Indirect Source Rules: A New And Evolving Frontier Of State And Local Vehicle Regulation

States and cities are increasingly using their using their police powerto regulate mobile source emissions. Warehouses – and the trucks that serve them – are already subject to an "indirect source rule" (ISR) in southern California, and similar warehouse ISRs are now being pursued in Colorado, New Jersey, and New York City. Warehouse owners, operators, and associated businesses – like logistics companies and truck fleet operators – should carefully track this spreading trend, but the impact of ISRs could also extend to other facilities that serve significant numbers of vehicles. Multiple jurisdictions are considering ISRs that could target a diverse array of facilities including ports, airports, railyards, entertainment venues, and universities.