Comment Log Display

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.