AB 39 obliges every California city, county, or city and county with more than 75,000 residents to adopt — or fold into their next general plan update — a local electrification, decarbonization, or community energy plan between January 1, 2027 and January 1, 2030. The required plans must identify local opportunities for EV charging and other zero-emission fueling, strategies for electrifying buildings (including incentives for low-income households), expansion of distributed renewable energy and storage, medium- and heavy-duty fleet refueling needs, and locations where grid upgrades will be necessary, all developed in coordination with the relevant utilities and load-serving entities.
The law matters because it shifts the mapping and prioritization of California’s on-the-ground electrification investments to local planning cycles, while also making those plans count as regional plans under CEQA Section 15125. That combination creates both an operational roadmap for infrastructure siting and a potential lever for streamlining environmental review — but it also raises practical questions about funding, utility coordination, and how jurisdictions will translate “identifying opportunities” into deliverable projects that benefit disadvantaged communities and low-income households.
At a Glance
What It Does
The bill requires qualifying jurisdictions to prepare and adopt a local electrification or decarbonization plan (or integrate such a plan into the general plan) that lists goals, policies, and feasible implementation steps covering EV charging, building electrification incentives, distributed energy resources, zero-emission fleet needs, and grid upgrade priorities. Plans must be developed in coordination with local publicly owned utilities, electrical corporations, and applicable load‑serving entities.
Who It Affects
Cities, counties, and consolidated city‑counties in California with populations above 75,000; local publicly owned electric utilities, investor‑owned electrical corporations, and load‑serving entities; developers and operators of EV charging and distributed energy projects; disadvantaged communities and low‑income households targeted for prioritized investments.
Why It Matters
By forcing jurisdictions to inventory infrastructure needs and identify implementation measures, AB 39 creates a predictable, locally grounded pipeline for electrification projects and signals priorities for funders and utilities. Designating these plans as regional plans under CEQA can change how environmental impacts are disclosed and considered at the project level.
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What This Bill Actually Does
AB 39 tells larger California cities and counties to prepare a locally grounded plan for electrification and decarbonization and gives them a three‑year window to do it. The statute does not prescribe a single template: jurisdictions can adopt a standalone electrification or community energy plan, or they can fold the required content into their next general plan update.
The obligation is to set locally based goals, policies, and feasible implementation measures — that is, concrete actions the locality can take to promote electric vehicle charging, building electrification incentives, distributed energy, and related infrastructure.
The bill enumerates six core topic areas for those plans: expanding EV charging and zero‑emission fueling (including removal of barriers); siting charging in residential, retail, commercial, and on‑street locations and creating public street charging corridors where needed; strategies to publicize, incentivize, and subsidize electrification of new and existing buildings (but not imposing building code requirements beyond state or federal law); expanding distributed renewable and storage resources such as rooftop and community solar and microgrids; identifying areas where medium‑ and heavy‑duty zero‑emission fleet infrastructure will be required; and coordinating with utilities and load‑serving entities to identify grid upgrade needs. The statute’s language focuses on identification and strategy rather than imposing immediate construction mandates.Importantly for environmental review and project proponents, a plan adopted to satisfy AB 39 is deemed a regional plan under CEQA’s Section 15125, which affects how cumulative and regional impacts are discussed in environmental documents.
The law also contains an explicit equity strand: jurisdictions must include policies or implementation measures that prioritize investments that directly benefit disadvantaged communities, low‑income households, and small businesses. Finally, AB 39 narrows the statutory definition of “decarbonization” to exclude building code and building‑material mandates, and it clarifies that jurisdictions may use preexisting plans or existing general plan provisions to meet the requirement if those documents already cover the statutory elements.
The Five Things You Need to Know
Jurisdictions must adopt an electrification/decarbonization/community energy plan — or integrate equivalent language into the general plan — on or after January 1, 2027 but no later than January 1, 2030.
The requirement applies only to cities, counties, and city‑counties with populations greater than 75,000 residents.
Plans must be developed in coordination with local publicly owned electric utilities, electrical corporations, and, if applicable, other load‑serving entities to identify where grid upgrades will be needed.
A plan adopted or designated to comply with this law is deemed a regional plan for purposes of CEQA Section 15125, affecting how regional and cumulative environmental impacts are considered.
The statute defines “decarbonization” to exclude building code or building‑material requirements and explicitly states a city or county is not required to include such building code mandates in its plan to the extent barred by state or federal law.
Section-by-Section Breakdown
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Deadline, plan types, and overall content requirement
This subdivision sets the adoption window (on or after Jan 1, 2027 but no later than Jan 1, 2030) and gives jurisdictions a choice: prepare a standalone electrification/energy/decarbonization plan or integrate the required content into the next general plan update. The language requires locally based goals, objectives, policies, and “feasible implementation measures,” which pushes jurisdictions to go beyond vision statements toward actionable steps (permitting changes, incentive programs, capital projects or prioritized investment lists) without prescribing a single approach.
