Legislative Bulletin - July 2, 2009
CA Announces More Delays in TRU Emissions Compliance Deadline Enforcement
Citing reasons highlighted by TRALA throughout the regulatory process, including high costs and availability of technology, the California Air Resources Board (CARB) has further delayed two compliance deadlines for the Transport Refrigeration Unit (TRU) Airborne Toxic Control Measure (ATCM):
1. The TRU registration and operator report requirements deadline for California based TRUs has been extended until July 31, 2009 (previously delayed from January 31, 2009, until March 16, 2009). Enforcement of the registration requirements will begin in August 2009.
2. The deadline for meeting the Low-Emission TRU (LETRU) In-Use Performance Standards for 2001 and older TRU engines has been delayed until December 31, 2009, (previously delayed from December 31, 2008, until July 16, 2009). Enforcement of the in-use performance standards will begin in January 2010, for all model year 2002 and older engines.
CARB is extending these deadlines 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 include: 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. Given these factors, CARB has determined that a two phase enforcement schedule would allow for more complete registration and provide some additional time for pre 2002 TRUs to come into compliance in an orderly manner.
The revised TRU registration, Operator Report, and In-Use Performance Standard schedule follows:
| July 31, 2009 | All California-based TRUs must be registered with CARB. If you are the owner of a TRU that is based outside of California, applying for an IDN is voluntary and there is no deadline. Initial Operator Report must also be submitted by this date. |
| August 2009 | CARB staff will begin field enforcement for registration of all California-based TRUs |
| December 31, 2009 | Compliance deadline for 2001 and older and 2002 model year TRU engines to meet the Low-Emission TRU In-Use Performance Standards |
| January 2010 | In-Use Performance Standard enforcement begins for model year 2002 and older TRU engines |
Additional information is available in TRU Advisory 08-15-R4. For more information on CARB’s TRU emissions regulation, including provisions allowing lessors to transfer reporting obligations to lessees, please contact TRALA’s Tom James at 703-299-9120 or at tjames@trala.org.