Town Hall: SB 415 Updates to California’s Warehouse Standards Requirements

AIR CRE hosted a Town Hall on November 12, 2025, led by Skyler Wonnacott, Vice President of Government Relations for the California Business Properties Association (CBPA), to walk Members through the significant changes affecting warehouse development and operations under California’s newly clarified Warehouse Standards.

The session focused on SB 415, the 2025 follow-up legislation that corrects and clarifies the 2024 21st Century Warehouse Standards (AB 98). Although AB 98 introduced the first statewide development requirements for large logistics facilities, the original language was unclear, inconsistent across jurisdictions, and in some cases impossible to implement. SB 415 delivers technical fixes and establishes the final, enforceable framework that applies moving forward.

This article provides:

• A recap of the most important points from the Town Hall
• A detailed explanation of the final requirements now in effect
• A full breakdown of each compliance category with Compliance Determination (when it applies) and Compliance Requirements (what must be done)
• The remaining unresolved issues (particularly redevelopment)

Overview: Why SB 415 Was Necessary

When AB 98 passed in 2024, it imposed new setback, buffering, truck routing, design, environmental, and operational requirements on logistics facilities.

But AB 98 was also:

• passed via last-minute amendments
• missing key definitions
• internally inconsistent
• interpreted differently across cities
• overly rigid for real-world logistics operations

Local governments struggled to determine exemptions. Developers could not model compliance. Cross-dock buildings appeared prohibited. Many infill and Inland Empire sites were rendered unusable.

CBPA, local governments, and industry partners formed a coalition to secure clarifications through SB 415. SB 415 does not undo AB 98. It makes AB 98 possible to implement.

1. Definition: “Logistics Use Development” (Foundational Requirement)

Compliance Determination

A project counts as a Logistics Use Development if it meets all of the following:

• It is a single building
• Primarily used for warehouse / storage operations
• Heavy-duty trucks are involved
• Goods move to business or retail customers (not onsite retail pickup)

SB 415 explicitly excludes:

• Agriculture (seasonal, ≤90 days active operation)
• Manufacturing
• Airports and seaports
• Coastal Act buffer lands
• Public access buffer areas
• Buildings serving onsite retail customers
• Facilities that are not primarily warehouse/logistics in purpose

If the use does NOT meet this definition, the rest of AB 98 does not apply.

2. Size Threshold: 250,000+ SF (Per Building)

Compliance Determination

The warehouse standards apply only if:

• The logistics use building is ≥250,000 sq. ft.
• Measured per building only (NOT cumulative site square footage)
• Office square footage is excluded from the calculation
• If expansion pushes a building past the 250,000-SF threshold, the law applies

Clarifications from Town Hall Q&A:

• A 240,000 SF building with 20,000 SF of office = 240,000 SF logistics → not subject
• Two buildings of 150,000 SF each do not combine to trigger the law
• Expanding a 240,000 SF building by 20% (logistics portion) will trigger AB 98
• Raising the roof:
  • If square footage does not increase → not triggered
  • If raising the roof creates added mezzanine/floor area → may trigger
  • Final interpretation may depend on local jurisdiction
• Rehab without added square footage never triggers AB 98
• Demolition + rebuild currently triggers (this is not fixed)

Compliance Requirements

If the building meets or exceeds 250,000 SF, it must comply with ALL applicable AB 98/SB 415 standards, including:

• Setbacks and buffers
• Dock door orientation
• Truck entrance rules
• Energy readiness (PV, EV, etc.)
• Noise/light/visual screening
• Truck route compliance (if applicable)
• Housing replacement (if applicable)

3. Sensitive Receptor Proximity: 900 Feet

Compliance Determination

The law applies only if a loading bay is within 900 feet of a sensitive receptor.

Sensitive receptors include:

• Homes
• Schools
• Daycares
• Libraries
• Playgrounds actively used by children
• Certain medical facilities

SB 415 clarifies:

• Passive parks alone do not count
• Playgrounds must be actively used by children and intended as such
• Condition-of-approval exceptions may apply

Compliance Requirements

If within 900 feet:

• All setback, buffering, orientation, and screening rules apply
• Full AB 98 site-plan requirements apply
• Noise/light mitigation standards must be met

If not within 900 feet:

• The project is exempt from most AB 98 design standards
• Energy and equipment improvements may still apply depending on building size/use

4. Setbacks & Buffer Zones

Compliance Determination

Applies only if:

• Logistics building is ≥250,000 SF and
• Loading bay is within 900 feet of a sensitive receptor

Compliance Requirements

Setback distances:

• 500 feet for buildings ≥250,000 SF
• 300 feet for smaller voluntary-compliance buildings

Buffers must include:

• Screening walls/fencing where needed to block direct views
• Light shielding to prevent spillover toward sensitive receptors
• Noise-reduction strategies such as:
  • Acoustical barriers
  • Orientation of equipment away from receptors
  • Enclosures for loud mechanical equipment
• Anti-idling measures with required signage (3-minute rule)
• Visual screening (trees, walls, or compliant substitutes)

SB 415 allows the buffer area to include:

• Drive aisles
• Passenger-vehicle parking
• Hardscape
• Walkways
• Landscaping within a right-of-way

Buffers are no longer required to be 100% landscaping — solving the infeasibility for infill and constrained parcels.

