What is in Store for State Underground Storage Tank Programs?

Posted on Thursday, July 17th, 2025 | Mark Barolo

The Future of State Tanks Programs in a Changing Landscape

What does the future hold? While no one can be certain, it is important to prepare for the possibilities. States are doing just that, and for various reasons, states are growing increasingly concerned about the future viability of their tanks programs. In recent years, state tanks programs have experienced declining revenues and staffing shortages and are feeling the crunch of having to do more with less. In addition, current and possible future changes in the petroleum storage industry, in the transportation sector, and in U.S. consumer habits feels like a journey into uncharted territory.

To express their concerns about the future, the states, through the Association of State and Territorial Solid Waste Management Officials (ASTSWMO), issued a position paper on the long term sustainability of state UST and LUST programs. In the paper, ASTSWMO outlined the complex mixture of issues and trends affecting the future of tanks programs. States called upon EPA to conduct a more detailed analysis of the concerning trends.

EPA’s Report and Forecasting Tool

In December 2024, the EPA’s OUST published “UST and LUST Program Challenges in a Changing Transportation Sector.” In the report, we describe the issues that state programs face in keeping their UST and LUST programs afloat for the long term. We also include a discussion of topics and alternatives that states should keep in mind as they engage in long term planning. The various issues currently affecting or likely to affect state programs in the future are many and complex. The issues intersect and interact with each other and may occur at different times and at varying intensities from state to state. They include:

• Aging tank infrastructure. Older tanks may be replaced at a higher rate and may lead to closure of facilities and consolidation of fuel storage infrastructure. A reduction in the number of operating UST systems will impact UST and LUST programs that receive funding from per tank fees.
• Owners of older tanks may have fewer options for insurance and may have to close or abandon tanks if they are unable to obtain insurance to demonstrate financial responsibility. This could mean more cleanups, and possibly more abandoned tanks, for state programs to handle.
• Older USTs may mean increased releases from tanks. States may experience higher expenditures for cleanup activities.
• Internal-combustion engines entering the market today use significantly less fuel than those in older vehicles aging out of use. Increasing fuel efficiency will have a significant impact on fuel demand.
• Alternative vehicle technologies require even less liquid fuel than the newest internal-combustion engine vehicles. Declining fuel sales will impact UST and LUST programs that receive funding through taxes or fees from fuel sales. These trends could lead to a decrease in revenues for state programs.

Each state faces a unique situation in terms of their UST infrastructure, existing and future transportation sector program budgets and priorities, and regulatory and legislative frameworks. The timing and magnitude of issues will vary from state to state. Environmental agencies need to plan ahead so that financial constraints do not curtail their ability to support UST release prevention and cleanup activities.

As states grapple with an uncertain future for their programs, there are many different factors they need to consider. Our report provides a menu of both general and specific ideas that states might consider using as they begin to plan and develop solutions. A few of the considerations that states should keep in mind are listed below.

• What is your state’s transportation environment and how might it impact your regulated community and UST and LUST programs?
• What incentives or requirements could you provide for upgrades or removals of aging UST systems?
• What funding mechanisms do you have available to address cleanups at abandoned sites?

State tanks program staff may have to describe and defend their budget and related concerns to stakeholders outside their immediate program. We hope our report helps state staff to articulate both their concerns and proposed solutions.

Accompanying our report is the “UST Futures Forecasting Tool” and “Users’ Guide.” The primary goal of the forecasting tool is to help states identify potential mismatches between state UST cleanup fund revenues and corrective action costs under a range of future energy use scenarios. We hope that the UST Futures Forecast Tool will help states anticipate challenges and test potential solutions by helping them estimate UST corrective action fund revenues and costs under a variety of declining fuel use scenarios.

States can populate the tool with data to examine the effects of various declining fuel use scenarios on facility closures, cleanups, and state fund solvency. States can model various future scenarios in order to estimate:

• The number of new release discoveries.
• State fund and program funding.
• The potential number of abandoned sites needing fuel cleanups.

The tool allows states to project the impact of different combinations of potential solutions. Where firm values are not available, the tool can be run under a range of assumptions to examine the range of likely outcomes. It is difficult to predict the pace of changes and the impact such changes will have on specific state UST and LUST programs. States should plan to reevaluate their situation and forecasts on a regular basis as the transportation and energy sectors continue to evolve.

The tanks program has made great strides at the national level over the past few decades. In order to continue our collective success, we must have healthy and sustainable tanks programs at the state level. As trends change and other issues emerge, EPA will continue to communicate and to work with states, industry, and other partners on solutions. I encourage you to read the report and to try out the forecasting tool. OUST’s technical team is available to discuss the document and the tool. Please reach out to Ryan Haerer (Haerer.ryan@epa.gov) and Tom Schruben (Schruben.thomas@epa.gov) if you have any feedback or questions.