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Planning model year 2010 reefer engine compliance should be underway

The California Air Resources Board's (ARB) recommendation to
refrigerated carriers that own model year (MY) 2010 transport
refrigeration units (TRU or reefer) that must comply with the TRU
Airborne Toxic Control Measure’s (ATCM) in-use performance
standards by the end of 2017 -- Your compliance planning
strategies, budget approval and financing processes should be
underway now.

Model year 2010 TRU engines must comply with the TRU ATCM’s
in-use performance standards by December 31, 2017.  Purchase
orders for compliance equipment (e.g. replacement TRUs) or
emissions control technology (e.g. diesel particulate filters)
must be placed before the TRU ATCM’s purchase order deadlines to
qualify for a compliance extension if delivery or installation
turns out to be delayed until after December 31, 2017.  To
qualify for this compliance extension, the TRU must be registered
in ARB’s Equipment Registration (ARBER) system, purchase orders
must be placed before the purchase order deadlines, and
compliance extension applications must be submitted by December
31st.

The purchase order deadlines that apply to TRUs are:
•       For replacement TRUs:  August 31st  (four months ahead of the
compliance deadline); and
•       For verified diesel particulate filter retrofits:  October 31st
(two months ahead of the compliance deadline).

Replacement trailers should be ordered much sooner due to long
lead times and the current manufacturing backlog.

Owners must exercise due diligence in attempting to comply by the
end of 2017.  Due diligence means conducting the compliance
process with a measure of prudence, responsibility, and diligence
that is expected from, and ordinarily exercised by a reasonable
and prudent person under the circumstances.  For example,
starting the research, budgeting, and financing well in advance
of the compliance deadline, and purchasing the compliance
technology by the purchase order deadline.  The compliance
extension application, with attached supporting documentation
that demonstrates due diligence was used, must be received at ARB
by December 31, 2017.

One compliance option to consider is hybrid electric TRUs and
TRUs equipped with electric standby, which are often referred to
as “eTRUs.”  eTRUs are a compliance option, when used in a way
that qualifies as Alternative Technology.  For more details about
these qualifications, please see ARB’s Guidelines for Electric
Standby and Hybrid Electric Systems for Alternative Technology
Compliance Strategies at:

http://www.arb.ca.gov/diesel/tru/documents/guidance_electricstandby_ets.pdf

In addition to being a compliance option for the TRU Regulation,
plugging in eTRUs while at loading docks or parking spots is a
great way to reduce emissions, noise, and operating costs.  Year
five of the Proposition 1B:  Goods Movement Emission Reduction
Program (Prop 1B) is offering an option for reimbursement of up
to $3,000 per electric power plug installed.  Local air districts
periodically issue solicitations for Proposition 1B funding.

Additional information can be found on the Prop 1B website at:
www.arb.ca.gov/gmbond .  If you are interested in applying for
Prop 1B funds, please send an email to [email protected] and
include “TRU project” in the subject line.  Also, include the
number and location of potential plugs and contact information
for your company.  Prop 1B program staff will compile emails and
pass information on to the local air districts.

A list of companies that offer compliance options, including
Alternative Technology (eTRU) compliance options, is available at
this link:
http://www.arb.ca.gov/diesel/tru/documents/control_option_matrix.pdf.

Please be aware that replacement engines are no longer a
compliance option because replacement engines must be cleaner
than the old engine being replaced and there is no replacement
engine that fits and functions that is cleaner than a MY 2010
engine (see TRU Advisory 13-18, page 7 for more detailed
explanation at:

http://www.arb.ca.gov/diesel/tru/advisories.htm).

All model year 2009 and older TRU engines (or units manufactured
in 2009 or earlier) should be in compliance now.  Please note
that trailer manufacture year and in-service dates are not used
to determine TRU compliance dates.  Noncompliant model year 2009
and older TRU engines/units must not be operated in California
unless they are brought into compliance immediately.

Written on Monday, June 5, 2017 by
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