Inside the Warehouse Indirect Source Rule or WAIRE

In May 2021, Rule 2305, the Warehouse Indirect Source Rule (ISR), also known as the Warehouse Actions and Investments to Reduce Emissions (WAIRE) Program, was adopted for warehouses with at least 100,000 square feet of indoor floor space in a single building located in the South Coast Air Basin (SCAB). SCAB is one of several regional air basin areas designated by California for air quality management and air pollution control in Southern California. According to the Environmental Protection Agency (EPA), SCAB covers large areas of Los Angeles, Orange, Riverside, and San Bernardino counties, including the Coachella Valley. The areas are home to more than 17 million people, approximately 44% of the population of the entire state of California.

The goal of Rule 2305 is to reduce emissions generated by warehouse operations, including freight trips to and from warehouses. The rule includes compliance and reporting requirements for warehouse owners and operators.

The program is being phased in over three years (2022–2025), starting with the largest facilities.

A Menu-Based Points System Measures Compliance

Each warehouse operator must calculate its yearly WAIRE Points Compliance Obligation (WPCO) to establish how many points it needs to earn annually. This figure is calculated based on the number of truck visits to the facility in a single year. However, it’s important to note that, even if the number of truck visits remains constant year over year, an operator’s WPCO will rise annually for at least the first three years as the system is phased in using defined annual variables.

Warehouse operators can earn compliance points via a menu-based system by completing actions such as investing in zero-emission (ZE) and/or near-zero emission technologies, using solar panels, installing on-site ZE charging or fueling infrastructure, or installing filtration systems in qualified buildings such as schools. Other options include creating a custom WAIRE plan or paying a mitigation fee of $1,000 per point.

While the rule is specific to warehouses in the South Coast Air Basin, the San Diego Air Pollution District is also exploring and trying to incorporate its own warehouse ISR. In addition, the California Air Resources Board (CARB) has acknowledged the potential of a statewide ISR to meet environmental goals.

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Source: EPA