Opinion: Dealing With California’s Reefer Rules

By James Ryden
Enforcement Division Chief
California Air Resources Board

This Opinion piece appears in the Dec. 10 print edition of Transport Topics. Click here to subscribe today.

The California Air Resources Board is recommending that truckers with transport refrigeration units, also known as reefers, pay attention to upcoming deadlines to avoid penalties.

California endures serious air pollution problems and is home to three of the five worst air-quality regions in the country. Diesel engines produce particulate matter — a toxic air contaminant responsible for 70% of the airborne carcinogens in California’s air.



Diesel emissions also are a significant environmental justice problem. Many California communities endure a variety of pollution sources — usually from industry, manufacturing, shipping and distribution.

CARB is required by law to identify sources of toxic air contaminants and minimize them. To that end, we passed the Transport Refrigeration Unit Airborne Toxic Control Measure in 2004.

The regulation applies to all transport refrigeration units and transport refrigeration unit generator-set engines that operate in California. Even those based outside California but coming into the state must comply, including those from Mexico coming into the commercial zone near the border.

Though transport refrigeration units and transport refrigeration unit generator-sets are relatively small — most about 35 horsepower — they congregate in large numbers at distribution centers near residential and business areas. The resulting emissions create a significant public health threat. For the benefit of these communities, as well as California in general,

CARB plans to aggressively implement this regulation.
The regulation’s limits will reduce diesel particulate matter emissions from this engine category by 65% by 2010 and by more than 90% by 2020.

With compliance dates for older engines quickly approaching, owners and operators are encouraged to work with board staff to assure their engines comply with this important state regulation. Early action not only will avoid penalties and minimize time off the road, it also will save money.

Owners and operators must know their engine’s model year and how the engine will meet the standards by deadline. If they are based in California, they must acquire an identification number for the engine and submit operator reports to the Air Resources Board.

Also, owners of facilities with 20 or more loading spaces serving refrigerated areas must submit a one-time report.  CARB has already taken enforcement action against a number of these facilities and reached settlement on a few cases. The details of these settled cases are available on CARB’s enforcement Web page at: www.arb.ca.gov/enf.enf.htm.

Engine compliance is possible in three different ways:

Retrofitting the engine with the appropriate level of verified controls, such as exhaust aftertreatment devices.

Using an engine of a class that has been tested and

Using any other approved technology, e.g., electric standby, cryogenic temperature control or CARB-approved alternative diesel fuels such as biodiesel.

Owners must apply for CARB identification numbers and submit operator reports by Jan. 31, 2009, for all units based in California. For units based outside California, identification numbers are voluntary but highly recommended to reduce inspection times at border crossings, scales, terminals and distribution centers.

Part of the regulation applies only to “large” facilities, i.e., those with 20 or more loading spaces serving refrigerated areas. Those facilities were required to submit a one-time report by Jan. 31, 2006.

Because this is a technology-forcing regulation, we provided plenty of time for manufacturers to develop systems to control emissions, but time has passed quickly. The first phase begins Dec. 31, 2008, when model year 2001 and older transport refrigeration units and transport refrigeration unit generator-set engines must meet in-use performance standards.

Model year 2002 engines must comply by the end of 2009. This pattern continues for subsequent model years, with mandatory compliance by the end of the seventh year after the engine model year.

CARB held two technology review workshops last summer to assess manufacturers’ progress on the technologies being developed. From these sessions, we believe there will be many timely options available.

Contact CARB staff to get information for your model year. We can work with you to be sure your strategy brings you into compliance. To get started, you will find our Diesel PM Control Technology Option Matrix and other helpful documents on our Web site: www.arb.ca.gov/diesel/tru.htm.

Funding to help offset some costs of compliance can be found through California’s Carl Moyer Fund. Fleets can compete for Carl Moyer Program multi-district funding but must be willing to comply at least three years early. More information can be found at CARB’s Carl Moyer Program Web site: www.arb.ca.gov/msprog/moyer/moyer.htm.

There is no provision for compliance extensions, so we urge owners and operators of transport refrigeration units and transport refrigeration unit generator-sets to contact us early and move quickly to ensure they meet the approaching deadlines.

To contact CARB regarding the TRU regulatory program call 1-888-TRU-ATCM. You may also sign up for the TRU e-mail listserv, which will provide you with routine program updates, at www.arb.ca.gov/listserv/tru.htm.

The California Environmental Protection Agency’s Air Resources Board is based in Sacramento, Calif., and employs more than 1,100 workers, including engineers, scientists and automotive technicians.