Comment Log Display

1- TRU IN-USE ULETRU DEADLINE OF 12/31/2023- 
This deadline for ALL in-use TRU's to be ULETRU compliant by
12/31/2023 will force an acceleration of all <25HP TRU's starting
with MY2017 thru current production to be filtered well ahead of
already planned schedules. 
This is not as per the planned 7yr schedule already enacted. 
This will put quite a financial and logistical burden on many
companies that purchased 7yr compliant units during those Model
years. Financially to purchase the filters and then logistically to
find service shops with personnel to install within that time
frame, meanwhile everyone else is trying to the do the same thing. 

In my opinion, You should continue the existing schedule to filter
after 7 yrs and make it such that all NEW TRU's after 12/31/2021 be
ULETRU.
This will bring lower emission units into the state sooner and the
companies can keep the current schedules to filter thru 2027 and
still meet your 2030 deadline for all units to be compliant with
ULETRU.  
We already have units on order that have 7yr engines and cannot
cancel or change the order at this late date. 

2- TRU REGISTRATION- 
The proposed TRU registration renewal of 1-2 years is too short. It
is my understanding that this new process will require a serial
numbered decal to be placed on each asset. This process of a 1 or 2
year renewal plan puts a level of difficulty to locate and install
the CARB decal being provided onto the specific vehicle within the
time frame required. Only to have to repeat the process again
within 12 to 24 months for each and every asset. For small captured
fleets this may not be such an issue but larger fleets and leasing
companies that do not have daily responsibility to manage asset
location, routes or drop yards will find it most difficult to
comply and will most likely receive fines more often despite having
paid the registration fee.
Suggestion#1- A 1 time registration for life of the asset or up to
7 years. Replacement decal to be installed on TRU within 90 days of
registration. Registration Decal to show TRU ARB registration
number and date of registration expiration.  
Suggestion#2- A 1 time decal with electronic annual renewal that
would not require a new decal when renewed. Officer can check
registration status electronically from CARB data base using TRU
s/n, ARB#, VIN# or TAG#. Companies could then update registration
and not have to revisit the asset to replace the decal.  
NOTE- if registration decal becomes damaged or missing there must
be an easy to use electronic process to order replacement.

3-TRU OWNER RESPONSIBILITIES for SOTL violations- 
For leasing and rental companies that do not provide management of
the driver, routes, loads, schedule appointments for pick and
deliveries or other daily asset activities. How can the owner be
held responsible for the SOTL fines? 

4-GPS REQUIREMENTS- 
Geo-fencing any facility can easily be accomplished within almost
any GPS product on the market today. However not all GPS products
can change the ping rate from 15 minutes to 1 minute based on an
asset being inside a Geo-fenced area when stationary for more than
15 minutes. I have talked to 2 different GPS companies, neither
will honor our current price structure for this level of reporting.
Both companies commented that to do this will take considerable
programming hours to modify their existing system to be able to
perform this level of reporting and this could easily double or
triple our monthly fee for data due to the increase in data
reporting being required. This will put yet another burden on
companies that will just pass the cost on to the consumer. 

Tim Anderson
Product Manager, Refrigeration
PLM FLEET,LLC
tanderson@plmfleet.com 
903-814-0014