Everything Warehouses Need To Know About the WAIRE Program 

The Warehouse Actions and Investments to Reduce Emissions (WAIRE) Program was adopted in May 2021. The South Coast Air Quality Management District (SCAQMD) passed this program, also called Rule 2305, to incentivize warehouse operators to implement renewable energy sources such as solar energy, battery energy storage systems, and electric vehicle charging stations.  

This rule promotes California’s environmental sustainability goals by reducing carbon emissions and helping reverse climate change. Specifically, WAIRE addresses warehouses as sources of air pollution and aims to reduce it, particularly in communities where they’re located.  

WAIRE is being implemented in phases and warehouse operators must understand the guidelines to avoid these penalties and develop more environmentally sustainable practices.  

Warehouses — and the heavy-duty trucks they rely on — are a significant source of air-polluting emissions in the South Coast Air Basin due to their role in supply chain logistics. To mitigate these emissions, the SCAQMD enacted Rule 2305. As part of AQMD Rule 2305, warehouse operators must earn points for various emission-reduction activities to fulfill their WAIRE Points Compliance Obligation (WPCO). The number of points a warehouse must earn depends on the number of trucks that visit it annually.  

Rule 2305 requires California warehouses to track and submit a report of their emission-reduction strategies annually. The WAIRE Program was implemented in three stages, with the last going into effect in 2024. If your site doesn’t earn enough WAIRE points to offset your WPCO, you must pay mitigation fees.  

Many warehouses face challenges in WAIRE compliance. The initial costs of compliance actions can be significant, and transitioning to clean energy options can temporarily interrupt business operations, which can add to the expense.  

Fortunately, operators have flexibility in how they earn WAIRE points. You can choose options that make the most sense or are part of your sustainability strategy. In the long term, the WAIRE Program is part of California’s goal to achieve net-zero emissions by 2045.  

Warehouses that are over 100,000 square feet earn points through a menu-based system. You can earn points using one or more of the following three methods:  

Each year, you must file an Annual WAIRE Report (AWR) outlining your actual truck trips, earned points, and metrics for your completed actions. Your reports must be submitted via the WAIRE Program online portal (POP). Your records are subject to audits and verification by the SCAQMD and must be retained for seven years.  

The WAIRE menu includes activities such as installing clean energy systems, adopting zero-emission vehicles, or improving your operational efficiency. You can accumulate points for buying or being visited by zero or near-zero-emission vehicles. Buying, leasing, or renting low or no-emissions vehicles counts toward this option, as does every visit to your warehouse from one. This is a good opportunity to earn points from third-party fleets.  

In addition to promoting activities that contribute to renewable energy, the WAIRE Program awards points for activities that reduce air pollution, particularly in the communities where they’re located. One such activity is upgrading the HVAC systems in communities that are located near hospitals or schools. You can earn points for installing or upgrading to a MERV 16 or better high-efficiency air filtration system as well as regularly replacing the filters.  

Developing a proactive plan for compliance will help you avoid fees and penalties and save money. You can bank WAIRE points to carry over, so if you’re implementing a high-point initiative this year, you may be able to use some of them next year.  

Installing solar energy is one of the most cost-effective and efficient methods of reducing emissions and meeting WAIRE goals. Commercial solar installations can also be used to power electric vehicle charging stations, which is another avenue for earning WAIRE points and powering electric yard trucks. 

There are two primary methods of earning WAIRE points through commercial solar energy: solar panel installation and solar energy usage. This allows you to keep earning points beyond your initial installation.  

Warehouses typically have flat roofs, which are ideal for installing rooftop solar panels. You can also install solar panels as part of carports or on other available land. Commercial solar energy systems earn WAIRE points based on the system’s kilowatt capacity. Larger systems earn more points, allowing you to scale up if you have ample space.  

Solar can be a great investment if you finance your project with a solar power purchase agreement (PPA). With commercial solar PPA financing, you have no upfront costs. The solar developer constructs, owns, maintains, and operates the solar project on your property. You’ll immediately see the benefits of reduced energy prices, lower emissions, and WAIRE points without an expensive capital outlay. And when combined with energy storage, you’ll also be able to control your energy usage and eliminate peak demand costs. This is particularly important for cold storage warehouses.  

Because you earn points based on the amount of energy your system generates, using PPA financing allows you to accumulate points for the excess energy your system generates. You can use this passive generation of WAIRE points to meet your WPCO or bank excess points for future years.  

Although you can’t earn WAIRE points for existing systems — though you can for using these systems — you can earn them for adding new capacity. If your solar installation exceeds the standard WAIRE menu option, you can propose a custom plan to earn additional points.  

A commercial solar energy installation can be the foundation of your sustainability and compliance efforts. It allows you to create a strategic renewable energy initiative that will deliver reliable, affordable energy and help you reduce emissions — all at minimal cost to your organization.  

REC Solar is experienced in helping southern California businesses navigate WAIRE requirements, so you can maximize your WAIRE points while minimizing your expenses — both upfront and ongoing. Sustainability is increasingly important for businesses and their customers. Switching to solar energy can help you comply with regulations and give you a competitive advantage in the marketplace. Reach out today to learn more about how we can help you create a more sustainable future.