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Regulation of Fuels and Fuel Additives: Renewable Fuel Standard ...

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Modifications to the rail, barge, tank truck, <strong>and</strong> terminal distribution systems will<br />

be needed to support the transport <strong>of</strong> the anticipated increased volumes <strong>of</strong> renewable<br />

fuels. These modifications include the addition <strong>of</strong> terminal blending systems for ethanol<br />

<strong>and</strong> biodiesel, additional storage tanks at terminals, additional rail delivery systems at<br />

terminals for ethanol <strong>and</strong> biodiesel, <strong>and</strong> additional rail cars, barges, <strong>and</strong> tank trucks to<br />

distribute ethanol <strong>and</strong> biodiesel to terminals. Terminal storage tanks for 100 percent<br />

biodiesel will also need to be heated during cold months to prevent gelling. In the past<br />

the refining industry has raised concerns regarding whether the distribution infrastructure<br />

can exp<strong>and</strong> rapidly enough to accommodate the increased dem<strong>and</strong> for ethanol. The most<br />

comprehensive study <strong>of</strong> the infrastructure requirements for an exp<strong>and</strong>ed fuel ethanol<br />

industry was conducted for the Department <strong>of</strong> Energy (DOE) in 2002 . 58 The conclusions<br />

reached in that study indicate that the changes needed to h<strong>and</strong>le the anticipated increased<br />

volume <strong>of</strong> ethanol by 2012 will not represent a major obstacle to industry. While some<br />

changes have taken place since this report was issued, including an increased reliance on<br />

rail over marine transport, we continue to believe that the rail <strong>and</strong> marine transportation<br />

industries can manage the increased growth in dem<strong>and</strong> in an orderly fashion. This belief<br />

is supported by the demonstrated ability for the industry to h<strong>and</strong>le the rapid increases <strong>and</strong><br />

redistribution <strong>of</strong> ethanol use across the country over the last several years as MTBE was<br />

removed. The necessary facility changes at terminals <strong>and</strong> at retail stations to dispense<br />

ethanol containing fuels have been occurring at a record pace. Given that future growth<br />

is expected to progress at a steadier pace <strong>and</strong> with greater advance warning in response to<br />

economic drivers, we anticipate that the distribution system will be able to respond<br />

appropriately. A discussion <strong>of</strong> the costs associated making the changes discussed above<br />

is contained in section VII.B. <strong>of</strong> this preamble.<br />

58<br />

"Infrastructure Requirements for an Exp<strong>and</strong>ed <strong>Fuel</strong> Ethanol Industry," Downstream Alternatives Inc.,<br />

January 15, 2002.<br />

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