ILTA Expresses Support for Finalization of EPA's Proposal to Retain Primary, Secondary 2015 Ozone NAAQS
International Liquid Terminals Association
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Letters, Comments & Testimony

Cathy Landry

ILTA Expresses Support for Finalization of EPA's Proposal to Retain Primary, Secondary 2015 Ozone NAAQS


Comments of the International Liquid Terminals Association
on 85 Fed. Reg. 49830
Docket No. EPA-HQ-OAR-2018-0279
Proposed Rule: Review of the Ozone National Ambient Air Quality Standards, 8/14/2020

October 1, 2020

Founded in 1974, the International Liquid Terminals Association represents 80 companies operating liquid terminals in all 50 states and in over 40 countries. Our members’ facilities provide critical links between all modes of transportation for liquid commodities, such as crude oil, petroleum products, chemicals, renewable fuels, fertilizer, vegetable oils and other food-grade materials that are central to the U.S. economy. Terminals provide essential logistics services that spur trade both within the United States and connect the U.S. economy with overseas markets. ILTA’s membership also includes about 400 companies that supply equipment and services to the terminal industry.

ILTA is pleased to support the U.S. Environmental Protection Agency’s proposal to retain the 2015 ozone National Ambient Air Quality Standards. In 2015, Administrator McCarthy concluded that the then-current primary ozone standard (with its level of 75 ppb) was not requisite to protect public health with an adequate margin of safety, and that it should be revised to provide increased public health protection. The secondary standard was similarly found not requisite to protect welfare. EPA went on to promulgate primary and secondary standards of 70 ppb, the same standards that EPA now proposes to retain.

Administrator Pruitt ordered the agency to conduct and complete the mandatory reassessment of the ozone NAAQS within the statutorily mandated five-year review period. EPA has collected and evaluated 1,600 “newly available” studies, including about 1,000 health studies. After reviewing this new information, the existing basis of knowledge, and in consultation with EPA’s Clean Air Scientific Advisory Committee, Administrator Wheeler has appropriately determined that the 2015 standards remain protective of public health and welfare.

All but one CASAC member agreed with the recommendation to retain the 2015 primary standard and the entire committee agreed with the recommendation to retain the secondary standard. This strong alignment with the agency’s science advisors further bolsters the Administrator’s finding and the case for retention of the current standards.

While public health and welfare are the only measures by which the agency may judge the adequacy of NAAQS, there is an economic benefit to the retention of the previous standards. When new, more stringent standards are found to be necessary, it usually triggers a round of new designations andredesignations of nonattainment areas that result in regulatory limits on the creation of new businesses and operation or expansion of existing businesses in those areas. By finalizing this proposal, EPA would give certainty to U.S. businesses regarding the adequacy of existing controls designed to meet the current standards to protect public health and welfare.

For the reasons stated above, ILTA supports finalization of the proposal to retain both the primary and secondary 2015 ozone NAAQS.


s/Kathryn Clay/


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