California WAIRE Program: What Warehouse Owners and Operators Need to Know

If you are trying to understand the California WAIRE Program, start here: Rule 2305, the Warehouse Actions and Investments to Reduce Emissions (WAIRE) Program, is a South Coast AQMD rule for warehouses that reduces emissions tied to goods movement.

It applies to warehouses with 100,000 square feet or more of indoor floor space in a single building, and it requires warehouse operators to earn WAIRE Points each year through approved actions, an approved Custom WAIRE Plan, a mitigation fee, or a combination of those paths.

For owners, operators, lenders, and warehouse investors, WAIRE is not just an environmental rule. It is now part of the operating and due diligence reality for industrial assets in the South Coast AQMD.

EPA approved Rule 2305 into the State Implementation Plan in September 2024, which means the rule now carries added federal enforceability on top of district-level enforcement.

If WAIRE compliance is going to affect a warehouse acquisition, retrofit, or redevelopment plan, it should be reviewed alongside broader sustainability services, construction risk management, and early-stage feasibility studies.

What Is the California WAIRE Program?

The California WAIRE Program is South Coast AQMD’s indirect source rule for warehouse-related emissions. Its purpose is to reduce nitrogen oxides (NOx) and diesel particulate matter (DPM) generated by truck traffic and goods movement activity associated with warehouses. South Coast AQMD describes it as Rule 2305, and its 2026 annual report calls it the nation’s first rule designed to reduce smog-forming emissions from the warehouse sector.

The rule is focused on the South Coast AQMD jurisdiction, which covers large areas of Los Angeles, Orange, Riverside, and San Bernardino counties, including the Coachella Valley. That geographic scope matters because many warehouse owners hear “California WAIRE Program” and assume it applies statewide. It does not. It is region-specific, but it is important enough that industrial owners across California are watching it closely.

For Southern California projects, this is also where local market knowledge matters. KOW’s Los Angeles location page is a natural internal link if you want to connect this topic to your regional presence.

Who Does WAIRE Apply To?

WAIRE applies to warehouse owners and operators when the building has at least 100,000 square feet of indoor floor space used for warehousing activities. But the obligation to earn points does not automatically hit every tenant in a large building. Under Rule 2305, operators generally must earn WAIRE Points when they operate at least 50,000 square feet of warehousing space in a qualifying warehouse, subject to the rule’s ownership and parent-company provisions.

The phase-in is already complete. Rule 2305 phased operators into the program over three years by warehouse size: buildings over 250,000 square feet started first, then 150,000 to under 250,000 square feet, then 100,000 to under 150,000 square feet. The rule’s annual variable reaches 1.0 for all phases in 2026 and beyond, which is one reason the rule has become a more serious planning issue for industrial portfolios.

How WAIRE Points Work

WAIRE is not a flat fee or simple checkbox program. It is a points-based compliance system. South Coast AQMD calculates each operator’s WAIRE Points Compliance Obligation annually based on truck activity associated with the warehouse.

The rule weights truck traffic, and Class 8 truck trips count more heavily than lighter trucks in the formula. Specifically, Rule 2305 defines WATTs as: Class 2b-7 truck trips + 2.5 × Class 8 truck trips.

Operators can satisfy that obligation by earning points through the WAIRE Menu, by using an approved Custom WAIRE Plan, by paying a mitigation fee, or by combining those methods. The WAIRE Menu includes actions such as acquiring or using ZE/NZE trucks, installing or using charging or fueling infrastructure, installing and using onsite solar, and certain filtration measures in nearby sensitive-use buildings.

A lot of warehouse operators hear “points” and assume they can freely buy, sell, or move them however they want. That is not how the rule works. Rule 2305 says WAIRE Points are not transferable except in specified circumstances, including limited transfers between warehouses under the same operator, transfers into future compliance periods at the same warehouse, and certain owner-operator transfers at the same site.

WAIRE Reporting Requirements

WAIRE compliance is not just about choosing the right actions. It is also about filing the right reports on time.

According to South Coast AQMD, warehouse facility owners must submit Warehouse Operations Notifications (WONs), while warehouse operators must submit an Initial Site Information Report (ISIR) and Annual WAIRE Reports (AWRs). These are submitted through the WAIRE Program Online Portal.

The timing matters. Rule 2305 says the ISIR is due by July 1 of the year in which the operator must submit its first Annual WAIRE Report, and the Annual WAIRE Report is due no more than 30 calendar days after January 1 beginning with the operator’s initial reporting date. In plain English, that means most operators think in terms of a January 31 filing deadline for the AWR.

South Coast AQMD’s 2026 annual report also notes that staff conduct desk audits of Annual WAIRE Reports and Warehouse Operations Notifications, and inspectors may conduct unannounced site visits to verify compliance and WAIRE Menu items. That means warehouse owners should treat the reporting file as something that may be audited, not just uploaded and forgotten.

