Warehouses > 150,000 sf Reporting Requirements – Due July 1, 2023 & January 31, 2024
South Coast Air Quality Management District (South Coast AQMD) adopted
Rule 2305, Warehouse Indirect Source Rule (ISR), on May 7, 2021. Rule 2305 applies to operators and owners of existing and new warehouses greater than 100,000 square feet. We covered the original implementation of this rule in an
earlier article ahead of the 2023 deadline.
The rule aims to reduce NOX and PM10 emissions from on-road trucks that deliver goods and off-road vehicles associated with warehouses and to otherwise facilitate emission and exposure reductions of these pollutants in nearby communities.
This effort is part of the 2016 Air Quality Management Plan (AQMP) and South Coast AQMD’s efforts to reduce basin-wide emissions to meet the National Ambient Air Quality Standards (NAAQS) by implementing new facility based mobile source measures such as the new Rule 2305.
Upcoming Requirements
Operators of warehouses greater than 150,000 square feet (sf) are required to submit:
Annual WAIRE Report Requirements (January 31, 2024)
- Number of truck trips, divided into two categories
- Category 1 – Class 2b through Class 7
- Category 2 – Class 8
- Method of earning WAIRE points (see below)
Operators of warehouses greater than 100,000 square feet (sf) and less than 150,000 sf are required to submit:
Initial Site Information Report (ISIR) Requirements (July 1, 2024)
- Number of truck trips, divided into two categories
- Category 1 – Class 2b through Class 7
- Category 2 – Class 8
- If fleet is owned or leased,
- Number of trucks and tractors serving a warehouse, by class and fuel type
- Total Vehicle Miles Traveled (VMT), by class and fuel type
- Typical dwell time at the facility, by class
- Information about which trucks or tractors are owned and which are leased
Past Requirements
Past requirements for operators of warehouses > 150,000 sf per the WAIRE rule includes:
Truck Trip Data Collection
Operators of warehouses greater than 150,000 square feet (sf) are required to collect truck trip data starting July 1, 2022. The truck trip data must include the following:
Initial Site Information Report (ISIR) Requirements
- Number of truck trips, divided into two categories
- Category 1 – Class 2b through Class 7
- Category 2 – Class 8
- If fleet is owned or leased,
- Number of trucks and tractors serving a warehouse, by class and fuel type
- Total Vehicle Miles Traveled (VMT), by class and fuel type
- Typical dwell time at the facility, by class
- Information about which trucks or tractors are owned and which are leased
Warehouse ISR Rule 2305 Requirements
South Coast AQMD adopted Rule 2305, Warehouse Indirect Source Rule (ISR), on May 7, 2021. Rule 2305 aims at reducing NOX and PM10 emissions associated with warehouses and mobile sources attracted to warehouses greater than 100,000 sf.
WAIRE & WATTs
The rule requires warehouse operators to earn Warehouse Action and Investments to Reduce Emissions (WAIRE) points from emission-reducing activities or pay mitigation fees based on the total NOX and PM10 emissions.
The number of WAIRE points that a warehouse operator must earn every year is based on Weighted Annual Truck Trips (WATTs). WATTs will be calculated based on verifiable truck trip data collected by the warehouse operator. If this data is unavailable, WATTs will be calculated based on the number of operational days and the warehouse size.
WAIRE points can be earned through completing specific actions from the WAIRE Menu, completing an approved Custom WAIRE Plan, or choosing to pay a mitigation fee of $1,000 per WAIRE point.
Warehouse ISR 2305 Reporting
The Annual WAIRE Report shall include truck trip data, number of WAIRE points earned, information regarding WAIRE points earned through the WAIRE menu, and current contact information.
Table 1. Reporting Deadlines by Phase
| Phase | Warehouse Size (sf) | Warehouse Operations Notification Date | Initial Site Information Report (ISIR) Date | Period for Truck Trip Data | Annual WAIRE Report Date | Period for Truck Trip Data |
| 1 | ≥ 250,000 | September 1, 2021 | July 1, 2022 | July 1, 2021 – June 30, 2022 | January 31, 2023 | January 1, 2022 – December 31, 2022 |
| 2 | ≥ 150,000 – < 250,000 | July 1, 2023 | July 1, 2022 – June 30, 2023 | January 31, 2024 | January 1, 2023 – December 31, 2023 |
| 3 | ≥ 100,000 – < 150,000 | July 1, 2024 | July 1, 2023 – June 20, 2024 | January 31, 2025 | January 1, 2024 – December 31, 2024 |
Important Clarifications
Phasing in Table 1 above is based on the total building size, not warehousing activity size. For buildings with multiple operators, all operators would be part of the same phase, based on the total building size.
Additional Information
If you have any questions regarding the rule and maintaining compliance for your facility, please email
Tiffany Wang, or
Hans Wahono.
