Halloween VDECS order deadline looms

The California Air Resources Board (CARB) reminds model year (MY) 2009 transport refrigeration unit (TRU) owners: If you want to qualify for compliance extensions, only a few days remain before the purchase order deadline for ordering Level 3-verified diesel emissions control strategies (VDECS). These include diesel particulate filters (DPF) for retrofitting engines.

MY 2009 TRU and TRU generator set engines must comply with the TRU regulation’s in-use performance standards by December 31, 2016.  Replacement engines are no longer a compliance option because they must be cleaner than the old engine being replaced, and there is no replacement engine that fits and functions that is cleaner than a MY 2008 engine.

Orders for replacement units that are placed after August 31 will not be eligible for compliance extensions if delivery or installation will be completed after Dec 31, 2016.

The TRU regulation does not allow compliance extensions if orders for VDECS, such as Level 3 DPFs, are placed after Oct 31, 2016 and installation is not completed by Dec 31, 2016.

However, if MY 2009 TRU owners order Level 3 DPFs before the end of October, installation by the end of 2016 is very likely possible. More importantly, if you order a Level 3 DPF before October 31 and delivery or installation is delayed so that you can’t comply by the end of 2016, you may qualify for a compliance extension.

To qualify for compliance extension:

•Purchase orders for Level 3 DPFs must be placed before October 31.

•The TRU must be registered in ARB’s Equipment Registration (ARBER) system.

•An application for extension must be submitted to CARB with the required documentation before Dec 31, 2016.

Owners must exercise due diligence in attempting to comply by the end of 2016. Due diligence means conducting the compliance process with a measure of prudence, responsibility, and diligence that is expected from, and ordinarily exercised by a reasonable and prudent person under the circumstances. The compliance extension application (with attached supporting documentation that demonstrates due diligence was used) must be received at CARB by Dec 31, 2016.

If you have questions about compliance or registration, call the TRU Help Line at 1-888-878-2826 or call 1-916-327-8737.

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