On October 3, 2025, Governor Newsom signed Senate Bill 415 (“SB 415”) into law, which refines and moderately narrows the sweeping new requirements for new or expanded logistics uses in California, which were enacted last year by AB 98. Under AB 98, new or expanded logistics uses were required to comply with stringent design guidelines and setback requirement when a loading bay fell within 900 feet of a sensitive receptor (e.g., residences, schools, daycares, public parks, nursing homes, and hospitals). AB 98 also implemented a number of siting, operational, and housing replacement requirements on all new logistics uses in the State.
SB 415 (1) adds clarifying terms to several major definitions that narrow the scope of AB 98’s restrictions, (2) imposes additional limits on local agencies’ ability to restrict logistics uses, and (3) clarifies the definition of the Warehouse Concentration Region.
Key Definition Clarifications
SB 415 replaces the term “logistics use” with “logistics use development,” which is defined as a property that is “primarily used as a warehouse”. This makes clear that AB 98 & SB 415 do not apply to properties that are primarily used for manufacturing or other non-storage functions.
The 21st Century Warehouse Standards articulated in AB 98 have been revised to make clear that the requirement to use the cleanest commercially available technology refers to the cleanest “off the shelf” commercially available technology, and does not refer to technologies that may not be easily accessible. SB 415 also clarifies that cold storage trucks are only obligated to plug in, as opposed to generally idling, if sufficient power exists at the property for the truck to charge.
Additionally, while AB 98 requires truck loading bays to be located on the opposite side of the development from sensitive receptor(s), SB 415 provides developers with additional flexibility to orient loading bays away from sensitive receptors, to the extent feasible.
Other Major Clarifiers
One major question raised by AB 98 was whether the required separate entrance for heavy-duty trucks could be shared with other vehicular traffic. SB 415 makes clear that shared entrances are permissible so long as there is a designated heavy-duty truck aisle, distinct from areas designated for non-heavy-duty traffic, such as separate lanes. In situations where a single development may consist of multiple buildings or logistics uses, SB 415 defines these developments as a “logistics park,” and clarifies that only one entrance for heavy-duty trucks is needed for the entire logistics park, so long as it meets the other requirements.
Another major question raised by AB 98 was whether the required buffer areas between logistics use developments and sensitive receptors could include landscaped areas within a public right-of-way or private pedestrian walkways. SB 415 makes clear that these landscaped areas within public rights-of-way and pedestrian walkways may be used to meet the buffering requirement.
Cities are also now expressly precluded from implementing ordinances or standards that prevent operators of logistical use developments from complying with the design guidelines or physical features required by AB 98, as amended.
Other notable clarifications include that: (1) it is acceptable for logistical use developments to utilize roads primarily meant for agricultural use as part of their trucking routes, (2) land utilized to ensure Californians have public coastal access is not considered a sensitive receptor, and (3) clarifying the scope of AB 98’s “grandfathering” provisions.
Changes to the Warehouse Concentration Region
Finally, SB 415 confirms that the Warehouse Concentration Region consists of the cities named in the statute, along with the unincorporated areas of Riverside and San Bernardino counties. This means that the 40 cities in Riverside and San Bernardino counties not named in AB 98 & SB 415 are not in the Warehouse Concentration Region.
Notably, absent from SB 415’s revisions were any provisions related to the redevelopment of existing industrial properties. However, it is anticipated that industry groups and stakeholders will continue to work with the Legislature to provide additional guidance on redevelopment and modernization in future Legislative sessions.
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Should you have any questions regarding the potential impacts of SB 415, please contact Alan Fenstermacher, Scott Cooper or Garret Hoff.
This e-Alert is published periodically by Rutan & Tucker, LLP and should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only.
