BEFORE THE 

SURFACE TRANSPORTATION BOARD 

STB EX PARTE NO. 672 

RAIL TRANSPORTATION OF RESOURCES CRITICAL 

TO THE NATION'S ENERGY SUPPLY 

COMMENTS OF THE 

U.S. DEPARTMENT OF AGRICULTURE 

Bruce I. Knight 

Under Secretary 

Marketing and Regulatory Programs 

U.S. Department of Agriculture 

Washington, D.C. 20250 

Date: July 12,2007 
AUTHORITYAND INTEREST 

The Secretary of Agriculture is charged with the responsibility under the Amicultural 

Adiustment Act of 1938 and the Agricultural Marketing Act of 1946 to represent the interests of 

agricultural producers and shippers in improving transportation services and facilities by, among 

other things, initiating and participating in Surface Transportation Board (Board) proceedings 

involving rates, charges, tariffs, practices, and services. 

SUMMARY 

The purpose of this public hearing is to examine issues related to the efficiency and 

reliability of rail transportation of resources critical to the Nation's energy supply, including 

coal, ethanol, and biofuels. The Department of Agriculture (USDA) thanks the Board for 

initiating this public hearing and supports an exchange of information. 

USDA is concerned that the growth of the ethanol industry could be hindered by potential 

constraints in the Nation's rail capacity to handle and ship ethanol and co-products, limited 

infrastructure to consolidate ethanol shipments at rail terminals, and the possible future lack of 

adequate capacity to blend ethanol with gasoline. 

Further, USDA is mindful that the rapid expansion of ethanol production is projected to 

result in large shifts in domestic corn use and acres planted. This could result in substantial 

changes in rail demand and grain transportation patterns. Increased demand for the rail 

transportation of fertilizer is also expected as corn production increases because corn requires 

much more fertilizer than soybeans and wheat. 
USDA appreciates the opportunity to participate in the discussion undertaken by STB, 

industry, carriers, and other government agencies. It is USDA's goal to provide input that aids 

the search for solutions to prevent or alleviate potential distribution problems associated with the 

expected increase in ethanol production. 

BACKGROUND 

On August 8,2005, President Bush signed the Energy Policy Act of 2005 (PL 109-58) 

into law. The comprehensive energy legislation established a nationwide renewable fuels 

standard (WS) that was to start at 4 billion gallons in 

2006 and increase to 7.5 billion gallons in 2012 (Table 

I). The RFS is the result of several years of 

negotiations between the ethanol industry, oil industry, 

1: The I*:net-- 

tenewabl 

Fuel 

Federal government, State interests, environmentalists, 2007 

2008 

agriculture, and consumer groups. These groups sought 2009 

to determine the best way to encourage a greater 

contribution from the domestic renewable fuel industry 2012 7.5 

in order to reduce our Nation's dependence on foreign oil. 

Under the RFS, an increasing percentage of our Nation's fuel supply is to be provided by 

renewable, domestic fuels, including ethanol and biodiesel. The key objectives are to reduce 

consumer fuel prices, increase energy security, improve environmental quality, and stimulate 

growth in rural America. 
The increased use of renewable fuels has expanded U.S. fuel supplies and eased the 

burden on the refining industry. While no new oil refineries have been built in the United States 

since 1976, over 120 ethanol production facilities have been built during this time, adding critical 

volume to the gasoline market. Blending ethanol with gasoline and biodiesel with diesel directly 

increases domestic fuel capacity. 

Support for renewable fuels remains strong at the Federal level. As a means of reducing 

our Nation's dependence on foreign oil, President Bush called for fuels standards to require 35 

billion gallons of renewable and alternative fuels in 2017. Congress is currently debating 

additional incentives for the production of alternative and renewable fuels as it considers actions 

to increase the RFS. 

The U.S. ethanol industry 

Expanded production capacity 

Figure 1: US Ethanol F'mduction ~rowth-~istoricd Production, 1 

surpassed the RFS in 2006, when 

4.9 billion gallons of ethanol were 

produced and used. Current annual 

ethanol production capacity stands 

at 6.3 billion gallons (Figure I). 

'02 '03 '04 '05 '06 107* ~o&*og*? 

Source: EnergvIn@rmatton Administmtfon: *Renewable Fuels Axsociation, June 14. 

