| Comment | Historically, various provisions of the PERP regulation
distinguished between owner-operated engines and those that are
part of a rental fleet. The distinction is important because of
the complexities of rental transactions and the relationship
between the rental engine owner and the operator. The
recently-proposed revisions to the PERP regulation continue to
distinguish between rented engines and owner-operated engines, but
in some cases may not adequately reflect the intricacies of rental
transactions. The attached comments identify those areas where
additional rule language will promote a more effective and
equitable PERP.
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