CARB


What is a TRU?
TRU is an abbreviation for transport refrigeration unit.

Rules
Two parts to regulation:
      · Facility Reporting Requirements
      · Owner/Operator Requirements

What is the purpose of the TRU ATCM regulation?
In February 2004, the California Air Resources Board (ARB) approved the Airborne Toxic Control Measure for In-Use Diesel-Fueled Transport Refrigeration Units (TRU) and TRU Gen Sets, and Facilities Where TRUs Operate (TRU ATCM).

The TRU ATCM is designed to use a phased approach over about 15 years to reduce the diesel particulate matter (PM) emissions from in-use TRU and TRU gen set engines that operate in California.

Who is affected?
Owners and operators of in-use diesel-fueled TRUs that operate in California, irrespective of whether they are registered in or outside of the State of California are affected. This includes all carriers that transport perishable goods using diesel-powered refrigeration systems on trucks, trailers, shipping containers, and railcars that operate in California. Facilities located in California with 20 or more loading dock doors serving refrigerated areas where perishable goods are loaded or unloaded for distribution on trucks, trailers, shipping containers, or railcars that are under facility control are also affected.


* Great Dane Trailers has compiled this information using CARB sources as it relates to trailers only.
   For the full scope of CARB and TRU regulations, please refer to the links on the right of this page or    contact the following:


TRU ATCM
Toll-Free Helpline:
888-TRU-ATCM  [888-878-2826]
Or 1-866-6DIESEL
Website: www.arb.ca.gov/diesel/tru.htm
Email: tru@arb.ca.gov or 8666diesel@arb.ca.gov
CARRIER TRANSICOLD
For CARB-related questions about Carrier equipment, visit www.trucktrailer.carrier.com
to find the Carrier dealer nearest to you.



1. Facility Reports
Applies to ”large“ distribution centers in California where TRUs operate under facility control

      · Large is 20 or more loading spaces serving cold storage areas (refrigerated and frozen)
      · This count also includes doors serving dry storage if there is easy access between the dry side and         cold side of the warehouse, such as a ”quick door,“ so that cold goods can be loaded onto trucks or         trailers docked at the dry side dock spaces.

Required reporting of

      · Facility information
      · TRU activities and inventory
      · Recordkeeping required to support reported values

Fines for delinquent reports are up to $1,000 per day.

Fines for falsified reports may be up to $35,000.

2. Owner/Operator Applicability
In-Use Performance Standards

ARB I.D. number (IDN)

Operator Reports

Note that Owner/Operator applicability is different from the Facility Report applicability.

TRU owners are also required to apply for ARB Identification Numbers (IDN) for ALL California-based TRUs:

      · IDNs are voluntary for TRUs that are based outside of California. Operators with TRUs that are based         out-of-state, but come into California regularly, may choose to register their TRUs with ARB to pre-        screen the TRUs compliance status and thus reduce inspection times at border crossings, scales,         distribution centers and truck stops.

TRU operators are required to submit Operator Reports if they operate California-based TRUs.

The owner/operator requirements include:

      · TRU engines must meet in-use performance standards (subsequent slides provide more detail).
      · ARB ID number applications for California-based TRUsare due July 31, 2009 (delayed from the deadline         in the regulation). The Initial Operator Report must also be submitted by this date for all California-based         TRUs. ARB staff will begin field enforcement for registration of all California-based TRUs.
            - Owners must register TRUs in ARB's Equipment Registration (ARBER) system.
            - ARB will issue a unique IDN for each TRU.

      · IDNs must be painted or affixed to the TRU housing within 30 days of being issued by ARB.

ARB is extending these deadlines because as the close of the grace period approached, it became clear that several thousand TRUs were not in position to comply by mid July. The reasons for this include: lack of timely action by TRU owners, higher costs for compliance than originally anticipated, some retrofit systems not becoming available until May 2009, tightening of credit, and longer lead times for delivery of systems. Given these factors, ARB has determined that a two phase enforcement schedule would allow for more complete registration and provide some additional time for pre 2002 TRUs to come into compliance in an orderly manner.
3. Electronic Submittals - ARBER
Go to the ARBER website: www.arb.ca.gov/arber/arber.htm

Download manual forms from the TRU website at: www.arb.ca.gov/diesel/tru.htm

4. Owner/Operator Requirements
Unique IDNs are issued to the owner by ARB for each TRU

The owner is responsible for permanently painting or affixing IDNs to each side of the TRU housing within 30 days of the IDN being issued:

      · Two exceptions are refrigerated railcars and TRU gensets (see TRU Advisory 80-03_R2).
      · The IDN numbers must be preceded by the letters "ARB" (e.g. ARB 012345678)
      · The color of the letters and numbers must contrast sharply with the background color.
      · The size of the letters and numbers must be such that they can be read during daylight hours from a         distance of 50 feet while the unit is stationary.
      · Markings shall be maintained in a legible condition.
5. In-Use Performance Standards
Less than 25 hp TRU/TRU Generator Set Engines

In-Use Performance Standard Requirement
LETRU Use 0.30 g/hp-hr engine or Level 2 VDECS retrofit
ULETRU Use Level 3 VDECS retrofit

Greater than 25 HP TRU/TR Generator Set Engines

In-Use Performance Standard Requirement
LETRU Use 0.22 g/hp-hr engine or Level 2 VDECS retrofit
ULETRU Use 0.02 g/hp-hr engine, Level 3 VDECS retrofit or Alternative Technology

LETRU = Low-Emission TRU In-Use Performance Standard
ULETRU = Ultra-Low-Emission TRU In-Use Performance Standard
VDECS = Verified Diesel Emission Control Strategy
Alternative Technology = ULETRU (and LETRU) if diesel PM emissions are eliminated at distribution centers and limited at delivery point facilities (...See TRU Advisory 08-02).

