AB 735 supplies a definitions framework that ties planning and zoning treatment to concrete green‑building and equipment standards for logistics use developments. It establishes two named categories — “21st century warehouse” and a more demanding “Tier 1 21st century warehouse” — each of which bundles energy, charging, and equipment requirements that projects must meet at building‑permit time.
Beyond technical standards, the bill fixes a 20% expansion threshold (excluding office space) for when an existing facility is considered an expansion, lists exclusions (rail‑served and retail‑facing facilities among them), and defines “sensitive receptors” and a named Inland Empire “warehouse concentration region.” The definitions will function as gating criteria in subsequent zoning, permitting, and incentive decisions and will influence developers, operators, utilities, and neighboring communities.
At a Glance
What It Does
Defines two regulatory categories of logistics buildings and prescribes specific building features (photovoltaics, cool roofing, skylights or efficient lighting), EV charging readiness and minimum installed chargers, microgrid/smart‑meter readiness for Tier 1, and equipment emissions standards for forklifts and small off‑road engines.
Who It Affects
Commercial developers, warehouse operators, trucking and fleet managers, EV charging and battery contractors, utilities responsible for grid upgrades, and local planning agencies handling zoning and permits in areas with logistics activity.
Why It Matters
By converting performance features into statutory definitions, the bill makes those features a formal lever in land‑use decisions and permit compliance; it also creates deadlines and feasibility tests that will drive capital investments, grid planning, and contracting practices in the logistics sector.
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What This Bill Actually Does
AB 735 is a definitions bill that converts a package of energy, charging, and equipment requirements into statutory categories used for planning and zoning. It creates two labels — “21st century warehouse” and “Tier 1 21st century warehouse” — and ties each label to a checklist of design and operational elements.
The statute treats these labels as objective yardsticks: a project either meets the listed criteria at the time its building permit is issued or it does not.
The baseline “21st century warehouse” requires compliance with the current Title 24 energy and green‑building standards plus specific features such as photovoltaic systems with battery storage, cool roofs, EV charging readiness, skylights or equivalent LED lighting, high‑efficiency HVAC, and electrical hookups at cold‑storage loading bays. The higher “Tier 1” level layers on grid preparedness measures — microgrid‑ready switchgear, smart‑metering readiness — and stricter parking and EV infrastructure minimums, including conduit in half the passenger spaces and installed chargers for at least 10 percent of passenger parking.Operational equipment is also covered.
The bill incorporates the State Air Resources Board’s forklift rule timelines into its definitions, requires small off‑road engines and on‑site forklifts to be zero‑emission to the extent they are operationally and technically feasible, and prohibits truck idling at cold‑storage bays where a plug‑in option and sufficient power exist. For feasibility, the statute explicitly bars cost as a factor, directing users to consider only technical operability, commercial availability, and on‑site power capacity.Finally, AB 735 defines what counts as a logistics use development for zoning purposes and lists several exclusions — most notably rail‑served facilities, Strategic Intermodal Facilities, retail storefronts, and short‑term agricultural structures.
It defines what constitutes a sensitive receptor (residences, schools, daycare, most parks and hospitals) and names a specific “warehouse concentration region” in the Inland Empire, which signals geographic areas where these definitions will be especially relevant for planning and mitigation decisions.
The Five Things You Need to Know
The bill defines an “expansion” as any enlargement of an existing logistics facility by 20% or more of its square footage and explicitly excludes office space from that calculation.
For baseline 21st century warehouses, the bill requires forklifts to be zero‑emission by January 1, 2030, 'to the extent operationally feasible, commercially off‑the‑shelf available, and adequate power available on site.', Tier 1 warehouses must be microgrid‑ready, smart‑metering ready, preinstall conduit in at least 50% of passenger parking, and have at least 10% of passenger parking equipped with EV chargers.
The statute prohibits truck idling or use of auxiliary engine power to run cold‑storage climate control at loading bays if the truck can plug in and sufficient power is available at the bay.
In assessing whether zero‑emission equipment is required, the bill bars using cost as a factor — operational feasibility, commercial availability, and on‑site power are the only permitted considerations.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Definition: '21st century warehouse' (baseline standards)
This provision lists the baseline building and operational elements a logistics development must have to be a “21st century warehouse.” It cross‑references current Title 24 energy and green‑building standards and then adds specific items such as photovoltaic installations with battery storage, cool roofing, EV charging readiness for medium/heavy and light‑duty vehicles, skylights or equivalent LED lighting, high‑efficiency HVAC, electrical hookups at cold‑storage loading bays, and a requirement to move toward zero‑emission forklifts and small off‑road equipment when feasible. Practically, this turns technical construction and equipment features into a statutory checklist evaluated at permit time.
Definition: 'Tier 1 21st century warehouse' (enhanced standards)
Tier 1 packages stronger resilience and electrification requirements: it repeats many baseline items and adds being microgrid‑ready, advanced smart‑meter ready, and specific parking EV infrastructure thresholds (conduit in at least 50% of passenger spaces and 10% installed chargers). It also accelerates the forklift zero‑emission date to January 1, 2028. The Tier 1 label is explicitly more demanding and will be the reference point when jurisdictions or programs call for higher performance standards.
