Comment Log Display

From: Maddox, William CAR [mailto:William.Maddox@carrier.utc.com] 
Sent: Monday, October 03, 2011 10:52 AM
To: Hill, Rodney@ARB
Subject: Carrier Transicold comments on 2011 TRU ATCM amendments


Dear Rod,

Thank you for the opportunity to comment on the proposed amendments
for the TRU ATCM that are being presented to the Air Resource Board
on October 20th.  Carrier Transicold has comments on two of the
proposed amendments and respectfully request staff consider minor
modifications to the language, which we believe still maintain the
intent.

•	For the proposed 2477.13(a)(4), as an OEM whose products are sold
by an independent dealer network, Carrier Transicold generally does
not have visibility of or contact with the ultimate purchaser prior
to sale.  Carrier Transicold would suggest that the language state
that the OEM update their owner and/or operators manual if the unit
is equipped with a flexibility engine & it is the responsibility of
the TRU dealer to notify the ultimate purchaser prior to sale.
•	For the proposed 2477.13(c)(2), Carrier Transicold would like to
suggest an alternative means of providing the registration
information.  Instead of requiring a printed registration document,
Carrier Transicold would like to pursue an on-line lookup system as
an alternative.  This alternative would prevent the need to provide
paper documents and save on natural resources. And as previously
discussed, this would ultimately provide the purchaser more direct
and accurate access to the information since the written documents
have a great potential to get lost during installation at a third
party, such as a trailer body OEM.

If you have any questions on our proposals, please do not hesitate
to contact me.


Regards.


Bill Maddox
Service Manager
Carrier Transicold
Athens, GA 30601