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tru -- TRU (reefer) owners: VDECS Retrofit Purchase Order Deadline Approaching

Posted: 03 Sep 2015 13:41:16
TRU (reefer) owners -- If you missed the August 31st deadline for
ordering new TRU units, the California Air Resources Board (ARB)
recommends that you take immediate action to order Level 3
verified diesel particulate filters for retrofitting your model
year (MY) 2008 engines by the end of 2015. 

MY 2008 TRU and TRU generator set engines must comply with the
TRU Regulation’s in-use performance standards by December 31,
2015.

Please be aware that replacement engines may no longer be 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 2008
engine (see TRU Advisory 13-18, page 7 for more detailed
explanation at: 
http://www.arb.ca.gov/diesel/tru/advisories.htm).  Orders for
replacement units that are placed after August 31st will NOT be
eligible for compliance extensions if delivery or installation
will be completed after December 31st, 2015.

However, if model year 2008 engine owners order verified diesel
emissions control strategies (VDECS), such as Level 3 diesel
particulate filters, by the end of October, installation by the
end of 2015 is most likely possible.  Furthermore, if you order a
Level 3 VDECS before October 31st and delivery or installation is
delayed so that you can’t comply by the end of 2015, you may
qualify for a compliance deadline extension.  

To qualify for this compliance extension, the following
conditions must be met:
1. Purchase orders for Level 3 VDECS must be placed by October
31st, 
2. The TRU must be registered in ARB’s Equipment Registration
(ARBER) system, and
3.  An application for extension must be submitted to ARB with
the required documentation by December 31st.  

Owners that place orders for Level 3 VDECS after October 31st
will NOT qualify for this compliance extension if they discover
they cannot comply by December 31st due to delays in delivery or
installation.  Owners must exercise due diligence in attempting
to comply by the end of 2015.  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, start the research, budgeting, and financing well in
advance of the compliance deadline, and purchase the compliance
technology before 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, 2015.

Also, California law now requires freight brokers, forwarders,
shippers, and receivers to only hire and dispatch TRU-equipped
trucks, trailers, shipping containers, and railcars that are
compliant with the TRU Regulation's in-use performance standards
if the perishable load will travel on California highways or
railways.  All TRUs and TRU generator sets must now be in
compliance with the in-use performance standards to be legally
hired to transport perishable goods on California highways or
railways.  Refrigerated motor carriers must be ready to show the
business entity that hires the carrier that they have compliant
equipment.  Please review ARB’s "Guidance for Brokers,
Forwarders, Shippers, Receivers, Carriers and Drivers:  Hiring
and Contracting TRU-Carrier Transport of Perishable Goods on
California Highways and Railways" at:
http://www.arb.ca.gov/diesel/tru/documents/guidance_broker-shipper-receiver.pdf

TRU generator set owners and operators should also review ARB’s
“Q&A for TRU Gensets” at:
http://www.arb.ca.gov/diesel/tru/documents/q&a_tru_gensets.pdf

For general information about the TRU Regulation and VDECS
information, the TRU Website is at: 
http://www.arb.ca.gov/diesel/tru/tru.htm
Scroll down toward the end of the webpage for Level 3 VDECS
information.

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

TRU Advisories are listed at: 
http://www.arb.ca.gov/diesel/tru/advisories.htm

TRU Compliance extension applications are at:
http://www.arb.ca.gov/arber/trureg/truextensions.htm

If you have questions about compliance or registration in ARBER,
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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