14 - Current and Expected Production Capacity 

12.6 

12 - 

10 - 

1 

= 8- 6.3 

6- 4.9 

B 

3.4 3.9 

4 - 2.1 

2.8 

currently under construction is 

expected to double annual ethanol production capacity to 12.6 billion gallons by the end of 2009, 

if not sooner. 

To date, logistical concerns have not hampered production growth (nor have they 

significantly hampered the continued construction and expansion of new plants). However, 
several issues that may arise as production grows include: 1) uncertainty about the location of 

and demand from terminal markets, 2) rail infrastructure to efficiently ship ethanol and coproducts, 3) shifts in grain rail transportation, 4) increased transportation demand for agricultural 

inputs, mainly additional fertilizer for increased corn acreage, and 5) expected long-term growth 

in freight volumes. 

EFFECTS OF INCREASED ETHANOL PRODUCTION ON RAIL TRANSPORTA TION 

Increased Sensitivity to Demand and Distribution Changes 

All three major transportation modes in the United States-rail, barge, and truck-are 

now at or near capacity. It is extremely unusual to see constraints in all three modes at the same 

time unless there is a major crisis such as a world war or a catastrophic natural disaster. 

Each transportation mode is experiencing a different set of constraints on capacity. In 

general, these capacity constraints include inadequate road or terminal infrastructure, a lack of 

motorized vehicles or cargo conveyances, and an insufficient number of trained operating 

personnel. Capacity constraints are being caused or aggravated by: 1) congestion that results in 

slower speeds, 2) changes in hours of service or other regulations, 3) deterioration of aging 

infrastructure that restricts the flow of traffic, and 4) excessive shut down time due to required 

maintenance. 

The lack of excess capacity increases the sensitivity of transportation modes to natural 

disasters and sudden changes in transportation demand and distribution patterns. Changes in 

transportation demand and distribution patterns associated with rapidly increasing ethanol 

production could impact rail network performance. The increased sensitivity of transportation 
modes became evident in the aftermath of Hurricanes Katrina and Rita in 2005, when truck and 

rail had insflicient capacity to transport displaced barge freight demand. 

Increased Demand for Rail Service 

Expanded ethanol 

FCgure 2: Projected Rail Carloads Needed for Corn, 

Soybeans, Wheat, Ethanol, and DDGS production is expected to result in 1 1,600,000 , 1.48 to 1.48 to 

1,550,000 

an increase in demand for rail 

services for ethanol and DDGS. 

The rise in ethanol and DDGS rail 

shipments should more than offset 

the expected decline in rail demand 

for grain transportation (discussed 

below). For marketing year1 

1.37 mil. 

1.45 mil. 1 

2005/06 

5 Ames 12.6 M. gal. ethanol production for 2008/09 and 2009110; aspunes corn production increases 

mot& to mcd projected export and feed upe of corn; my bean and heat prochion mchanged O Assuna Agncultual Projections prqected ethanol oldptll and corn USBP for 2008109 and 2009110 

Asumea 12.6 bil. gal. ethanol production in 2008/09 and2009110; corn production as forecart in 

A@cultual Projection% adjurt corn mag8 for feed and ethanol production. 

Sources: UDA, World Agricultwal %ply and Demand Estimates, July 12,2007; 

US)& Agricultual Projections to 2016, Febnary 2007. * -projections 

2007108, USDA projects U.S. 

railroads will transport 1.45 million railcars of the three major grains, ethanol, and DDGSnearly 6 percent higher than the prior marketing year (Figure 2). 

Corn production in the U.S. for the 2007108 marketing year is expected to reach about 

12.8 billion bushels, up approximately 2.3 billion bushels (22 percent) from last year.2 The 

larger corn crop is the result of expanding ethanol production and high corn prices. But, a larger 

1 The marketing year for corn and soybeans begins September 1 and the marketing year for wheat 

begins June 1. 

Projections assume the railroad modal share for domestic and export movements of each grain 

remains the same as in 2004 as reported in USDA, Agricultural Marketing Service, Transportation 

and Marketing Programs, Transportation of U.S. Grains: A Modal Share Analysis, October 2006. 

Market shifts and rail tariff prices could change modal shares. 
corn crop will not necessarily translate into increased rail demand for grain transportation 

because: 1) trucks dominate the transportation of corn to ethanol plants, 2) a significant share of 

the increase in the corn crop will be trucked to ethanol facilities, 3) soybean production is 

expected to be reduced because many farmers switched to planting corn, and 4) the diversion of 

corn to ethanol plants has led to a reduction in feed use and exports of corn. 

