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Today the California Air Resources Board (ARB or CARB) adopted
amendments to the Transport Refrigeration Unit (TRU) Airborne
Toxic Control Measure (ATCM). Owners of TRUs and TRU generator
sets equipped with model year 2003 engines should make compliance
decisions now and order compliance technology now to ensure
compliance with the in-use standards by December 31, 2010.  In
addition, owners of TRUs and TRU gen sets that are equipped with
flexibility engines need to register their TRUs in ARB’s
Equipment Registration (ARBER) system.

The amendments to the TRU ATCM included:

1)  All model year (MY) 2003 engines will now be allowed to meet
either the Ultra-Low-Emission TRU (ULETRU) in-use standard or the
less stringent Low-Emission TRU (LETRU) in-use standard. 
Compliance with one of these in-use standards is required by
December 31, 2010.  If a TRU owner chooses to comply with LETRU
in 2010, they will still be required to meet ULETRU seven years
later (by the end of 2017).  If an MY 2003 engine owner chooses
to comply with ULETRU in 2010, there will be no in-use compliance
deadline in 2017.

ULETRU can be met by retrofitting with a Level 3 verified diesel
emissions control strategy (VDECS), which reduces particulate
matter (PM) emissions by at least 85 percent.  LETRU can be met
by retrofitting with a Level 2 VDECS, which reduces PM emissions
by at least 50 percent.  Compliance may also be maintained by
repowering the unit with the cleanest engine that will fit and
perform in the unit, but compliance with ULETRU is required seven
years after the engine model year or effective model year (if the
replacement engine doesn’t meet a current emissions standard). 
Level 2 and Level 3 VDECS that may be used to comply with the TRU
ATCM’s in-use standards are listed at the TRU Website in the
bottom section at:  http://www.arb.ca.gov/diesel/tru.htm .  As
indicated above, owners of TRUs and TRU gen sets equipped with MY
2003 engines need to order compliance technology now.

2)  Flexibility engines are engines that were manufactured to
meet a less stringent emissions standard than was in effect at
the time of manufacture.  When an engine is manufactured to meet
a less stringent prior-tier emissions standard than is currently
in effect, the effective model year is the last year that the
prior-tier standard was in effect.

Flexibility engines that have been installed prior to 2011 will
now use the engine’s manufacture year as the basis for
determining the in-use requirements and deadlines.  This will
allow current owners of TRUs seven years of operational life
after the engine manufacture year.  If owners are unsure whether
they have a flexibility engine, they should contact the TRU
manufacturer.  Also, as indicated above, these owners need to
register units equipped with flexibility engines in ARBER so that
compliance date adjustments can be made by ARB for flexibility
engines.

Flexibility engines that are installed in the future will have a
shorter operational life, based on the effective model year (as
described above).  Compliance with the ULETRU in-use standard
will be required seven years after the effective model year of
flexibility engines installed in 2011 and thereafter.

The adopted regulatory language for these amendments is available
in the Initial Statement of Reasons (Staff Report), Appendix A,
at:  http://www.arb.ca.gov/regact/2010/tru2010/tru2010.htm

If you have any questions, please contact the TRU Help Line at
1-888-878-2826 or call 916-445-5516.