March 24, 2020
Mr. Richard Corey
Executive Officer
California Air Resources Board
P.O. Box 2815
Sacramento CA 95812
RE: Transport Refrigeration Unit Regulation
Dear Mr. Corey:
Given the unprecedented events related to the COVID-19 virus outbreak which are confronting the State of California and the nation, the undersigned organizations request an immediate pause to your agency’s development of its Transport Refrigeration Unit Regulation. This pause will allow the companies affected by the proposed regulation to focus on ensuring the nation‘s supply chain provides essential goods like food, beverages and medicine to the residents of the state. Although the duration of this event is unknown, we believe a delay is warranted and appropriate.
As you are aware, draft regulatory language was first released on March 12, 2020 for a two-week comment period. Much has happened since this release including social distancing, school closures, work-from-home requirements, and stay-in-place orders. Operational impacts have been especially acute in the industry sectors subject to this regulation, including grocers, retailers, food distributors and refrigerated fleets.
While our organizations would like to continue to work with your staff on the development of the regulation, these efforts to minimize the spread of the virus are limiting our ability to provide additional information. For example, while we would like to have CARB staff visit cold storage warehouses to discuss how the proposed language would impact these facilities, it is simply not possible at this time. In addition, collecting and submitting data to support changes to the proposed language cannot be a priority at this time.
Finally, even when the extraordinary public health protection measures being enacted at this moment ease, it is widely believed that the precipitous drop in economic activity tied to these events will result in a prolonged recessionary period which will likely coincide with the rule’s largest capital expenditures to achieve compliance.
The efforts to keep us safe, healthy and supplied are shared by government, private citizens and businesses alike. The members of our organizations will continue to do their part in these difficult times. In this current crisis, we ask for your help in allowing us to focus on supplying the State of California, together, by temporarily pausing rule development.
Respectfully,
California Trucking Association
American Trucking Associations
Agricultural and Food Transporters Conference
BOMA California
Britton Konynenburg Partners
California Business Roundtable
California Chamber of Commerce
California Food Producers
California Grocers Association
California Manufacturers & Technology Association
California Railroads
California Retailers Association
Glendora Chamber of Commerce
Inland Action
International Council of Shopping Centers
La Verne Chamber of Commerce
Los Angeles County Business Federation
Majestic Realty Co.
NAIOP of California
Pacific Merchant Shipping Association
Pacific Mountain Logistics
San Gabriel Valley Economic Partnership
Sierra Pacific Warehouse Group
Western Growers Support TRU Rule