Mr. Fuchs has a deep understanding of the vital role the STB serves in the American supply chain given its charge to provide economic regulation for the freight rail industry. As a board member since 2019 he has intelligently shaped many rulemakings to help the rail industry better serve its customers and the American public.

Before his time on the Board, Mr. Fuchs served as senior professional staff member for surface transportation and merchant marine for the Senate Commerce, Science and Transportation Committee and was instrumental in drafting the STB Reauthorization Act of 2015, the Fixing America’s Surface Transportation Act of 2015, and the Positive Train Control Enforcement and Implementation Act of 2015.

We strongly urge you to confirm Patrick Fuchs for a second term at the STB.

Sincerely,
Agricultural Retailers Association
American Chemistry Council
American Cotton Shippers Association
American Farm Bureau Federation
American Feed Industry Association
American Malting Barley Association
American Soybean Association
AmericanHort
Consumer Brands Association
Growth Energy
International Dairy Foods Association
International Fresh Produce Association
National Association of Wheat Growers
National Cotton Council
National Council of Farmer Cooperatives
National Farmers Union

National Grain and Feed Association
National Milk Producers Federation
National Oilseed Processors Association
North American Millers’ Association
North American Renderers Association
Pet Food Institute
The Fertilizer Institute
US Rice Producers Association
USA Rice

The post Growth Energy Signs Trade Letter in Support of Transportation Board Confirmation appeared first on Growth Energy.

The United States is home to 210 biorefineries across 27 states that have the capacity to produce more than 17 billion gallons of low carbon, ethanol. Today, ethanol makes up more than 10 percent of our nation’s fuel supply, and we’re poised to do much more with expanded use of higher ethanol blends like E15, a fifteen percent ethanol fuel blend.

To deliver low-cost, low-carbon fuel to American drivers, our industry is dependent on safe, timely, and efficient rail service, with nearly 70 percent of our production moved by rail. In fact, ethanol represents the largest hazmat commodity shipped by rail, with 438,000 carloads shipped and a fleet of nearly 39,000 cars in 2021 alone.

Additionally, our industry ships more than 200,000 cars per year of distillers dried grains (DDGS) and more than 10,000 cars of corn oil. Rail service is vital to moving ethanol and related coproducts from our biorefineries, located primarily in the Midwest, to consumers across the country and around the world.

From 2005 through 2021, our industry shipped 5.24 million tanker cars of ethanol safely to destinations throughout the country. In that time, our industry has experienced just a handful of notable derailments, representing a fraction of a percent of all ethanol trains. None of these derailments were caused by our product. In nearly all of ethanol derailments, the cause has been either broken track or railroad failure.

After a lengthy and extensive process over the last decade, our industry has completely turned over our entire tank car fleet, thus meeting the compliance deadline of the FAST Act for ethanol cars. Our industry has already phased out the use of the DOT 111 railcar and is nearing the final phaseout compliance deadline for the few potential remaining CPC1232 cars in use for ethanol. According to the Railway Supply Institute (RSI), the new DOT 117 car represented nearly 80 percent of cars in use in 2021. With these moves, our industry has invested significantly in purchases and long-term leases to meet the compliance requirements while accommodating the growing need for biofuels.

Tank Car Thermal Protection Standard
While there are a number of items in the ANPRM relative to rail transport, we want to raise our strongest concerns with the discussion about a possible revision to the thermal protection standard under section Z. The ANPRM discusses several items relative to the tank car thermal protection standard. The current thermal protection standard is a performance requirement of a tank car and thermal protection system when exposed to a 1600-degree F pool fire for 100 minutes, and a 2200-degree F torch fire for 30 minutes.

Notably, the ANPRM talks about an effort to potentially double the existing performance standard to 200 minutes with seemingly little rationale for doing so. Our members are firmly committed to safe transport of ethanol by rail; however, we believe additional thermal protection measures may not be practical and do not offer a significant benefit especially when weighed with the potential impact on cost and the supply chain for both new cars and the existing fleet. While there are a great deal of questions about what impact may occur by doubling the performance standard, the ANPRM and Norfolk Southern provide very little data about what the potential benefit may be from such a major change. Presumably, doubling the performance standard may offer some limited delay on a high pressure or high energy event; however, the change does nothing to prevent such an event and more importantly does nothing to address the root cause of a train derailment. Additionally, adding more thermal insulation would add substantially more weight that would reduce the amount of ethanol shipped in each tank car which would then require more ethanol shipments added to the rail line. More shipments added to the rail line would thus increase the potential for an incident.

Growth Energy and its members fully support and continue to advocate for the continued safe transport of ethanol by rail. We believe that the overwhelming majority of ethanol shipments continue to be made safely and without incident each and every day, and that additional data and analysis needs to be done well ahead of changing the existing thermal protection performance standard given the tremendous impact on the existing rail infrastructure and ultimately on American consumers. While not covered directly in this ANPRM, we are hopeful that PHMSA and the Federal Rail Administration (FRA) continue to address the root causes and solutions to derailments and regulatory efforts be focused on these root causes accordingly.

Thank you for the opportunity to comment and in advance for your consideration.

The post Growth Energy Comments to PHMSA on Proposed Rail Safety appeared first on Growth Energy.

