Major impact expected to warehouse owners and operators in Southern California

After delaying the vote in April, the Southern California Air Quality Management District (SCAQMD) held a vote for immediate implementation of the WAIRE program for South Coast Air Basin, Salton Sea Air Basin, and Mohave Desert Air Basin. This area consists of Orange County as a whole, as well as large portions of Los Angeles, Riverside, and San Bernardino Counties. While compliance will still be phased in beginning in 2022, all warehouse owners will be required to report size and tenant information for their warehouse facilities over 100K SF, located within the SCAQMD governed area in by September 2021. This report will be required annually, and updates will be required any time there is a square footage or tenant change. Reports will be made through a yet-to-be-developed online portal and requires any operator using over 100K SF of space to earn or purchase WAIRE Points (Warehouse Actions and Investments to Reduce Emissions). Any facility/operator that has a WPCO (WAIRE Points compliance obligation score) of 10 or less, will not be required to earn WAIRE Points.

Current Compliance Timeline by Warehouse Size:

• Warehouses 250K SF and over will be required to begin tracking and self-reporting for compliance Aug 2, 2022
• Warehouses between 150K SF -250K SF would begin Aug 1, 2023
• Warehouses between 100K SF and 150K SF would begin July 31, 2024

Approximately 2,902 warehouse owners and 3,995 warehouse operators are expected to be impacted by this ruling. One major barrier to compliance for owners and operators will be the commercial availability of clean energy fleets. Class 8 zero emission trucks (semi-trucks), which provide the highest WAIRE point value for emission friendly vehicles, are not currently available. Class 4-7 zero and net zero emission trucks are commercially available as delivery and mass transportation vehicles, but medium to heavy freight emission friendly vehicles are just becoming commercially available through 2021 and 2022. The good news is that once warehouse owners and operators are running emission friendly fleets, they don’t just earn points by purchasing the vehicles, they earn points for every trip to or from their facility by an emissions-friendly vehicle.

The other option for warehouse owners or operators to reach compliance is to purchase the WAIRE points needed under the “mitigation fee only” option. For the first year of the program, the SCAQMD Board believes that this route would be the more expensive route and estimate a cost of approximately $.83/SF to warehouse owners and operators.

The goal of this ruling is to reduce emissions in one of the worst air quality zones in the county. Proponents of Source Rule 2305 have stated that the reduction of emissions from this rule will be a 10-15% decrease in Nox emissions by 2031. This reduction would allow the area to meet current federally mandated air quality standards set forth by the EPA. For more information and updates, please check the SCAQMD website.