AB 98: Warehouse Setbacks, Loading Bays, and Truck Access

California’s AB 98 sets statewide design and siting rules for warehouse developments, and the California warehouse standards it creates take effect January 1, 2026.¹ If a new or expanding logistics facility has a loading bay within 900 feet of a home, school, daycare, park, care facility, or hospital, the project must meet mandatory buffers, loading bay orientation rules, truck routing requirements, anti-idling signage, and clean energy design elements. Senate Bill 415 later refined several definitions. The rules below reflect the current statute.

What Counts as a Covered Warehouse

AB 98 applies to a “logistics use development,” meaning a building used primarily as a warehouse for moving or storing goods shipped to business or retail customers, where heavy-duty trucks handle most of the freight. Retail stores where the public shops onsite are not covered, even with large inventories. Also excluded: buildings served primarily by rail, strategic intermodal facilities combining rail and warehousing on one footprint, and seasonal agricultural operations running 90 consecutive days or fewer per year.²

An expansion is a covered project when it adds 20 percent or more to the existing building’s square footage, excluding office space.² A 200,000-square-foot warehouse adding 40,000 square feet of storage is in. Adding the same square footage as offices is not.

The 900-Foot Trigger and Sensitive Receptors

The threshold that pulls a project into AB 98’s siting and buffer requirements is a loading bay within 900 feet of a “sensitive receptor.” If nothing on that list sits within 900 feet, the project falls outside those mandates.³

Sensitive receptors include:²

Residences, including houses, apartments, condos, group homes, dormitories, and retirement homes.
Schools, preschool through grade 12.
Daycare facilities, including in-home daycare.
Publicly owned parks and playgrounds primarily used by children. Parks built as a condition of a logistics project’s own approval, coastal access land, and airport or seaport buffer zones are excepted.
Nursing homes, hospices, long-term care facilities, and similar live-in care housing.
Hospitals.

Which Projects Face Which Rules

Section 65098.1 sorts covered projects by zoning and size.⁴ The dividing line is 250,000 square feet. Larger projects must incorporate the fuller “Tier 1” design standards; smaller covered projects follow a baseline version of the same requirements.

Projects of 250,000 square feet or more on industrial-zoned land (or on sites where a rezoning application was submitted by September 30, 2024, and later approved), with a loading bay within 900 feet of a sensitive receptor.
Projects of 250,000 square feet or more on non-industrial land, developed or undeveloped, with a loading bay within 900 feet of a sensitive receptor.
Projects on non-industrial land within designated warehouse concentration regions, which face an elevated tier of requirements regardless of size.
Projects under 250,000 square feet on industrial-zoned land, with a loading bay within 900 feet of a sensitive receptor.

Required Buffers

A covered project within 900 feet of a sensitive receptor must build a physical buffer that fully screens the warehouse from the receptor. Width depends on zoning, measured from the property line of every adjacent sensitive receptor:³

Industrial-zoned sites: at least 50 feet.
Non-industrial sites: at least 100 feet.

The buffer is not empty setback. It must include a solid decorative wall, a landscaped berm and wall combination, or a landscaped berm at least 10 feet tall. It must also include drought-tolerant ground landscaping with proper irrigation, plus two rows of evergreen, drought-tolerant screening trees along the full length of the adjacent receptor’s property line, spaced no more than 40 feet apart, planted in a minimum 36-inch box. Palm trees do not count toward this requirement.⁵ SB 415 clarified that the buffer area may also contain hardscape, vehicle access, passenger parking improvements, landscaping in public rights-of-way, and pedestrian walkways.

Loading Bay Placement and Truck Access

Truck loading bays must be placed on the side of the building that faces away from the nearest sensitive receptor, to the extent feasible. Heavy-duty diesel truck drive aisles cannot run along sides of the building directly adjacent to a sensitive receptor’s property line.

