Government Affairs Brief

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.

From refinery operations to leading HSSE at JET Infrastructure, Todd’s career reflects growth, adaptability, and impact. Drawing on experience across refining and midstream, he focuses on strengthening safety, supporting people, and improving operations at every level.

His advice is simple: listen first, take on new challenges, and don’t be afraid to step outside your role. As the industry evolves, he stays focused on doing the work well and supporting his team.

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. 

From military service and emergency response to terminal operations, Jason Alvarez brings a steady, systems-driven approach to safety and performance at Howard Energy Partners. Focused on strong systems, leadership, and continuous improvement, he emphasizes the role of trust and accountability in building high-performing teams, offering a forward-looking view of an industry evolving through technology and collaboration.

New to the terminal industry, Jonathan Hawkins joined Pin Oak in October 2024 as an Environmental Specialist, supporting terminal operations by maintaining compliance with air, water, and waste programs while contributing to safety initiatives. Since his company joined ILTA, he has attended events and contributed to Committees, finding value in connecting with and learning from other members. When he’s not working, you’ll likely find him golfing, hunting, or fishing.