5. Dock Door Orientation

Compliance Determination

Applies if:

• The project qualifies as a logistics use development
• Building ≥250,000 SF
• Within 900 feet of a sensitive receptor

Compliance Requirements

AB 98 originally required “opposite-side orientation,” which would have banned cross-dock facilities.
SB 415 replaces this with:

Dock doors must face away from the nearest sensitive receptor “to the extent feasible.”

Owners must:

• Show orientation on the site plan
• Document infeasibility if orientation cannot fully comply
• Retain feasibility analysis for local review
• Maintain noise/light screening regardless of orientation

6. Expansion Threshold (20% Rule)

Compliance Determination

AB 98 requirements are triggered if:

• A logistics use building expands by 20% or more,
• Based on logistics-only square footage
• Counted per building
• Office space excluded

Examples:

• 100,000 SF warehouse + 20,000 SF office
  • Logistics portion = 100,000 SF
  • 19,999 SF expansion = exempt
  • 20,000 SF expansion = triggers AB 98
• Complete demolition + rebuild = triggers AB 98 (This is the unresolved redevelopment issue)

Compliance Requirements

If the 20% threshold triggers compliance:

• The building must meet all AB 98 design and operational standards
• Setbacks, buffers, orientation apply at the time of expanded building permit
• If expansion pushes building above 250,000 SF → full compliance
• Energy readiness must be implemented in expanded footprint

7. Truck Route & Local Circulation Planning

Compliance Determination

Applies to jurisdictions with existing or proposed logistics use developments.

NOT required for:

• Cities/counties with no logistics activity
• Rural jurisdictions without warehouses
• Areas where no future logistics use is anticipated

Compliance Requirements

Jurisdictions must:

• Update circulation elements (truck routes) on a phased basis
• Create designated truck routes for heavy-duty trucks
• Ensure access via arterial, major, or commercial/ag/industrial roads
• Include separate truck entrance or mixed entrance with truck-dedicated lane
• Show “good faith effort” to avoid AG enforcement

Projects must:

• Demonstrate that heavy-duty truck access uses compliant roadways
• Include an appropriate entrance configuration
• Install signage directing trucks to routes/highways (SB 415 addition)

8. Truck Entrance Requirements

Compliance Determination

Applies to all covered logistics use developments (≥250,000 SF + receptor proximity).

Compliance Requirements

Sites must provide either:

1. A dedicated heavy-duty truck entrance, connected to a compliant truck route, arterial road, major corridor, or qualifying road

-OR –

2. A shared entrance with a truck-dedicated lane and a passenger-vehicle lane

SB 415 clarifies that only one entrance is required — solving a major AB 98 infeasibility.

9. Energy, Equipment & Electrification Readiness

Compliance Determination

Applies to all buildings that meet AB 98 size/use criteria, regardless of receptor proximity.

Compliance Requirements

Projects must incorporate:

• PV-ready roofs
• Cool roof standards
• EV-charging readiness in parking areas
• Forklift / SORE plug-in readiness
  • Only if adequate electrical power is available (SB 415 added the “and sufficient power is available” clause)

Additionally:

• AB 98 reporting requirements are harmonized with existing South Coast AQMD programs
• No double reporting required (SB 415 fix)

10. Housing Replacement Requirements

Compliance Determination

Triggered only if:

• A project would demolish currently occupied affordable housing
• “Currently occupied” replaces the former 10-year lookback rule

NOT triggered if:

• Housing is market-rate
• Housing is vacant
• Housing has not been occupied in years
• The demolished structure is not residential

Compliance Requirements

If triggered:

• Housing must be replaced at a 2:1 ratio
• Replacement must be affordable housing
• Replacement requirements apply through entitlement conditions
• Market-rate housing no longer triggers replacement
• Developers now have clarity on responsibility and scope

11. Exempt Uses (Does Not Apply)

AB 98 does not apply to:

• Agriculture
• Seasonal operations
• Manufacturing
• Airports
• Seaports
• Coastal access buffer uses
• Retail-serving logistics
• Pre-September 30, 2024 approved/entitled projects
• Developments more than 900 feet from sensitive receptors
• Buildings under 250,000 SF
• Expansions <20%
• Rehab/TI without added square footage

12. The Major Unresolved Issue: Redevelopment

SB 415 did not address redevelopment feasibility.

Currently:

• Complete demolition + rebuild triggers AB 98
• No safe harbor for modernizing obsolete industrial facilities
  • Infill and brownfield redevelopment remain restricted due to setback limitations, receptor proximity, dock orientation constraints, and design standards unfit for legacy industrial parcels

CBPA indicated this will be a top legislative priority in 2026.

What This Means for Industrial Owners & Brokers

• You can now determine with certainty whether a property is subject to AB 98
• The compliance steps are clear and consistent statewide
• Infill sites are more viable than before SB 415
• Cross-dock design is preserved
• Expansions are easier to model
• Truck routing rules are now jurisdiction-appropriate
• Affordable housing replacement rules are predictable
• AQMD redundancy is eliminated
• Redevelopment remains problematic (future legislation required)

This is a significant improvement over the original AB 98 implementation pathway and restores functionality to California’s industrial development pipeline.

Speaker