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tru -- Be Aware! New 2014 Trailer TRUs Equipped with Tier 4i Flexibility Engines Only Have About 5 Years Operational Life

Posted: 25 Mar 2014 15:29:00
Transport refrigeration unit (TRU or reefer) and TRU generator
set (gen set) owners need to be aware that new 2014 trailer
TRUs/gen sets equipped with Tier 4i flexibility engines that were
manufactured in 2014 must meet the Ultra-Low-Emission TRU
(ULETRU) in-use performance standard by December 31, 2019; so the
operational life of these TRUs/gen sets is only 5 years plus the
remainder of 2014. 

Flexibility engines do not meet the emissions standards that are
currently in effect at the time of engine manufacture.  A Tier 4i
flexibility engineís effective model year is 2012 (the last year
that Tier 4i was in effect).  If Tier 4i flexibility engines
manufactured in 2014 are installed in a new TRUs/gen sets in
2014, California law requires the in-use performance standard
requirements and compliance deadlines to be based on the enginesí
effective model year (2012), not the engineís manufacture year or
TRUsí/gen setsí model year.  This results in the ULETRU in-use
performance standard compliance deadline of December 31, 2019,
(seven years after the effective model year) for flexibility
engines manufactured in 2014, so the operational life of these
TRUs/gen sets is only 5 years plus the remainder of 2014.

California Air Resources Boardís (ARB) TRU Regulation requires
original equipment manufacturers (OEM) to disclose to the end
user in writing prior to sale, if a TRU/gen set is equipped with
a flexibility engine.  The regulation requires a written
disclosure notice to be provided with TRUs/gen sets equipped with
flexibility engines, with instructions to dealers telling them
they are required to notify the ultimate purchaser of this
disclosure prior to sale.  Dealers are required by law to pass
the written disclosure to the ultimate purchaser at point of
sale.  These disclosure requirements include all of the
following:
1.	Notice that the TRU/gen set is equipped with a flexibility
engine that meets a less stringent emissions standard than the
emissions standard in effect at the time that the engine was
manufactured.
2.	Provide the effective model year of the flexibility engine.
3.	Notify the ultimate purchaser that if they register the
TRU/gen set in ARBís Equipment Registration (ARBER) system, they
are required report the effective model year of the flexibility
engine, not the year that the flexibility engine was
manufactured.
4.	If the TRU/gen set is operated in California, the owner will
be required to bring the flexibility engine into compliance with
the ULETRU in-use standard seven years after the effective model
year of the engine (in the case of a Tier 4i flexibility engine
manufactured in 2014, by December 31, 2019).

Also, under California law, if a TRU OEM equips TRUs/gen sets
with a flexibility engines, they are required to attach
supplemental engine labels that provides all of the information
needed to register those engines in ARBER.

Tier 4i flexibility engines that were manufactured in late 2013,
may be installed in TRUs and TRU gen sets during the first
several months of 2014 without losing operational life.  This is
consistent with past policy.  The TRU OEM reports the engine
manufacture year to ARB so that those units can be identified.

TRU Advisory 12-24 provides a more detailed explanation of the
consequences of purchasing TRUs equipped with flexibility
engines.  TRU Advisories are listed at: 
http://www.arb.ca.gov/diesel/tru/advisories.htm

Where can I get more information?

For general information about the TRU Regulation, the TRU Website
is at:  http://www.arb.ca.gov/diesel/tru/tru.htm

Information about Level 3 VDECS is at:
http://www.arb.ca.gov/diesel/tru/tru.htm#mozTocId341892

The ARBER registration website is at: 
http://www.arb.ca.gov/arber/arber.htm

ARBER Registration Help pages are at: 
http://www.arb.ca.gov/arber/trureg/trureg.htm

If you have questions about in-use performance standard
compliance, registration in ARBER, or in-use compliance
extensions, please call the TRU Help Line at 1-888-878-2826 or
call 1-916-327-8737.

Background:  TRUs are refrigeration systems powered by integral
diesel internal combustion engines designed to control the
environment of temperature-sensitive products that are
transported in trucks, trailers, shipping containers, and
railcars.  The emissions from these units are a source of
unhealthful air pollutants including particulate matter, toxic
air contaminants, nitrogen oxides, carbon monoxide, and
hydrocarbons, that all pose a potential threat to both public
health and the environment. These units often congregate in large
numbers at California distribution centers, grocery stores, and
other facilities where they run for extended periods of time to
ensure their perishable contents remain cold or frozen. These
distribution and loading facilities are often in close proximity
to schools, hospitals, and residential neighborhoods.  In 2004,
the TRU Airborne Toxic Control Measure (ATCM) was adopted by the
Board to reduce diesel particulate matter emissions from TRUs and
TRU gen set engines.  Amendments were adopted by the Board in
November 2010 and October 2011.



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