South Coast Air Quality Management District (SCAQMD) adopted Rule 2305, Warehouse Indirect Source Review (ISR), on May 7, 2021. Rule 2305 applies to operators and owners of existing and new warehouses greater than 100,000 square feet.

The rule aims to reduce NO_X 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 SCAQMD’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.

IMMEDIATE ACTION REQUIRED: All warehouse facility operators greater than 250,000 square feet (sf) within SCAQMD’s jurisdiction must collect truck trip data for their facility starting July 1, 2021.

Truck Trip Counting Tips for Operators

Definition of a Truck Trip

Truck trips are defined as one-way trips that tractors and straight trucks make to a warehouse facility when delivering goods to or from another location. Truck trip data is required for two categories: 1) Class 8 tractors trailers and 2) Class 2b-7 straight trucks. Truck trips must be counted, and records must be verifiable, where date and time of the truck trips recorded may be tied to the compliance period records for review.

The following is from the WAIRE Implementation Guidelines updated in late June 2021.

Method for Counting Truck Trips

The truck trip data needs to be accurately collected using a method that is reliable and verifiable since it will be used to determine a warehouse operator’s WAIRE Points Compliance Obligation (WPCO). The truck trip counts can be collected either:

1. every day at the time of occurrence (i.e., contemporaneously)
2. extrapolated from data collected during a representative peak period

Warehouse operators are responsible for maintaining data to support the truck trip count. Adequate records that document all reported information, including truck trip counts, must be made available to South Coast AQMD for verification and must be maintained for seven years.

Verifiable counts of truck trip data can be provided through the following methods:

1. Guard shacks – Many warehouse operators employ a guard or other personnel to staff their gate guard shack to control trucks entering the warehouse. The guard or warehouse personnel who interact with the driver of the truck entering the warehouse would complete a log of the truck entering with both visual observations of the truck and may supplement with additional questions asked of the driver of the truck. A guard shack log would include such information as the number and class of trucks (Class 2b to 7 vs. Class 8) or alternatively the number and type of trucks (tractor or tractor-trailers vs. straight trucks). The logs could be either a) daily or b) a representative sample (no case should be less than one weekday (Monday – Friday, for the warehouse’s entire operating hours) per month and one weekend day (Saturday or Sunday, for the warehouse’s entire operating hours) per month (if the warehouse is open on weekends).¹ The name of the guard or personnel completing the guard shack log should be on the log itself in case further clarification is needed.
2. Electronic Telematics Systems – These systems are used to track truck activity, typically through the use of on-board GPS systems and fleet management software. These systems can track when equipped vehicles are located at a warehouse.
3. In-Roadway or Driveway Sensors – Various sensor technologies are available to count vehicles such as pneumatic tubes, radar, or lasers installed at a driveway. These devices are used to count the number of vehicles passing a certain point and can provide truck classification data (e.g., straight trucks).
4. Video Monitoring – Many warehouse operators already employ security cameras to monitor their gates. Warehouse operators could use staff or software to identify the number and type of trucks that enter the gate and note truck Class (i.e. straight trucks vs. tractors) from video recordings. Video recordings and subsequent counts can be continuous but in no cases should be less than one weekday (Monday – Friday) per month and one weekend day (Saturday or Sunday) per month (if the warehouse is open on weekends). ^[1]
5. Contracts, Manifests, Receipts, or other similar records – Many warehouse operators are responsible for shipments to/from their warehouse, including with their own fleet or through third party fleets. Records such as contracts or manifests that document the loads delivered to or picked up from a warehouse can be used to determine truck trip information provided that all trips to a site are documented (which could include supplementary sources of data, such as through methods described above).

Compliance Actions and Due Dates for Owners and Operators

Table 1 below includes upcoming compliance due dates and obligations for warehouse owners, and Table 2 below includes upcoming compliance due dates and obligations for warehouse operators.

Table 1. Warehouse Owners – Upcoming Compliance Due Dates and Obligations

Table 2. Warehouse Operators – Upcoming Compliance Due Dates and Obligations

For additional information on the reporting requirements and deadlines, please view South Coast AQMD Warehouse ISR Rule 2305 Reporting Requirements.

Trinity Can Help

Trinity Consultants can support individual large warehouse operators to customize verifiable guard shack data collection logs to meet this rule requirement. Please email Tiffany Wang or Valerie Rosenkrantz to request additional information.

[1] Each weekday and weekend day once-per-month representative sample must be taken at least three weeks apart from the next respective sample. With this less intensive once-per month sampling method, a representative peak weekday and weekend day must be recorded (with documentation indicating why those days of the week were chosen). The weekday count may then apply to all weekdays during that month, and the weekend count may then apply to all weekend days during that month.