California clamps down on refrigeration unit emissions

Jan. 1, 2005
Manufacturers and dealers of refrigeration units and the fleets that buy them will be impacted by new regulations from the California Air Resources Board

Manufacturers and dealers of refrigeration units — and the fleets that buy them — will be impacted by new regulations from the California Air Resources Board

Following almost two years of staff research and public comment, the Air Resources Board published new regulations governing exhaust emissions from the engines used to power transport refrigeration units and the generator sets used during highway operation of marine containers cooled by electric refrigeration units.

The stated purpose of the rules is to reduce particulate emissions from small diesel engines by 75% by the year 2010 and by 85% by 2020.

Although the state has published the new rule, it was not done without opposition. During the comment period, the California Trucking Association complained that the rule “is more far-reaching than any measure yet made by an air quality agency of the United States or Europe.”

The new rules became effective December 10, 2004, and apply with equal force to units operated by fleets based in California and to units operating in California on a temporary basis. This would include truckload carriers making deliveries in the state or carriers picking up shipments for destinations out of state.

The rule also applies to anyone involved in selling refrigeration units and gen sets, including manufacturers and dealers. The two horsepower categories used by the regulation separate units into those with engines rated at less than 25 hp and those rated at 25 hp and above.

According to a scientific review panel of the California Environmental Protection Agency, diesel exhaust has the potential to cause lung cancer in up to 450 out of one million people. The report also suggested that as many as 14,580 premature deaths in California can be attributed to diesel exhaust annually.

In addition to slashing the allowable exhaust emissions from small diesel engines, the new rule establishes recordkeeping standards for all California business facilities with 20 or more dock loading spaces at locations with refrigerated storage areas. These facilities must submit a one-time report to the Air Resources Board by January 1, 2006, detailing the use of refrigeration engines at the locations.

Long lead-times

Although the engine exhaust rule sets strict emission limits, it allows significant lead-time before fleet operators are required to alter existing units or replace them. Fleets can use refrigeration units and gen sets from the 2001 model year or earlier until 2007. Following 2007, units from 2001 or earlier must meet California's standard for low emissions, which is 0.3 grams per horsepower-hour for units rated at 25 hp or less and 0.2 g/hp-hr for units producing more than 25 hp. Units from the 2001 model year or earlier that meet this standard can be operated in California through 2014 after which a different standard for ultra low emissions becomes effective.

The lead-time for units built during the 2002 model year runs for a year longer, with no changes demanded for 2007 or 2008. These units are subject to the low emission standard from 2009 through 2015 and must begin meeting the ultra low emission standard in 2016. Only units from the 2002, 2001, and older model years will be subject to the low emission standards. Starting with the 2003 model year, units must meet the ultra low emission standard after a period of exemption. For instance, 2003 model year units have until 2010 to meet the ultra low standard. The lead-time extends to 2011 for 2004 model year units, to 2012 for units built in 2005, 2013 for 2006 units, 2014 for units from 2007, and so on with units built in 2013 meeting the ultra low standard in 2020.

Take a number

All in-state refrigeration unit and gen set operators will be required to apply for an Air Resources Board identification number on or before January 31, 2009. Among the information that will be requested the make, model, model year, and serial number of the unit; the terminal or other locations where the equipment is assigned; the vehicle identification number and the license number of the straight truck or trailer on which the unit is mounted.

The application must state when compliance with the rule was achieved and which level of compliance is involved. If compliance was achieved by replacing the engine in an existing unit or by using retrofit equipment under a verified diesel emission control strategy, the application must identify who did the installation work.

The Air Resources Board says that those out-of-state fleets may apply voluntarily for an identification number by submitting the same information required from California-based fleets.

Between 2004 and 2008, most out-of-state longhaul trucking companies are expected to replace existing refrigeration units with units that meet both the proposed federal Tier 4 standards and the California standards.

The Air Resources Board staff does not believe that entire out-of-state refrigerated fleets will need to comply. Modern truck dispatching such as global positioning systems, can enable dispatchers to sending only compliant vehicles to California.

Rewards for early compliance

California is offering fleets an incentive to meet the standards earlier than required. This applies to units from the 2002 or earlier model years.

If a fleet brings a 2002 or older unit into compliance with the low emission standard one year earlier than required, compliance with the ultra low emission standard can be delayed for a year. Complying two years early allows a two-year delay, and three years early results in a three-year delay. Reaching low emission compliance 183 days early in a calendar year provides credit for one year of delay for ultra low emission compliance.

The state will issue a certificate for those units approved for delay. Operators must maintain a copy of the certificate in a watertight container inside the unit housing.

As an alternative to running certified engines, refrigeration unit or gen set operators can choose to retrofit equipment with equipment that meets the standard for verified diesel emission control strategies.

To meet the low emission standard with retrofit equipment, the control strategy must reduce particulate emission by 50% or more. To meet the ultra low emission standard with retrofit equipment, emission reduction must be 85% or more or produce no more particulates than 0.01 gram per horsepower-hour.

Physical facility reports

Reports on physical facilities are due by January 31, 2006, based on information that was current as of December 31, 2005. This report must provide contact information for a responsible official of the facility and provide all the North American Industrial Classification codes that apply to the facility. Facility operators are required to report the number of dock doors serving refrigerated storage space and the number of square feet in the refrigerated space.

Operators must report the number of refrigeration unit or gen sets controlled by the facility. This section of the report must provide the model year and horsepower rating for units. Operators must also report the number of refrigerated trucks, trailers, containers, or railcars that they rent or lease. The report must contain a total of all operating hours for refrigeration units or gen sets controlled by the facility for the year 2005.

In addition, operators must report the average number of weekly inbound trucks, trailers, containers, or railcars delivering to the facility during 2005. This number is to be calculated by totaling all inbound shipments for 2005 and dividing by 52. The same information using the same calculation is required for outbound shipments. Operators are required to report the average total number of hours weekly that refrigeration units or gen sets for outbound loads operate while at the facility. The same information is required for inbound loads while the equipment is at the facility. Operators also must report the number of trailers used for cold storage and the total annual hours of engine-powered refrigeration time along with the total annual hours that electric standby is used.

Facility report information must be maintained and made available to state inspectors on request for a minimum of three years.

For a complete copy of the regulation and the Final visit

About the Author

Gary Macklin