AQMD Rule 2305 Fee Calculator

AQMD rule 2305

Calculate the AQMD Rule 2305 mitigation fees you will owe at the end of the year based on the size of your warehouse and the number of visits by diesel trucks. The free online calculator is provided below as a service to our readers.

Why read this article and use this AQMD Rule 2305 Fee Calculator

This online calculator calculates the charges resulting from the new South Coast Air Quality Management District Rule 2305 that measures the square feet of a facility, counts the number of diesel truck visits, and estimates the mitigation fees you will owe at the end of the year. It provides a background on the AQMD rule 2305 and explains important relevant terms.

South Coast Air Quality Management District Rule 2305 - CLASS 8 TRUCKS AT A WAREHOUSE

Introduction to AQMD Rule 2305

You may have heard about the South Coast Air Quality Management District Rule 2305  otherwise known as the Warehouse Indirect Source Rule (ISR). It was adopted on May 7, 2021

The rule requires warehouses greater than 100,000 square feet to directly reduce nitrogen oxide (NOx) and diesel particulate matter (PM) emissions, or to otherwise facilitate emission and exposure reductions of these pollutants in nearby communities.

The AQMD warehouse rule 2305 is a menu-based points system requiring warehouse operators to annually earn a specified number of points. These points can be earned by completing actions from a menu that can include acquiring and using natural gas, Near-Zero Emissions and/or Zero-Emissions on-road trucks, zero-emission cargo handling equipment, solar panels, or zero-emission charging and fueling infrastructure, or other options.

Alternatively, warehouse operators can choose to pay a mitigation fee. Funds from the mitigation fee will be used to incentivize the purchase of cleaner trucks and charging/fueling infrastructure in communities nearby.

This guide is designed to assist warehouse operators to understand the new rule and anticipate future mitigation fees. Also, strategies are provided to avoid paying the fee and instead invest in the warehouse operation in a practical way.

South Coast Air Quality Management District Rule 2305 - diesel truck visits
South Coast Air Quality Management District Rule 2305 – diesel trucks visiting a warehouse

What you need to know about Air Quality Management District Rule 2305

To calculate the South Coast Air Quality Management District’s new rule 2305, you will need to know the following:

  • The total square footage of your warehouse
  • The number of diesel truck visits per year
  • WATTs score
  • WAIRE points earned
  • Annual WAIRE Points Compliance Obligation (WPCO)
  • The WAIRE program stringency factor by year and warehouse size

Although, the rule is fairly straightforward, understanding the terms is necessary to perform the calculation and understand the possible fees owed starting in the year 2022.

Does Rule 2305 Apply to my Operation?

A warehouse operator who has a building with at least 100,000 square feet of floor area and 50,000 square feet are used for warehousing is required to report diesel truck visits, and earn WAIRE points or pay mitigation fees.

To determine the square footage of your warehouse, take the length of the warehouse and multiply it by the width of your warehouse. If it is greater than 100,000 and the at least half is used for warehousing activities, you are subject to Rule 2305.

South Coast Air Quality Management District Rule 2305 - diesel truck pollution
South Coast Air Quality Management District Rule 2305 – diesel truck pollution

Background of the South Coast AQMD Rule 2305

On 7 May, the South Coast Air Quality Management Area (South Coast AQMD) adopted Regulation 2305 (the “Regulation”) which aims to regulate nitrogen oxide (NOx) emissions and diesel particulate associated with truck traffic at warehouses. The Regulation will significantly increase compliance costs for warehouse operators in the South Coast Air Basin, requiring operators to achieve compliance through mechanisms such as green projects or discount taxes. The South Coast AQMD estimates that the Regulation will affect approximately 4,000 warehouses in the South Coast Air Basin, with an estimated total compliance cost of $979 million per year. The first report required by warehouse operators under the regulation will be on September 1, 2021. The Regulation does not regulate emissions directly from warehouses or any other sources but does impose requirements on facilities such as indirect sources of contaminants as a result of over-the-road commercial trucks and other vehicle emissions occurring at these facilities. The Regulation specifically applies to sources of distribution centers greater than or equal to 100,000 square feet of interior floor in the same building, existing or new, anywhere within the jurisdiction of the South Coast AQMD. South Coast AQMD stated that they generally expect the implementation of Rule 2305 to reduce the level of emissions in the form of smog from sources associated with over-the-road trucks visiting warehouses by 10% to 15%.

