row and impacts on community residents/businesses were the some of the stated reasons for the LA Alliance lawsuit. Following a tour of the neighborhood in late-2017, a United Nations (UN) official stated that the number of public toilets available to unhoused residents failed to meet minimum sanitation standards for UN refugee camps.

Mere blocks away from Skid Row sits once of the City’s most visible and centrally-located vacant parcels—the site of the former Parker Center (150 N. Los Angeles Street). Discussions about demolishing the building and constructing a new City facility in its place began as early as 2006. After several years of planning and consideration of options, the City decided to move forward with construction of a 753,740-square-foot office tower for City employees known as the Los Angeles Street Civic Building. The effort was embedded into the Civic Center Master Plan, which is a multi-year effort to add at least 1.2 million-square-feet of office space to the area around City Hall.

Demolition of the Parker Center began in 2018 and was certified as complete as of February 2020. Concurrent with that process, the City developed and issued a Request for Qualifications (RFQ) to identify a short-list of qualified teams to design, build, finance, operate, and maintain the newly constructed building. But the City canceled the RFQ due to concerns about project costs and uncertainty about potential savings associated with selling properties or terminating leases. In June 2020, the Council instructed BOE, CAO, and Economic Workforce Development Department to report back with procurement alternatives, but it does not appear that the request has been completed.

The Council recently approved a motion to explore redeveloping the Civic Center area by building 3.5 million-square-feet of housing and consolidating/building 1.5 million-square-feet of office space. Given that the larger redevelopment effort remains in flux, the Parker Center site will continue to sit dormant for an undetermined period of time. This lull presents the City with an opportunity to formally assess whether the site would be appropriate for interim housing (e.g., tiny homes, safe sleeping) or support facilities such as restrooms, showers, and laundry.

Both the location and size (> 100,000-square-feet) of the parcel are promising, but a formal assessment is needed to determine whether there are any significant contamination concerns or other issues that would make repurposing the site impractical or cost prohibitive. For example, the demolition and excavation process has left portions of the site below grade, which may present site preparation challenges.

Parking lots and underutilized properties – In addition to vacant sites or other large, unused properties, the City should consider repurposing underutilized properties to further support its homelessness initiatives. These types of sites are periodically evaluated, but establishing criteria and reporting requirements would help identify these sites on an ongoing basis.

Though sometimes an overlooked asset, many of the City’s facilities have parking lots for employees, members of the public, or City fleet vehicles and equipment. Some parking lots associated with City facilities may already possess certain characteristics that could make them suitable for repurposing. They are flat, paved, and may be located close to existing power, water, and other utility assets, which makes it easier to prepare sites for homeless housing solutions. For example, a City-owned parking lot at 19020-19040 Vanowen Street in Council District 3 was repurposed for a tiny home village.

Other large, flat, and paved spaces that are not specifically used for parking may also be suitable, such as underutilized service yard spaces. However, departments would need to carefully examine whether hosting homeless housing or safe parking programs would negatively impact operations, the safety employees or unhoused individuals, or City infrastructure.

Airport properties – Los Angeles World Airports (LAWA) is a proprietary department which maintains control of its own properties. LAWA officials reported airport properties generally cannot be used for homeless housing initiatives due to certain federal restrictions. The City would need to pay fair market value for any revenue generating LAWA properties converted to homeless housing. Another challenge is that some of the properties owned by LAWA were acquired due to public health concerns about noise or other issues.

LAWA is currently working with the FAA to determine whether airport properties identified in conjunction with a City Council District can be used to support homeless housing programs–including parcels adjacent to LAX and Van Nuys Airport. The following properties are being considered for safe parking:

• Portion of Lot E, or construction support site north of Lot E (both sites not currently in use) – 5455 W. 111th Street, Los Angeles, CA 90045; and
• Van Nuys FlyAway Overflow Parking – 7691 Gloria Ave., Los Angeles, CA 91406.

These properties are being considered for tiny home villages:

• Manchester Square – North of Century, east of Aviation, west of La Cienega; and
• Northside Phase II – North of Westchester Blvd, east of Fire Station 5, west of La Tijera.

In addition, LAWA has significant aviation‐related landholdings in Palmdale. Much of that property is not currently in use and, although LAWA is exploring potential future uses, they likely would take some time to develop. In the past, LAWA has received inquiries from the County of Los Angeles regarding the potential utilization of some portion of the Palmdale landholdings for temporary homeless housing. The following Palmdale properties are being considered:

• 4037 E Ave P-8, Palmdale, CA 93552; and
• 39516 25th Street East, at P Street, Palmdale CA 93550.

The FAA’s initial response requested additional information about how long sites would be repurposed for and LAWA’s plan to secure and maintain sites. In addition, the FAA cautioned that it would not support a plan to house people in areas that have been previously determined to be—or soon will be—incompatible with residential use.