Since 97 percent of U.S. ethanol is produced from corn, transportation demand, corn use, 

originations, and destinations for corn may shift. In April, for example, USDA lowered the 

expected feed use of corn in 2006107 by 3.5 million tons, resulting in more than 11,000 fewer 

carloads of corn that otherwise would have been shipped by rail. USDA projects 2007108 corn 

use3 for ethanol to reach 3.4 billion bushels, up 58 percent from last year, while feed use and 

exports are projected to decrease by 1 and 5 percent, respectively. 

Transportation shifts are expected to continue into the 2007108 corn-marketing year, and 

over the next several years. Increased ethanol production could cause major corn-producing 

states to become corn-deficit states, resulting in the rail movement of corn from other states. The 

sourcing of grain for the export market is also expected to shift. 

In 2004, rail moved 33 percent of U.S. corn to export locations and 32 percent to 

domestic processors, feed lots, and dairies4 Corn constitutes 50 percent of all rail grain 

 movement^.^ 

Currently, 1 bushel of corn used in ethanol production yields approximately 2.75 gallons of 

ethanol and 17.5 pounds of DDGS. 

4 Transportation of U.S. Grains: A Modal Share Analysis, U. S. Department of Agriculture, 

Agricultural Marketing Service, Transportation and Marketing Programs, Transportation Services 

Branch, October 2006, pg. 13. 

5 Association of American Railroads, Freight Commodity Statistics, 2005. 
Increased rail service demand is expected to impact railcar fleet6 composition and 

availability for moving corn, 

ethanol, and DDGS. Grain is 

Figure 3: Carloads of Ethanol Terminated by 

Class I Railroads, 2000-2005 

90,m 1 82,483 

2000 '01 '02 '03 '04 '05 

2005. It is possible that shifts in Source: STB, Waybill Sample 

shipped in covered hopper railcars 

(C 1 13 and C 1 14). The covered 

hopper railcar fleet as of January 1, 

2007, totaled 268,000-almost 2 

percent higher than on January 1, 

transportation patterns could put a strain on grain railcar availability. 

Ethanol is currently transported by rail, barge, and truck. Railroads shipped about 60 

~,'~oo - 

percent of ethanol produced in the United Sates in 2005, or 82,483 carloads (Figure 3). 

@Qao 

According to preliminary Freight Commodity Statistics, railroads kept up with ethanol 

production growth in 2006-ethanol production grew by 26 percent fiom the previous year and 

the Class I railroads' origination of all alcohols7 grew by 28 percent. 

As ethanol production capacity approaches 12.6 billion gallons, demand for rail 

transportation of ethanol may grow dramatically to an estimated 245,000 total ethanol carloads 

per year. This growth is almost three times the amount of ethanol shipped in 2005. Railroads 

assert that this is well below the 1.2 million grain carloads and 20.8 million total carloads they 

4 

"" 

58.324 

g 

Railcar fleet statistics are from Association of American Railroads, telephone conversation with 

Craig Rockey on July 3,2007. 

Preliminary data does not include ethanol-specific statistics. Nearly all of the growth in alcohol 

movements during 2006 is expected to be fiom increased ethanol movements. Freight 

Commodity Statistics, compiled by Escalation Consultants, Inc. 

- 

J S0,oOO - 

40,000 - 

30,000 - 

m,ooo - 

l0,oOO - 

o , 

. - 48,668 

43,244 39,764 
originated in 2006. The rapid growth in ethanol movements and a shift in transportation 

patterns, however, are expected to occur in the next 18-24 months. The consequences of these 

changes occurring during a relatively short period could include a strain on rail transportation 

and logistics infrastructure, thus possibly resulting in disruptions to rail service. 

The production of ethanol co-products4istillers dried grains with solubles (DDGS)-is 

expected to grow proportionally with ethanol production. DDGS are typically shipped in jumbo 

covered hopper railcars or containers to domestic feedlots and export markets. According to 

preliminary Freight Commodity Statistics, railroads originated 22,683 DDGS carloads in 2006- 

3 1.5 percent higher than in 2005. If demand for DDGS continues to grow as production 

increases, demand for railcars and rail service will grow as well. 

