TRU (reefer) owners: Planning model year 2008 reefer engine compliance should be underway

The California Air Resources Board (ARB) recommends to refrigerated carriers that own model year (MY) 2008 transport refrigeration units (TRU or reefer) that must comply with the TRU Regulation's in-use performance standards by the end of 2015 -- your compliance planning strategies, budget approval and financing processes should be underway now.

Please be aware that replacement engines may no longer be a compliance option because replacement engines must be cleaner than the old engine being replaced and there is no replacement engine that fits and functions that is cleaner than the old MY 2008 engine that needs to comply (see TRU Advisory 13-18, page 7 for more detailed explanation at:

http://www.arb.ca.gov/diesel/tru/advisories.htm).

Model year 2008 TRU engines must comply with the TRU Regulation's in-use standards by Dec. 31, 2015. Purchase orders for compliance equipment (e.g. replacement trailers or units) or emissions control technology (e.g.

diesel particulate filters) must be placed before the TRU Regulation's purchase order deadlines to qualify for a compliance extension if delivery or installation is delayed until after Dec. 31, 2015. To qualify for this compliance extension, the TRU must be registered in ARB's Equipment Registration (ARBER) system, purchase orders must be placed before the purchase order deadlines, and compliance extension applications must be submitted by Dec. 31.

The purchase order deadlines that apply to TRUs are:

For TRUs, and engine replacements: Aug. 31 (four months ahead of the compliance deadline); and
For verified diesel particulate filter retrofits: Oct. 31 (two months ahead of the compliance deadline).

Replacement trailers should be ordered much sooner due to long lead times and the current manufacturing backlog.

Owners must exercise due diligence in attempting to comply by the end of 2015. Due diligence means conducting the compliance process with a measure of prudence, responsibility, and diligence that is expected from, and ordinarily exercised by a reasonable and prudent person under the circumstances. For example, starting the research, budgeting, and financing well in advance of the compliance deadline, and purchasing the compliance technology before the purchase order deadline. The compliance extension application, with attached supporting documentation that demonstrates due diligence was used, must be received at ARB by Dec. 31, 2015.

All model year 2007 and older TRU engines (or units manufactured in 2007 or earlier) should already be in compliance now. Please note that trailer manufacture year and in-service dates are not used to determine TRU compliance dates. Noncompliant model year 2007 and older TRU engines/units must not be operated in California unless they are brought into compliance immediately.