Every covered facility must also provide a separate entrance for heavy-duty trucks. That entrance must connect to a designated truck route, arterial road, major thoroughfare, or a local road that predominantly serves commercial or industrial uses. Under SB 415, “predominantly serves” means that more than 50 percent of the properties fronting the road within 1,000 feet of the truck entrance are designated for commercial, agricultural, or industrial use. Truck entry, exit, and internal circulation must all be located away from sensitive receptors.⁴ The separate truck entrance can take the form of a driveway with one lane dedicated to heavy-duty trucks and another for other vehicles, rather than a fully independent access road.

Signage Requirements

Anti-idling signs must be posted at site entrances and at truck loading bays, stating a three-minute engine idling restriction for heavy-duty trucks.⁶ That is stricter than the five-minute limit found in some older general guidance.

Directional signs must also be installed at every heavy-duty truck exit driveway, pointing drivers toward the designated truck route in the facility’s truck routing plan and toward the state highway system.⁶ Signage obligations apply to both new developments and expansions.

Clean Energy and Building Design

AB 98’s “21st century warehouse design elements” require light-duty electric vehicle charging readiness and installed charging stations, along with energy-efficient building features such as skylights covering at least one percent of the roof area or equivalent LED lighting.¹ Facilities of 250,000 square feet or more must meet the full Tier 1 set; smaller covered projects follow the baseline version.⁴

Some of the charging infrastructure cost may be offset by the federal Alternative Fuel Vehicle Refueling Property Credit under Section 30C of the Internal Revenue Code. Through June 30, 2026, businesses can claim 6 percent of depreciable costs, up to $100,000 per charging port. Businesses that meet prevailing wage and apprenticeship requirements qualify for a 30 percent credit with the same per-item cap.⁷ Whether the credit will be extended past June 2026 is unsettled.

What Local Governments Can and Cannot Do

Cities and counties cannot approve a covered logistics development that fails to meet or exceed AB 98’s standards.⁸ They also cannot impose rules that would physically prevent a developer from including the features the state requires, such as buffer walls, truck entrances, or signage.

Local authority is preserved in two ways. A city or county can still deny a project outright, and it can adopt standards stricter than AB 98’s.⁸ AB 98 is a floor, not a ceiling. A jurisdiction wanting larger buffers, taller walls, or more extensive EV infrastructure can require them. The statute also does not displace any mitigation measures required under the California Environmental Quality Act, so CEQA obligations continue to run alongside AB 98.

Grandfathering and the Five-Year Clock

AB 98 does not apply to every warehouse already in California. Fully exempt from the new requirements are:

Logistics projects where the local entitlement process began before September 30, 2024.
Logistics projects that received local agency approval before January 1, 2026.
Mixed-use projects that may create sensitive receptors on the logistics site itself, as long as no existing sensitive receptors sit within 900 feet of the loading bay.

A separate set of carve-outs targets just the setback and buffer rules while leaving other AB 98 obligations in place. Warehouses in existence as of September 30, 2024, are exempt from buffer requirements even if a sensitive receptor is later built nearby. The same protection extends to projects that were in the entitlement process as of that date, and to new projects where the developer’s entitlement process began before a nearby sensitive receptor started its own.

These setback protections last through the entitlement and development period but expire if no construction activity occurs within five years of the entitlement approvals. A developer who secures approvals under a grandfathered exemption and then delays construction too long loses that protection, and must meet the full buffer standards at that point.

1
California Legislative Information. AB-98 Planning and Zoning: Logistics Use: Truck Routes
2
California Legislative Information. California Code Government Code 65098
3
California Legislative Information. California Code Government Code 65098.2
4
California Legislative Information. California Code Government Code 65098.1
5
City of San Diego Official Website. AB 98: Warehouse Design and Build Standards
6
California Legislative Information. California Code Government Code 65098.3
7
Internal Revenue Service. Alternative Fuel Vehicle Refueling Property Credit
8
California Legislative Information. California Code Government Code 65098.5