Comment submitted by Institute for Policy Integrity at New York University School of Law

Summary: 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.