There are two levels of Stringency:

      · LETRU (Low-Emission TRU)
      · ULETRU (Ultra-Low-Emission TRU)

There are compliance options for meeting the in-use performance standards.

      · Retrofit with the required level of VDECS
      · Use an engine that has been certified to meet an emissions limit (without deterioration).

      * Lead times are typically three to four months for most compliance technologies, so orders should be         placed by September 1, 2009, in order to ensure compliance by December 31, 2009.

The top table shows the in-use performance standards for less than 25 hp TRU engines.

The lower table shows the in-use performance standards for 25 hp and greater TRU engines.

Alternative Technologies may also be used to meet ULETRU (and LETRU), but to qualify, TRU diesel PM emissions must be eliminated at distribution centers and limited at delivery point facilities. There will be more about this in a later slide.

6. In-Use Performance Standards Compliance Schedule
Engine Model Year In-Use Compliance Standard Compliance Date
  LETRU ULETRU
2002 and older December 31, 2009 December 31, 2016
2003 N/A December 31, 2010
2004 N/A December 31, 2011
2005 N/A December 31, 2012
2006 N/A December 31, 2013
2007 N/A December 31, 2014
2008 N/A December 31, 2015
2009 N/A December 31, 2016
2010 N/A December 31, 2017
2011 N/A December 31, 2018
2012 N/A December 31, 2019
2013 N/A December 31, 2020
2014 N/A December 31, 2021

Generally, the compliance date is December 31st of model year plus 7 years. See TRU Advisory 08-01_R1 for exception allowing use of TRU model year.

This table shows that compliance dates are phased in, based on the engine model year.

Looking at the first row, you can see that model year 2001 and older engines must comply with LETRU by the end of 2009. ARB is delaying enforcement of this first compliance date until six months after authorization approval was received from the U.S. Environmental Protection Agency Agency to allow for more complete registration and to provide additional time for pre-2002 TRUs to come into compliance in an orderly mannder. So enforcement begins January 1, 2010.

      · Then, these same model years, if they are still in use, must comply with the more stringent ULETRU
        in-use standard by the end of 2016.

On the second row, you can see that model year 2002 must comply with LETRU by the end of 2009. There will be no grace period for this compliance date or any other in-use performance standard compliance dates.

      · 2003 and subsequent model years skip LETRU and must comply with ULETRU by the end of the 7th         year after the engine model year (again, no grace period will be provided).
      · Then, model year 2002 engines, if they are still in use, must comply with ULETRU by the end of 2016, 7         years after meeting LETRU.

2003 and subsequent model years skip LETRU and must comply with ULETRU by the end of the 7th year after the engine model year (again, no grace period will be provided).

      · So, model year 2003 engines would have to meet ULETRU by December 31, 2010.
      · Model year 2004 engines would have to meet ULETRU by December 31, 2011.
      · And this pattern continues until new engines are equipped with a diesel particulate filter that reduces
        diesel particulate matter by a t least 85 percent (meets 0.02 grams per hp-hour emission level).

You can see from this table that all in-use TRU engines must eventually comply with ULETRU in order to operate legally in California.

The model year is displayed on the engine label, which is typically located on the valve cover or oil pan. If there is no engine label, it's usually because it is older than a Tier 1 engine. Tier 1 started in 1999 for 25 - 50 hp engines and year 2000 for less than 25 hp engines. The engine serial number may also be used to determine the model year of the engine. Ask your TRU dealer for help in determining the model year of the engine if you can't find or read the engine label or serial number.

The engine model year is used to determine the compliance date for the in-use performance standards, except in the case where the unit model year is only one year later. Then the unit model year or manufacturer year may be used to determine the compliance date(s). If the difference between engine model year and unit model year is more than one year, then the engine model year must be used. See TRU Advisory 08-01_R1.

7. Compliance Options for Meeting In-Use Performance Standards
Replace in-use engine with new or newer engine

Replace in-use engine with a rebuilt/remanufactured engine that meets a cleaner certified emissions configuration

Retrofit with required level of VDECS

Use Alternative Technology

8. Verified Diesel Emission Control Strategies (VDECS) for TRUs
VDECS' Executives Order (EO)

      · VDECS are verified for specific engine models and model years
            - Read the EO and VDECS owners manual before buying
      · Specific conditions may apply

Enforcement Issue

      · If not matched to right engines and installed appropriately, then DECS is not verified and installation
        is illegal.
9. Alternative Technologies
Electric standby or hybrid electric/diesel

      · To qualify, TRU engines must not operate at distribution centers - diesel emissions at facilities must
        be eliminated.
            - Must plug in at any delivery point where more than 2 TRUs present or delivery takes more than
              30 minutes
10. Enforcement
ARB implementation and enforcement

      · Beginning January 1, 2010
      · Inspections at border crossings, scales, roadside, terminals, distribution centers and delivery points
      · Operator - fines up to $1,000/day (per California Health and Safety Code)


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