regulatory compliance

Federal and state regulations are pushing equipment manufacturers and fleets to pursue lower-emission heavy-duty vehicles, and Rule 2305 in California is among the requirements that could affect fleets operating in the state.

Rule 2305 — also known as the Warehouse Actions and Investments to Reduce Emissions (WAIRE) Program or the Warehouse Indirect Source Rule (ISR) — requires warehouse operators to track and record every truck trip coming in and out of the facility to monitor the indirect emissions coming from the trucks that visit their locations.

Every time an internal combustion truck enters their facility, warehouses can face potential fees. Each truck trip from a tractor has a 2.5 times higher compliance impact than straight trucks due to their higher emissions, according to the South Coast Air Quality Management District. Truck trips are defined as one-way trips to or from a warehouse facility when delivering goods. Warehouse operators need to annually account for the total truck trips at each regulated facility, and then offset those emissions. The more trucks - especially Class 8 trucks - that visit a warehouse, the more mitigation fees a warehouse operator has to pay.

However, warehouse operators can reduce or eliminate their WAIRE mitigation fees by implementing emission-reduction activities, such as leasing electric yard tractors and adding zero-emission truck trips to the site. Zero-emission actions earn points that can offset the mitigation fee impact from truck visits. As a result, warehouse owners and operators may put pressure on fleets to use low- or zero-emission vehicles when visiting their locations.

The rule is designed to reduce NOx and diesel emissions and reduce air pollution in the South Coast Air Quality Management District, which includes Orange County, western San Bernardino County, western Riverside County, including the Coachella Valley, and southern Los Angeles County.

SCAQMD has taken a phased in approach with the rule. The largest warehouses — those that are 250,000 square feet and above — had to file their first annual WAIRE report by Jan. 31, 2023. Facilities between 150,000 and 250,000 square feet had to file their first report by Jan. 31, 2024. Facilities between 100,000 and 150,000 had to file an Initial Site Information Report by July 2, 2024, and will have to file their first annual report by Jan. 31, 2025. SCAQMD is now actively issuing Notices of Violation for non-reporting and non-compliance.

Penske Truck Leasing has a wide range of low- and zero-emission vehicles that can help warehouse operators or fleets serving facilities within the South Coast Air Quality Management District. To learn more about available options, contact us today.

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