The AQMD Rule 2305 Compliance Obligation

Under the Rule, the South Coast AQMD requires warehouse and distribution center operators to perform a number of actions to achieve a sufficient number of points to meet a calculated compliance obligation. The “Warehouse Operations and Investment to Reduce Emissions (WAIRE) Compliance Points” are measured according to a set of specific formulas. Operators must submit a WAIRE plan application with their specific plan to collect points to meet the calculated obligation each year through the implementation of various specific actions. Points earned come from investments and expenditures on zero-emission vehicles and infrastructure. In some cases, WAIRE points can be banked or transferred to other organizations under the same operational control for compliance purposes, thus eliminating the need to make multiple investments over different facilities. Alternatively, a warehouse operation may choose to pay a mitigation fee instead ($ 1,000 per WAIRE point).

South Coast AQMD says it will use the proceeds of mitigation fees to encourage the purchase of cleaner trucks and to support investment in zero-emissions fuel infrastructure in nearby communities. Reporting requirements include an initial report on on-site information like warehouse square footage and WAIRE annual reports that include information on truck travel and earned WAIRE points.

The Implementation Schedule for the AQMD Rule 2305

The AQMD Rule 2305 introduces a three-year phase-in period, applied first to the largest distribution centers as a priority. The proposed rule will require compliance based on the size of the facility and is as follows:

2022: Warehouses equal to or greater than 250,00 square feet

2023: Warehouses equal to or greater than 150,00 square feet

2024: Warehouses equal to or greater than 100,00 square feet

Weighted Annual Truck Trips (WATTS) – definition

  • All truck trips (to or from the warehouse) occurring over the 12-month compliance period
  • If more than one operator occupied the warehouse, then WATTS is calculated individually for each operator
  • WATT𝑠 = 𝐶𝑙𝑎𝑠𝑠 2𝑏 𝑡𝑜 7 𝑇𝑟𝑢𝑐𝑘 𝑇𝑟𝑖𝑝𝑠 + [2.5 × 𝐶𝑙𝑎𝑠𝑠 8 𝑇𝑟𝑢𝑐𝑘 𝑇𝑟𝑖𝑝𝑠]
  • Class 2b to 7 truck trips = All trucks or tractors entering or exiting a warehouse truck gate(s) or driveway(s) that are truck Class 2b, 3, 4, 5, 6, or 7. If truck class information is not available, Class 2b to 7 trucks are all straight trucks that entered or exited a warehouse truck gate(s) or driveway(s)
  • Actual truck trip data to the warehouse must be collected by the warehouse operator using methods that contemporaneously record verifiable truck trips.

Warehouse Actions and Investments to Reduce Emissions (WAIRE) – definition

  • WAIRE Points will be earned for the actions/investments completed each compliance period and only for the portion of the year that a warehouse operator occupies a warehouse
  • WAIRE Points must be earned only for warehouse operators in buildings with ≥100,000 square feet dedicated to warehousing activities, and who operate at least 50,000 square feet of the warehouse
  • Warehouse operators must earn points every 12-month compliance period

AQMD Rule 2305 WATT points and mitigation fee calculator

This is just an estimator and is offered as a guide only. Please consult the AQMD for specific guidance pertaining to your individual warehouse operations.

How to Earn WAIRE points and Avoid Paying the Rule 2305 Mitigation Fees

To earn WAIRE points and avoid paying the AQMD Rule 2305 mitigation fees, there are a number of things a warehouse operator can d. The WAIRE “menu” of actions was developed for PR 2305. WAIRE points from this menu can only be earned for “surplus” actions, that “go beyond existing federal and state regulations already applicable.” Under the WAIRE point menu, there are nine categories of actions a business can take to avoid paying the rule 2305 mitigation fees.

