Comment submitted by Interstate Power Systems

Dear Ms. Kee: Subject: Comments on Docket ID No. EPA-HQ-OAR-2026-2905, Proposed Rule: Phasedown of Hydrofluorocarbons: Excluding Road and Intermodal Container Transport Refrigeration Units from the Hydrofluorocarbon Leak Repair Requirements As an authorized dealer of Carrier Transicold, Interstate Power Systems supports the EPA’s proposed rule, Phasedown of Hydrofluorocarbons: Excluding Road and Intermodal Container Transport Refrigeration Units from the Hydrofluorocarbon Leak Repair Requirements (“Proposed Rule”). This exemption would help provide clarity to the transport refrigeration industry and eliminate confusion caused by the 15 pound threshold. Please see our comments below in support of excluding road and intermodal TRUs from this requirement. •The proposed rule steers customers towards purchasing smaller, less efficient TRUs to stay below the reporting threshold. •This would result in the smaller units being cycled on and running more frequently than the larger, more efficient units to maintain the required temperatures to keep America’s food and medical supplies safe. •The additional runtime due to decreased efficiency would increase fuel use (by 5–10%), and result in higher CO2 emissions (potentially over 950 million additional pounds of CO2 annually if all affected TRUs are modified). •The additional run time and load on the smaller units would lead to more wear and tear for our customers causing more frequent breakdowns. •More frequent breakdowns would lead to downtime, much greater expense, and more refrigerant loss for our customers that are already having a hard time keeping their businesses running in this economic environment. •This would also further intensify the labor shortage our industry is facing as drivers will not remain in the transport refrigeration industry with increased repair downtime and less income. •All of these potential issues risk increasing the amount of spoiled perishable goods. This would lead to more waste of food, medical supplies, chemicals, and other temperature sensitive goods the American people require. In summary, we urge the EPA to approve the TRU exemption to provide regulatory certainty for American business and to protect American consumers from the associated risks and cost created by this addition to the AIM act. Thank you for the opportunity to provide our supporting comments.