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Legal Alert

Deadline for Warehouses to Submit Compliance Reports to SCAQMD Extended to February 14, 2025

Deadline for Warehouses to Submit Compliance Reports to SCAQMD Extended to February 14, 2025

The South Coast Air Quality Management District (SCAQMD)’s Rule 2305 affects almost 4,000 warehouses located in Orange County and in the urbanized areas of Los Angeles, San Bernardino, and Riverside Counties that are 100,000 square feet in size or larger. Annual reports are required to be submitted through the SCAQMD’s WAIRE Program Portal by January 31, 2025. Due to impacts from the wildfires in Los Angeles County, the due date for the reports for the 2024 compliance period has been extended to February 14, 2025.

Every year warehouse operators are required to commit to implement enough strategies from a “menu” or pay a mitigation fee to satisfy the number of “points” the operator is required to earn. The number of “points” is based on the number of annual truck trips to and from the warehouse.

Operators of warehouses are required to:

  • Calculate the total number of trucks that entered or exited the site for the year (January 1 – December 31), and estimate the number of truck trips for the upcoming year. A single visit from a truck is equal to two trips. This information is used to determine how many “points” the operator needs to “earn”.
  • Select a compliance method to achieve the required number of points: (1) commit to implement strategies from a menu; (2) pay a mitigation fee ($1,000 per point); or (3) develop a customized plan.
  • Submit an Annual Report by January 31 of each year to document the number of points the operator is required to achieve for the compliance period, and demonstrate how the required number of points will be earned.
  • Submit the Annual Report through the online system available here.
  • Pay the administrative report fee.
  • Keep records for seven years showing the number of truck trips and the selected strategies that are being implemented.

The menu of strategies includes: purchasing zero emission or near zero emission trucks, installing onsite solar panel systems, and installing charging infrastructure.

The SCAQMD conducts unannounced on-site inspections of warehouse facilities. Some of the information that the inspector may require includes: truck trip count records, fleet data (invoices, vehicle registration, model year, fuel type, license plate numbers), and information about any onsite energy generation equipment. Non-compliant warehouses can be subject to fines of more than $11,000 per day per violation.

For More Information, Please Contact:

Alene Taber
Alene Taber
Counsel
Los Angeles, CA