Question 1

Why is No Ethanol Fernandina opposed to RYAM constructing an ethanol manufacturing facility in  Fernandina Beach?

Accepted Answer

There are several reasons. Ethanol is a highly flammable hazardous chemical that carries substantial risk of accidental fires and explosions.

The proposed location puts residents and island ecosystems in harm's way. It is adjacent to a densely populated area within the City of Fernandina Beach on Amelia Island and situated along the environmentally sensitive Amelia River.

​​It puts dangerous chemicals on our roads. If constructed, three tanker trucks a day (over 1000 a year) filled with ethanol will cut through a dense residential area, then travel the busy commercial route through our city, across the Shave Bridge, and over the busiest roads in Nassau County to I-95.

What's more, it is illegal. The City's Comprehensive Plan (CP) and Land Development Code (LDC) specifically prohibit chemical manufacturing or refining in the Industrial Zone where RYAM’s plant is located, and the City has obtained legal advice that a 2G Bioethanol Plant employs chemical manufacturing as well as refining processes, and therefore is prohibited.
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The LDC also prohibits "heavy metal fabrication, batch plants, salvage yards, rubber or plastic manufacturing, and other uses generating potentially harmful environmental or nuisance aspects."

Question 2

How can RYAM be stopped from building the ethanol manufacturing facility?

Accepted Answer

The City must approve RYAM's site plan before construction may begin. On February 4, 2025, the City issued RYAM a formal interpretation that the City views RYAM's application to build an ethanol manufacturing facility at its Gum Street location to constitute chemical manufacturing or refining that is strictly prohibited by both our Comprehensive Plan and Land Development Code. As such, no further action will be taken on RYAM's site plan application. RYAM has 30 days to appeal the City's interpretation to the City's Board of Adjustment.
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We expect RYAM to sue the City. RYAM's application asserts that its ethanol production would not use either chemical processes or refining processes and therefore should be allowed. 
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Organized and widespread public opposition will continue to be critical to helping stop the facility's construction.
 
The decision about whether or not the facility can be built ultimately may rest with the court system.​​​​

Question 3

What is the City's approval process and timeline?

Accepted Answer

December 19, 2024
RYAM submitted its site plan application to the City.
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December 30, 2024
The City returned the application as incomplete.
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January 28, 2025
RYAM resubmitted its application to the City.
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February 3, 2025
Deadline for the City to deem the application complete or incomplete, or to deny it.
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February 4, 2025
The City denied RYAM's application because the proposed ethanol plant is prohibited by the CP and LDC.
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February 28, 2025
RYAM filed a complaint in the Fourth Judicial Circuit Court of Florida against the City of Fernandina Beach alleging the City's denial of its plans to build an ethanol manufacturing plant are unauthorized.

Question 4

Why does RYAM think the City should approve its ethanol manufacturing plans?

Accepted Answer

RYAM claims that its ethanol production process is a "fermentation" process and not a "chemical" process, and therefore is allowable under the City's CP and LDC.

Question 5

Should the City allow the proposed plant if RYAM establishes it won’t be conducting any chemical manufacturing or refining processes?

Accepted Answer

No it should not. Even if deemed to not be chemical manufacturing, RYAM’s proposed ethanol plant presents harmful environmental and nuisance impacts, which are spelled out in our LDC.

A nuisance can be anything that interferes with the rights of the public or an individual, and we believe this should include living under the threat of personal injury or damage to property from a plant explosion or fire, and RYAM’s proposal to truck ethanol through the City.

Question 6

What is the risk of fire or explosion?

Accepted Answer

RYAM has not yet shared a detailed risk assessment that considers conditions at the proposed site, but we believe there is a serious risk of fires and explosions.
  
​The close proximity of the proposed ethanol facility to RYAM’s large mill operation, its LignoTech operations, and the Eight Flags 20 MW onsite power plant will increase the risk of fire because they present significant sources of spark. 
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Stonehouse Safety, a leading expert in industrial risk assessment, cites over 20 explosions/fires associated with the production of ethanol (https://stonehousesafety.com/explosions-associated-with-ethanol-production/)over the past 10 years. Based on the after-action reports on recent accidents at ethanol plants across the United States, a serious danger is presented by ethanol manufacturing because ethanol vapors, which are heavier than air, odorless, and highly-flammable, can escape from production equipment, piping, and storage tanks, and travel along the ground until they are ignited by a source of spark.

Question 7

Why is ethanol so dangerous?

