ILTA Comments in Support of EPA's Reclassification of Major Sources as Area Sources
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ILTA Comments in Support of EPA's Reclassification of Major Sources as Area Sources

Comments of the International Liquid Terminals Association


Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act

84 FR 36304; Docket # EPA-HQ-OAR-2019-0282

September 24, 2019


The International Liquid Terminals Association (ILTA) is pleased to provide these comments in support of EPA’s action that will allow a major source to reclassify to an area source at any time by limiting its potential to emit (PTE) hazardous air pollutants (HAP) to below the major-source thresholds. As EPA has explained in the notice, the Clean Air Act (CAA) does not require that a source remain a major HAP source once designated as such. This action will potentially incentivize source operators of major HAP facilities to reduce their HAP PTE and thereby allow them to redesignate to an area source and reduce their regulatory burden.


In response to EPA’s question related to Comment C-3, ILTA is confident that allowing facilities to redesignate from major HAP sources to area source will not result in increased actual HAP emissions. As noted by EPA, changes in classification from major to area sources have already been undertaken by facilities based on the January 25, 2018 guidance memorandum withdrawing the previous “once in, always in” guidance. EPA’s analysis showed that these reclassifications will not result in increased emissions. This is a strong indication that similar future redesignations for major to area sources will not result in HAP emissions increases.


In response to EPA’s question regarding Comment C-32, ILTA believes that HAP PTE limits for facilities seeking to redesignate to area sources should not be required to undergo public notice and comment [1].  Designations of major HAP sources involve potential emissions above threshold levels that may be of concern to the public and should be subject to public notice and comment. However, it is not clear why that is necessary for when lower limits are achieved allowing for reclassification to an area source. The source operator’s submission of the basis for its change to EPA or the permitting authority should be sufficient.


Founded in 1974, the International Liquid Terminals Association represents more than 80 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.

ILTA’s membership also includes nearly 400 companies that supply equipment and services to the terminal industry.




Peter Lidiak

Vice President, Regulatory Affairs



[1] Excluding unrelated requirements, such as if the permitting action to lower HAP PTE below the major source threshold includes changes that would trigger public notice under the permitting agency’s requirements.  For example, a major modification to a Title V permit that requires public notice. 

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