CARBs Warns of 5-Year limits of 2014 Trailer TRUs with Tier 4i

Transport refrigeration unit (TRU or reefer) and TRU generator set (gen set) owners should be aware that new 2014 trailer TRUs/gen sets equipped with Tier 4i flexibility engines that were manufactured in 2014 must meet the Ultra-Low-Emission TRU (ULETRU) in-use performance standard by December 31, 2019; so the operational life of these TRUs/gen sets is only 5 years plus the remainder of 2014.

Flexibility engines do not meet the emissions standards that are currently in effect at the time of engine manufacture.  A Tier 4i flexibility engine’s effective model year is 2012 (the last year that Tier 4i was in effect).  If Tier 4i flexibility engines manufactured in 2014 are installed in a new TRUs/gen sets in 2014, California law requires the in-use performance standard requirements and compliance deadlines to be based on the engin’s effective model year (2012), not the engine’s manufacture year or TRUs’/gen sets’ model year.

This results in the ULETRU in-use performance standard compliance deadline of December 31, 2019, (seven years after the effective model year) for flexibility engines manufactured in 2014, so the operational life of these TRUs/gen sets is only 5 years plus the remainder of 2014.

California Air Resources Board’s (ARB) TRU Regulation requires original equipment manufacturers (OEM) to disclose to the end user in writing prior to sale, if a TRU/gen set is equipped with a flexibility engine.  The regulation requires a written disclosure notice to be provided with TRUs/gen sets equipped with flexibility engines, with instructions to dealers telling them they are required to notify the ultimate purchaser of this disclosure prior to sale.  Dealers are required by law to pass the written disclosure to the ultimate purchaser at point of sale.  These disclosure requirements include all of the following:

1. Notice that the TRU/gen set is equipped with a flexibility
engine that meets a less stringent emissions standard than the emissions standard in effect at the time that the engine was manufactured.

2. Provide the effective model year of the flexibility engine.

3. Notify the ultimate purchaser that if they register the TRU/gen set in ARB’s Equipment Registration (ARBER) system, they are required report the effective model year of the flexibility engine, not the year that the flexibility engine was manufactured.

4. If the TRU/gen set is operated in California, the owner will
be required to bring the flexibility engine into compliance with the ULETRU in-use standard seven years after the effective model year of the engine (in the case of a Tier 4i flexibility engine manufactured in 2014, by December 31, 2019).

Also, under California law, if a TRU OEM equips TRUs/gen sets with a flexibility engines, they are required to attach supplemental engine labels that provides all of the information needed to register those engines in ARBER.

Tier 4i flexibility engines that were manufactured in late 2013, may be installed in TRUs and TRU gen sets during the first several months of 2014 without losing operational life.  This is consistent with past policy.  The TRU OEM reports the engine manufacture year to ARB so that those units can be identified.

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