South Coast Air Quality Management District’s Warehouse Indirect Source Rule

South Coast Air Quality Management District (SCAQMD) adopted Rule 2305, Warehouse Indirect Source Rule – Warehouse Actions and Investments to Reduce Emissions (WAIRE) Program in May of 2021.  SCAQMD Rule 2305 applies to warehouses larger than 100,000 square feet and requires a reduction in nitrogen oxide (NO_X) and diesel particulate matter (PM) emissions from mobile sources associated with the operation of subject warehouses.

The first step towards compliance is to determine the WAIRE Points Compliance Obligation (WPCO) for the warehouse.  The WPCO is calculated based on the number and type of truck trips to and from the warehouse annually and subject facilities must maintain records of daily truck trips to and from the warehouse with truck class information. Once the WPCO is determined, warehouse operators can choose between three options or use a combination of the three options to meet their compliance obligation.

1. The first option is the payment of an annual mitigation fee of $1,000 per WAIRE Point.
2. The second option is to participate in the menu-based points system of the warehouse rule to reduce NO_X and PM emissions. The number of WAIRE Points earned from the menu depends on the action or investment. WAIRE Menu actions include:
   • Acquisition and use of zero emission and near-zero emission trucks.
   • The installation and use of electric vehicle supply equipment or electrical charging stations.
   • The installation and use of solar panels.
   • The installation and use of a hydrogen station.
3. The final option is to follow an approved Custom WAIRE Plan. A Custom WAIRE Plan must:
   • Demonstrate how the proposed action will earn WAIRE Points and how the emissions reductions are quantified and verified.
   • Describe NO_X and/or diesel particulate matter emissions reductions from the proposed action.
   • Achieve emissions reductions no later than three years after plan approval.
   • Reduce emissions within three miles of the warehouse.
   • Include a schedule of key milestones and a description of the location where the proposed actions will occur.

Custom WAIRE Plans must be submitted for approval prior to implementation and may be rescinded if there is inadequate progress towards completion of the plan.

SCAQMD’s Warehouse Indirect Source Rule has a three-year phase-in period based on warehouse size. The initial compliance period for each phase consists of January 1 through December 31 of the compliance year.

• Phase 1 consists of the largest warehouses, greater than or equal to 250,000 square feet. Phase 1 warehouses have an initial compliance period during 2022 and must submit their Initial Annual WAIRE Report (AWR) by January 31, 2023.
• Phase 2 includes warehouses greater than or equal to 150,000 square feet to less than 250,000 square feet. The initial compliance period for Phase 2 warehouse is 2023, with initial AWR due by January 31, 2024.
• Phase 3 consists of warehouses between 100,000 and 150,000 square feet. The initial compliance period for Phase 3 warehouses is 2024 and these warehouses must submit their initial AWR no later than January 31, 2025.

An Initial Site Information Report (ISIR) must be submitted by July 1 of the initial compliance period. The ISIR must contain warehouse information, truck trip information, and anticipated methods to meet the WAIRE Points Compliance Obligation.  The Annual WAIRE Report must include warehouse operator information, truck trip data, how WAIRE points were earned, and information about the WAIRE points.

ALL4 has generated strategies to ensure compliance with SCAQMD Rule 2305 including development of a WAIRE Program Recordkeeping Tool and conducting a WAIRE Points Initiative evaluation to help clients identify options to reduce their WPCO.  If you have questions about SCAQMD’s Warehouse Indirect Source Rule, please contact Emily Dykeman at edykeman@all4inc.com or 909.477.7129.