EV charging and publicly accessible charging corridors
These clauses demand inventories and strategies for expanding EV charging across private parking (residential, retail, commercial), public streets, and visitor destinations, and they call for removing barriers to expansion. Practically, that will force planners to assess curb access, parking rules, permitting timelines, curbside electrical capacity, and potential street‑level corridor designations — all issues that affect siting feasibility and timing for public and private charging investments.
Building electrification incentives and distributed energy resources
The bill asks jurisdictions to identify strategies to electrify new and existing buildings, explicitly encouraging incentives and subsidies for property owners and low‑income households while stopping short of imposing local building code mandates. It also requires identifying opportunities for distributed renewable resources and storage (rooftop/community solar, microgrids, batteries), which means plans should map locations suitable for DERs and consider interconnection, land use, and storage siting issues that affect local resilience and reliability.
Medium/heavy‑duty fleets and grid upgrade coordination
Jurisdictions must identify areas where public or private medium‑ and heavy‑duty zero‑emission fleets operate and will need fueling or charging infrastructure, and they must coordinate with local publicly owned utilities, electrical corporations, and other load‑serving entities to map where distribution or transmission upgrades will be necessary. This coordination clause ties municipal planning to utility capital planning cycles and raises the practical need for data‑sharing agreements and timelines aligned with utility upgrade lead times.
Compliance options, applicability, CEQA status, and definitions
Subdivision (b) lets jurisdictions designate existing similar plans or rely on current general plan provisions if they already meet the statutory elements, reducing duplication where appropriate. Subdivision (c) limits the mandate to jurisdictions with over 75,000 people. Subdivision (d) declares a qualifying plan a ‘regional plan’ for CEQA Section 15125, affecting environmental review of cumulative impacts. Subdivision (e) supplies definitions, notably excluding building code and material mandates from the meaning of “decarbonization,” and cross‑references utility and income definitions from existing code sections.
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Explore Energy in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Disadvantaged communities and low‑income households — the law requires prioritized and equitable investment policies, making these communities explicit targets for subsidies, incentives, and siting of charging and clean energy projects.
- Regional and local planners — the statute creates a clear scope for electrification planning, giving planning teams a mandated checklist and CEQA status that can support coordinated infrastructure pipelines.
- Clean energy and EV infrastructure developers — early identification of corridors, sites, and grid constraints reduces siting uncertainty and helps build a project pipeline that financiers and utilities can evaluate.
- Public and private fleet operators planning zero‑emission transitions — the requirement to map fleet infrastructure needs gives fleets a clearer picture of where charging/refueling investments and grid support will be prioritized.
Who Bears the Cost
- Cities, counties, and city‑counties over 75,000 residents — they must allocate staff time and budget to prepare plans (or amend general plans), host outreach, and carry forward implementation steps without a guaranteed funding source.
- Local publicly owned utilities and electrical corporations — required coordination to identify grid upgrade needs will likely lead to additional studies, planning costs, and eventual capital investments that affect ratepayers and utility capital programs.
- State and local taxpayers or utility ratepayers — paying for identified grid upgrades, public chargers, subsidies, or incentive programs will require funding that ultimately falls on public budgets or utility rates unless covered by grants.
Key Issues
The Core Tension
The law balances two legitimate goals — accelerating electrification to meet climate and air quality goals, and preserving local planning discretion and fiscal limits — but that balance is uneasy: local plans can identify infrastructure needs and prioritize equity, yet jurisdictions and utilities may lack clear funding, authority, or aligned timelines to turn those plans into delivered projects, shifting difficult trade‑offs onto ratepayers, local budgets, and future permitting cycles.
AB 39 creates a planning requirement that helps expose where investments are needed, but it does not secure funding or assign construction obligations. That creates a familiar implementation gap: jurisdictions will produce priority lists and feasible measures, yet the statute contains no dedicated revenue, grant trigger, or mandate that utilities or developers pay to implement the plans.
Coordination language with utilities is necessary but non‑binding; the bill doesn’t change utility rate‑making or capital authorization processes, so timelines and cost allocation for grid upgrades will still follow utility and CPUC rules.
The statute’s substantive language emphasizes “identification” and “feasible implementation measures” rather than mandated timelines for project delivery, which preserves local discretion but also introduces ambiguity about the level of detail required. The CEQA designation as a regional plan can help frame cumulative impacts, but how courts and lead agencies treat that designation will depend on the depth of analysis in each plan.
Finally, the equity obligation focuses on prioritizing investments for disadvantaged and low‑income communities, but absent dedicated funding or specific entitlement changes, those promises risk remaining aspirational unless the state or other funders align resources with the locally identified priorities.
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