More than 900 warehouses cited under Southern California’s WAIRE program

Southern California’s release of a list of more than 900 warehouse facilities cited under the WAIRE Program highlights a growing compliance challenge: environmental obligations increasingly depend on operational data, reporting, and emissions accountability, not just permits and equipment.

The South Coast Air Quality Management District (South Coast AQMD) recently published a list of more than 900 warehouse facilities that have received Notices of Violation (NOVs) related to the Warehouse Actions and Investments to Reduce Emissions (WAIRE) Program. The violations have drawn attention to one of the nation’s most closely watched indirect source rules and serve as a reminder that warehouse operators face increasing regulatory scrutiny over truck-related emissions.

Unlike traditional air regulations that directly regulate smokestacks or equipment, the WAIRE Program regulates emissions associated with warehouse activity itself. Adopted as Rule 2305, the program is designed to reduce air pollution generated by the movement of goods, particularly the heavy-duty diesel trucks that travel to and from warehouses. The rule applies to warehouses with at least 100,000 square feet of indoor floor space in a single building within the South Coast AQMD jurisdiction, which includes portions of Los Angeles, Orange, Riverside, and San Bernardino Counties.

How the WAIRE program works

The WAIRE Program uses a menu-based compliance system rather than prescribing a single control technology. Warehouse operators must earn WAIRE points each year through approved actions, implement an approved custom WAIRE plan, pay a mitigation fee, or use a combination of those approaches. Qualifying actions may include supporting zero emission or near-zero emission trucks, installing charging infrastructure, or implementing other emission-reduction measures.

A facility's compliance obligation is largely based on truck activity. Operators must track and report the number of truck trips associated with their warehouses and use that information to determine annual compliance obligations. The program therefore places significant emphasis on recordkeeping, reporting, and data accuracy.

Why so many violations?

The large number of cited facilities does not necessarily indicate widespread excess emissions. In many cases, environmental violations stem from administrative and reporting failures rather than visible pollution events. Under WAIRE, warehouse owners and operators must submit required notifications and annual reports, maintain supporting records, and demonstrate how compliance obligations were met. Failure to complete these requirements can result in enforcement actions even when facilities continue operating normally.

The situation reflects a broader trend in environmental compliance. Regulators increasingly rely on data driven programs that require facilities to quantify activities, maintain extensive records, and submit annual compliance reports. As a result, organizations may face enforcement risks from incomplete truck trip data, missed reporting deadlines, or insufficient documentation just as readily as from equipment related violations.

A sign of things to come?

The WAIRE Program is widely viewed as a pioneering indirect source rule because it targets emissions associated with warehouses through transportation activity rather than directly regulating emission sources at the facility. As states and local agencies continue exploring ways to reduce emissions from goods movement and transportation networks, other jurisdictions may look to Southern California's approach as a model.

For warehouse operators, the recent enforcement activity underscores the importance of understanding applicability, maintaining accurate truck-trip records, and ensuring annual reporting obligations are completed on time. As the list of cited facilities demonstrates, compliance increasingly depends not only on reducing emissions but also on documenting and proving that required actions were taken.