South Coast Air Quality Management District Rule 2305 – Warehouse Actions and Investments to Reduce Emissions (WAIRE) Program
August 3, 2021
By: Jason Gambito & Dasni Ahangama
South Coast Air Quality Management District (SCAQMD) adopted Rule 2305 in April of 2021. This rule requires warehousing including manufacturing facilities with at least 100,000ft2 of indoor floor space in a single building to reduce NOx and PM10 emissions associated with mobile sources. The rule is expected to reduce smog-forming emissions by 10-15% from warehouse-related sources beyond existing State and Federal regulatory requirements.
Rule 2305 Summary
- Operators of facilities with at least 50,000ft2 of warehouse activities are required to submit a one-time Initial Site Information Report (ISIR), Annual WAIRE Report, and meet Warehouse Point Compliance Obligation (WPCO), based upon Weighted Annual Truck Trips (WATTs). The WPCO is set to become stringent as the years progress.
- Operators will offset the WPCO with WAIRE Points that are generated by investing in zero-emission trucks, charging or alternative fueling stations, on-site renewable energy or other mitigation strategies that are defined in the rule. Operators can also implement a Custom WAIRE Plan with SCAQMD approval or pay a mitigation fee.
- WAIRE Points can be banked for up to 3 years and can be transferred to operations under the same control or at the same facility.
- Exemptions to this rule include:
- Operators with less than 50,000ft2 warehousing activities are exempt from all rule requirements.
- Operators are exempt from requirements to generate WAIRE Points for any year in which the WPCO requirement is less than 10 points.
Key Compliance Deadlines
September 1, 2021 – Applicability Reporting Deadline
Owners of facilities greater than 100,000 ft2 must submit a Warehouse Operation Notification (WON) for entities leasing at a warehouse building, and the space used for warehousing for each lessee and the building owner.
Subsequent Compliance and Reporting Deadlines
Annual Reporting and Compliance Requirements
- By July 1 of the first Annual WAIRE Report period, operators with at least 50,000ft2 of active warehouse space must submit a one-time Initial Site Information Reports to include estimated truck trips fueling and energy data, and the intended strategy for generating WAIRE Points.
- By January 31 of each year, operators must submit Annual WAIRE Reports to certify truck trips and the WAIRE points that were generated for the year.
Immediate Compliance Management Actions
- Review warehousing activities to confirm and report rule applicability to SCAQMD.
- Compile annual truck trip data to estimate future potential WPCO.
- Review the costs and benefits of allowable compliance options and develop a multi-year strategy for earning WAIRE Points.
The professionals at Montrose Environmental Solutions can help with determining Rule 2305 applicability and developing cost effective multi-year compliance strategies.
Montrose Environmental Solutions Contact:
Principal, Permitting & Compliance
SCAQMD Online Resources
Note: The contents of this document are not inclusive. Montrose is not liable for wrong or incorrect information. Refer to the most current Rule for additional details.
Jason Gambito brings over 9 years of industry experience to the Montrose team, where he currently serves as Principal. He specializes in air quality permitting and compliance, with a focus in Southern California. In addition, Mr. Gambito has extensive experience with wastewater, stormwater permitting and compliance. His broad client base includes food production, aerospace manufacturing, plating facilities, fiberglass production, and healthcare facilities. Mr. Gambito is a Qualified Industrial Stormwater Practitioner (QISP) with the California State Water Board and a Certified Permitting Professional (CPP) with SCAQMD. Mr. Gambito earned his Bachelor’s Degree in Chemical Engineering from California State University, Long Beach.
Dasni Ahangama brings over 3 years of industry experience to the Montrose team, where she currently serves as a Staff Scientist II. She specializes in air quality and stormwater permitting and compliance, with a focus in Southern California. In addition, Ms. Ahangama has experience with municipal Land Management Systems and urban planning. She holds a Master’s in Urban and Regional Planning and B.S. in Earth Systems Science with a minor in Global Sustainability.