At the time of writing this article and publishing this calculator, the WAIRE menu options available to facilities to gain WAIRE points and meet their annual WPCOs is as follows:

  • Zero-emissions (ZE) and near-zero-emissions (NZE) truck acquisitions and usage
  • ZE and NZE truck visits from a non-owned fleet
  • Electric vehicle charger acquisition and usage
  • Hydrogen filling station acquisition and usage
  • ZE yard truck acquisition and usage
  • Solar panel acquisition and usage
  • High-efficiency filter systems acquisition and replacement filters
  • Transport refrigeration unit plug acquisition and usage
  • Pay mitigation fee

For more detail on the WAIRE points menu, including the point values for each action taken, read the South Coast AQMD’s Technical Report here.

Environmental Justice Implications for AQMD Rule 2305

With e-commerce booming during the pandemic economy, rapidly growing numbers of warehouses, and, by connection, expanding distribution channels that support them, will likely become the focus of more intense scrutiny by environmental justice communities and advocates – as well as that of the Biden Administration. By targeting air emissions stemming from activities associated with warehouses, including indirect source emissions resulting from freight trucks driving to and from warehouses, the Rule begins to address the longstanding concerns of neighboring environmental justice communities who often face the most direct impacts.

The Rule may be subject to legal challenge, which could potentially stay its implementation. For example, the Rule requires a warehouse to install solar energy panels, but that will not do anything to significantly reduce diesel truck emissions or ambient ozone concentrations created by truck activities. Several concerns were also raised that the mitigation fee included in the rule is an unlawful special tax. Environmental groups commented that the Rule is not sufficiently stringent to protect communities neighboring industry. South Coast AQMD was also required to comply with the California Environmental Quality Act (CEQA) for adoption of the Rule, and determined that in several areas, environmental impacts would be significant. Given the broad swath of competing comments, and the tendency for CEQA to invite litigation, a challenge may be imminent. For now, distribution warehouses subject to South Coast AQMD’s Rule 2305 should consider evaluating the limited exemptions, preparing a compliance strategy, and planning based on the implementation schedule provided in Table 2 of the approved Rule. Affected warehouse operators should also begin preparing the first reports due under the Rule on September 1, 2021.

The rule may be subject to legal objections that may apply. For example, the change requires the installation of solar panels in a warehouse, but this does not contribute to the reduction of emissions from Class 2b-Class 8 over-the-road (OTR) trucks or to environmental ozone levels generated by transport truck activities. Concerns have also been raised that the mitigation fee included in the rule is an unlawful special tax. Environmental groups said the rule is not strict enough to protect the environment of neighboring communities. The South Coast AQMD was also asked to comply with the California Environmental Quality Act (CEQA) before the adoption of the rule, and concluded that the environmental impact would be significant in a number of areas. Given the broad swath of competing comments, and the tendency for CEQA to invite litigation, a challenge may be forthcoming. For now, distribution warehouses subject to South Coast AQMD’s Rule 2305 should start preparing a compliance strategy based on the implementation schedule noted above. Distribution centers equal to or larger than 250,000 will need to complete a warehouse operations notification and submit it by September 1, 2021

South Coast Air Quality Management District Rule 2305: Warehouse Indirect Source Rule IMPLEMENTATION SCHEDULE
South Coast Air Quality Management District Rule 2305: Warehouse Indirect Source Rule Implementation Schedule


Compare LPG Forklift to Hydrogen Forklift

Hydrogen fuel cell for a forklift without covers

Compare LPG forklift to hydrogen forklift. To understand the fuel and maintenance savings available by switching from a propane (LPG) forklift to a hydrogen forklift, calculate your savings below. Our savings calculator will help identify the costs of running a propane forklift compared to a hydrogen fuel cell forklift. Your savings are based on the information you provide and some key industry data points.

