Government Affairs Brief

ILTA, as part of the CFATS Coalition, sent identical leaders to the chairman and ranking members of the House Energy and Commerce Committee, House Homeland Security Committee and Senate Homeland Security and Government Affairs Committee. Both letters are attached.

ILTA worked with an industry coalition to provide comments to Chemical Safety Board on its recent reporting rule. The CSB Reporting Industry Coalition asked that CSB consider an alternative approach to what they proposed that was included in the agency’s 2009 Advance Notice of Proposed Rulemaking. That would allow CSB to continue to review media and NRC reports to identify accidents they want to investigate and then request the facility operators to report in greater detail on the incidents of interest. This would avoid CSB collecting nearly 2,000 reports annually and rather look in depth at a much smaller number of incidents each year.

PFAS are a large and diverse group of chemicals with unique properties that have been used in a broad number of beneficial applications for years. Heightened attention to potential health effects of certain PFAS has led to an increased public concern and interest in new regulatory protections in this area.

We understand these concerns and are committed to working with legislators, regulators, and all stakeholders to establish risk-based standards that protect human health and the environment. We also support the development of a consistent approach and clear timelines for assessing and regulating specific PFAS across all relevant federal agencies to ensure that government regulations, actions, and communications are coordinated for maximum effectiveness.

The International Liquid Terminals Association (ILTA) appreciates the opportunity to provide comments on the Surface Transportation Board’s (STB’s) proposal to modify its regulations regarding demurrage billing requirements. The International Liquid Terminals Association (ILTA) represents more than 85 companies operating liquid terminals in all 50 U.S. states and in 37 countries. Our members’ facilities form a critical link in the transportation of a wide range of liquid commodities, including crude oil, refined products, chemicals, renewable fuels, fertilizers, vegetable oils and other food grade materials.

RE: Comments on Proposed National Emission Standards for Hazardous Air Pollutants:
Organic Liquids Distribution (Non-Gasoline) Residual Risk and Technology Review
Docket ID No. EPA-HQ-OAR-2018-0074, 84 Fed. Reg. 56288 (October 21, 2019).

The American Chemistry Council (“ACC”) and the International Liquid Terminals Association (ILTA)
respectfully submit these comments on the U.S. Environmental Protection Agency’s (“EPA”) proposed
National Emission Standards for Hazardous Air Pollutants (NESHAP): Organic Liquids Distribution
(OLD) (Non-Gasoline) Residual Risk and Technology Review (84 Fed. Reg. 56288, October 21, 2019)
(“proposed standards”).