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Regulatory Updates

South Coast Air Quality Management District Rule 2305: Warehouse Indirect Source Rule

July 6, 2021

South Coast Air Quality Management District (SCAQMD) has recently passed a rule impacting southern California warehouses. The rule is intended to reduce local and regional emissions of NOx and diesel particulate matter (PM). These emissions are problematic to both human and environmental health. Targeting warehouses with this policy was deemed necessary by the SCAQMD to best address ozone and PM levels that exceed federal air quality standards, encourage the use of zero emissions vehicles and clean energy sources as well as meet other air quality goals within the district.

The rule will require warehouse owners and operators that are utilizing 100,000 square feet or more for warehousing activities to take specific actions each year to earn Warehouse Actions and Investments to Reduce Emissions (WAIRE) points to comply with the rule. WAIRE points can be earned by completing a variety of different emissions lowering actions, for example purchasing a zero emissions, or near zero emissions, vehicle and using it, installing and utilizing solar panels or installing and using hydrogen fueling stations. The number of WAIRE points that a warehouse needs to earn is based on the number of truck trips associated with a warehouse which is then multiplied by a stringency and annual variable which is based on the compliance period and size of the warehouse. If warehouses cannot earn enough points or choose not to take actions, a mitigation fee of $1000 per point will be due.

Warehouses within the first phase, that are 250,000 square feet or larger, will need to begin collecting required data as soon as July 1, 2021. This data will be used in an Initial Site Information Report which will be due in July 2022 for the warehouses included in this phase. This data will also be used in the annual WAIRE report due January 2023. Warehouses smaller than 250,000 square feet will also need to complete this data collection and report submissions in future compliance years based on size. All warehouse owners in the area will need to complete a warehouse operations notification and submit it by September 1, 2021.

Next Steps – TRC Can Help:

As stated above, warehouses 250,000 square feet and larger will need to collect data starting July 1, 2021. TRC can assist warehouse operators with the development of forms and procedures for data collection. We can further assist with the required report writing, notifications and consulting on solutions for WAIRE point earning for all warehouses impacted by this rule.


To learn more about how TRC can help please contact Rachel Mireles at 949-358-5210 or

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