California’s SB 415 Amends AB 98: New Standards for Logistics and Warehouse Projects

California's landmark Assembly Bill 98 (AB 98), authored by Carrillo and Reyes in 2024, established the state's first comprehensive standards for the siting and operation of logistics developments, including warehouses, distribution centers, and similar freight operations.

While AB 98 aimed to address environmental and equity concerns in regions with a high density of warehouses, the broad and often ambiguous mandates imposed on local governments and developers across California led to more problems than solutions. From the beginning, both legislators and advocates acknowledged the need for a "cleanup" bill to provide a more precise and balanced approach to regulating logistics developments while still maintaining the original intent behind AB 98.

On Friday, October 3, 2025, Governor Newsom signed Senate Bill 415 (SB 415), introduced by Reyes in 2025. This new bill addresses several recognized issues with AB 98 but still leaves some questions unanswered. For a more detailed discussion about AB 98, please refer to our legal alert and webinar on the topic.

The amendments in SB 415 are generally favorable to developers and local agencies. To learn more about SB 415, we invite you to join our webinar on November 12, 2025. Click here to register.

Developers

Clarifying Definitions

• Defining Logistic Use Developments. AB 98 included a definition for “logistics use,” but it also used terms such as “logistics use development” and “logistics facility” when discussing various development standards and conditions. This mixing of similar but distinct terms created uncertainty regarding the interpretation of the bill. SB 415 addresses this uncertainty by consistently using the term “logistics use development” throughout the law.
• Logistics Use Development Exemptions. The exemptions listed in AB 98 were ambiguous regarding whether a manufacturing or agricultural use qualified as a logistics use development. SB 415 clarifies that manufacturing uses with ancillary distribution do not qualify as logistics use developments. It also provides an exception for buildings that are primarily used for agricultural operations when the use is limited to a single period of 90 consecutive days or less each year.
• Defining Sensitive Receptors. SB 415 adds two exceptions to AB 98’s sensitive receptor definition: (1) land used to ensure the public’s right of access to the sea, or other public access, pursuant to the California Coastal Act or the McAteer-Petris Act; (2) Land developed at or adjacent to an airport or seaport for the express purpose of creating a buffer area between sensitive receptors and an airport or seaport facility.
• Defining Warehouse Concentration Region. AB 98 defined the Warehouse Concentration Region to include the Counties of Riverside and San Bernardino, as well as several cities within those two counties. SB 415 clarifies that the reference to the Counties of Riverside and San Bernardino was to the unincorporated areas of those counties.
• Multi-Building Projects. AB 98 did not distinguish between projects that contained a single building and those that contained multiple buildings. The lack of differentiation created issues in determining whether specified AB 98 development standards applied on a building-by-building or project-by-project basis. SB 415 adds a “Logistics Park” definition to distinguish standards applicable to multi-building projects. Most development standards will now apply on a building-by-building basis, but (as explained below) the separate truck entrance requirement can be satisfied on a building-by-building or project-by-project basis.
• Rezone Clarification. AB 98 imposed additional development standards on logistics use developments within 900 feet of a sensitive receptor that are: (1) “on land not zoned industrial; or (2) on “land that needs to be rezoned.” SB 415 clarifies that annexing land into a jurisdiction does not qualify as rezoning the property if the zoning in the annexing jurisdiction is similar to the zoning applicable to the property in the prior jurisdiction.

