By Yasaman Azar Houshang
South Coast Air Quality Management District’s (SCAQMD) Governing Board adopted Rule 2305, on May 27th, 2021 with the approval of majority of board members as well as the support of the community members. Rule 2305, better known as Warehouse Indirect Source Rule (ISR), is the first of its kind in the air district, due to the fact that it’s targeting mobile source operations in the district, which is usually out of local air district’s jurisdiction and is regulated by the state Air Resources Board.
Under this rule, owners and operators of warehouses with greater than or equal to 100,000 SF of floor area who operate at least 50,000 SF of their facility for warehousing activities, have to earn points by taking actions and making investments in projects that would result in emission reduction. These points, named Warehouse Actions and Investments to Reduce Emissions (WAIRE) points by SCAQMD, can be achieved by implementing some of the options provided by the air district including but not limited to the list below:
- Acquisition and Utilization of ZE and NZE Trucks and Yard Trucks
- Installation and Utilization of ZE Charging Infrastructure and Solar Panels
- Installation of Filter Systems in Residences, Schools, Hospitals, etc.
Facilities can also develop their custom compliance plan and upon approval by SCAQMD, utilize options from their custom plan to achieve emission reduction goals.
The compliance obligation and the number of WAIRE points that are required by each facility is determined based on facility size, compliance year, and the number of truck trips and truck weight class. If a facility is unable to earn sufficient WAIRE points, a mitigation fee of $ 1,000 per unfulfilled WAIRE points shall be paid to the air district.
Warehouses located under SCAQMD jurisdiction in Los Angeles, San Bernardino, Riverside and Orange counties will be phased into the program in 3 steps, based on their size with the first phase of enforcement starting for facilities with floor area equal or greater than 250,000 SF. Owners and operators of these facilities are required to submit an Initial Site Information Report by July 1, 2022 and have to take action to earn WAIRE points and submit WAIRE report on annual basis starting on January 2023, for operations during calendar year 2022. Facilities with floor area less than 250,000 SF and equal or greater than 100,000 SF will be phased in subsequent years.
At NV5, we have extensive experience developing client specific compliance plans as well as preparing regulatory reports for local and state agencies and can provide assistance to warehouse owners and operators that are finding their facilities subject to this rule.
For all inquiries and assistance regarding this matter please contact Yasaman Azar Houshang.