The demand for rail transportation by all commodities so far this year has been weaker 

than expected due to slower than expected U.S. economic growth and lower demand from the 

automotive and construction sectors. Weak year-to-date demand for intermodal rail movements 

and from several other industries reliant on rail transportation has also contributed to lower than 

normal demand for rail transportation. The shift of corn used for ethanol production to local 

truck transportation has also compounded weaker than expected demand for rail transportation, 

but increased future corn production is expected to nearly offset this shift in coming years. 

Weaker than expected demand has eased railroad constraints in certain areas, but capacity issues 

and concerns remain. 

Increased Need for Adequate Infrastructure Investment 

The railroad industry will be challenged to meet the demands of tomorrow. Rail freight 

is forecast to increase from 1,879 million tons in 2002 to 3,525 million tons by 2035, an increase 
of nearly 88 percent.8 In order to meet expected future demand for rail transportation, the 

railroad industry would likely need to invest heavily in railroad infrastructure. 

Even though more railroads are attaining revenue adequacy, resulting in return-oninvestment constraints being less of a factor, railroads are still. faced with limits as to how much 

of their profits they can invest to increase capacity. In addition, the economics of the railroad 

industry (as occurs with other industries) provides an incentive for railroads to limit rail capacity 

in order to maximize profits, especially when railroads may not have effective competition from 

other transportation modes or other railroads. 

Inadequate rail infrastructure investments could result in ethanol and other agricultural 

shippers facing significant difficulties in obtaining adequate rail service in the future. This could 

also lead to smaller ethanol shippers raising issues regarding the Common Carrier Obligation if 

larger ethanol shippers receive what is perceived as better service. 

Railroad Capacity Constraints 

As new ethanol production facilities enter the market, railroads have begun to put in I 

place policies limiting rail service availability to ethanol plants. These policies limit service that 

would increase congestion near or on already congested rail lines. Some destination points, 

including DallasIFt. Worth, TX, have had embargoes in place, requiring ethanol shippers to 

obtain permits for shipping ethanol to those locations on the railroad. An East Coast railroad 

8 U. S. Department of Transportation, Federal Highway Administration, Office of Freight 

Management and Operations, Freight Analysis Framework, 2006. 
recently lifted an embargo on ethanol shipments, which was put into place originally due to 

congestion problems. Rail service limitations could deter or slow additional ethanol production. 

Need For Adequate Supply of Ethanol Rail Tank Cars and DDGS Railcars 

Ethanol is shipped in 

standard tank railcars (TI 08). As 

of January 1,2007, the TI08 fleet 

was at 41,000, but orders for new 

construction are expected to almost 

1 Wgure &New Rail Tank Car Orders, Deliveries, and Backlog 1 

0rdcrs m Deliveries 0 Backlog 

1 

10,111 9,936 

Qtr1 Qtr2 Qtr3 Qtr4 Qtr1 Qtr2 Qtr3 Qtr4 Qtr1 1 

double this fleet in the next 2-2 '/z 1 '05 '05 '05 '05 '06 '06 '06 '06 '07 

Source: Rail Supply Institue, quarterly reports. 

years. 

Rail tank cars are nearly all privately owned, either by leasing companies or shippers. 

The railroads have been advising builders of new ethanol plants to ensure an adequate supply of 

railcars. As a result, orders for new rail tank cars started to increase in the 4' quarter 2005 and 

continued to increase through the 3rd quarter 2006 (Figure 4). Rail tank car manufacturers 

increased production lines, but the backlog grew from about 10,000 railcars in the 3rd quarter 

2005 to a peak of 36,334 railcars in the 4'h quarter 2006, but has decreased to 36,166 railcars in 

the 1' quarter 2007. The ethanol industry focused on ethanol rail cars first because they are 

relatively inexpensive and easy to build as compared to covered hopper railcars used to ship 

grain and DDGS. 
Increased demand for shipping DDGS has also expanded demand for super jumbo 

covered hoppers. From first quarter 2005 through first quarter 2007, new deliveries for DDGS 

railcars have totaled 1 1,307-most of the growth occurred in 2006. DDGS are estimated to use 

about 70 percent of this fleet. 

~lowability~ issues associated with shipping DDGS have created expectations of a shorter 

lifespan of DDGS railcars, thus making them relatively more costly than the rail tank cars. 

DDGS are also shipped in containers for export. The same flowability issues have started to 

affect availability of containers. In addition to an efficient logistics infrastructure, an adequate 

supply of railcars for ethanol (and cars/containers for DDGS) is needed to sustain growth in the 

ethanol industry. 

