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.

On behalf of the American Fuel & Petrochemical Manufacturers (“AFPM”), American Petroleum Institute (“API”), American Chemistry Council (“ACC”), and International Liquid Terminals Association (“ILTA”), we are pleased to submit these comments on OSHA’s proposal to modify the fall protection requirements in the Walking-Working Surfaces standard that apply to fixed ladders that extend more than 24 feet above a lower level. 91 Fed. Reg. 17,165 (Apr. 6, 2026) (“the NPRM”).

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.

Pursuant to the Louisiana Code of Civil Procedure, the International Liquid Terminals Association ("ILTA") and the Liquid Energy Pipeline Association ("LEPA"), appearing as Amici Curiae, respectfully submit the Amicus Brief in Support of Rosefield Fourchon Operating, LLC's Appeal.