Propane Forklift

Propane forklifts are a very popular PIT (powered industrial forklift) in the United States. The reason is that the forklift is inexpensive to buy and easy to refuel. But most warehouse managers do not realize that the cost of forklift maintenance and the cost of fuel is far higher than an electric forklift that is equipped with a hydrogen fuel cell.

propane forklifts parked in a row
Toyota Propane Forklifts

Electric Forklifts Equipped with Hydrogen Fuel Cells

Electric forklifts powered by hydrogen fuel cells are less expensive to fuel and less expensive to maintain.

Forklift fuel cell being fueled with hydrogen
Forklift fuel cell being fueled with hydrogen

Compare LPG forklift to hydrogen forklift. Calculate your maintenance and fuel-saving below. You will find that LPG forklifts are far more expensive to run than electric forklifts powered by hydrogen fuel cells.

Buy Hydrogen Forklifts Here

If you are interested in hydrogen fuel-cells for forklifts, visit this link.

Plug Power Sells Hydrogen Fuel Cells for Forklifts

Plug Power calls their fuel cells for forklifts, GenDrives.

GenDrive hydrogen fuel cells are designed specifically with material handling power in mind. As a drop-in replacement, our units fit into an existing electric lift truck’s battery compartment as a one-to-one battery replacement.

Fuel cells for forklifts allow you to drive productivity and streamline operations while maximizing forklift fleet uptime. They are also a good approach for reducing greenhouse gas emissions in warehousing.


What is the Ampere-Hour Capacity of a Forklift Battery?


Forklift Battery Model Decoder – if you are trying to find out the ampere-hour capacity of your forklift battery, look no further. You can calculate the ampere-hour capacity of your forklift battery here using just the model number of the battery for reference.

If you want to know the ampere-hour capacity of a forklift battery, the information is hiding in the battery model number. Use this handy decoder to unlock the secrets contained in the forklift battery model number.


Enter the forklift battery model number in the spaces provided below

Decode the model number of a lead-acid battery. This decoder will tell you the voltage and the ampere-hour capacity of your lead-acid battery based on information contained in the battery model number only.

Available Ampere-Hours in a Forklift Battery

Because a forklift battery is never supposed to be discharged below 80% depth of charge, meaning there is always supposed to be 20% AH left in the battery so that the battery is not damaged, the available ampere-hours is 80% of the total number of amps.

How to calculate the kilowatts (kW) in a forklift battery

Also shown below is the calculated (approximate) kilowatts in the battery. This is calculated by multiplying volts by the amps and then dividing it all by 1000.

Explanation of the meaning of the forklift battery model number

Here is a detailed explanation of the meaning of each component of the forklift battery model number.

18 refers to the number of cells. Multiply this by 2 to get the voltage of the battery: 36 volts in the case of our example.

125 refers to the number of amps per cell.

13 refers to the number of negative plates in a cell. Take 13, minus 1, and divide by 2. This equals 6. Now multiply the middle number (number of amps per cell) by half the last number (minus 1). In our example, the number is 6.

The True Cost To Charge A Forklift Battery


Many companies have no idea how much they are spending to charge a forklift battery. Costs are hidden, and difficult to calculate, until now. Use this online calculator to estimate the cost to charge batteries for forklifts.

Estimate the Cost to Charge your Electric Forklift Batteries – It is more than you think!

This calculator is provided to support your internal discussions about reducing operating costs in your warehouse. Please use this as an informal estimate only. Please consult with your accounting firm before making business decisions based on the information provided here.

The Data Points of Charging a Forklift Battery

Here are the key data points that will go into the calculation of the cost of charging a forklift battery.

Forklift battery voltage

Forklifts and lift trucks that fall into the category of PIT (powered industrial trucks) run on these voltages in North America:

  • 24 volts
  • 36 volts
  • 48 volts
  • 80 volts (rarely)

In Europe, forklift voltages are often 80 volts.

