California Assembly Bill 98 is a planning and zoning law that sets statewide requirements relating to design, operation and environmental standards for specified classes of development projects, including logistics uses and warehouses. The bill is part of California’s ongoing efforts to reduce air pollutant emissions and regulate warehouse and trucking activity.
California Assembly Bill 98 (AB 98) is a planning and zoning law that sets statewide requirements relating to design, operation, and environmental standards for specified classes of development projects, including logistics uses and warehouses.
Beginning Jan. 1, 2026, AB 98 would prescribe various warehouse design and build standards for proposed new or expanded logistics-use developments. The law establishes stringent mandates on warehouse design and location, parking, landscaping buffers, housing replacement, and truck routes, seeking to minimize adverse air quality impacts to nearby existing communities. AB 98 would prohibit a city and/or county from approving a logistics development that does not meet or exceed the standards outlined in the bill.
Warehouse operators will be required to submit a truck-routing plan to and from the state highway system based on the latest truck-route map to the city and/or county. Revisions may be allowed in specified circumstances.
Beginning Jan. 1, 2028, AB 98 would also require a city or county to update its circulation element, including identifying and establishing specific travel routes to avoid residential areas and concentrations of sensitive receptors. AB 98 establishes specific standards for truck routes, including signage identifying the routes, truck parking and appropriate idling facility locations. In addition, the bill would require the truck routes to be publicly available and shared with warehouse operators, fleet operators, and truck drivers.
The bill also requires the South Coast Air Quality Management District, home to a “warehouse concentration region” (in Riverside and San Bernardino counties) to deploy air monitoring systems from Jan. 1, 2026 until Jan. 1, 2032 to collect air pollution measurements in communities near operational logistics use developments, and provide an evaluation of the air pollution impact to the legislature on or before Jan. 1, 2033.
Regulatory Components of AB 98
The bill sets forth several requirements for new and expanded warehouse projects depending on a variety of factors, including the date of the planning application, size of the warehouse, whether the site is zoned for industrial use, and the location of the warehouse in relation to sensitive receptors. Existing facility expansions of 20% or more are subject to AB 98. The bill’s requirements are generally focused on a project’s relationship to sensitive receptors, including residences, schools, daycares, publicly owned parks and playgrounds, nursing homes, and related facilities and hospitals.
Warehouse projects subject to AB 98 will be required to implement a variety of design and build standards including (but not limited to) the installation of photovoltaic systems and associated battery storage; cool roofing; light-, medium- and heavy-duty vehicle charging readiness and charging infrastructure; sky lights or LED-efficient lighting; conduits for TRU hookups; high efficiency HVAC systems; strategic orientation of loading bays, separate truck entrances and exits; buffering and screening to mitigate for light and noise; anti-idling signage and truck routing provisions; and zero-emission forklift and landscape equipment, as feasible.
AB 98 also includes site requirements to ensure warehouse developments are located on roadways suited to handle the associated traffic, and that predominantly serve commercial uses. Facility operators will also be required to establish and submit for approval a truck routing plan to and from the state highway system and to restrict trucks from traveling residential streets or near other sensitive receptors. Even though these neighborhoods may not be near the project site or warehouse, these vehicles may cause pollution concerns if their route takes them near a sensitive receptor.
Determining Regulatory Responsibility
Existing or proposed logistics-use developments and property currently in a local entitlement process may be exempt from these regulations. Other exemptions may exist for other projects based on AB 98’s three main criteria: size, zoning, and distance from sensitive receptors. Notably, mixed-use developments that include new residential uses as well as new logistics uses may be exempted if there are no existing sensitive receptors within 900 feet of the proposed loading bay.
Utilizing a Consultant for Regulatory Compliance
AB 98 targets new warehouse projects coming down the development pipeline, and there are various regulatory elements to consider on the front end. The most critically important of these elements is project siting, referring to the specific requirements and standards that must be met when selecting and approving locations for new or expanded logistics-use developments. In addition, a variety of factors must be considered depending on the size and location of the project and its proximity to sensitive land uses.
Third-party sustainability consultants, including FirstCarbon Solutions (FCS), an ADEC Innovation, can assist developers in navigating AB 98 compliance. Consultants are particularly invaluable in areas such as technical analysis and planning, due diligence site assessments, screening-level analysis, as well as permit clearance and CEQA compliance, including Indirect Source Rule (ISR). These services are useful in considering warehouse placement in conjunction with other industrial sources, such as freeways, helping you identify opportunities to stay ahead of the curve.
