Brazilian Sugarcane Industry Association (UNICA) • 1711 N Street NW • Washington, DC 20036

Phone +1 (202) 506

5299 • Fax +1 (202) 747

5836

• washington@unica.com.br • www.unica.com.br/EN

July 20, 2009

VIA ELECTRONIC MAIL

Environmental Protection Agency

Air and Radiation Docket and Information Center

Mailcode: 6102T

1200 Pennsylvania Avenue, NW

Washington, DC 20460

Submission of CommentsClean Air Act Waiver to Increase the AllowableEthanol Content of Gasoline to 15 PercentDocket EPA-HQ-OAR-2009-0211

To Whom It May Concern:

The Brazilian Sugarcane Industry Association (UNICA) welcomes the opportunity to providespecific comments to the U.S. Environmental Protection Agency (EPA) in support of the requestfor a Clean Air Act waiver to increase the allowable ethanol content of gasoline to 15 percent(Docket ID No. EPA

-HQ-

OAR

2009

0211).As the largest representative organization of the Brazilian ethanol industry, our extensiveexperience with low, medium and high ethanol content blends is highly relevant to EPAconsideration of approving the use of higher than 10% ethanol blends in U.S. gasoline. Ourcomments in this letter are structured as follows: (I) Introduction of UNICA’s expertise withethanol blends; (II) Brief review of the Brazilian experience with ethanol

gasoline blends; (III)Key technical aspects in support of the waiver application; and, (IV) Conclusion.

In short, UNICA respectfully recommends that EPA increase the allowable ethanol content of gasoline to 15 percent (E15) or consider an alternative blend higher than 10 percent. Asdescribed below, nearly a century of Brazilian experience with ethanol blended fuels at 15percent and higher demonstrates that

such fuels can lead to significant environmental andgreenhouse gas benefits without environmental concerns or technology modifications thatdiffer from those of E10. Thus, UNICA submits the comments below to reinforce that EPA canraise the allowable ethanol

content to achieve its goals of

realizing technologically feasible, costefficient improvements that lead to real environmental benefits.

UNICA Comments on

E-15 Waiver

Page 2Docket ID No. EPA-HQ-OAR-2009-0211

UNICA’S EXPERTISE IN ETHANOL BLENDS

The Brazilian Sugarcane Industry Association (UNICA) is the leading trade association for thesugarcane industry in Brazil, representing nearly two

thirds of all sugarcane production andprocessing in the country. Our 128 member companies are the top producers of sugar, ethanol,renewable electricity and other sugarcane co

products in Brazil’s South

Central region, theheart of the sugarcane industry. Brazil is the world’s largest sugarcane

producing country withover half a billion metric tons of cane harvested yearly.Last year, Brazil produced over 31 million tons of sugar and about 27.5 billion liters (7.3

billiongallons) of

sugarcane

ethanol. In addition, the mills generate their own power from thesugarcane feedstock. Official government data indicates that sugarcane mills producedapproximately 16,000 GWh

of electricity (corresponding to about 3% of the country’s annualelectricity demand) last year.

As a result of Brazil’s innovative use of ethanol in transportation and biomass for cogeneration,sugarcane is the leading source of renewable energy in the nation, representing 16% of thecountry’s total energy needs according to official government data. Our industry is expandingexisting production of ethanol

derived renewable plastics and, with the help of innovative U.S.

based companies, soon will offer b

io-

based hydrocarbons that can replace carbon

intensivefossil fuels. Partnerships and close relations between the sugarcane sector and multinationalcompanies has been extensive and involves a variety of services and goods such as cellulosicethanol research; supply of agricultural technology, products and machinery; processautomation; cogeneration equipment; auto

parts; motor vehicles; ethanol production; anddevelopment of bio

plastics and trading.

II.

