SCAQMD Warehouse Rule 2305
The South Coast Air Quality Management District (SCAQMD) adopted Rule 2305, the Warehouse Indirect Source Rule, on May 7, 2021. Owners and operators associated with warehouses 100,000 square feet or larger are required to report information to the District.
Warehouse Owners: The WON Report
Owners of warehouses 100,000 square feet or larger must submit a Warehouse Operators Notification (WON) report by September 1, 2021. The report includes information such as the entities operating within the facility and the amount of space operated by each entity. The WON report will need to be submitted in the Program Online Portal (POP), which can be accessed on the SCAQMD’s website here.
Warehouse Operators: The ISIR
Within warehouses 100,000 square feet or larger, any operator who controls at least 50,000 square feet will be required to submit an Initial Site Information Report (ISIR). The deadline for the first ISIR is dependent upon the size of the operations:
- 250,000 square feet or larger – ISIR due July 1, 2022;
- 150,000-249,999 square feet – ISIR due Jully 1, 2023; or
- 100,000-149,999 square feet – ISIR due July 1, 2024.
The ISIR will require information on truck trips made to the warehouse, as well as operation of the operator’s vehicles (by miles traveled) and yard trucks (by operating hours), for the 13 months prior to the applicable deadline. Thus, affected warehouse operators should start collecting this information as soon as possible. Truck trips are categorized by vehicle class, with Class 8 (tractor) trucks reported separately from Class 2B through 7 (straight) trucks.
Operators within eligible warehouses who control less than 50,000 square feet must submit a statement attesting that they are exempt from the requirements of Rule 2305.
Warehouse Operators: The WAIRE Program
Submitting an ISIR is the first step to register applicable operators in the Warehouse Actions and Investments to Reduce Emissions (WAIRE) program. Subsequently, operators with at least 50,000 square feet of warehousing activities must continue to track truck trips every year and submit an annual report of this information by January 31st. Warehouse operators in the WAIRE program are obligated to provide offsets for their truck trip emissions in the form of “WAIRE points,” which can be generated through potential compliance pathways outlined in the WAIRE menu or by paying mitigation fees. For more information, visit the SCAQMD website here.
Yorke staff has worked with the SCAQMD throughout the development of Rule 2305, and we are familiar with the District’s requirements and expectations for reporting. Yorke can assist warehouse owners and operators with the following:
- Preparing the WON report and submitting it to the SCAQMD via POP;
- Determining applicability of Rule requirements;
- Identifying truck trip data tracking methodologies and developing a tracking system;
- Reviewing data for accuracy and completeness;
- Preparing the ISIR and submitting it to the SCAQMD via POP;
- Estimating annual WAIRE point obligations;
- Preparing annual WAIRE compliance reports based on truck trip tracking;
- Evaluating eligible offsets and compliance pathways in the WAIRE menu; and
- Creating a custom WAIRE Plan and seeking approval from the SCAQMD.