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I would first like to say that the report is exceptional in its
details and content and the approach by the CARB is world leading.

I have spent the last 35yrs in the transport refrigeration
community and I have a number of comments about the report.

1 - I would highly recommend that the all TRU's engines are subject
to confirmation of service cycles on the engine and then a
confirmation via emission testing that the engine is fit for
purpose. (I.e. is performing to OEM set standards) If it failed
then the TRU should be quarantined until fit for purpose. 
2 - You talk about NOX - PM emitters but you must also consider the
HFC gas emission and Global Warming Potential. Again an annual
certified check of the refrigeration equipment should be carried
out and recorded and units that fail are again quarantined until
corrected and retested.  
3 - You talk about retrofitting the TRU equipment with DPF filters
and total equipment replacement. Whats is the plan to promote NON
diesel driven equipment. In the UK and EMEA area both Thermo King
and Carrier promote ZERO emission equipment with low GWP gases. Why
is this not in California it would work and do what you need for
all distributions needs. But there are plenty of alternative types
of TRU equipment in the UK and EU markets that would perform the
tasks needed.  

You have taken some great steps towards getting to the ultimate
prize of Zero emissions and Zero GWP potential don't stop the
momentum and don't allow the OEMs to control the market.  Please
get in touch if I can help you further.