Warehouse Actions and Investments to Reduce Emissions (WAIRE)

South Coast Air Quality Management District (SCAQMD) adopted Rule 2305 – Warehouse Indirect Source Rule (ISR) – Warehouse Actions and Investments to Reduce Emissions (WAIRE) Program on May 7, 2021. The purpose of the WAIRE Program is to reduce local and regional emissions of nitrogen oxides and particulate matter, and to facilitate local and regional emission reductions associated with warehouses and the mobile sources attracted to warehouses in order to assist in meeting state and federal air quality standards for ozone and fine particulate matter. The rule applies to owners and operators of warehouses located in the SCAQMD jurisdiction with 100,000 square feet (SF) or more of indoor warehouse space in a single building.

?The WAIRE Program is a menu-based point system. Warehouse operators are required to earn a specific number of points every year, called the Warehouse Points Compliance Obligation (WPCO). The WPCO for a warehouse is determined by the Weighted Annual Truck Trips (WATTs). WATTs is calculated by the amount of truck trips of a straight truck (Class 2b to 7) and the amount of truck trips of a tractor (Class 8) multiplied by a factor of 2.5. The WAIRE Program has been set to be phased in over 3 years, beginning in 2022 through 2025. As such, a warehouse operator’s WPCO is calculated with the applicable Stringency factor and Annual Variable for the compliance year and warehouse building size.

?

Warehouse operators are required to submit an Initial Site Information Report (ISIR) regarding their operations and earn a specific number of WAIRE Points each year, which can be earned through:

?

• Completing actions off the WAIRE Menu;
• Implementing an approved, site-specific Custom WAIRE Plan; or
• Paying a mitigation fee.

?

Warehouse operators can bank WAIRE Points for a future year, or transfer points to another warehouse that they operate. Annual WAIRE Reports (AWR) documenting compliance are due on January 31 for the previous reporting year. Warehouse owners are only required to submit basic information (Warehouse Operations Notification) about the building and their tenants; however, warehouse owners can opt-in to earn WAIRE Points if they choose.

?Warehouse operators may be exempt from parts of the rule if:

?

• If they operate less than 50,000 SF for warehousing activities;
• If the number of points required is less than 10; or
• If the WAIRE menu action chosen underperforms due to circumstances beyond the operator’s control, such as manufacturer defect.

?

The WAIRE Program is being phased in over time based on the warehouse size, according to the table below. Initial Site Information Report for Phases 1 and 2 were due in July 2022 and 2023, respectively; Phase 3 will be due on July 1, 2024. The next AWR for Phases 2 and 3 will be due in January 2024 and 2025, respectively, for the previous reporting year.

?If your warehouse is between 150,000 SF and 250,000 SF in size, an AWR will need to be submitted by January 31, 2024, for the 2023 reporting year.

About Citadel EHS

Citadel EHS has over 30 years of experience in supporting our clients with their environmental compliance needs and guiding them through the different regulatory processes. Our Environmental Compliance practice, led by Principal Nalinna Rasu, is here for your WAIRE Program needs, including plan preparation, compliance documentation, training, and plan implementation.??

Read more about the WAIRE program here:

https://www.aqmd.gov/home/rules-compliance/compliance/waire-program

Meet the Expert

Nalinna Rasu, CAC, CDPH, CHMM, LEED AP

Principal, Environmental Compliance

[email protected]

(818) 246-2707