WAIRE Compliance Options: Menu, Custom Plan, or Fee

Most warehouse operators end up thinking about WAIRE in three buckets.

1. WAIRE Menu Actions

This is the most straightforward path. Operators earn points from approved actions already listed in Table 3 of Rule 2305, such as ZE trucks, charging infrastructure, hydrogen fueling infrastructure, onsite solar, or certain filtration investments.

2. Custom WAIRE Plan

A Custom WAIRE Plan can work for operators whose site conditions or logistics profile do not fit neatly into the standard menu. But it is not informal. Rule 2305 requires the plan to show quantifiable, verifiable, and real emissions reductions, and the application must be submitted at least 270 days before the Annual WAIRE Report is due for the compliance period in which the plan will earn points.

3. Mitigation Fee

If an operator does not earn enough points through actions or a custom plan, Rule 2305 allows the remaining obligation to be satisfied through a mitigation fee of $1,000 per WAIRE Point. South Coast AQMD has also launched the WAIRE Mitigation Program to direct collected fees toward emissions-reduction projects. In a February 2026 webinar, the district said it had collected approximately $60 million in mitigation fees to date and that 2026 would be the first year of the mitigation program.

Why the WAIRE Program Matters in Industrial Due Diligence

The WAIRE Program is easy to misread as a narrow compliance issue. It is broader than that.

If you are underwriting, acquiring, refinancing, leasing, or repositioning a Southern California warehouse, WAIRE can affect:

• operating costs

• capex planning

• charging and infrastructure strategy

• solar planning

• lease structure and operator responsibility

• reporting workload

• enforcement exposure

That is why it belongs in pre-acquisition and pre-development review, not just year-end compliance. If a site will need infrastructure investment to satisfy WAIRE efficiently, that should be surfaced early through a construction feasibility study, a pre-construction review, or a broader environmental and operational risk review such as KOW’s post on evaluating environmental risks in construction projects.

How Warehouse Owners and Operators Should Prepare

A practical WAIRE strategy usually starts with five questions:

Know whether the building is actually subject to Rule 2305

Do not assume based on gross building size alone. Confirm the rule’s warehousing-space definitions and operator thresholds.

Confirm who owns the compliance obligation

WAIRE involves both warehouse facility owners and operators, but the reporting and points obligations are not identical. Ownership structure, lease structure, and operational control matter.

Get serious about truck-trip data

Truck traffic is a core input into the WAIRE calculation. If the data is weak, the compliance strategy is weak.

Compare the economics of actions versus fees

Some operators will find that EV charging, solar, or fleet-related investments make more sense than repeatedly paying the mitigation fee. Others may need a hybrid strategy.

Treat WAIRE as an asset-planning issue, not just a filing issue

This is where KOW can connect the dots between sustainability services, construction risk, feasibility, and long-term asset decision-making.

Final Takeaway

The California WAIRE Program is one of the most important warehouse regulations in Southern California right now. It applies to qualifying warehouses in the South Coast AQMD, uses a points-based compliance framework tied to truck activity, and requires both reporting discipline and real operational planning. It is also no longer something owners can afford to treat as experimental or temporary. EPA approved Rule 2305 into the SIP in 2024, the phase-in is complete, and South Coast AQMD is actively auditing, inspecting, and enforcing the program.

For warehouse owners, operators, developers, and lenders, the better move is to address WAIRE early, model the compliance path clearly, and build it into the site’s long-term operating plan.

FAQs

What is the California WAIRE Program?

The California WAIRE Program is South Coast AQMD Rule 2305, a warehouse emissions rule that requires qualifying warehouse operators to reduce goods-movement emissions through WAIRE Points, custom plans, mitigation fees, or a mix of those options.

Does WAIRE apply across all of California?

No. WAIRE applies within the South Coast AQMD jurisdiction, not statewide. That includes large portions of Los Angeles, Orange, Riverside, and San Bernardino counties.

What size warehouse triggers WAIRE?

Rule 2305 applies to warehouses with 100,000 square feet or more of indoor floor space in a single building. Operators generally must earn points when they control at least 50,000 square feet of warehousing space in a qualifying building, subject to the rule’s detailed provisions.

How much is the WAIRE mitigation fee?

The rule sets the mitigation fee at $1,000 per WAIRE Point.

What reports do operators have to file?

Warehouse operators generally need to file an Initial Site Information Report and Annual WAIRE Reports, while warehouse facility owners must file Warehouse Operations Notifications.

Can WAIRE Points be banked or transferred?

Yes, but only in defined circumstances. Rule 2305 allows limited transfers between warehouses under the same operator, transfers into future compliance periods at the same warehouse, and certain owner-operator transfers at the same site. It is not a free-form point marketplace.