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Legal Alert

New Regulations Proposed for TRUs

New Regulations Proposed for TRUs

By 2020, the California Air Resources Board (CARB) intends to adopt regulations designed to reduce emissions of greenhouse gases and particulate matter from Transport Refrigeration Units (TRUs). The proposed regulations could impose significant costs on the transportation industry by limiting the time TRUs can operate using cold storage, requiring the development and use of electric or hybrid-electric TRUs and the installation of associated infrastructure to accommodate the TRUs.

Cold storage operations occur when the refrigerated truck, trailer, railcar, or shipping container is parked but operates to provide cold storage for perishables where there is no other capacity for refrigeration. This includes supplementing grocery store cold storage capacity around major holidays and during loaded inbound or outbound trailer wait times, like at distribution center parking over weekends, or at truck stops and rest areas.

Some of the concepts under consideration by CARB are:

  • Requiring TRUs to plug into an electric power grid when stationary, which would require the development of hybrid-electric TRUs, all-electric units, or all-electric stationary transport refrigerators.
  • Use of cryogenic transport refrigerators using liquid nitrogen, air, or CO2.
  • Building additional cold storage capacity at grocery stores and other facilities that currently rely on cold storage.
  • Requiring the use of logistics, scheduling tracking and dispatching procedures.

CARB held its initial workshop on April 13, 2016. CARB plans to conduct surveys and outreach to stakeholders, and hold more workshops to evaluate the feasibility of the various concepts. The next workshop will be held during this summer. Interested parties should consider keeping abreast of developments and providing input on the effect these proposed regulations will have on their operations in California.

CARB's plans to reduce emissions from TRUs are part of the state's broader effort to reduce greenhouse gas emissions from the freight industry. Four state agencies are currently developing a "Sustainable Freight Action Plan" that will include new emissions reduction goals that will affect the entire industry.  A draft plan is expected to be released in May 2015.

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