The amendments address the use of electronic standby and hybrid electric systems as an option for CARB compliance. TRU compliance can be maintained beyond seven years if an E/S system is used, as long as it adheres to the CARB guidelines.
Transport Refrigeration Units Alternative Technology Compliance Strategies —– Electric Standby and Hybrid Electric systems
This document explains requirements for the use of Electric Standby and Hybrid Electric systems (together referred to as E/S) as an option for compliance with California’s TRU regulations. A TRU’s compliance can be maintained beyond the seven year maximum if an E/S system is integrated into the equipment and used within the guidelines for an Alternative Technology. Also provided are specifications for businesses interested in providing electronic-tracking systems to affected TRU owners. These requirements were added in the 2011 Amendments, effective October 15, 2012.
What are Electric-Standby and Hybrid-Electric TRUs?
An Electric Standby TRU has a refrigeration system that may be selectively powered by either a diesel-fueled internal-combustion engine or an integrated electric motor. A “Hybrid Electric TRU” is powered by a diesel fueled internal-combustion engine coupled with an electric generator that provides electricity to an electric-motor driven refrigeration system within the same housing. Both are capable of being powered via an external source, such as the electric power grid.
What is required to qualify an E/S as an Alternative Technology?[note color=”#d9d8d3″]For E/S to qualify as an Alternative Technology, there must be no diesel-engine operation at nonretail delivery points, other than during emergency, normal ingress, egress and yard maneuvering, unit/engine pre-trip inspections, diagnostics, or repair operations.[/note]
Nonretail pick-up and delivery points must have compatible electric power plugs and TRUs must be plugged into electric power plugs when they are undergoing cool downs or are loaded with perishable goods, other than during the exceptions listed above.
*TRU-engine operation at retail delivery points is limited to 30 minutes; otherwise the unit must be plugged into electric power plugs to prevent diesel engine operations that exceed 30 minutes at each retail delivery point.
For TRU owners who elect to use E/S as a compliance option, the regulation’s 2011 amendments include requirements to phase-in use of electronic-tracking systems to replace manual recordkeeping. This phase-in requires 50 percent of an owner’s E/S TRUs to be equipped with an electronic tracking system by December 31, 2012, and 100 percent by December 31, 2013.
What is the difference between retail and non-retail delivery points?
“Nonretail Delivery or Pick-up Points” are wholesale perishable-goods distribution facilities or businesses in the supply chain prior to the retail facilities or businesses; that include: food manufacturing facilities, shipper warehouses, transfer points, distribution centers, cold storage warehouses, and intermodal facilities where perishable goods are loaded or unloaded.
“Retail Delivery Points” are facilities or businesses where perishable goods are delivered to retail businesses that sell these goods to end users; that includes: grocery stores, convenience stores, drug stores, restaurants, and prison or school cafeterias.
1What are the requirements for non-perishable goods that do not need climate control?
[note color=”#d5d3cd”]If a trailer is loaded with non-perishable goods that do not require TRU operation, there are no time limits for ingress or egress; however records must be kept to show there is no engine or motor operation. [/note]What are the requirements for TRU owners that elect to use E/S as a compliance option?
TRU owners who elect to use E/S as a compliance option must:
1. Followthephase-inrequiring50percentoftheE/STRUfleetbeequippedwithan electronic tracking system by December 31, 2012, and 100 percent by December 31, 2013;
2. Install an electronic tracking system that tracks time, location, engine-hour meter readings, elapsed engine-run time, standby electric motor-hour meter readings, and elapsed standby electric motor-run time at each nonretail and retail pickup and delivery point for each TRU using E/S as a compliance method;
3. Coordinate with the electronic tracking system supplier to create a geo-fence around each retail and non-retail pickup and delivery point;
4. Provide ARB access to online records for each E/S using TRU – records must be maintained on a secure server controlled by the electronic-tracking system supplier; and,
5. Update the ARBER registration with information concerning the supplier of the electronic tracking system.
What information must an Electronic Tracking System collect?
An “Electronic Tracking System” must:
1. Acquire and log, at a minimum, the date, time, TRU engine-hour meter reading, and location data at a rate of at least one reading per minute – with no more than 10 minutes in any data gap;
2. Be capable of determining if the TRU or TRU gen set is in California and the engine’s run-time in California for each day;
4. Allow tracking-data collection by an independent entity with no other business relationship to the owner or operator of the TRU or TRU gen set.
a. The data shall be stored on a server that is secure from tampering and inaccessible to the TRU or TRU gen set owner or operator, other than to download reports over the Internet.
b. An inspector shall have free access to download from this website reports showing the TRU or TRU gen set engine’s daily operation in California.
What companies supply electronic tracking systems?
A list of companies offering electronic tracking for TRU compliance is available at ARB’s TRU Helpline at 888-878-2826 (888-TRU-ATCM). This list does not imply an ARB endorsement or recommendation, and is not screened or ranked in any way. Companies not listed should call the TRU Help Line and request to be added. Users of this list are advised to use due diligence in evaluating offerings from companies on this list.