Phasedown of Hydrofluorocarbons: Excluding Road and Intermodal Container Transport Refrigeration Units from the Hydrofluorocarbon Leak Repair Requirements

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.

Ryder System, Inc. supports the proposed rule to exempt road and intermodal container transport refrigeration units from hydrofluorocarbon leak repair requirements. The company argues that the requirements would impose unnecessary compliance burdens and costs without improving safety or environmental outcomes, given the industry's existing incentives to maintain equipment.

The Joint Retail Associations, representing various food retail and grocery organizations, strongly support the EPA's proposed exemption of road and intermodal container transport refrigeration units from leak repair requirements. They argue that the exemption is necessary to prevent significant compliance costs, supply chain disruptions, and increased food prices for consumers.

The Institute for Policy Integrity at New York University School of Law opposes the proposed rule, arguing that the EPA violates the AIM Act and acts arbitrarily and capriciously by failing to consider or monetize the climate costs of exempting road and intermodal container transport refrigeration units from leak-repair requirements. They also request that the EPA disclose its use of artificial intelligence tools in the rulemaking process.

The U.S. Chamber of Commerce supports the EPA's proposal to exempt road and intermodal container transport refrigeration units from certain hydrofluorocarbon leak repair requirements. They argue that the exemption provides necessary clarity, supports supply-chain reliability, and ensures the AIM Act's phasedown remains practical and technically sound.

The Natural Resources Defense Council (NRDC) opposes the proposed rule to exempt road and intermodal container transport refrigeration units from hydrofluorocarbon leak repair requirements. They argue the exemption is unnecessary based on industry practices, that the EPA's cost-saving estimates are exaggerated, and that the agency should reject further requests to broaden the exemption.

The International Fresh Produce Association (IFPA) supports the proposed rule to exempt road and intermodal container transport refrigeration units from hydrofluorocarbon leak repair requirements. They argue that additional regulations would threaten food supply chain availability, increase costs for consumers, and create logistical challenges for transporting perishable goods.

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.

Carrier Global Corporation supports the EPA's proposed rule to exempt road and intermodal container transport refrigeration units (TRUs) from hydrofluorocarbon leak repair requirements. The company argues that the current regulation was an inadvertent oversight that imposes significant, uncalculated costs on the industry and consumers without providing meaningful environmental benefits.

Interstate Power Systems, an authorized dealer of Carrier Transicold, supports the proposed rule to exempt road and intermodal transport refrigeration units from hydrofluorocarbon leak repair requirements. They argue that the current requirements would lead to less efficient equipment, increased fuel consumption, higher CO2 emissions, and greater operational costs and risks for the transport refrigeration industry.