An Indirect Source Rule (ISR) requires facilities like warehouses, ports, and airports to offset air pollution from equipment, trucks, trains, and ships used at, or travelling to and from, their facilities.
What's the problem?
The South Coast Air Quality Management District's ISR on warehouses requires limiting truck idling, installing electric chargers, or switching to electric vehicles. If building operators cannot meet these requirements, they must pay a substantial mitigation fee — all in an attempt to reduce emissions from sources they often neither create nor have direct control over.
Where the approach runs into trouble
- Implementation costs. Retrofitting or replacing existing equipment with cleaner technologies can be substantial, and infeasible in certain buildings.
- Limited technology availability. The availability and effectiveness of zero-emission and low-emission technologies varies, and they may not be commercially available.
- No proof of emission reductions. There is little evidence that ISRs will reduce emissions, or that mitigation fees collected will lead to further investment in reducing NOx.
- Enforcement and compliance. Ensuring that all affected facilities comply can be challenging. Enforcement may require substantial resources for inspections, audits, and penalties, which can strain regulatory agencies.
- Complexity of monitoring and reporting. ISRs often require detailed tracking and reporting of emissions. That complexity can lead to difficulties in data collection and accuracy, and to increased administrative burdens for businesses.
