South Coast Air Quality Management District (SCAQMD) 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.

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.

IMPORTANT CLARIFICATIONS

• Definition of “goods movement” refers to movement of raw, semi-finished, and finished materials and products. The total size that may be used for warehousing must include areas used for storage of raw, semi-finished, and finished materials and products.
  • The truck trip data collection requirement must include truck trips delivering or picking up raw, semi-finished, and finished materials and products.
• Phasing in Table 1 below 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.
• The Initial Site Information Report (ISIR) requires some additional truck trip information for operators that own or lease their truck fleet.

Upcoming Requirements

Truck Trip Data Collection (July 1, 2021)

Operators of warehouses greater than 250,000 square feet (sf) are required to collect truck trip data starting July 1, 2021. The truck trip data must include the following:

Annual WAIRE Report Requirements

• Number of truck trips, divided into two categories
  • Category 1 – Class 2b through Class 7
  • Category 2 – Class 8

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 Operations Notification (September 1, 2021)

Warehouse facility owners must submit the Warehouse Operations Notification to SCAQMD by September 1, 2021. The notification must include the following:

• Legal name and contact information of any entity leasing at least 50,000 sf of space
• Duration of the current least term
• Warehouse size and square foot that may be used for warehousing activities
• Last known legal name and contact information of previous entities leasing at least 50,000 square feet
• Square feet of the warehouse that is used by the warehouse facility owner for warehousing activities

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 NO_X and PM₁₀ emissions associated with warehouses and mobile sources attracted to warehouses greater than 100,000sf.

WAIRE and WATTs

The rule will require 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 NO_X 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

Warehouse owners must submit a warehouse operations notification by September 1, 2021. Warehouse operators must submit an Initial Site Information Report (ISIR) and an Annual WAIRE Report.

The reporting deadlines for the ISIR and the Annual WAIRE Report differ by phase, as shown in Table 1. There are three phases of warehouses based on size.

The ISIR shall include warehouse size, truck trip data, fleet data, alternative fueling station data, yard truck data, and alternative energy generation equipment data. The ISIR must also include whether the warehouse operator anticipates earning WAIRE points from the WAIRE menu, by completing a Custom WAIRE Plan, or by paying the mitigation fee.

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

Additional information and training resources can be found on the WAIRE Program website. For guidance on the truck trip data collection requirement, view this article, South Coast AQMD Warehouse ISR Rule 2305 Immediate Action Guidance

If you have any questions regarding the rule and maintaining compliance for your facility, please email Tiffany Wang or Valerie Rosenkrantz.