Comment submitted by Truck Renting and Leasing Association (TRALA)

Summary: The Truck Renting and Leasing Association (TRALA) strongly supports the EPA's proposed rule to exclude road and intermodal container transport refrigeration units (TRUs) from HFC leak repair requirements. They argue that these mobile units operate in different environments than stationary equipment and that applying stationary requirements would create significant compliance burdens, costs, and supply chain disruptions.