Supply Chain Issues 

There is concern that the efficiency of the ethanol transportation system may begin to 

depend on the ability of the blending market to accommodate additional quantities of ethanol. If 

constraints on blending capacity were to idle ethanol capacity as early as September -just as 

harvest of this year's corn crop begins - it could exacerbate a shortage of grain storage capacity 

and further disrupt the transportation system. 

During storage and transport, DDGS tend to cake and bridge between particles. Thus, 

flowability has become one of the major issues that needs to be addressed for effective sales, 

marketing, distribution and utilization of distillers grains. Because these co-products do not 

always flow easily fiom railcars, workers sometimes hammer the car sides and hopper bottoms in 

order to induce flow. This can lead to severe damage to the rail cars themselves and can also pose 

worker safety issues. 
The supply and demand of ethanol may become 

temporarily out of sync because blenders require time 

and desire additional financial incentives to add 

blending capacity. These extra financial incentives 

could be in addition to the current blender tax credit of 

$0.5 1 per gallon, which is in place through 2010. 

Blenders are watching Federal and State legislative 

processes carefully to assess the legislative risk to their 

capital investments. 

The potential demand for ethanol if the U.S. 

goes to El 0 (a gasoline blend, containing 90 percent 

gasoline and 10 percent ethanol) in all regions would be 

approximately 14 billion gallons (Table 2). Some 

regions of the Nation have expanded ethanol use faster 

than others. For example, California is expected to 

approve an increase in the use of ethanol in gasoline 

from the current 5.7 percent limit to 10 percent by the 

end of 2007. Legislatures in southeastern States are also 

considering increasing ethanol-blending requirements. 

This adds to the uncertainty of ethanol demand in terms 

of volumes, timing, and geographic location. 

.,,ie 2--, ",entia. -.hano. . ,lumes ion gallons, Based on 10% blend of2004 Motor Gaa 

Consumption) 

Ethanol Consumption 

Potential % 

State Potential 2005 Increase 

New Hampshire 

New Jersey 

New Mexico 

New York 

North Carolina 

North Dakota 

Ohio 

Oklahoma 

Oregon 

Pennsylvania 

Rhode Island 

South Carolina 

South Dakota 

Tennessee 

Texas 

Utah 

Vermont 

Virginia 

Washington 

West Virginia 

Wisconsin 

(united States I 13,997 1 4,0591 245 

Source: DOElEIA 

h~://www.eia.doe.~ov/emeu/statc:d seds updates.hhnl 

(next update planned for 8/03/07) 

Wyoming 

72 

436 

98 

577 

443 

36 

524 

191 

155 

523 

38 

259 

44 

306 

1,158 

104 

35 

398 

270 

85 

257 

33 1 

I I I 

7 

6 

328 

116 

17 

264 

3 1 

100 

10 

27 

29 

2 

106 

25 

23 

127 

6,386 

1,526 

76 

280 

111 

99 

399 

42 1 

30 1 

60 

3,890 

4,568 

275 

972 

275 

102 
It is more efficient and cost effective for railroads to move unit trains consisting of about 

95 cars moving from one origin to one destination. The need for construction of terminals that 

consolidate production of several ethanol plants into more efficient unit trains may become the 

key to the efficiency of rail ethanol transportation and ultimately the ability of ethanol production . . 

to expand. Unit train movements are expected to increase the average number of loadings per 

year for each ethanol tank car, which could help alleviate potential tank car shortages. 

Due to the efficiency of unit 

trains, rail tariff rates are typically lower 

than those for single-car and smaller 

shipments. For example, BNSF's tariff 

rate for a single-car rate for a shi~ment V A 'Unit Train: A 95- dbauol tm , -J at 1 - 

'~arhcrrd Train: A 95-w e4ba10I train origimhg at 2 or 3 plaats 

fiom Southwest Iowa to California is 

$1,200 higher per car than the unit train tariff rate (Table 3). 

Locations capable of accepting unit trains of ethanol currently include: 1) Watson and 

Carson, CA, 2) Ft. Worth and Arlington, TX, 3) Chicago, IL, 4) Albany, NY, 5) Providence, RI, 

6) Sewaren and Linden, NJ, 7) Baltimore, MD, and 8) Stockton, CA. Future demand locations 

could include population centers in the Southeast, the Delta Region, and the Pacific Northwest. 