Accepted Answer

Ethanol vapors can ignite at about 57.2 degrees Fahrenheit when exposed to an ignition source under normal atmospheric conditions.
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There is potential for a fire to start in any part of RYAM's proposed ethanol plant, and there is potential for that fire to travel to any other part of the plant. This is the “potentially harmful environmental impact” that the City prohibits in its LDC.
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Industrial risk assessment experts at Stonehouse Safety report:(https://stonehousesafety.com/explosions-associated-with-ethanol-production/)
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Due to its highly flammable nature, ethanol carries a substantial risk of causing fires and explosions, which underscores the importance of being aware of its flash point. Ethanol’s flash point at atmospheric pressure is around 14 °C (57.2 °F), indicating that its vapors can catch fire at or above this temperature when exposed to an ignition source. When it burns, it has a smokeless blue flame that is not always visible in normal light.
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When the vapor mixes with air reaching a concentration between flammability limits, it becomes flammable and, since it’s heavier than air, it stays along the ground as it spreads. The vapor may travel considerable distances and potentially cause fires and explosions far from the source and flashback. Consequently, spaces that are not well-ventilated, particularly those below ground levels such as trenches, conduits, shafts, and sewers, are at a higher risk for the build-up of flammable substances or mixtures, where a Vapor Cloud Explosion (VCE) may occur.​​

Question 8

How could ethanol vapors at RYAM’s plant escape?

Accepted Answer

Flammable ethanol vapors are readily formed during production, when moved for storage, and during transportation, according to the industrial risk assessment experts at Stonehouse Safety. 
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Even a small leak in a pipe could cause ethanol to escape. It would then quickly vaporize due to our climate and travel along the ground creating a grave fire hazard.
 
Another potential flash point would be the daily transfer of ethanol from the storage tanks into tank trucks for transporting through the plant site, out Gum Street to 8th Street, and over the Shave Bridge into the County and on to RYAM’s customers.

Question 9

Can ethanol production harm the Amelia River?

Accepted Answer

We are concerned about the potential harmful impact of an ethanol spill. RYAM states “nor will the project harm the health of local waterways.” It won’t if no ethanol gets into the adjacent marsh and water. But no one, even RYAM, can be certain this won’t occur.
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According to Gexcon,(https://www.gexcon.com/blog/ethanol-associated-hazards-and-safety-measures) one of the world's leading companies in safety and risk management, “Apart from its flammability and health hazards, ethanol also presents environmental concerns, particularly in the event of a spill. If ethanol enters water systems, it can reduce oxygen levels, which harms aquatic life.” 
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RYAM’s ethanol storage tanks will be located approximately 30 feet from the marsh adjacent the south shoreline of the current RYAM mill.
 
Since there is potential for a spill, there is potential for that spill to get into the marsh, which is a “potentially harmful environmental impact” that our City codes prohibit.

Question 10

What are the risks of transporting ethanol?

Accepted Answer

The primary risk is accidents that may result in spills, fires and/or explosions.
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If constructed, three tanker trucks a day (over 1000 a year) filled with ethanol will cut through a dense residential area, then travel the busy commercial route through our city, across the Shave Bridge, and over the busiest roads in Nassau County to I-95.
 
We believe both the City and County should evaluate this risk and seek advice from the Northeast Florida Regional Council to evaluate safety emergency preparedness for potential accidents and explosions on City and County roads.
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The US Department of Transportation (DOT) recommends evacuation zones as wide as a 1/2 mile in all directions from the site of any tanker truck incident involving ethanol.

Question 11

What role does the Florida Department of Environmental Protection (FDEP) play in the approval process?

Accepted Answer

The FDEP has issued an air pollution permit for the facility to be constructed.
 
RYAM applied for the permit in November 2023, and after opposition from our community and a legal challenge filed by a local resident (eventually withdrawn), the permit was issued in November 2024.​

Question 12

What is the difference between what RYAM is calling '2G BioEthanol' and 'ethanol'?

Accepted Answer

There is no difference. RYAM intends to manufacture ethanol using byproducts from its pulping operation rather than first generation materials, such as corn, sorghum and barley. The risks are the same.
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In general, No Ethanol Fernandina supports the production of ethanol as an alternative source of fuel, but we feel strongly it should be produced in remote areas where people and the ecosystem are out of harm's way.

Question 13

What is our City’s Comprehensive Plan?

Accepted Answer

The City of Fernandina Beach 2030 Comprehensive Plan (CP) is our City’s growth management tool and can be best described as the City’s "constitution." It is the basis for which how laws developed and enforced, and it is our blueprint for development and serves as a guide for land use decision making.
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As the basis for our City’s Land Development Code (LDC), our Municipal Code, and our Capital Improvement Program, it leads the City to achieve a smart growth form of development and enables current and future commissions and administrations to be proactive, rather than reactive, in City planning.

Question 14

Can the Comprehensive Plan be amended?

Accepted Answer

Yes it can be amended, but like the US Constitution, only through a formal prescribed process. Because it is designed to be a living document, the State of Florida requires cities to conduct an Evaluation and Appraisal Review (EAR) every seven years.

Question 15

​What are the LDC and FLUM?

Accepted Answer

Our Land Development Code (LDC), derived from our Comprehensive Plan, contains our City’s land use and zoning regulations.
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The FLUM or Future Land Use Map lays out the City’s various zoning districts.

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