WAIRE Program
Compliance
Understand it. Comply Smarter.
The Warehouse Actions and Investments to Reduce Emissions (WAIRE) Program sets mandatory annual compliance obligations for warehouses across Los Angeles, Inland Empire, Riverside, San Bernardino, and Orange County. Xos helps you meet them — without waiting years for utility infrastructure.
What Is the WAIRE Program?
The Warehouse Actions and Investments to Reduce Emissions (WAIRE) Program — formally SCAQMD Rule 2305 — is a mandatory Warehouse Indirect Source Rule (ISR) that took effect in 2021. It applies to warehouses of 100,000 square feet or more located within the South Coast Air Quality Management District.
Under WAIRE, each covered facility must earn a minimum number of WAIRE Points (WPs) — the WAIRE Points Compliance Obligation (WPCO) — each compliance year. Points are earned through approved WAIRE Menu actions: deploying zero-emission trucks, installing EV charging infrastructure (EVSE), generating onsite solar energy, or entering into ZE drayage agreements. Facilities that cannot fully meet their obligation must pay a WAIRE mitigation fee, but this is consistently the most expensive option.
Who Must Comply?
Any operator of a warehouse of 100,000 sq ft or larger within the South Coast Air Basin.
This includes 3PL providers, retailers, manufacturers, and e-commerce distribution operators across Los Angeles County, San Bernardino County, Riverside County, and Orange County.
The Compliance Cycle
Each year, covered facilities submit an Annual WAIRE Report (AWR) to SCAQMD documenting earned WAIRE Points, truck visit data, and mitigation fee payments. Facilities entering the program for the first time first file an Initial Site Information Report (ISIR) to establish baseline data. Annual WAIRE Point Compliance Obligations (WPCOs) increase on a defined schedule through 2031 — making early action on fleet electrification and EVSE deployment strategically valuable.
How Is Your WAIRE Points Compliance Obligation (WPCO) Calculated?
Every covered warehouse chooses one of two methods to calculate its annual WPCO. One is almost always more favorable — and grows more advantageous as your fleet electrifies.
Under the Weighted Annual Truck Trips (WATTs) method, your fee obligation (WPCO) is calculated based on the actual number and class of medium- and heavy-duty truck visits to your facility during the calendar year. Each truck visit is weighted by vehicle class, with Class 8 truck visits adding the most to your fee obligations per visit.
Because your obligation reflects real operational activity, slower periods reduce your point requirement automatically. Zero-emission truck visits earn you compliance points, meaning that every Xos electric truck serving your facility earns points towards meeting your obligation.
For the majority of WAIRE-covered warehouses in the Inland Empire, Los Angeles, Riverside, and surrounding counties, the WATTs method produces a meaningfully lower compliance obligation than the square footage alternative.
The square footage method calculates your WAIRE Obligation based solely on the total square footage of your warehouse, regardless of how many trucks actually visit or how lean your freight operations are during the year.
Because it is disconnected from actual operational activity, the square footage method typically produces a fee obligation (WPCO). A large distribution center with low relative truck traffic may carry a far smaller WATTs-based obligation than a square footage calculation.
This method may be chosen by operators who prefer not to track truck visit data in detail, but in most scenarios, the simplicity does not justify the higher compliance cost over a multi-year compliance horizon.
Important: Regardless of method, unmet WPCO may be satisfied by paying WAIRE mitigation fees to the SCAQMD. However, fees are intentionally priced above the cost of clean equipment, making zero-emission truck acquisition and EV charging infrastructure deployment the more cost-effective path for nearly every facility over a 3–5 year horizon.
WAIRE Is More Flexible Than You Think.
Rule 2305 includes several provisions that can work significantly in your favor — especially for multi-facility operators and early movers on fleet electrification and EV charging infrastructure.
Ready to Build Your
WAIRE Compliance Strategy?
Xos can help you model your WAIRE Points Compliance Obligation (WPCO), identify the optimal WAIRE Menu action mix, and stack available incentives to minimize total compliance cost — for warehouses across Los Angeles County, Inland Empire, Riverside, San Bernardino, and Orange County.