ILTA Comments on EPA Proposed Rule - National Emission Standards for Marine Tank Vessel Loading Operations

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. 

This rulemaking responds to Clean Air Act requirements for review of existing technology-based air emissions standards at least every eight years, and for updates to those standards if warranted by advances in technology, industry practices, or the cost effectiveness of controls. The proposed rule results from EPA’s assessment of 40 C.F.R. 63 Subpart Y, or Subpart Y, containing technology-based standards that apply tomarine tank vessel loading operations (MTVLO). Subpart Y contains maximum achievable control technology (MACT) standards that apply to certain MTVLO at major sources of Hazardous Air Pollutants (HAP), and reasonably available control technology (RACT) standards that apply to MTVLO that meet throughput thresholds for loading gasoline or crude oil.

Many of our comments, though not all, address EPA’s requests for comment in the rule proposal Preamble. The headers of these comments are marked, “C-1,” “C-2,” and so forth, following EPA’s requested convention in the Preamble.

Attached below is a copy of the full comments.