Newsletter

President Donald Trump clearly stated the importance of energy to our nation’s prosperity through several executive orders, including Executive Order 14154 (Unleashing American Energy) and Executive Order 14156 (Declaring a National Energy Emergency). Liquid terminals in the United States are exactly the type of infrastructure that will help deliver American energy (and other critical materials) to the marketplace and support the goal articulated in EO 14154 of restoring American prosperity.

The following are a few examples of how ILTA members’ operations can support the vision for energy security and economic growth.

• EO 14154 – “It is the policy of the United States to protect the United States’ economic and national security and military preparedness by ensuring that an abundant supply of reliable energy is readily accessible in every State and territory of the Nation.”

ILTA Perspective: ILTA members operate over 2,000 terminals across all 50 states, providing critical infrastructure for transporting energy, agricultural goods, chemicals, and more. These materials can be raw inputs essential for U.S. manufacturing or finished goods destined for domestic consumption or export. Simply put, you cannot make an abundant supply of reliable energy available in all 50 states without a robust terminal network.

• EO 14156 – “The integrity and expansion of our Nation’s energy infrastructure—from coast to coast—is an immediate and pressing priority for the protection of the United States’ national and economic security.”

ILTA Perspective: ILTA members can help support the integrity and expansion of the nation’s energy infrastructure by providing more capacity to store and distribute liquid commodities in more locations. We look forward to working with the Trump administration to ensure that regulatory requirements imposed on terminals are aligned with the integrity.

• EO 14156 – “The United States’ insufficient energy production, transportation, refining, and generation constitutes an unusual and extraordinary threat to our Nation’s economy, national security, and foreign policy.”

ILTA Perspective: Liquid terminals form an integral part of the “circulatory system” of America’s economy, without which producers and consumers cannot efficiently be connected. The United States needs a resilient terminal industry to ensure there is an unencumbered flow of liquid commodities, including crude oil to refineries, finished gasoline to the market, and petrochemicals to countless American manufacturers. We believe our nation’s terminals play a pivotal role in alleviating threats to the nation’s economy, national security, and foreign policy, consistent with the President’s EO 14156.

Download a copy of the full letter below.

California Air Resource Board:

The International Liquid Terminals Association (ILTA) appreciates the opportunity to provide comments on the California Air Resource Board’s (“CARB”) California Corporate Greenhouse Gas Reporting Program, and writes specifically in response to CARB’s implementation question(1)(d):

Should entities that sell energy, or other goods and services, into California through a separate market, like the energy imbalance market or extended day ahead market, be covered?

We write to strongly discourage CARB from including such entities under the definition of entities that “do[] business in California” as including them raises serious constitutional concerns. Specifically, a definition that included these entities would create significant Due Process concerns, as well as violate the Commerce Clause and notions of federalism by attempting to subject out-of-state entities to this law based on actions that have no or at best only a theoretical nexus to the State of California. CARB must adopt a reasonable definition of “doing business” in California in order to provide a clear and workable definition to regulated entities and to ensure its climate disclosure implementation rules are on sound legal footing.

Attached below is a copy of the full comments.

Dear Assistant Secretary Parker,

On behalf of the Employers Emergency Response Rulemaking Coalition (“Coalition”), I am submitting the following comments on the Occupational Safety and Health Administration’s (“OSHA”) Notice of Proposed Rulemaking (“NPRM”) for a new “Emergency Response Standard,” to replace the existing “Fire Brigades Standard,” 29 C.F.R. § 1910.156, Docket No. OSHA-2007-0073, published in the Federal Register on February 5, 2024.

INTRODUCTION

The Employers Emergency Response Rulemaking Coalition is composed of a broad array of industries impacted by OSHA’s proposed rule. The Coalition is comprised of multiple organizations, including trade associations, representing thousands of facilities located across the United States. Included among its members are companies in petroleum refining, chemical and petrochemical manufacturing, liquid terminal operations, agriculture, aerospace and defense, and other industries. Coalition members are leaders in safety and privately embedded emergency response programs that have a substantial interest in the outcome of OSHA’s rulemaking, as it will have a significant impact on how they manage such programs.

For years, Coalition members have voluntarily implemented effective emergency response programs. In that time, our members learned valuable lessons about the practices and policies that most effectively prevent and mitigate risks to our emergency responders. The comments we share represent the collective wisdom of employers and the employees who respond to emergencies. Our objective is to ensure that OSHA’s Emergency Response Standard effectively protects the safety and health of employees, volunteers, and the surrounding community, utilizing the most reasonable set of requirements possible.

Attached below is a copy of the full comments.

The International Liquid Terminals Association (ILTA), submit these comments responding to the Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA) Reporting Requirements Notice of Proposed Rulemaking (NPRM) published by the Cybersecurity and Infrastructure Security Agency (CISA) in the Federal Register on April 04, 2024. ILTA represents 82 commercial operators of over 600 aboveground liquid storage terminals that handle a wide range of liquid commodities, including crude oil, refined petroleum products, chemicals, fertilizers, animal fats, and vegetable oils. For this reason, CIRCIA’s reporting requirements are of special interest to ILTA.

Download the comments below.

About 18 years ago, Mitchell Garner was searching for a career that had meaning, discipline and a place where strong bonds could be developed. He ended up accepting a position as an industrial firefighter for a company in Corpus Christi, Texas, where he and his colleagues were resident contractors to major oil and gas companies along the Gulf Coast.

“That career opportunity opened me to a world of knowledge about industry operations and industrial safety,” said Garner.

Years later, he transitioned to a terminal company in the Houston area where he spent nine years in their EHS department. Today, as Regional Manager of Safety and Emergency Response for LBC Tank Terminals, Garner truly enjoys the work he does.