1. The Council should instruct the CAO—in coordination with departments such as BOE, GSD, City Planning, LADBS—to complete formal site assessments for the 26 properties listed in the Appendix of this report to determine whether they can be used for interim housing or support facilities.
2. The Council should instruct the CAO—in coordination with departments such as BOE, GSD, City Planning, LADBS—to complete a formal site assessment of the Parker Center site to determine whether it can be used for interim housing or support facilities on a temporary basis until redevelopment plans are finalized. The Council should also request that LAHSA report back with options about how the site can be used to assist unhoused Angelenos in the Skid Row and Civic Center area.
3. The Council should instruct the CLA to establish a City-led interagency working group/task force to address planning, coordination, and capacity issues related to homeless housing. The working group should specifically include, but not be limited to, federal agencies, State of California agencies, the County of Los Angeles, neighboring cities, and other public sector organizations, such as universities, utilities, and transportation agencies.
4. The Council should instruct the CAO, in conjunction with GSD, to establish guidelines for when a Council-controlled department should consider a property underutilized, and develop a process by which department property managers regularly report to CAO and GSD asset management groups any properties that may be underutilized. The process should prioritize identification of underutilized parking lots and maintenance yards.
5. The Boards of Commissioners for the Department of Water and Power, Los Angeles World Airports, and Port of Los Angeles should instruct their respective departments to develop a formal process by which each entity periodically evaluates properties to identify vacant, surplus, or underutilized sites that may be suitable for homelessness initiatives. The analysis should take into account any land use, revenue, or regulatory restrictions that apply to the proprietary departments’ assets.
6. The Board of Commissioners for Los Angeles World Airports should instruct the department to continue working with the FAA to obtain permission to repurpose the six sites currently being considered and to identify additional sites for review.

Scope and Methodology – The initial property inventory provided by GSD included approximately 8,000 City-owned properties. We worked to clean/prepare the data and determined parcel sizes through a matching process with data from the Los Angeles County Assessor and other sources. Next, we identified properties that met key criteria:

• minimum 20,000 square feet lot size; and
• property status designated as “vacant” (i.e., unused) in the GSD database, properties without structure descriptions, and properties listed with an “unknown” status.

After we identified a preliminary list of properties that met our minimum size (20,000 sq. feet) and status (vacant/unused) criteria, we reached out to the relevant City departments to obtain additional information about the property to determine suitability. This process also offered departments with an opportunity to suggest additional sites which may not have been identified during our analysis of GSD data.

• Is the property primarily under your department’s control?
• Does the property have any buildings on it?
• Is the property vacant or unused land?
• Does your department or the City have any plans to develop the property in the next year?
• Are there any public health, public safety, or environmental risks associated with the property?
• Is the property subject to legal/regulatory restrictions prohibiting its use for homeless housing or shelter?
• Has your department or the City ever considered using the property for homeless housing or shelter?

Finally, we conducted site visits for selected sites to make basic observations about site conditions in accordance with guidance provided by BOE. These site visits and observations were preliminary in nature and are not intended to replace formal assessments for suitability by subject matter experts in City departments.

Research limitations – We did not include the properties of three City departments in our parcel-by-parcel analysis. However, it is important to note that this exclusion is not an indicator that these departments do not have an important role in assisting with the City’s overall effort to identify and evaluate its properties for interim shelter.

Recreation and Parks – Although RAP manages more than 400 park sites—many with large open spaces—the City’s parks, recreational sites, and cultural centers host a wide variety of programs and events and are widely used by members of the community. As a result, these sites did not meet the vacant/unused criteria in our analysis. However, underutilized parking lots or operations yards on RAP-controlled property may be appropriate.

Department of Water and Power – We sought from LADWP additional clarifying information for approximately 600 properties. However, the complex nature of the department’s infrastructure assets made obtaining information about each site from managers and technical specialists from across the water and power systems difficult. LADWP representatives noted that open spaces owned by the department are often not well-suited for housing because the sites host critical infrastructure, some of which can be underground.

Los Angeles World Airports – We did not assess the suitability of LAWA properties as part of our review. LAWA officials reported that the use of airport land is under the oversight of the Federal Aviation Administration (FAA) and, generally, airport properties cannot be used for housing due to grant assurances that set forth incompatible land uses; FAA requirements that the airport receive fair market value for the use of their property; specific grant assurances that preclude the erecting of structures or bringing together person, accept for the parking of automobiles; and/or other FAA rules and regulations regarding the use of airport land.

Results – Overall, we identified 26 vacant/unused City-owned sites which met our minimum criteria, may be habitable, and warrant formal assessment. Although entire sites may not be buildable or suitable for housing or other facilities, the combined parcel square footage for the locations we identified is approximately 1.7 million square feet.

The property profiles that follow provide basic information about the sites and potential issues affecting site viability. We recommend that the City undertake formal assessments of these sites to determine whether they can used for bridge housing, safe parking, safe sleeping villages, or tiny home villages.

View a list of the identified 26 vacant/unused City-owned sites.