Frequent Questions

If a parent company has wholly owned pipeline and terminal subsidiaries, can the facilities be aggregated and reported by the parent if the facilities meet the contiguous facilities requirement? Can a parent report all facilities for its wholly owned subs

Each registered entity reports to EPA. If the parent company is the registered entity for each of its facilities, then the parent company will report. If each subsidiary facility is its own registered entity, then each of those entities must report.

If the facilities are contiguous and custody is maintained by one entity (the parent owner in this case), they may be aggregated. In that case the owner must register as an entity, and the aggregated facility must also be registered (§ 80.597(c) and (d)).

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