Indirect Source Review: An answer to mega-warehouse pollution

Across the country, more warehouses are now located near homes, schools and community centers than ever before. Fueled by the nation-wide expansion of e-commerce delivery, a single warehouse may generate hundreds of truck trips a day, increasing harmful asthma-causing air pollutants such as Nitrogen Dioxide and particulate matter. Air pollution from trucks is also associated with increased health risks at other stages of life, including raising the risk of preterm birth and the risk of dementia, heart disease, and stroke in adults. Using a framework called Proximity Mapping in ten states, Environmental Defense Fund found that warehouses are disproportionately located in environmental justice communities, which are predominantly low-income communities and communities of color. In these communities, where diesel truck pollution is concentrated, childhood asthma rates often far exceed the national average.  

In response to this growing health problem, several states have proposed or implemented measures to control air pollution from these facilities; these measures are known as “Indirect Source Reviews”. The associated rules can institute many types of requirements including: 

• The use of zero-emissions trucks, 
• On-site solar power charging, 
• Funding air filters for impacted communities, 
• Considering alternate delivery methods where appropriate, and 
• Enhancing requirements or standards for warehouses operating in disadvantaged communities. 

Illinois

According to updated EDF analysis, warehouse square footage and warehouse-generated truck trips in Illinois have grown exponentially, especially in the last five years. Industrial-scale warehouses now compose over one billion square feet across the state, and each day, they generate hundreds of thousands of truck trips to service one of the nation’s busiest freight hubs and make deliveries. 

To address the problem of pollution from warehouses, EDF and several environmental justice organizations, environmental non-profits and health organizations created the Warehouse Pollution Reduction Act. The act would decrease diesel pollution, increase communities’ abilities to track incoming warehouses, and encourage warehouses to hire locally. 

Read more about the Illinois warehouse boom

New York

In New York, disadvantaged communities cover 8% of the state but contain half of all warehouses. Black, Hispanic/Latino, and low-income residents are nearly 1.5x more likely to live near a warehouse (compared to the state average). New York legislators are considering the Clean Deliveries Act (S1180/A3575), which would require warehouses to curb their pollution by taking specific actions towards meeting yearly reduction requirements. The program is designed to be highly flexible so that it is easy for warehouses to comply regardless of their particular needs. It also includes enhanced requirements for warehouses near schools or disadvantaged communities. Like other states, New York’s rule is modeled on California’s successful warehouse pollution reduction rule. The Clean Deliveries Act is an important way that New York can protect its most vulnerable communities while also taking a stand against federal backsliding on air quality protection.

Read more about the New York warehouse boom

New Jersey

In New Jersey, up to 1 in 3 residents live near a mega-warehouse and face elevated exposure to freight truck pollution, according to a Coalition for Healthy Ports and Environmental Defense Fund proximity mapping report for the state. The New Jersey legislature is considering an Indirect Source Review program (S3546/A4679) to address the health concerns and disproportionate impacts of. The bill includes several flexible options for facilities - such as warehouses - to reduce health-harming pollution while minimizing impacts to operational costs. The program is modeled on the South Coast Air Quality Management District’s rule in Southern California, which has successfully reduced air pollution in partnership with warehouses with benefits outweighing costs by three to one. New Jersey must recognize the need for a solution to this health crisis and implement an indirect source review.