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Comment 3 for Transport Refrigeration Unit Regulation Concept (truregulation-ws) - 1st Workshop.
First Name: Alfonso
Last Name: Arambula
Email Address: alfonso.arambula@arb.ca.gov
Affiliation: CARB Enforcement
Subject: 2478.3 Stationary Operating Time Limit (SOTL)
Comment:
I suggest specifying that a Trailer TRU or TRU Gen Set must change location by 10 feet with respect to the applicable facility geofence for the SOTL to restart at zero. Not specifying the distance that must be traveled to restart the SOTL to 0 may lead to challenges enforcing SOTL violations. Primarily, SOTL violations may be contested because the rule does not specify a necessary travel distance to restart the clock to zero. A violator may point to the rule as written and state the violation was issued incorrectly because their Trailer TRU changed location with respect to the applicable facility geofence restarting their clock to zero because their Trailer TRU changed location by 8 feet.
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Date and Time Comment Was Submitted: 2020-03-23 10:11:51
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