Comment submitted by American Trucking Associations (ATA)

Summary: The American Trucking Associations (ATA) supports the EPA's proposed rule to exempt road and intermodal container transport refrigeration units from hydrofluorocarbon leak repair requirements. They argue that these units operate in unique mobile environments where existing maintenance practices already address leaks, and that the proposed exemption aligns with the EPA's original regulatory intent while avoiding significant operational and economic burdens on the trucking industry.