New terminal market facilities that would consolidate smaller ethanol shipments from numerous 

plants into unit trains are under construction in Manly, IA, and St. Louis, MO. 

In summary, several supply chain issues can pose significant problems to growth in the 

ethanol industry. Sustained expansion in the ethanol industry will depend, in part, on the 
blending market being able to accommodate larger quantities of ethanol. Growth in rail terminal 

market development and facilities also is likely to be important. 

ISSUES FOR FUTURE DISCUSSION 

Rail infrastructure, efficiency, and reliability are not the only factors that can limit the 

production and distribution of renewable and alternative fuels. As the renewable and alternative 

fuel industry matures, the entire supply chain for renewable and alternative fuels will likely be . 

scrutinized for inefficiencies and potential bottlenecks that could hinder our Nation's goal of 

reducing dependence on foreign oil. USDA poses the following rail related questions to 

encourage dialogue toward workable solutions to the various issues that could impede the 

production and distribution of renewable and alternative fuels via rail. 

Issue: The volume of DDGSproduced may be greater than the feed industry can absorb, 

causing logistical concerns in the future. 

Ethanol producers are working to develop both domestic and export demand. Since 

domestic demand is not expected to consume all the DDGS likely to be produced, export demand 

will become essential to successfully increasing ethanol production capabilities. In addition, 

scientific research is progressing on determining the proper amount of DDGS to include in feed 

rations by type of animal and developing DDGS standards. 

Issue: How can ethanol and DDGS transportation data availability be improved? 
Statistics on rail grain movements have developed over time and are fairly easy to access 

and monitor each week. Availability of similar data for ethanol rail movements is not as readily 

available on a timely basis. Business and policy decisions can be influenced by the amount of 

accurate and timely information. USDA believes that any improvements in this area would 

greatly benefit both business interests and policy makers. 

Issue: Will the production of cellulosic ethanol affect investments in new transportation and 

distribution capacity Cfor the additional ethanol volumes, as well as the inbound feedstock)? 

Currently, corn is the main feedstock for ethanol plants, but the amount of ethanol that 

can be produced from corn is far below the national renewable and alternative fuel production 

goals proposed by President Bush. As economically competitive methods of producing 

cellulosic ethanol or other renewable fuels are discovered, ethanol plants could be developed in 

regions currently not producing ethanol. This could possibly require investments in rail capacity 

and other distribution infrastructure. The location of these ethanol plants would likely be close 

to the location of the feedstock production because cellulosic feedstock is likely to require more 

feedstock volume to produce a gallon of ethanol than corn. The geographic areas of potential 

expansion of cellulosic ethanol production need to be evaluated for the best logistical integration 

into the existing and growing corn-based ethanol industry. 

CONCLUSION 

USDA thanks the Board for initiating this public hearing on an issue that is important to 

agricultural and biofuels shippers. USDA is concerned that the growth of the ethanol industry 

could be hindered by potential constraints in the Nation's rail capacity to handle and ship ethanol 
and co-products, limited infrastructure to consolidate ethanol shipments at rail terminals, and 

possible future lack of adequate capacity to blend ethanol with gasoline. 

The rapid expansion of ethanol production is projected to result in large shifts in domestic 

and export corn use, as well as corn acres planted. This could result in substantial changes in rail 

transportation demand and grain transportation patterns. Increased demand for the rail 

transportation of fertilizer is also expected because corn requires much more fertilizer than 

soybeans and wheat. 

USDA urges STB and all other interested parties involved to consider these issues 

carefully. It is USDA's hope that the information presented and questions raised in our 

comments are beneficial to the Board as it continues to monitor issues related to the efficiency 

and reliability of rail transportation of ethanol and biofuels. 

C' Under Secretary 

Marketing and Regulatory Programs 

U.S. Department of Agriculture 

Washington, D.C. 20250 
I, Bruce Blanton, cwtifjl that on this 12th day of July, 2007, I caused a copy of the 

foregoing dcmmmt to be served by fhtst-class ma& postage prepaid, on all parties of 

reccnd in STB Ex Pate No. 672. 

Bruce Blanton 

Associate Deputy Administrator 

Tnmsportation Services Branch 

Transportation and Marketing Programs 

Agricultural Marketing Service 

U.S. Department of Agriculture 

Washington, D.C. 20250