Government Affairs Brief

ILTA and its member companies are dedicated to providing safe, sustainable, efficient, and reliable storage and logistics services for bulk liquids. In July 2021, our Board of Directors adopted our organization’s first Environmental, Social, and Governance (ESG) principles. One of these principles affirms our industry’s commitment to continually reviewing new technologies and procedures that might improve emissions monitoring and yield emissions reductions. 

ILTA has put this pledge into action by engaging with the U.S. Environmental Protection Agency (EPA) on a technology review of gasoline distribution equipment and facilities, focused on emissions on hazardous air pollutants. Since EPA initiated this technology review and rulemaking in Spring 2021, ILTA and its members have been in dialogue with EPA officials, providing detailed information about the proper operations of gasoline storage tanks and loading facilities.  

In September, ILTA weighed-in with the White House to express ILTA’s members’ concerns about a nationwide freight rail strike. Given the ILTA membership’s reliance on freight rail to move customers’ products and to ensure deliveries, the pending nationwide strike by rail workers.

In May 2022, the Transportation Security Administration (TSA) issued a Security Directive for Pipelines, generally referred to as SD02B. The goal of the May 2022 security directive was to prescribe efforts that owners and operators of hazardous liquid and natural gas pipelines or liquified natural gas (LNG) facilities needed to implement to improve cybersecurity awareness, reporting, and preparedness.

On September 6, 2022, EPA published its long-awaited proposed designation of perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). The hazardous substance designation triggers a reporting requirement to immediately report releases of PFOA and PFOS that meet or exceed the reportable quantity of 1 pound or more in a 24-hour period. The proposed rule is likely to impact a wide range of entities including manufacturers (including importers and importers of articles), processors, other downstream product manufacturers and users, and waste management and wastewater treatment facilities. 

CISA, Can You Hear Me?

This is not a new take on the popular children’s move song, but rather the position that the U.S. Department of Homeland Security’s Cybersecurity and Infrastructure Security Agency (CISA) is taking with the public regarding cybersecurity regulations. CISA is hosting a series of public listening sessions to gather public input on implementing regulations requiring covered entities to report covered cyber incidents and ransomware payments to CISA. The public listening sessions are being held in the following locations and at the following places https://www.cisa.gov/circia