Warehouse operators across Southern California are under increasing regulatory pressure — and many are feeling the financial strain. Rule 2305, also known as the Warehouse Indirect Source Rule or WAIRE Program, is now being actively enforced by the South Coast Air Quality Management District (SCAQMD), and noncompliance can come with serious consequences.
WAIRE was created to address the significant emissions impacts caused by truck activity — specifically Class 2b to Class 8 trucks — coming and going from warehouses. The rule’s purpose is clear: warehouse operators must take emission mitigation actions and/or make clean technology investments to offset their environmental impact. When they don’t, they’re required to pay a compliance mitigation fee — and that’s where things are getting costly.
Compliance Rates Lag, Audits Rise
Despite being in effect since 2022, WAIRE compliance remains low. Only about 20% of warehouses have met their full compliance obligations, according to recent data.
As a result, SCAQMD has ramped up audits, inspections, and Notices of Violation (NOVs) to warehouse operators who either failed to submit reports, did not take sufficient mitigation actions, or failed to pay their respective fees. These violations come with hefty fines — some potentially in the tens or hundreds of thousands of dollars — which can dramatically impact a company’s bottom line.
Many operators are learning the hard way: paying the compliance fee is often significantly more expensive than taking proactive mitigation actions.
What Are Emission Mitigation Actions?
The WAIRE program allows warehouse operators to earn compliance points by implementing emission-reducing strategies, such as:
- Deploying zero-emission trucks
- Installing electric vehicle (EV) infrastructure
- Supporting solar panel installations
- Purchasing low-emission yard equipment
Each of these actions earns “WAIRE Points” that count toward meeting your facility’s annual obligation. If you fall short, you’re required to pay the WAIRE mitigation fee — which can quickly add up.
In 2023, more than half of the warehouses that submitted WAIRE reports opted to pay the fee instead of implementing emission reduction strategies. While this may seem like a convenient route in the short term, it’s proving to be the most expensive option — not just in terms of money, but also in missed opportunities for sustainability leadership.
Don’t Wait for an Audit — Take Action Now
This is where proactive planning can make all the difference.
With SCAQMD turning up the heat on noncompliant facilities, it’s more important than ever to take action early — and strategically.
Too many warehouse operators are finding themselves hit with large fees or fines simply because they didn’t know where to start. The truth is, with the right guidance, most facilities can dramatically reduce what they owe — and in the process, build a stronger, greener supply chain. WAIRE compliance actions don’t have to be as costly as outright mitigation fees and can actually be a driver of sustainable long-term value.
TRC specializes in helping warehouse operators navigate WAIRE compliance in a cost-effective, strategic way. By assessing each facility’s operations and WAIRE obligations, TRC tailors mitigation strategies that deliver both regulatory compliance and meaningful emissions reductions, while managing long-term costs.
Depending on the strategy implemented, TRC has helped clients reduce their WAIRE compliance costs by up to 70%. And in total, the firm has helped clients avoid more than $16 million in WAIRE-related fees to date.
Meet TRC at ACT Expo
Want to learn more? Juliana Rodríguez Ortiz, Director of Regulatory Compliance will be sharing expert insights at ACT Expo 2025 during the panel session, “Warehouse Sector: Logistics from Storage to Shipment,” happening on Wednesday, April 30, 2025.
Not registered for ACT Expo yet? You can still join — you can reach out to Juliana Rodríguez Ortiz directly at jrodriguezortiz@trccompanies.com for potential ACT Expo discounts and more information regarding your facility’s specific needs and opportunities under the WAIRE program.
Final Thoughts on WAIRE
WAIRE compliance is no longer optional — but the path you choose can make all the difference. Whether you’re looking to avoid fines, reduce operational costs, or position your business as a sustainability leader, now is the time to take a smarter approach.
TRC is here to help you get there.