Given the objective to reduce carbon emissions from the transportation sector, waiting for the market to transition to ZEVs without seeking solutions for the dominant powertrain on the roads is a strategy which ignores the substantial reductions which can be achieved in current and future ICEVs. Embracing strategies to reduce carbon emissions from the nearly 300 million ICEVs that will continue to operate in the U.S. for the next several decades is imperative.

Fortunately, total lifecycle, as well as tailpipe, emissions reductions are already being achieved by increasing use of biofuels and reducing the carbon intensity of the fuel mixtures used in ICEVs. Additional near-term steps to reduce the carbon intensity of fuels will play a critical role in limiting the expected increase in cumulative mobile source greenhouse gas (GHG) emissions. ICEV technologies and the associated fuels can continue to be employed over broad and energy-intensive transportation applications while making substantial contributions to near- and long-term GHG emissions reductions. In fact, substantial reductions in GHG emissions from LDVs in the near term can only be achieved by reducing emissions from ICEVs.

Stillwater Associates was engaged by the Transportation Energy Institute to identify and analyze the potential opportunities to expand on this critical GHG-reduction strategy. In this report, we examine the benefits achievable through the decarbonization of the existing on-road U.S. ICEV fleet given the extended timeframe which will be required to transition that fleet to ZEVs.

The post Decarbonizing Combustion Vehicles: Transportation Energy Institute appeared first on Growth Energy.

“The science behind the benefits of midlevel ethanol-blended fuels like E25 and E30 is well documented by national laboratories, automobile manufactures, and scientific institutions,” said Growth Energy Vice President of Regulatory Affairs Chris Bliley. “Stable policies and access to market drivers will enable our industry to provide low-carbon, more affordable, high-performing, sustainable vehicle fuel solutions.”

Growth Energy has long advocated for higher octane, midlevel ethanol blends and first submitted a proposal for a 100 RON, E30 fuel nearly seven years ago, when the agencies first developed joint standards for vehicles. Most recently, Bliley testified on this topic at an EPA/NHTSA hearing in Dearborn, Michigan, on Sept. 25, 2018.

Growth Energy will continue to encourage EPA and NHTSA to remove regulatory barriers to the adoption of high octane, midlevel ethanol blends like E25 and E30. This would include approving fuel blends like a 100 RON, E30 fuel for vehicle certification. It would also include requiring minimum octane standards, updating fuel economy formulas, re-establishing flex-vehicle credits, and ensuring year-round sales of E15 and higher blends by June 1, 2019, which would provide cleaner, more affordable fuel for our nation’s drivers.

Go here to view a full copy of our submitted comments.

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For further information contact:
Leigh Claffey
(202) 545-4000
LClaffey@GrowthEnergy.org

The post Growth Energy Submits Comments Today on Proposed SAFE Vehicle Rule appeared first on Growth Energy.

“The American ethanol industry stands ready to move America forward,” said Bliley. “With a stable policy and access to drivers, we believe we can deliver low-carbon, low-cost, high-performing, sustainable vehicle fuel solutions.”

Bliley continued, stating that “[t]he science supporting the benefits of a high-octane fuel, and specifically a midlevel ethanol blend in the E25-E30 range, in conjunction with a high compression ratio engine is not new, and has been well-explored by the national laboratories, automobile manufacturers, and other scientific institutions. Ethanol has a very high-octane number, has a lower carbon content than the gasoline components it replaces, and has many other benefits that assist in combustion to increase engine efficiency and reduce both greenhouse gas and tailpipe criteria pollutant emissions.”

Growth Energy has long advocated for higher octane, midlevel ethanol blends and first submitted a proposal for a 100 RON, E30 fuel nearly seven years ago, when the agencies first developed joint standards for vehicles. The benefits of supporting high-octane, midlevel blends like E25 and E30 have been well documented by a range of national, scientific, and private institutions.

Growth Energy continues to encourage EPA and NHTSA to remove regulatory barriers to the adoption of high octane, midlevel ethanol blends. This includes approving blends like 100 RON, E30 fuel for vehicle certification, requiring minimum octane standards, updating fuel economy formulas, re-establishing flex-vehicle credits, and granting waiver relief for all ethanol blends over 10 percent; all of which would provide a cleaner, more affordable fuel for our nation’s drivers.

To read Chris Bliley’s testimony as prepared for delivery, visit our website.

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Press Contact:
Leigh Claffey
202.545.4000
LClaffey@growthenergy.org

The post Growth Energy Vice President Chris Bliley Testifying Today at EPA, NHTSA SAFE Hearing appeared first on Growth Energy.

“This proposal provides a valuable opportunity to highlight the benefits of high-octane, low-carbon fuels, such as mid-level ethanol blends like E30,” said Growth Energy Vice President of Regulatory Affairs Chris Bliley. “We look forward to participating in this discussion to show how ethanol blends can help automakers meet future GHG standards and provide immediate consumer benefits.”

Growth Energy, the nation’s top ethanol advocate, has been a leader in raising this issue going back to 2012 when the standards were first being implemented, as well as in subsequent rulemakings. In October of 2017, Growth Energy submitted comments to the Environmental Protection Agency in support of the use of higher biofuel blends in the Final Determination of the Mid-Term Evaluation of Greenhouse Gas Emission Standard for Model Years 2022-2025 Light-Duty Vehicles.

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Press Contact:
Leigh Claffey
202.545.4000
LClaffey@growthenergy.org

The post Growth Energy Statement on Release of New CAFE/GHG Emission Standards appeared first on Growth Energy.