Government Affairs Brief

The International Liquid Terminals Association (ILTA) submits these comments responding to the Notice of Proposed Rulemaking (NPRM) published by the Federal Aviation Administration (FAA) in the Federal Register on May 06, 2026. 

The American Petroleum Institute (API), the Liquid Energy Pipelines Association (LEPA),2the American Fuel & Petrochemical Manufacturers (AFPM), the International Liquid Terminal Association (ILTA), and the National Association of Manufacturers (NAM) (collectively, the “Associations”) respectfully submit the following comments in response to the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) “Pipeline Safety: Breakout Tank Inspection” Notice of Proposed Rulemaking (NPRM) (Docket No. PHMSA-2025-1271). The Associations welcome the opportunity to comment in this proceeding and commend PHMSA for recognizing the need to modernize pipeline safety regulations.

The American Petroleum Institute (API), the American Fuel & Petrochemical Manufacturers (AFPM), and the International Liquid Terminals Association (ILTA) (collectively, “the  Associations”) respectfully submit these comments in response to EPA’s Advance Notice of  Proposed Rulemaking seeking to reconsider key provisions of the 2024 CWA Hazardous  Substances Facility Response Plan (FRP) rule (40 CFR Part 118). The Associations represent  facilities across the petroleum, petrochemical, and liquid bulk terminal sectors that collectively  handle the majority of CWA hazardous substances subject to the rule.

The International Liquid Terminals Association (ILTA) appreciates the opportunity to provide comments on the proposed amendments to the National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Marine Tank Vessel Loading Operations (MTVLO) (91 FR 10559, March 4, 2026).

Founded in 1974, the International Liquid Terminals Association represents over 60 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. 

The International Liquid Terminals Association (ILTA), submit these comments responding to the Advance Notice of Proposed Rulemaking (ANPRM) published by the Pipeline and Hazardous Materials Safety Administration (PHMSA) in the Federal Register on December 04, 2025. ILTA represents more than 60 commercial operators of over 600 aboveground liquid storage terminals that handle a wide range of liquid commodities, including crude oil, refined petroleum products, chemicals, fertilizers, animal fats, and vegetable oils. Many of these terminals operate under PHMSA’s Hazardous Materials Regulations (HMR). For this reason, PHMSA’s potential revisions to the HMR regarding highly automated transportation systems are of special interest to ILTA.

ILTA is concerned with this ANPRM’s provisions on shipping papers, hazard communications, packaging, and security plans & in-depth training, with an emphasis on the negative impact this ruling could have on smaller terminal operators.