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California Reefer Rules Postponed…again

SACRAMENTO, Cal. - Once again, the California Air Resources Board (CARB) has delayed the compliance deadline for meeting emissions standards from transport refrigeration units (TRU). Enforcement of in...

SACRAMENTO, Cal. –Once again, the California Air Resources Board (CARB) has delayed the compliance deadline for meeting emissions standards from transport refrigeration units (TRU). Enforcement of in-use performance requirements for TRU engine model years 2001 and older will now commence Dec. 31, 2009.

The compliance deadline was originally Dec. 31, 2008. However, that was postponed until July 17, 2009, as a result of the US Environmental Protection Agency’s delayed approval, which was granted Jan. 16, 2009. CARB provided a six-month enforcement grace period to allow carriers additional time to pursue compliance methods.

CARB says it is extending the compliance deadline to Dec. 31, 2009 because as the close of the grace period approached, it became clear that several thousand TRUs were not in position to comply by mid-July. The reasons for this included: lack of timely action by TRU owners; higher costs for compliance than originally anticipated; some retrofit systems not becoming available until May 2009; tightening of credit; and longer lead times for delivery of systems.

The regulations, Airborne Toxic Control Measure (ACTM) for In-Use Diesel-Fueled Transport Refrigeration Units (TRU) and TRU Gen Set and Facilities Where TRUs Operate, use a phased-in approach during the next 13 years to reduce diesel particulate matter (PM) emissions from TRUs and TRU generator set engines that operate in California.

Any carrier operating a TRU within California must comply with the in-use performance standards, regardless of whether vehicles are registered in or outside of the state or in Canada.

Commonly referred to as TRU ATCM, the regulations establish two levels of stringency for in-use performance standards, which vary by horsepower range: low emission and ultra-low emission. The standards are based upon model year of the TRU engine.

These standards can be met by using a TRU engine that meets the required engine certification value or by retrofitting the engine with the required level of CARB Verified Diesel Emission Control Strategy (VDECS), such as diesel particulate filters. Among the diesel emission control strategies verified by CARB:

• Dinex Exhausts’ Dinex DiSiC Level 3 Plus diesel particulate filter (;

• Huss Filters’ FS-MKS Level 3 diesel particulate filter (;

• Proventia’s FTF and Bobtail FTF Level 2 Plus flow-through filters (;

• Rypos’ DPF/LETRU Level 2 Plus diesel particulate filter (;

• Thermo King’s PDPF Level 2 Plus flow-through filter (

Alternative technologies can also be used to meet the low emission and ultra-low emission in-use performance standards. These include electric standby, hybrid electric/diesel equipment, all-electric truck refrigeration solutions, cryogenic temperature control systems or hybrid cryogenic temperature control systems and other technology approved by CARB to not emit diesel PM or increase public health risk near a facility.

Other compliance options being investigated that could become available in the future are alternative fuel-powered engines, alternative diesel-fueled engines and fuel cell-powered temperature control systems. Development work on compressed natural gas (CNG) and liquefied petroleum gas (LPG) was done, but never made it to market.

Biodiesel is close to completion of the multi-media assessment, but then a biodiesel producer would need to apply to CARB for verification of B100 (pure biodiesel) as a VDECS. Once biodiesel is approved as a VDECS, it can be used as a compliance option, but not until then.

TRU in-use performance standards begin with reefers with a model year 2001 or older engine. Compliance requires that these engines be replaced or retrofitted with CARB-verified diesel emission control devices or technology to reduce PM emissions by 50%. These engines must have at least at an 85% PM reduction on or before 2016.

The next in-use performance standards compliance deadline date – for TRU engine model year 2002 -is Dec. 31, 2009.These units must also reduce PM emissions by 50% by the end of the year and by 85% on or before 2017.

Model year 2003 units must reduce PM emissions by at least 85% by the end of 2010; model 2004 and beyond by Dec. 31 of the model year plus seven years.

Enforcement of TRU ACTM in-use performance standards will be done by CARB officials through inspections at border crossings, weigh and inspections stations, terminals, distribution centers, truck stops and anywhere else TRUs are found operating.

Violations of in-use requirements could result in penalties that range from $500 per unit or up to $1,000 per day per violation.

Refrigerated fleets are coping with the CARB TRU regulations in a variety of ways.

While there has been an awareness of the impending regulations, “many fleets have delayed action, hoping that industry associations would successfully push to overturn the legislation,” says Bud Rodowick, Thermo King’s manager of fleet performance.

While delivering CARB compliance seminars over the past few years to hundreds of customers, Rodowick has been surprised by the number of fleets that are just beginning to learn of or have been misinformed about the regulations. He has also heard from a number of fleets that say they simply aren’t going to haul freight in and out of California.

The “on-again, off-again” mixed messages fleets received from the various agencies and associations involved have contributed to a reluctance to act, adds David Kiefer, Carrier Transicold’s director of marketing and product management. It has been difficult for the average fleet owner to justify the high cost associated with compliance not knowing whether or not the legislation would actually stand.

“Even now, the District of Columbia Circuit Court of Appeals is scheduling a review,” Kiefer says. “This again has some fleets wondering whether they should hold off on this big expense or not, and that’s a pretty big gamble.”

Cost of compliance for CARB VDECS currently ranges from about $4,000 to $7,000. The cost to replace a TRU engine varies from $4,000 to $10,000.

That’s quite a bit of money to ask fleets to invest in an old TRU, especially at a time when so many fleets are already struggling, says Kiefer. “If the cost of compliance were only a couple hundred dollars, we wouldn’t even be discussing this.”

The appropriate compliance solution is dependent upon several key issues, including capital availability to invest in new refrigerated trailers or compliance, and the TRU itself, agree Kiefer and Rodowick.

For TRUs with low hours -meaning the major components like the compressor, evaporator coil and microprocessor are in good shape -fleets tend to replace just the engines because the result is a “like-new” reefer, says Kiefer.

Fleets that have TRUs that have experienced heavy use are inclined to invest in new reefers instead of replacing the engine.

“A new engine in an older, high-hour unit may not make sense,” says Rodowick. “In many cases, it’s more advantageous in terms of overall cost of ownership to purchase a new TRU.”

Another complication for fleets is the CARB regulations that call for retrofitting existing reefer trailers with SmartWay technologies. A program of the US EPA, SmartWay is a partnership between government, business and consumers to find environmentally cleaner, more fuel-efficient transportation options. In its simplest form, the SmartWay brand identifies products and services that reduce transportation-related emissions.

As per these CARB regulations, model years 2009 and 2010 refrigerated trailers and those 2002 and older must b
e retrofitted with SmartWay-verified technologies by the end of 2012. Model year 2003 and 2004 refrigerated trailers must be retrofitted by the end of 2017, model year 2005 and 2006 refrigerated trailers by the end of 2018 and model year 2007 and 2008 refrigerated trailers by the end of 2019.

Kiefer says the use of electric standby is growing as a compliance option for those operations that support this type of solution, for example distribution fleets and grocery companies that can support the power-supply infrastructure.

“There is an often-overlooked part of the CARB legislation that says that as long as a company properly uses and documents the use of electric standby as the compliance option, it will not have to add any emissions-reducing upgrades to the engine or replace the engine in the future.”

CARB estimates the TRU ATCM regulations will reduce emissions from TRU and TRU gen set engines by approximately 65% in 2010, and by some 92% in 2020, resulting in “significantly improved air quality and associated health benefits.”

Additional information on the regulations and compliance can be found on the TRU section of the CARB Web site at,or by phoning the TRU Help Line at 888-TRU-ATCM.

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