Tractor-Trailer Greenhouse Gas Regulation
California Air Resources Board (CARB) diesel regulations focus on engine emissions reductions. The only way to reduce greenhouse gas (GHG) emissions from a truck is through improved fuel economy. To accomplish CARB’s goal of reduced GHG from trucking operations, this rule mandates the purchase of new SmartWay verified trucks and trailers and requires aerodynamic retrofitting and low roll resistance (LRR) tires on in-use trucks and trailers. The regulation targets ONLY trucks that pull 53-foot or longer “van” style trailers. Basically, if you pull a 53-foot dry van or reefer, this regulation applies to you. If you pull a livestock trailer, HHG trailer, tanker, or any open equipment, this regulation does not apply. If you pull exclusively intermodal equipment you are also exempt.
Compliance flexibility options that would have allowed fleets phased-in compliance are no longer available. Those options required filing a Compliance Plan with CARB by January of this year for small fleets (20 or fewer trailers) and large fleets had two options available but needed to file Compliance Plans with CARB back in 2010 and 2012.
There are exemptions from the rules available but their usability for many out-of-state truckers is negligible. A short-haul exemption is available for tractors and trailers that accrue no more than 50,000 miles annually (inside and outside California) and a local-haul exemption is available for trucks and trailers that travel no further than 100 miles from their home terminal regardless of total annual miles accrued. CARB will also grant a single five-day pass per registered motor carrier for a single non-compliant truck and trailer to travel in California.
Transportation Refrigeration Unit (TRU) Regulation
There are two different emissions standards required to be met for TRUs, which depends on the model year (MY) of the engine in your unit. The LETRU (Low-Emission TRU reduces particulate emissions by 50 percent) applies to TRUs equipped with 2003 or older MY engines. The ULETRU (Ultra-Low Emission TRU reduces diesel emissions by 85 percent) standard applies to all 2004 and newer units and ultimately to all older TRUs. If you’re thinking about buying a used trailer with an older TRU and running into California, inspect in thoroughly to be sure it complies. Otherwise you could easily be making a financial mistake costing tens of thousands of dollars to bring the TRU into compliance.
A very simple rule of thumb to follow for this regulation is to add seven years to the age of the diesel engine in the unit. For example, if the date of manufacture on your engine is 2006, replace or retrofit the unit by December 31st of this year. The compliance date for each year is always December 31st of the year. Currently, CARB has only verified two manufacturers of diesel particulate filters (DPF) for retrofitting as capable of achieving the ULETRU standard.
Beginning this year, new federal emissions standards went into effect for 25-50 horsepower (hp) diesel engines typically used in reefer units. This is referred to as the Tier 4f standard. Manufacturers are allowed to sell units containing Tier 4 Interim (Tier 4i) engines, also called flexibility engines. If you purchase a unit with one of these engines, it will need to be replaced by December 31, 2019 regardless of when you initially purchased it.
California-based truckers have an additional compliance obligation. They must register their TRUs in the Air Resources Board Equipment Registration (ARBER) database, which will generate an Identification Number (IDN) which must be displayed on the TRU. Out-of-state operators of TRUs are NOT required to register in ARBER, but as I’ll discuss in the final installment of this series, shippers are beginning to demand proof of compliance as a pre-condition to getting loaded making registration in ARBER a practical necessity.
Make sure to read Part IV of this article series, coming next week on Team Run Smart, to get more information and tips on how to understand CARB regulations.