May 15, 2023
In May 2021, the South Coast Air Quality Management District (SCAQMD) in Southern California adopted rule 2305, or the Warehouse Actions and Investments to Reduce Emissions (WAIRE) Program.
The warehouse program aims to reduce diesel and nitrogen oxide emissions from shipping and warehousing. It seeks to meet environmental regulations and guidelines set by the federal government and to create a cleaner environment.
The official WAIRE guidelines read: The WAIRE Program determines a warehouse operator’s WAIRE Points Compliance Obligation (WPCO) based on annual truck trips to each applicable new and existing warehouse that has at least 100,000 square feet of indoor floor space within a single building that may be used for warehousing activities.
This freight warehousing program applies to warehouses within the jurisdiction of the SCAQMD.
Shipping and warehousing operators must submit a one-time Initial Site Information Report about their warehouse operations and get their initial WAIRE points. Then, each year, they must submit Annual WAIRE Reports that document and demonstrate their yearly compliance with the program.
Report submission and payment of associated fees are done through the WAIRE Program Online Portal (POP).
All records used to demonstrate compliance with this warehouse program must be kept by shipping and warehousing operators or owners for at least seven years. They must be made available to SCAQMD upon request for audits or other inquiries.
WAIRE is a point system that requires freight warehousing operators to earn a certain number of points each year. The scoring is primarily based on the number of trucks or transportation services that are driven through the warehouse. This includes all carriers and drivers that go to and from the location, regardless of whether it is an in-house trucking warehouse.
Points are earned via the following:
Completing actions in the WAIRE menu
A site-specific custom WAIRE plan
Paying $1,000 per point (the set mitigation fee to offset the obligation for earning points)
Extra points can be saved up for the future or transferred to other warehouses.
The collected mitigation fees will be used to help the environment. They incentivize the use of zero/near-zero emission (ZE/NZE) trucks as well as ZE charging and fueling infrastructure for communities located near the warehouses that paid the fee.
Shipping and warehousing operators can earn points through the following:
Acquiring ZE/NZE trucks
Reducing diesel-powered trucking warehouse visits
Using ZE yard trucks
Installing ZE charging or fueling infrastructure
Beginning or finalizing infrastructure projects
Using onsite ZE charging or fueling infrastructure
Installing onsite solar panels
Installing MERV 16 or greater filters in certain buildings.
The number of WAIRE points depends on the specific action taken and its size or scope.
Page 20 of this official document outlines in detail how warehouse operators can earn WAIRE points to comply with Rule 2305.
For awarding points to emission-cutting actions not included in the WAIRE Menu, the WAIRE program allows for the submission of a Custom WAIRE Plan. It can include points for the following:
Running jointly owned off-site ZE charging or fueling infrastructure
Using battery storage systems in freight warehousing
Implementing energy management initiatives that lead to reduced emissions from local natural gas-fired power plants
The plan can also include local hiring to be counted as points for reducing employee commute emissions.
However, WAIRE Points can only be earned upon approval of the plan. Any warehouse program actions or investments made before approval will not be considered.
The SCAQMD conducts desktop and field audits and warehouse inspections to verify compliance with the WAIRE program. For desktop audits, warehouse operators and owners may be asked for further documentation to support their submitted WAIRE Program reports.
SCAQMD inspectors may conduct unannounced visits to freight warehousing facilities to verify compliance with record keeping and other requirements. They may tour the facility to check the onsite presence of equipment related to the WAIRE Program.
Upon identifying discrepancies in the warehouse operator’s WAIRE Program reporting or facility, the inspector will discuss the issue with the shipping and warehousing operator to determine the cause of the issue or require further documentation.
If proof cannot be provided to support the reported information, the warehouse operator may need to obtain more WAIRE Points to meet their WPCO.
The WAIRE rollout schedule consists of three phases:
Operators of trucking warehouse facilities spanning more than 250,000 square feet must have submitted their initial site information report by July 1, 2022. The deadline for their first annual WAIRE report was due on Jan 31, 2023, covering the first compliance period from January 1, 2022, to December 31, 2022.
The compliance period and initial site information report due dates for smaller warehouses (between 100,000 and 249,999 square feet) will commence in 2023 and 2024.
For the second phase of the warehouse program (warehouses between 150,000 and 250,000 square feet), the due dates and first compliance period shift by one year from the dates of the first phase.
The dates shift by another year for the third phase (warehouses between 100,000 and 150,000 square feet).
The WAIRE Program aims to reduce the impact of shipping and warehousing operations on the environment. It is a step towards rendering any warehouse a sustainable business. Falling short of WAIRE points to meet WPCO can result in undesirable enforcements and shelling out hefty sums.
New questions may arise about how to manage a warehouse or organizing a warehouse in the wake of this warehouse program.
MDB Transportation’s green fleet can help you with compliance. Our transportation company specializes in sustainability in transportation infrastructure and provides transparent and seamless freight transportation in Los Angeles.
We will continue our efforts to lead the freight warehousing and trucking industry toward a cleaner, greener, and eco-friendly future. Expand your warehouse resources with our innovative and sustainable local truck driving offerings.
