SB 415’s Key Amendments to AB 98
Implications for Industrial Development in California

On Friday, October 3, 2025 Governor Gavin Newsom signed SB 415 (Reyes) into law, delivering long-awaited clarifications to AB 98 (2024). AB 98 codified statewide standards governing new or expanded logistics use developments, known as “21st Century Warehouse” standards. The passage of SB 415 marks a serious step forward for California’s commercial real estate and goods movement sectors. SB 415 is a practical clean-up measure that improves the ability to implement development projects while preserving the intent of state policy: modernizing industrial development while protecting neighboring communities.

SB 415 Refines Definitions and Scope of Development Standards: 

• Establishes the term logistics use development as the regulated use type.
• Creates a logistics park category to distinguish standards for multi-building projects. Standards generally apply per building, but truck entrance requirements can now be satisfied at either the project or building level.
• Clarifies that the Warehouse Concentration Region (WCR) applies only to unincorporated areas of Riverside and San Bernardino counties. The WCR does not apply to Los Angeles and Orange counties.
• Refines the definition for a sensitive receptor by excluding designated coastal access lands, as well as airport and seaport buffer areas.
• Exempts manufacturing uses with ancillary distribution as a logistics use development. SB 415 also excludes agricultural buildings as a logistics use development if such facilities are used 90 or fewer consecutive days per year.

Affirmation of Entitlement Timelines: 

• SB 415 affirms that AB 98 does not apply to logistics use development projects already in the entitlement process. Specifically, AB 98 does not apply to:
• Projects that began entitlements before September 30, 2024, or if local approval was granted to a project before January 1, 2026.
• A logistics use development involving mixed uses – including new homes or other new sensitive uses on site – insofar as no existing sensitive receptor is within 900 feet of a loading dock.

More Flexible Truck Access and Site Design Standards: 

• A truck access entrance can now be satisfied by one driveway with dedicated truck and passenger lanes.
• Clarifies that loading docks must face away from the nearest sensitive receptor, as opposed to the “opposite side.” Greater flexibility and practicality are allowed for site layouts.
• Buffer areas can now include public right-of-way landscaping, hardscaping and passenger vehicle parking when contributing to separation.
• Local commercial, agricultural and industrial roadways can now qualify as appropriate truck-serving frontage.

Practical Compliance and Phasing:

• To meet compliance with CalGreen standards, a project must meet the energy efficiency rules that are in place when a building permit is issued, and not when a project is entitled.
• The truck idling prohibition established in AB 98 now applies only if adequate on-site power is available, and trucks are capable of plugging in. 

Local Government Responsibilities:

• AB 98 required every city and county to update its General Plan Circulation Element to include a truck route that steers trucks away from residences. Local jurisdictions outside of the WCR now have the option to adopt a truck route ordinance instead of a Circulation Element amendment.
• With respect to the timing of truck route compliance, cities outside the WCR must comply by January 1, 2028, or January 1, 2030 for “smaller jurisdictions.” The latter includes cities with a population of 50,000 or fewer, and counties with less than 100,000 people.
• Local jurisdictions must ensure that at least one truck route enforcement officer is trained by the California Highway Patrol if training is made available at no cost.

Balance Between State and Local Authority:

• Local governments cannot enact standards that block compliance with AB 98’s mandatory requirements. Zoning discretion for local government, however, remains fully intact, and cities can continue to allow or reject logistics use development projects through land use policies.

Housing Protection Requirements:

• SB 415 confirms the 2:1 housing replacement. Relocation duties remain applicable where triggered, and are supplemental to the Housing Crisis Act and other housing laws.

NAIOP SoCal Advocacy Priority for 2026:
The negotiated changes in SB 415 bring much-needed clarity to AB 98, reducing barriers to development while maintaining strong community safeguards. Our work continues in 2026. NAIOP SoCal will remain strongly engaged with our partners and policymakers to address unresolved issues around modernization and infill redevelopment, ensuring California’s land use policies support economic growth and community well-being.

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