ILTA Testifies on Gasoline Distribution Rule
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Kathryn Clay
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ILTA Testifies on Gasoline Distribution Rule

EPA published its proposed amendments to regulations of gasoline distribution emissions on June 10 and provided a 90-day comment period. ILTA submitted a request for an extension which the agency has denied.

ILTA has formed five working groups to develop comments focused on different aspects of the proposed rule. The groups are Leak Detection, Tanks, VCUs, VRUs, and Loading Equipment. In addition to our extensive technical comments, ILTA has engaged the firm Nossaman to compose a cover letter describing the legal support for our key positions.

EPA held a virtual public hearing on June 27. ILTA was only industry representative to provide testimony. Other participants included the Heritage Foundation and several environmental groups. In its testimony, ILTA noted that its member companies are dedicated to providing safe, sustainable, efficient, and reliable storage and logistics services for bulk liquids. As outlined in our Environmental, Social, and Governance principles (adopted in July 2021), our member companies strive to maintain air quality for the communities in which we operate. In addition to meeting the current standards for air emissions, we have pledged as an industry to continue to review new technologies and procedures for further emissions monitoring and reductions.

 Our testimony noted that ILTA pleased to have the opportunity to share information with EPA during its work to develop the proposed amendments. This included information related to emissions control equipment and practices and associated costs. We also hosted a virtual tour for EPA officials of a terminal site. In addition, we helped facilitate discussions between EPA officials and manufactures of a key category of emissions controls -- vapor combustion units.

EPA’s proposal would lower the emission limits for loading racks at large bulk gasoline terminals from 80 to 35 milligrams of total organic carbon per liter of gasoline loaded. This provision alone will account for a major share of the reductions in hazardous air pollutant emissions that the proposed rule would achieve. While this change to NESHAP Subpart 6B will impose costs to industry – estimated by EPA to be $9,700 per ton of HAP emissions reduced – ILTA believes that it achieves the right balance between cost and environmental protection.

ILTA testified that most terminals will be able to accommodate the costs of the new standard without passing along significant costs to their customers. The lower standard considered, 10 milligrams per liter, would result in substantial cost increases that terminals would be forced to pass along the distribution chain, resulting in significantly higher gas prices. The regressive nature of gasoline prices would have made the lower standard considered particularly hard-hitting for low-income communities.

ILTA agreed that it is appropriate to maintain the current requirements for small terminals for submerged loading rather than adopting new requirements. Similarly., ILTA agrees with EPA’s assessment that it is not cost-effective to lower the standard below 10 milligrams per liter for loading operations under NESHAP subpart R. ILTA also supported EPA’s overall assessment that “the proposed changes to control requirements for affected gasoline distribution facilities will improve human health exposures for most populations, including for surrounding communities with environmental justice concerns.” 

ILTA stressed that it is working to develop technical comments to detail a number of concerns and to suggest some improvements. This is a complicated rulemaking involving amendments to several Clean Air Act provisions. We have already identified portions of the proposed rule which could subject terminal facilities to overlapping, conflicting, or inconsistent requirements. Others could impose significant costs without yielding discernable environmental benefits. Still others could create safety concerns. In some areas, the proposed amendments would require unnecessary or ineffective monitoring or testing processes.

For more information about how your company can participate in the comment development process, please contact Rob Ferry at rob.ferry@tgbpartnership.com.

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