Learning Lessons from Los Angeles’s TOC Program

Challenges and opportunities as TOC continues to drive affordable housing production

I’ve written before about Los Angeles’ Transit Oriented Communities (TOC) Program, an inclusionary housing program designed to allow for increased density in residential and mixed-use projects near major transit stops in exchange for a developer commitment to include a set percentage of affordable housing units in those projects.  Since implementation began in late 2017, the TOC Program has consistently been the City’s strongest driver of affordable housing production.

The TOC Program is just one response to two of California’s most significant challenges: a dire lack of affordable housing and the fight against climate change.  In recent years, municipalities throughout California have struggled to meet housing needs, and construction of new housing units in the state has not kept apace of demand, resulting in increased housing costs that rank among the highest in the nation.  At the same time, California faces pressure to achieve ambitious greenhouse gas reduction goals in the relatively near term.  Meeting those goals will require significant decreases in transportation sector emissions, which represent about 40 percent of the state’s GHG emissions.  Particularly impacted by both the affordability and climate change crises are low-income Californians, whose communities suffer disproportionate impacts from lack of housing availability and vulnerability to climate change—and who also are California’s most reliable transit riders.

Transit-oriented development initiatives like the TOC Program are one possible way to address these issues.  While the TOC Program is currently facing a legal challenge from a well-known Los Angeles slow-growth group, it remains an important example of transit-oriented inclusionary housing policy.  It’s worth exploring both the ways in which structural and legal constraints may be impeding the TOC Program’s full capacity to augment affordable housing supply and the lessons that lawmakers seeking to tackle both housing and greenhouse gas reduction goals can take away from the program’s implementation to date.  To that end, I’ve authored a Pritzker brief that takes a look at some of the program’s constraints and offers recommendations to increase the program’s efficacy.  It also explores how the program can provide data and lessons learned to lawmakers considering similar inclusionary transit-oriented development programs within their jurisdictions, or even at the state level.

The paper’s recommendations include:

  • Alterations to the TOC Program itself to address existing structural and legal hurdles to its full implementation, including through better interagency coordination, adoption of a pilot program to test limited streamlining efforts, and expansions of its applicability;


  • Better data collection and analysis to assess the program’s performance to date, including data regarding discretionary and non-discretionary program applications, legal challenges to applicant projects, neighborhood patterns and demographics in program incentive areas, and trends in vehicle miles traveled (VMT) and transit ridership among applicant project occupants; and


  • Lawmaker attention to lessons learned from TOC Program implementation, including stakeholder experiences, the relationship of the discretionary approval process to the program’s efficacy, financial constraints impacting developer utilization of the program, and a critical review of affordability designations and requirements associated with the program.

As lawmakers throughout the state work to tackle climate change and improve housing outcomes for Californians, the TOC Program’s implementation can offer important insights and serve as a valuable trove of information.

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Reader Comments

One Reply to “Learning Lessons from Los Angeles’s TOC Program”

  1. And don’t forget parking:
    1. ax the state law banning charging market rate for preferential residential area permits, and
    2. block residents of new transit-adjacent buildings from getting area permits. (keeping “California’s most reliable transit riders” riding)

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About Julia

Julia Stein is Supervising Attorney for the Frank G. Wells Environmental Law Clinic, and Project Director for the Emmett Institute on Climate Change and the Environment a…

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About Julia

Julia Stein is Supervising Attorney for the Frank G. Wells Environmental Law Clinic, and Project Director for the Emmett Institute on Climate Change and the Environment a…

READ more