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Transport refrigeration unit (TRU) owners need to be aware that
the engine repower compliance option will cease to exist for
model year 2008 and newer TRU engines after the end of 2014. 

Repowering a TRU ceases to qualify as a compliance option when
the replacement engine is no cleaner than the engine being
replaced.  Title 13 California Code Regulations section 2477.5(i)
stipulates that a replacement engine shall meet a more stringent
emissions standard than the original engine.

Examples follow:
1.	Model year (MY) 2008 through 2012 Tier 4i in-use engines rated
at 25-50 horsepower (hp) used in trailer TRUs or TRU generator
sets:  The only replacement engine that is known to fit and
perform is another Tier 4i replacement engine, which does not
result in a cleaner replacement engine.  Therefore, the repower
compliance option for 25-50 hp trailer TRU and TRU gen set
engines fails to qualify for MY 2008 through 2012 Tier 4i engines
that need to comply with the in-use performance standards seven
years after the engine model year or effective model year.

2.	MY 2008 and newer Tier 4f in-use engines rated at less than 25
hp in truck TRUs:  The only replacement engine that is known to
fit and perform is another Tier 4f less than 25 hp replacement
engine, which does not result in a cleaner replacement engine. 
Therefore, the repower compliance option for less than 25 hp
truck TRU engines fails to qualify for MY 2008 and newer  Tier 4f
engines that need to comply with the in-use performance standards
seven years after the engine model year or effective model year.

A Q&A to this effect has been added to TRU Advisory 13-18 at: 
http://www.arb.ca.gov/diesel/tru/documents/advisory_13_18.pdf .

It should also be noted that the repower compliance option is not
very attractive for MY 2007 trailer TRU engines that must comply
by the end of 2014 because this only results in about five years
of compliance before the ULETRU in-use performance standard has
to be met.  For example, if a trailer TRU has an MY 2007 original
engine that must comply by December 31, 2014, and the owner
chooses to repower the TRU with a Tier 4i replacement engine, the
effective model year of the replacement engine is 2012 (the last
year that tier 4i was in effect), and compliance with ULETRU
in-use standard would then be required by December 31, 2019
(seven years after the effective model year).  In this example,
the operational life of the replacement engine would only be
about five years (late 2014 to December 31, 2019).  This example
is also included in the updated TRU Advisory 13-18 (starts at the
bottom of page 2).

Retrofitting with a Level 3 Verified Diesel Emissions Strategy
(VDECS) may be something to consider because Level 3 VDECS meet
the TRU Regulation’s ULETRU In-Use Performance Standard.

Where can I get more information?

For general information about the TRU Regulation, the TRU Website
is at:  http://www.arb.ca.gov/diesel/tru/tru.htm

Information about Level 3 VDECS is at:
http://www.arb.ca.gov/diesel/tru/tru.htm#mozTocId341892

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

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

Sign up for the TRU List Serve at:
http://www.arb.ca.gov/listserv/listserv_ind.php?listname=tru

If you have questions about in-use performance standard
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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