Issues & Policy
Advocacy & Leadership
Issues & Policy
As the leading trade association for the bulk liquid terminal industry, ILTA represents its members by actively engaging policymakers in Washington and across the country. ILTA works to foster a regulatory environment that enables terminal companies, the communities they serve, and the broader industry to thrive.
ILTA’s Joint Committee, which brings together industry professionals specializing in the environment, government, health, safety, and security fields, is the association’s active policy and advocacy development body. Within it, ILTA established the Government Affairs Committee (GAC), a dedicated group of individuals in government affairs and corporate leadership roles who help shape and implement strategic advocacy initiatives that align with our policy goals.
For more information about the Joint Committee, the Government Affairs Committee, or ILTA’s advocacy priorities, please contact:
Our Priorities
Key Policy Priorities
Explore the legislative and regulatory issues that shape ILTA’s advocacy efforts and support a safe, efficient, and competitive liquid terminal industry.
Chemical Facility Anti-Terrorism Standards (CFATS)
In 2007, the Department of Homeland Security’s (DHS) Chemical Facility Anti-Terrorism Standards (CFATS) program was created to help prevent terrorist attacks on high-risk chemical facilities. CFATS requires covered chemical facilities to prepare Security Vulnerability Assessments and implement Site Security Plans that must satisfy the risk-based performance standards outlined in the rule. As a result, ILTA submitted a Petition for Declaratory Order to DHS in 2009, requesting that gasoline be declared exempt from CFATS. In July 2016, DHS issued clarifying guidance, but not a final regulation, which indefinitely suspended the due date for gasoline terminals to report chemicals of interest in gasoline mixtures.
As of July 2023, Congress allowed funding and authorization of the CFATS program to lapse, leaving a regulatory gap in terminal facility oversight. It remains uncertain if or when Congress will move to reauthorize CFATS, but ILTA continues to advocate for the program’s importance with DHS and on Capitol Hill.
Coast Guard Regulations
MTSA 2027 Implementation Deadline
In response to the upcoming 2027 implementation deadline for the Maritime Transportation Security Act (MTSA), ILTA established an MTSA Working Group. The group’s objective is to ensure the industry is well-informed about the rule and to develop a “best practices” guide to support effective and consistent compliance. Click here for more information on the MTSA Working Group. Similarly, on June 2, 2026, the U.S. Coast Guard’s (USCG’s) Office of Cybersecurity Policy (CG-MCP) issued Policy Letter 01-26: Cybersecurity Assessment Initial Scoping and Process. The Policy Letter provides guidance that regulated entities may use to identify Information Technology (IT) and Operational Technology (OT) that is “in scope” for the purposes of compliance under the MTSA Cybersecurity Regulation (33 CFR Part 101 – Subpart F). This process is centered on the use of a Cybersecurity Assessment (CSA). The Policy Letter was issued as part of the USCG’s broader effort to support implementation of the MTSA Cybersecurity Regulation, which requires MTSA-regulated facilities to develop and submit Cybersecurity Plans and conduct CSAs no later than July 16, 2027. ILTA’s concern is that the Policy Letter goes beyond what the regulation requires in 33 CFR Part 101 – Subpart F. For example, the regulation requires the CSA to “analyze all networks to identify vulnerabilities to critical IT and OT systems and the risk posed by each digital asset.” That language suggests that the CSA should be focused on identifying and assessing risks to critical IT and OT systems (i.e., those systems that, if compromised or exploited, could result in a Transportation Security Incident). ILTA is working with a coalition of association partners to engage Coast Guard leadership on more practical guidance.Transportation Worker Identification Credential (TWIC) Reader Rule
In May 2022, the United States Coast Guard (USCG) attended the ILTA Conference & Trade Show and announced that USCG was likely to issue a regulation delaying the implementation of the final TWIC Reader Rule. In December 2022, ILTA advocated for legislation formally delaying the Reader Rule date from 2023 to 2026, effectively delivering a 3-year extension to the Final Reader Rule. Also in December 2022, USCG issued a Notice of Proposed Rulemaking requesting comments on a possible extension of the Final Reader Rule for at least 3 years to as many as 6 years. ILTA provided comments supporting a meaningful extension, if a more secure and cost-effective program could be developed as a result of the delay. In October 2024, USCG issued a rule delaying the implementation date of the Final Reader Rule to May 8, 2029.
Security
Cybersecurity
Federal policy is increasingly focused on preserving the cybersecurity of critical infrastructure. Several government agencies, including the Department of Energy (DOE), the Department of Homeland Security (DHS), the U.S. Coast Guard, the Cybersecurity & Infrastructure Security Agency (CISA), and the Transportation Security Administration (TSA) have jurisdiction in this area. Along with other agencies responsible for cybersecurity, the agencies coordinate activities under a cybersecurity framework published by the National Institutes of Standards and Technology.
ILTA advocacy seeks to build upon other federal government efforts to engage private sector stakeholders to improve coordination between various Federal agencies engaged in cybersecurity policy and educate policymakers on the needs and circumstances of the terminal industry.
Of note, ILTA submitted a comment package on CISA’s Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA) reporting rulemaking in July 2024.
Terminal Facility Protections from Unauthorized Drone Usage
Drones are a valuable tool that can be used to perform important tasks to support the entire energy supply chain, such as conducting equipment inspections, security surveillance, and providing emergency response. Like any other tool, though, the misuse of drones can pose significant and unique risks to critical infrastructure such as bulk liquid terminal facilities.
