AB-602’s Capital Improvement Plan Mandate for Large Jurisdictions

AB-602 made one thing clear: for California’s largest jurisdictions, charging development impact fees without a detailed roadmap of projects is no longer an option. The law defines “large jurisdiction” as any county with more than 250,000 residents, along with every city within such a county. That captures most of California’s urban regions, and it sets a higher bar for them than for smaller communities.

The higher bar is the requirement to prepare and adopt a Capital Improvement Plan as part of the fee program. In simple terms, the CIP is the anchor document that transforms fee schedules from abstract numbers into visible commitments. It tells the story of how dollars collected from new development will be invested back into the community in the form of infrastructure and facilities.

But not just any project list will do. AB-602 pushes large jurisdictions to spell out their CIPs with real precision. Each plan must identify specific projects, describe what those projects will deliver, and show where and when they will be built. It must estimate the total costs of those projects, and just as importantly, break out the share of those costs attributable to new growth versus the share that benefits the existing population. That allocation is the heart of the fairness test — ensuring that fees paid by developers go only toward the portion of facilities needed to serve new residents and businesses.

Timing also matters. A compliant CIP should lay out a schedule, indicating when projects are expected to break ground and when they will be completed. That timeline ensures accountability: funds are not just collected but are tied to improvements the community can track. The plan must also line up with broader policy and planning documents, such as the General Plan and departmental master plans, so that every piece of infrastructure connects back to long-term community goals.

For large jurisdictions, this requirement reshapes the entire process of fee adoption. Instead of relying on broad categories like “parks” or “roads,” cities and counties must put forward an itemized, transparent roadmap — one that can be reviewed, debated, and updated as circumstances evolve. The Capital Improvement Plan becomes the linchpin of both legal defensibility and public trust.

AB-602 raises the stakes, but it also raises the opportunity. By demanding detailed, transparent CIPs, the law gives large jurisdictions a chance to show that growth will be matched with real, tangible investments. In a state where development pressures and infrastructure needs often collide, the CIP requirement offers a way forward that is both fair and accountable: growth pays its way, and communities see the results in bricks, mortar, and public facilities.