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Updated Proposed
CARB Regulations

April 2020

In August 2019, we reported on the proposed new regulations by California Air Resources Board (CARB) that would impact TRUs that operate in California.

In August 2019, we reported on the proposed new regulations by California Air Resources Board (CARB) that would impact TRUs that operate in California. As of March 2020, all but one of these proposals have changed. Most are specific to a date adjustment or the use of a diesel particulate filter (DPF).

As a fleet owner, we want you to be aware of and prepared for how these regulations could impact your business. You will find all of the latest CARB proposed regulations outlined on this page.

CONCEPT INTENT:

All TRU's must register with CARB - Timing 2022.

DRAFT INTENT SUMMARY OF CHANGE
DRAFT INTENT: All TRUs must register with CARB by Dec. 31, 2021. SUMMARY OF CHANGE: No Change

CONCEPT INTENT:

All newly manufactured truck, trailer, domestic shipping containers and rail TRUs manufactured with refrigerant must have a Global Warming Potential (GWP) less than or equal to 2,200 - timing 2022.

DRAFT INTENT SUMMARY OF CHANGE
DRAFT INTENT: On or after Dec. 31, 2021, all newly manufactured truck, trailer, domestic shipping containers and rail TRUs manufactured with refrigerant must have a Global Warming Potential (GWP) less than or equal to 2,200. SUMMARY OF CHANGE: Firm date of Dec. 31, 2021 versus 2022.

Implications:

TRU equipment manufacturers will be able to meet requirements by 2022 of the lower GWP on new equipment. Customers with maintenance facilities should proactively reach out to their suppliers to assure their shops can transition to the new refrigerant while supporting legacy equipment.

CONCEPT INTENT:

All trailer and domestic shipping containers TRUs will meet zero-emission operation when parked or stationary for more than 15 minutes at an applicable facility - timing 2025.

DRAFT INTENT SUMMARY OF CHANGE
DRAFT INTENT: On or after Dec. 31, 2023 all new trailer and domestic container TRUs and gen-sets must have the ability to operate in zero-emission mode. TRUs cannot operate in a manner that exceeds a stationary operating time limit (SOTL) of 15 minutes within an applicable facility. SUMMARY OF CHANGE: Firm date of Dec. 31, 2023 for new equipment versus 2025.
DRAFT INTENT: On or after Dec. 31, 2027 all trailer, domestic container TRUs and gen-sets must comply with the 15 minute stationary operating time limit at applicable facilities. SUMMARY OF CHANGE: Firm date of Dec. 31, 2027 for all equipment versus 2025.

Implications:

Operating a TRU without the ability to meet stationary operating time limits (SOTL) creates significant risks for carriers that pickup and deliver at facilities that have the ability for them to plug in and operate in zero-emission mode. Beginning immediately, for fleets operating in CA and run their equipment for 7+ years, purchasing units with electric standby or the ability to convert to electric standby needs to be given consideration in the TRU selection process.

CONCEPT INTENT:

All trailer and domestic shipping container TRUs must be equipped with electronic telematics system - timing 2025.

DRAFT INTENT SUMMARY OF CHANGE
DRAFT INTENT: New equipment must be equipped with electronic telematics system by Dec. 31, 2023. SUMMARY OF CHANGE: Firm date of Dec. 31, 2023 for new versus 2025.
DRAFT INTENT: All equipment must be equipped with electronic telematics system by Dec. 31, 2027. SUMMARY OF CHANGE: Firm date of Dec. 31, 2027 for all versus 2025.

Implications:

Selecting a TRU with a factory integrated ETS assures current and future compliance regardless of regulatory requirements and timing.

CONCEPT INTENT:

All trailer, domestic shipping container, rail box car TRUs, and gensets must meet the US EPA Tier 4 final emission standards for 25-50 hp engines.

DRAFT INTENT SUMMARY OF CHANGE
DRAFT INTENT: On or after Dec. 31, 2023 all new trailer, domestic shipping containers, rail TRUs and gen-sets must meet US EPA Tier 4 final emission standards for 25-50 HP engines. SUMMARY OF CHANGE: Firm date of Dec. 31, 2023 for new equipment versus 2025 for all equipment.1
DRAFT INTENT: On or after Dec. 31, 2023 all legacy < 25 HP TRUs with a manufacturing date prior to Dec. 31, 2023 must have a level 3 verified diesel emission strategy device, such as a diesel particulate filter (DPF). SUMMARY OF CHANGE: Any < 25 HP unit to operate with a diesel particulate filter (DPF) regardless of unit age.2
DRAFT INTENT: On or after Dec. 31, 2030 all trailer, domestic shipping containers, rail TRUs and gen-sets must meet US EPA Tier 4 final emission standards for 25-50 HP engines. SUMMARY OF CHANGE: Firm date of Dec. 31, 2030 for all TRUs to meet 25-50 horsepower emissions versus 2025.3

Implications:

1 Evergreen solutions will continue to see escalating residual values versus

2 < 25 HP product will have a full 7 year useful life if purchased by 2023, assuming DPF is added. Diesel particulate filters (DPF) are no longer a means to indefinitely meet emission regulations. The end of life for DPF units is 2030.

3 > 25 HP TRUs purchased now, require no additional investment to meet emissions requirements in California.

Draft Regulatory Language:

https://ww3.arb.ca.gov/cc/cold-storage/documents/Draft%20TRU%20Regulatory%20Language_03122020.pdf

CARB Presentation:

https://ww3.arb.ca.gov/cc/cold-storage/documents/tru_conceptslidesworkshop3192020.pdf

*The information provided herein does not, and is not intended to, constitute legal advice; instead, all information, content, and materials are provided for general informational purposes only. If you have any questions about this information, you should consult with your individual attorney to provide assurances that the information – and your interpretation of it – is applicable or appropriate to your particular situation. The information is provided "as is;" no representations are made with respect to the accuracy of the information.

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6243 Netherhart Road
Mississauga, Ontario L5T 1G5
1-800-990-9662

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