SB 415 Finalizes California’s Warehouse Standards Framework: Key Requirements for Industrial Owners

SB 415 finalizes and clarifies California’s statewide Warehouse Standards for large logistics facilities. Enacted in October 2025, the bill addresses the inconsistencies and implementation issues within AB 98, the 2024 law that established the state’s first uniform development rules for major logistics projects.

After publishing our December 2024 article on AB 98: How to Navigate California’s New Logistics Regulations, GM Properties has continued to monitor these changes closely. With SB 415 now in force, our partners at AIR CRE and the California Business Properties Association (CBPA) held a Town Hall: SB 415 Updates to California’s Warehouse Standards Requirements, to explain the final definitions, thresholds, and compliance requirements.

The following summary captures the core updates from that Town Hall and outlines what industrial owners should need to understand as they evaluate existing assets, plan expansions, or pursue new development.

Final Definition of “Logistics Use Development”

SB 415 refines the definition of a logistics-use facility to avoid misclassification and improve consistency across jurisdictions. A project is covered only if all of the following are true:

• It is a single building whose primary use is warehouse/storage distribution.
• It involves heavy-duty trucks and shipments destined for business or retail customers.
• It does not fall under an exempt category (e.g., agriculture, manufacturing, airport/seaport, retail operations, or seasonal uses).

If a building does not meet this clarified definition, the Warehouse Standards requirements as set in AB 98 or SB 415 do not apply.

Size Threshold: 250,000 SF (Per Building)

SB 415 confirms that the Warehouse Standards apply only to logistics-use buildings 250,000 sf or larger, based on per-building calculations.

Clarifications include:

• Office square footage is excluded from the logistics-use calculation.
• The threshold is not cumulative across multiple buildings on a site.
• Expansions that push the logistics portion above 250,000 sf trigger the standards.
• Example: A 240,000 sf warehouse + 20,000 sf office = 240,000 sf logistics → not covered.

Proximity Trigger: 900 Feet to Sensitive Receptors

Design and on-site mitigation requirements apply only when loading docks are within 900 feet of sensitive receptors such as:

• Residential uses
• Schools and day-care centers
• Hospitals, libraries, and playgrounds actively used by children
• Certain medical facilities

Projects with loading bays beyond 900 feet may avoid the most restrictive setback and buffering requirements, though other standards (e.g., electrification readiness) may still apply.

Setbacks and Buffer Requirements

For covered projects (logistics use + ≥250,000 sf  + within 900 feet):

• A 500-foot setback is required from loading bays to sensitive receptors.
• Smaller, voluntary-compliance buildings must meet a 300-foot setback.
• SB 415 allows buffer areas to include drive aisles, parking, walkways, landscaping, and certain public right-of-way segments—an important clarification for infill sites.

Buffering must include:

• Screening walls or fencing
• Noise and light mitigation
• Landscape screening
• Anti-idling signage (3-minute rule)

These improvements aim to reduce neighborhood impacts and provide predictable design guidelines for owners.

Dock-Door Orientation (“Feasible Orientation” Standard)

AB 98 originally required dock doors to be placed on the opposite side of the building, which would have prohibited widely used cross-dock configurations.

SB 415 resolves this issue:

• Dock doors must face away from the closest sensitive receptor “to the extent feasible.”
• Feasibility may be based on operational needs, site geometry, safety, and circulation constraints.
• If full reorientation is not possible, enhanced screening and buffering must be applied.

This is a major improvement that preserves modern industrial design efficiencies.

Expansion Trigger: 20% Rule

The Warehouse Standards apply when a logistics-use building expands by 20% or more, even if the building remains below 250,000 sf.

Expansions that do not add square footage—such as roof raises—generally do not trigger the standards. This rule is especially important for owners modernizing older logistics assets where expansions are common.

Truck Route and On-Site Circulation Requirements

Local jurisdictions must designate compliant truck routes that serve logistics uses. Projects must demonstrate:

• Truck access along approved industrial or arterial roads
• A dedicated truck entrance or a dedicated truck lane at shared entrances
• Signage directing trucks to approved routes and freeway access points

This requirement adds predictability for both owners and agencies reviewing site plans.

Electrification, Energy, and Equipment Readiness

Electrification-readiness applies to all triggered logistics-use buildings, regardless of proximity to sensitive receptors. Requirements include:

• PV-ready and cool-roof design
• EV-ready parking for light-duty vehicles
• Plug-in readiness for forklifts and small off-road equipment, subject to available electrical capacity
• Alignment with AQMD reporting to avoid duplicate obligations

SB 415’s clarifications give owners more practical flexibility in meeting these requirements.

Housing Replacement Trigger

Triggered only if a project involves demolishing currently occupied affordable housing. If triggered, owners must replace those units at a 2:1 ratio, and the replacement units must remain affordable. This does not apply to:

• Market-rate housing
• Vacant units
• Non-residential buildings

Exemptions and Remaining Issues

Exemptions include:

• Manufacturing
• Seasonal agricultural uses
• Airports and seaports
• Buildings under 250,000 sf
• Expansions under 20%
• Projects more than 900 feet from sensitive receptors
• Interior TIs or rehab work without added square footage

Unresolved:
Redevelopment (demolition followed by rebuild) is still treated as new development and therefore fully subject to the Warehouse Standards. Industry groups continue to monitor whether future legislation may address this gap.

What Industrial Owners Should Do Now

• Assess any property approaching or exceeding 250,000 sf.
• Confirm receptor proximity early in site planning.
• Review budgets for required screening, setbacks, circulation, and electrification elements.
• Evaluate whether upcoming expansions may trigger the 20% rule.
• Incorporate SB 415’s clarified definitions and metrics into entitlement and design processes.

SB 415 ultimately brings greater clarity and consistency—but compliance requires early evaluation.

How GM Properties Can Support You

GM Properties works directly with industrial owners to assess SB 415 impacts and ensure that development and expansion plans remain feasible. We can assist with:

• Project-level compliance evaluations
• Budgeting and timeline adjustments
• Coordination with local jurisdictions and consultants
• Long-term asset and operational planning