February 13, 2024

Navigating Warehouse Emission Regulations: Understanding Southern California's WAIRE Program

Banking WAIRE Points for a Greener Future: Maximizing Benefits and Avoiding Fees

Southern California warehouse operators face costly regulation fees to offset emissions from the trucks that come and go from their facilities.

Warehouse Indirect Source Rule (ISR) 2305 incentivizes warehouse owners/operators to adopt renewable technologies such as solar systems, energy storage, and EV charging stations to reduce mitigation fees.

What is the WAIRE Program?

The South Coast Air Quality Management District (AQMD) implemented ISR 2035 in 2021, introducing the Warehouse Actions and Investments to Reduce Emissions (WAIRE) Program to curtail air pollution by 10%-15% in five years.

Over 4,000 warehouses in parts of Los Angeles, Orange, Riverside, and San Bernardino counties fall under the South Coast AQMD jurisdiction and are subject to the WAIRE program’s compliance and reporting standards.

The WAIRE program has been phased in over time based on warehouse size. Phase 3 started in January 2024, meaning operators of warehouses with 100,000 square feet to 149,999 square feet must submit their Initial Site Information Report by July 1, 2024.

How does the WAIRE Program work?

The WAIRE program is a point-based system that moderates emission-reducing activities for warehouses with 100,000 square feet or more of indoor spaces in one building.

Operators must meet a certain threshold of points based on the number of truck visits to that warehouse in one year, called the WAIRE Points Compliance Obligation (WPCO).

Failure to meet the WPCO results in paying a mitigation fee of $1,000 per point, which could reach six figures in some instances.

Earning WAIRE Points​

The program rewards points to warehouse facility operators for completing actions on its extensive menu, such as adopting eco-friendly equipment and vehicles for their operations.

There are three main ways for warehouse facilities to earn WAIRE points:

WAIRE program action items
  • Complete actions from the WAIRE menu
  • Find an approved site-specific plan and complete its tasks
  • Pay an Emissions Mitigation Fee

The quickest way to earn the most points is to purchase zero or near-zero-emission trucks and earn points from their annual number of trips.

Are there Exemptions?

There are a few exemptions from ISR 2305, which include warehouses with less than 50,000 square feet and facilities with a score of less than 10 WPCO.

Exemptions can also be made if a WAIRE menu action item underperforms because of circumstances outside the operator's control, like a manufacturer defect.

Avoiding future fees

WAIRE points can only be banked for three years after they are earned, so it is essential to determine how to earn points, retain compliance, and avoid fees continuously.

Electrifying one’s fleet can yield the most points, but it can result in a significant spike in energy usage.

Combining sustainable energy solutions is a powerful play as annual solar production and EV charger usage generate WAIRE points for electricity used per kilowatt hour.

A ZE fleet energized by EV charging stations powered from rooftop solar backed by an energy storage system will earn significant WAIRE points and reduce electricity costs for years.

If a warehouse operator earns points that exceed its WPCO, the extra points can be rolled over to future years or transferred to other warehouses under the same operator.

Green Convergence can help implement WAIRE

ISR 2305 has proven to be a complex program for many Southern California warehouse owners and operators to comply with its guidelines.

Green Convergence is the go-to contractor with a proven track record and industry expertise to incorporate energy solutions into your warehouse operations.

Our financial experts utilize federal and state-backed incentives and rebates to keep installation costs low while navigating policy changes.

The in-house design team can craft optimized solutions for your needs, while the installation team’s quality workmanship ensures the system lasts.

Learn how your warehouse facility can utilize renewable energy solutions to reduce electricity costs and comply with ISR 2305 by contacting one of our experts.


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