Ampere hour of the forklift battery

The ampere hour capacity, also known as the AH of a battery, describes the total capacity of the battery’s cells. The ampere hours capacity, AH, is found hidden in the model number of the battery. To find out what the AH is of a forklift’s battery, follow the red cable from the connector up to the battery and then remove the plastic cover. The battery model number will be listed there.

Sometimes, there is a sticker on the side of the forklift battery noting the ampere-hour capacity of the battery.


How to Calculate the Ampere-Hour Storage Capacity of a Forklift Battery

There is a lot of information available in the forklift battery model number. To calculate the energy storage capacity of a battery, take the middle number from the model number and times by the last number once you have subtracted 1 and divided it in half. Here is an example:

Model number: 18-125-15

15 – 1 / 2 = 7 x 125 = 875 ampere-hours (AH). Find out more and calculate the AH in your forklift battery.

The Efficiency of a Charger

The efficiency of a forklift charger is based on the Average Power Conversion Efficiency, which means the ratio of DC output power to AC input power. Said another way, it is the comparison of the AC kWh drawn from the wall versus the number of DC kWh that are delivered to the battery.

The Columbic Efficiency of a Forklift Battery

The efficiency of a battery to accept a charge is what is called Coulomb’s Law. The coulombic efficiency is the rate at which electrons transfer.

If you are charging a lithium-ion battery, use 99%. Otherwise, 85% is a good number to use for a lead-acid forklift battery. If you are fast charging the battery, decrease the efficiency (less that 85%). If the battery is newer and being charged in a cooled area, raise it to 90%. Remember, the ability of a battery to accept a charge will never be 100%, so you need to discount the energy being received into the battery. The older the forklift battery, the hotter it charges at, the faster you try to charge it, and the greater than 70% you complete the charge with, the lower your coulombic efficiency will be.

Peak Demand Charge

To understand the peak demand charges a business needs to pay, think of peak demand as the highest rate paid for the highest usage in any 15 minute period.

If you think you are paying only 10 cents per kW, but you are charging all your Lithium-ion batteries all at the same time when the team goes on break at 11 am, you can be certain your entire day will be charged at the peak demand rate you were paying at 11 am.

Commercial customers typically face demand charges ($/kW) based on their peak demand during each billing period. This peak demand is usually defined as the highest average electricity usage occurring within a defined time interval (often 15 minutes) during the billing period. For many commercial customers, demand charges can account for 30 to 70
percent of the total charges on a monthly electric bill. Demand charge rates vary considerably across utilities, locations, building sizes, and building types. Because peak
demand is based on how and when a customer uses electricity, even two customers that consume similar amounts of electricity and are billed under the same utility rate may incur vastly different demand charge expenses, depending on their peak demand.

So, if your normal rate is 10 cents per kWh, divide it by .3 in order to gross the amount up by 70%.

Enter the number of lift trucks (forklifts, pallet jacks, turret trucks)

A lift truck is the term we use to refer to PIT (powered industrial trucks). Count the number of units in your material handling fleet. This will impact the cost to charge forklift batteries.

The number of forklift batteries to charge

How many batteries do you have for your PIT fleet? Do you have only one battery per lift truck? Then this number is likely the same as the number you entered for lift trucks. If it is more, then you are likely changing batteries. If it is the same, you are likely opportunity-charging batteries. If you have a single shift, it is possible that you are simply parking your lift trucks and charging them.

The Price of a Forklift Battery

Use this calculator to look up the approximate retail price for a forklift battery based on the forklift type.

These forklift battery prices are based on published prices as of December 2020. You can expect a 3% to 5% price increase each year.

Forklift Battery Price

Look up the price of a forklift battery by selecting the type of lift truck, and then the width of the battery compartment in inches. The width dimension refers to the number of inches that the forklift battery measures down the length of the forklift from the front to the back of the forklift battery compartment. It is not the width of the forklift, but the length of the forklift battery compartment space (only).