REVIEW OF BRAZILIAN EXPERIENCE WITH ETHANOL-GASOLINE BLENDS

This section of our comments reviews the Brazilian experience with ethanol

gasoline blendsboth from a policy as well as from a technical aspect. Each section will begin with a summary,followed by a more detailed analysis.

Evolving Policy that Increased Ethanol Blends to 25% in Brazilian Gasoline

Brazil’s successful experience with ethanol-blends in gasoline goes back to the early 1900s.During our century of experience with ethanol blends and a steady path of incremental changes,all vehicles and engines in Brazil –– on and off road, as well as small engines –– that rely ongasoline fuels operate with ethanol blends up to 25 percent. There is no “pure” gasolineavailable for sale in Brazil today. Throughout these many changes in ethanol’s blend content,there were very few incidents where the existing fleet had to undergo engine re-tuning or recalibration or where there were noticeable negative effects on emission control systems over the useful life of the engine.

See “Attachment 1” for a detailed chronology of the various ethanol blends approved for gasoline in Brazil, both national and

at a regional level.

UNICA Comments on

E-15 Waiver

Page 3Docket ID No. EPA-HQ-OAR-2009-0211

In 1929, the sugarcane industry in Brazil wasseriously affected by start of the Great Depression. Inaddition to the economic crisis looming, which hadsuppressed sugar demand,

the sugarcane crop in1929 was very large, further depressing sugar prices.An answer to this dual

problem

–

low sugar demand,high cane crop

–

was urgently needed.Based on previous experiments in Brazil andelsewhere blending ethanol to gasoline, it w

as clear

then

– as it is today –

that ethanol

gasoline blendswork well with existing spark

ignition engines.

With this experience in hand, producing ethanolfrom surplus sugarcane and blending the renewable fuel with gasoline became a practical wayto balance the sugar market and create an alternative product for the sugarcane industry andan alternative source for necessary energy and fuels. The government and industry actedquickly, and in 1931 Federal Decree Nº 197.717 required gasoline to contain a minimumvolume of 5% ethanol (E5). The government also ordered that its own vehicle fleet use E10 inorder to demonstrate the feasibility of higher ethanol content blends and evaluate ethanol as afuel extender since all gasoline consumed in Brazil was imported.During the next decade, various efforts were undertaken to increase the use of ethanol. In1933, an ethanol oversupply in Northeastern States led to ethanol

gasoline blends containing40% ethanol (E40). In 1938, Federal decree Nº 737 extended the 5% ethanol blend mandate tothe gasoline produced domestically by the newborn oil refining industry. The following year,approximately 38 million liters of ethanol (10 million gallons) was blended into gasoline.As World War II complicated Brazil’s ability to import petroleum products, due partly to thesubmarine threats to oil tankers in the Atlantic, only a limited supply of gasoline was availablefor Brazilian vehicles. As with many other countries, Brazil had to implement fuel rationing toavoid the collapse of the domestic transportation system, critical for a continental country suchas Brazil. The government again turned to the sugarcane industry for assistance in what wasthen considered emergency measures. The industry responded quickly to meet the demand leftby gasoline and, by 1944, vehicles in Brazil’s largest city, São Paulo, were running with blends of up to 85% ethanol to gasoline.

At the end of the war, the recovery of the sugar prices and return of affordable and accessibleoil undermined the supply and demand of ethanol fuel. Despite the lower economic and

energy-

related importance of blends in this era, however, such blended fuels continued to be

Starkman, E., H. Newhall, and R. Sutton.

Comparative Performance of Alcohol and Hydrocarbon Fuels

. Tech. University of California: SAE International, 1964. Print. Ser. 640649.

Cytrynowicz, Roney.

Guerra sem guerra a mobilização e o cotidiano em São Paulo durante a Segunda Guerra Mundial

. SãoPaulo, SP, Brasil: Geração Editorial, Ed USP, 2000. Print

In this 1920s figure, the Brazilian Agriculture Ministry isrunning a vehicle with ethanol