Editorial comment
Six months into the 119th Congress, the political landscape under the second Trump Administration has taken shape. President Donald Trump has repeatedly expressed his commitment to bolstering the nation’s liquid fuel industry in his tenure.
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The International Liquid Terminals Association (ILTA), the only trade association advocating solely for the bulk liquid terminals industry in Washington D.C., has been hard at work moving several key issues for the sector in this new administration. Below is an overview of the two most pressing matters that can and should be addressed by Congress and the White House in the next two years: EPA’s 2024 final gasoline distribution rule and PFAS firefighting foam liability protection for terminals.
EPA gasoline distribution rule
In May 2024, the Environmental Protection Agency (EPA) finalised amendments to its rule titled ‘National Emissions Standards for Hazardous Air Pollutants for Gasoline Distribution Facilities and New Source Performance Standards for Bulk Gasoline Terminals.’ In its finalised amendments, EPA revised the requirements for storage vessels, loading operations, and equipment to reflect cost-effective developments in practices, processes, or controls, as well as to reflect the best system of emission reduction for loading operations and equipment leaks.
ILTA has long been engaged on this issue, meeting with EPA since the proposed rule was published in 2023 to steer it in a productive direction. New EPA Administrator Lee Zeldin has sided with industry, and ILTA continues to work with its experts on revisions.
PFAS firefighting foam liability protection Per- and polyfluoroalkyl substances, also known as PFAS, are key ingredients in liquid terminal firefighting foams, specifically aqueous film-forming foams (AFFF). ILTA member facilities, long required by Occupational Safety and Health Administration (OSHA) standards, must store and use AFFF to address any potential fire event that could jeopardise the health and safety of workers, the surrounding community, and the environment. Moreover, terminals are designed with extensive fire suppression systems specifically designed for AFFF and often test these systems to ensure emergency preparedness.
The CERCLA designation of PFOA and PFOS places the risk of legal and financial liability on ‘passive receivers’ of PFAS, such as bulk liquid terminals, who were acting in accordance with legally required safety standards. Terminals, as good actors and passive receivers for foams, should not be held liable for PFAS remediation under a potential Superfund designation. ILTA is working with several congressional offices to introduce a bill that would provide such liability protection for entities that have had to rely on AFFF for their safety operations for decades.
Moving forward
Again, this is only a small overview of ILTA’s advocacy efforts. ILTA continues to be engaged with its membership to better understand how it can represent the critical terminals industry in Washington D.C.