Clarifying Standards

• Access Requirements. Beginning January 1, 2026, all new logistics use developments will need to be sited on specified roadways. One of the roadways permitted under AB 98 was local roadways that predominantly served commercial uses. SB 415 expands the types of local roadways that can accommodate logistic use developments to include roadways that predominantly serve agricultural or industrial uses in addition to commercial uses.
• Separate Truck Entrance. AB 98 required a logistics use development within 900 feet of a sensitive receptor that is 250,000 square feet or larger, or requires a zone change to have a separate truck entrance. SB 415 clarifies that a driveway with a lane dedicated to heavy trucks qualifies as having a separate truck entrance. It also clarifies that projects with more than one building need only include a single separate entrance for the entire project, not one for each building.
• Truck Bay Orientation. AB 98 required a logistics use development within 900 feet of a sensitive receptor to orient truck loading bays on the opposite side of the sensitive receptor (to the extent feasible). SB 415 makes two notable changes to this development standard. First, it softens the orientation requirement by requiring the loading docks to be located “away from” the sensitive receptor, rather than on the “opposite side” of the sensitive receptor. Second, it clarifies what to do if there are multiple sensitive receptors on different sides of the logistics use development by requiring the loading docks to be located away from the nearest sensitive receptor (to the extent feasible).
• Buffer Area. AB 98 required specified buffer areas for logistics use developments within 900 feet of a sensitive receptor, but it was unclear what could be included in the buffer area. SB 415 clarifies that the buffer area may include landscaping, access, hardscape, and improvements for passenger vehicle parking. It also clarifies that the buffer area may include “any landscaped areas within a public-right-of-way or public or private pedestrian walkways.”
• Idling Standards. AB 98 required a logistics use development within 900 feet of a sensitive receptor to prohibit idling or using auxiliary engine power for climate control equipment if the truck is capable of plugging in at the loading dock. SB 415 provides an exception to this prohibition if sufficient power is not available.
• Timing of Energy Standards. AB 98 required a logistics use development within 900 feet of a sensitive receptor to comply with the most current building energy efficiency standards in CalGreen. However, it was unclear whether a developer must comply with the standards in effect at the project approval stage or the building permit stage. SB 415 clarifies that a logistics use development must comply with the energy efficiency standards in effect at the time the building permit is issued.
• Clarifies Small Off-Road Engine. AB 98 required logistics use developments within 900 feet of a sensitive receptor that either: (1) are 250,000 square feet or larger; or (2) require a zone change to use only zero-emission small off-road engines (subject to strict feasibility exceptions). SB 415 clarifies the definition of a small off-road engine to mean spark-ignition engines rated at 19 kilowatts or less, or 25 horsepower or less.
• Housing Replacement Obligation. SB 415 clarifies that the AB 98 housing replacement obligation is supplemental to the housing replacement obligation outlined in the Housing Crisis Act of 2019.

Cities and Counties

• Alternative Compliance for Truck Route Requirements. AB 98 required all cities and counties to amend their respective circulation element to include a truck route that avoids residential communities. SB 415 permits jurisdictions outside the Warehouse Concentration Region to adopt an ordinance rather than adopting a full general plan circulation element amendment.
• Timing for Truck Route Compliance. AB 98 required all jurisdictions in the Warehouse Concentration Region to amend their circulation elements by January 1, 2026, and all jurisdictions outside the Warehouse Concentration Region to amend their circulation elements by January 1, 2028. SB 415 extends the compliance date by two years (i.e., January 1, 2030) for smaller jurisdictions outside the Warehouse Concentration Region. Smaller jurisdictions” include cities with a population of 50,000 or less and counties with a population of 100,000 or less. SB 415 also exempts cities and counties with no existing or approved logistics facilities until they approve their first logistics project. Once such a project is approved, the jurisdiction has two years to complete its ordinance or plan update.
• Enforcement Officer. SB 415 requires cities and counties that must adopt a truck route to appoint at least one enforcement officer who has completed specified training provided by the California Highway Patrol, assuming such training is available and at no cost.
• Attorney General Enforcement. AB 98 permitted the Attorney General to impose a fine of up to $50,000 every six months for a jurisdiction’s failure to comply with the truck route requirement. SB 415 now requires the Attorney General to file a lawsuit before levying a fee for noncompliance with the truck route requirement. SB 415 also softens enforcement by allowing a judge to consider whether the city or county “is making a good faith effort” to comply with the truck routing requirement.
• Preemption. SB 415 prohibits cities and counties from adopting or enforcing any rule or standard that would prevent a logistics use development from complying with the standards outlined in AB 98 (as amended by SB 415).

SB 415 represents an important step toward refining California’s approach to regulating logistics use developments. If you have questions about how SB 415 or AB 98 may impact your projects, please contact the Allen Matkins Land Use & Natural Resources team.