Expansion threshold and 'logistics park' definition
The bill defines 'expansion' as a 20% or greater increase in existing logistics square footage and excludes office space from that calculation—this matters for permit reviews and potential re‑entitlement triggers. It also defines 'logistics park' as a multi‑building development of logistics uses, clarifying that these definitions apply to both single buildings and multi‑building campuses.
What is—and is not—a 'logistics use development'; truck classes
The statute defines logistics use developments as primarily warehouse buildings moving or storing goods where heavy‑duty (class 7/8) trucks are primary movers, and it spells out exclusions: retail storefronts open to the public, predominantly rail‑served buildings, Strategic Intermodal Facilities (with an explicit multi‑criteria definition), and short‑season agricultural buildings. The separate definition of class 7 and 8 trucks standardizes what counts as heavy‑duty for policy and enforcement purposes.
Sensitive receptor definition and park exceptions
AB 735 defines 'sensitive receptor' to include residences, schools, daycare, most parks used by children, nursing homes, and hospitals, but it carves out parks or public access areas that are included as conditions of approval for the logistics project, coastal/public access land, or land developed as airport/seaport buffers. This narrows when nearby open space counts as a receptor requiring special mitigation or siting consideration.
Equipment emissions and feasibility test
The bill incorporates the State Air Resources Board's forklift regulation timelines and mandates zero‑emission small off‑road engines where operationally and technically feasible; where not feasible, the cleanest commercially available technology must be used. Crucially, the text disallows cost as a factor when deciding operational feasibility, focusing determinations on technical operability, market availability, and on‑site power capacity—this raises practical questions for permitting and compliance verification.
Warehouse concentration region
The statute names a specific geographic 'warehouse concentration region' covering unincorporated Riverside and San Bernardino counties and a list of Inland Empire cities. By calling out this region, the bill signals where these definitions and any downstream regulatory or mitigation expectations will have heightened relevance, potentially channeling many requirements and scrutiny to already high‑logistics areas.
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Explore Infrastructure 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
- Residents and sensitive sites near logistics facilities — tighter definitions and equipment standards aim to reduce local air and noise impacts from idling and diesel equipment, potentially improving neighborhood air quality over time.
- Employees working in compliant warehouses — improved HVAC, lighting, on‑site power readiness, and electrification of forklifts and equipment can reduce workplace exposures and create demand for new technical skills.
- Utilities and EV charging providers — new conduit, charger installation requirements, and microgrid readiness will create contract and project opportunities for grid upgrades, battery storage, and charging infrastructure deployment.
- Municipalities in the named warehouse concentration region — having clear statutory definitions helps planning departments apply consistent permitting rules and justify mitigation conditions tied to the bill’s performance criteria.
Who Bears the Cost
- Warehouse developers and property owners — higher upfront capital costs for PV+storage, microgrid‑ready switchgear, EV charger infrastructure, and zero‑emission on‑site equipment will increase construction and fit‑out budgets.
- Logistics operators and fleet managers — accelerating adoption timelines for zero‑emission forklifts and contracting preferences for zero‑emission small off‑road equipment will force fleet replacement and procurement changes.
- Utilities and distribution system operators — the bill’s EV and microgrid requirements will likely require distribution upgrades, interconnection work, and new demand management programs, which can strain local grid capacity planning.
- Contracted service providers using small off‑road engines (landscaping, maintenance) — suppliers who rely on internal combustion small engines may face higher compliance costs and the need to source new zero‑emission equipment.
Key Issues
The Core Tension
AB 735 pits an aggressive, technology‑forward approach to decarbonizing and modernizing warehouses against practical constraints of grid capacity, equipment availability, and permitting mechanics: the law demands quick adoption of zero‑emission technologies and grid‑ready infrastructure while intentionally prohibiting cost as a rationale for delay, leaving implementers to reconcile ambitious environmental goals with technical and logistical realities.
The bill sets technical and operational standards but leaves multiple implementation questions unresolved. It requires feasibility assessments that exclude cost as a consideration, which creates a doctrinally precise but practically awkward test: who makes the call that a technology is 'operationally feasible' or that 'adequate power' exists on site?
Absent a clear administrative process or appeal path, developers and local permitting agencies will face legal and technical disputes over these determinations.
Grid capacity is another open issue. Tier 1’s microgrid‑ready and EV parking requirements assume the availability of on‑site and upstream power, but many distribution systems in logistics hubs are already near capacity.
The statute does not allocate funding or create a statewide interconnection fast‑track, so meeting the power and charger requirements may depend on utility timelines, rate decisions, or off‑site grid reinforcement. That creates a timing mismatch between building permits (which fix the applicable Title 24 standards at permit issuance) and broader grid build‑out schedules.
Finally, the bill’s geographic focus on Inland Empire jurisdictions and its exclusion of rail‑served and intermodal facilities implicitly steers certain types of freight development away from ports and rail corridors and toward truck‑served inland locations. That reallocation could reduce exposure near ports but increase traffic, land‑use pressure, and cumulative impacts in defined warehouse concentration regions—precisely where AB 735 imposes its standards, potentially amplifying local infrastructure strains without providing compensating investments.
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