TRU purchase order deadline approaches

Aug. 25, 2016

Order compliance technology now for your 2009 transport refrigeration units (TRUs) to beat purchase order deadlines and to avoid penalties due to manufacturer or installer delays.

August 31, 2016, is the purchase order deadline for new replacement TRUs and TRU generator sets. Model year 2009 engines/units must meet the TRU regulation’s in-use performance standards by December 31, 2016. It is probably too late to order refrigerated trailers due to long backlogs at refrigerated trailer manufacturers.

The California Air Resources Board (CARB) recommends that TRU and TRU generator set owners take action now to order compliance options to ensure TRU model year 2009 engines (or units manufactured in 2009) comply with in-use performance standards by the end of 2016. Replacement engines are no longer a compliance option because they must be cleaner than the old engine being replaced and there is no replacement engine that fits and functions that is cleaner than an MY 2009 engine.

The TRU regulation allows compliance extensions if delivery or installation is delayed. To qualify for these extensions, the unit must be registered in CARB’s Equipment Registration (ARBER) system and purchase orders must be placed early enough to take into account large order backlogs, delivery, installation, holiday, and typical year-end compacted schedules. The TRU regulation has these purchase order deadlines:

•For unit replacements—By the end of August, or four months ahead of the compliance deadline.

•For verified diesel particulate filter retrofits—By the end of October, or two months ahead of the compliance deadline.

Owners must exercise due diligence in attempting to comply by the end of 2016. 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, start the research, budgeting, and financing well in advance of the compliance deadline, and purchase the compliance technology before the purchase order deadline. The compliance extension application (with attached supporting documentation that shows due diligence was used) must be received at CARB by Dec 31, 2016.

All model year 2008 and older engines (or units manufactured in 2008 or earlier) should be in compliance now. Note that trailer manufacture year and in-service dates are not used to determine compliance dates. Non-compliant model year 2008 and older TRU/TRU genset engines/units must not be operated in California unless they are brought into compliance immediately.

For general information about the TRU regulation, access www.arb.ca.gov. To obtain answers to questions, call the TRU Help Line at 1-888-878-2826 or 1-916-327-8737.