Bulk liquid terminals house all manner of liquid products, including oil, gasoline, chemicals, biofuels like ethanol, sustainable aviation fuel, asphalt, and beyond. As such, most of these materials housed on site are classified as Chemicals of Interest (COI), recognized by DHS CISA as liquid materials of national security concern which can pose public health and safety concerns if not handled properly.
Outside actors, using drones to survey such facilities, can gain overt and unnecessary access and surveillance to terminal operations and the materials being stored. In the wrong hands, drones can easily be used to damage a terminal site, causing spills or fires, harming both employees and the local communities where they work.
In 2016, Congress passed legislation requiring the Federal Aviation Administration (FAA) to create “flight restricted zones” around critical infrastructure, offering some protection to bulk liquid terminals. On May 6, 2026, FAA published a Notice of Proposed Rulemaking (NRPM) titled, “Designation-Restrict the Operation of Unmanned Aircraft in Close Proximity to a Fixed Site Facility,” which would outline the process for obtaining an unmanned aircraft flight restriction (UAFR) for certain fixed-site critical infrastructure facilities.
ILTA has remained involved on both the legislative and regulatory front in ensuring terminals are defined as critical infrastructure and protected from unauthorized drone usage. ILTA continues to engage FAA in ensuring rulemaking protects bulk liquid terminals from unauthorized drone usage, while also working with Congress to introduce legislation defining bulk liquid terminals as critical infrastructure and protecting them from unauthorized drones.
EPA Air Emissions Regulations
PFAS
Recent information indicates that per- and polyfluoroalkyl substances, also known as PFAS, are detrimental to the environment and human health. U.S. EPA and many states have begun regulating PFAS, especially relating to discharges as an environmental contaminant.
PFAS is a key ingredient in liquid terminal firefighting foams, specifically, aqueous film forming foams (AFFF). ILTA member facilities, long required by a collection of state and local fire codes and industry best practices, used PFAS-based AFFF.
In Congress, policymakers are developing policies aimed at regulating and removing PFAS from the environment. Policymakers are also debating which parties should be held liable for PFAS usage, following EPA’s April 2024 rulemaking to designate two PFAS substances, PFOA and PFOS, as a hazardous substance under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA or “Superfund”). This rulemaking means property owners and purchasers might be responsible for clean-up and remediation costs, including possibly for past property ownership and past pollution.
Given the patchwork of state laws and timelines to address PFAS, ILTA is working to secure federal liability protection for terminal companies that have historically relied on PFAS-based foams to comply with safety standards.
ILTA supported S.1432, “The Fire Suppression PFAS Liability Protection Act,” which was introduced by Senator Cynthia Lummis in the 118th Congress. In the 119th Congress, we continue to advocate for a bipartisan introduction of legislation like S. 1432 that would protect the bulk terminal industry during the transition away from AFFF.
In addition, ILTA continues to meet with EPA officials regarding clearer CERCLA enforcement guidelines for our members.
Permitting Reform
Historically, Senator Joe Manchin III, Former Chairman of the Senate Energy & Natural Resources Committee, led an effort to implement significant federal permitting reform in several key areas of interest to ILTA members. Some of the key aspects of the proposed reforms are: (1) Reforming the National Environmental Policy Act (NEPA) compliance and challenges, differentiating between large significant projects and lesser regionally significant projects; (2) limiting litigation for select significant projects; (3) creating a national list of differing types of energy infrastructure projects; and (4) adjusting the Federal Energy Regulatory Commission (FERC), amongst other objectives.
Permitting processes are often subject to lengthy delays because of the sometimes overlapping and opaque authority of multiple government regulators. This reform effort would lead to potential impact for ILTA members as they undertake new projects to expand or increase capacity or replace infrastructure. Agencies that would be impacted are the Department of Interior, EPA, FERC, and U.S. Army Corps of Engineers.
ILTA is currently tracking numerous bills related to permitting reform in the 119th Congress and are looking forward to the continued discussion around creating a common-sense permitting environment.
Occupational Safety & Health Administration (OSHA) Regulations
OSHA has longstanding engagement with the terminal industry through OSHA’s Process Safety Management (PSM) rule and EPA’s Risk Management Program (RMP), both of which impose process safety requirements to protect workers and prevent releases at facilities that store threshold amounts of certain hazardous chemicals.
The status of OSHA’s “atmospheric tank” exception via possible PSM regulatory changes remains critical to ILTA members. ILTA continues to be engaged in workplace safety, PSM, and other regulations while advocating on behalf of terminal members. ILTA continues to work with EPA and OSHA to pursue reasonable and cost-effective measures that are proven in protecting workers and the environment.
OSHA’s heat exposure and worker protection programs are critical to the operations of the terminal industry. Worker protections were a focus for OSHA and the Biden Administration. In July 2023, the Biden Administration announced action to be taken by OSHA to address climate-change-impacted worker protection regulations. The specific action is focused on reducing heat-related deaths and injuries for workers. ILTA submitted comments on the final rule in January 2025.
In the second Trump administration, ILTA worked with members to develop testimony during OSHA’s informal rulemaking hearing, advocating against overburdensome requirements for Heat Illness and Injury plans. ILTA showcased that many companies already implement these types of plans which are tailored to the needs of the respective sites. You can view the full testimony here.
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