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June 23, 2009


Environmental Protection Agency
Air and Radiation Docket and Information Center
Mailcode 2822T
1200 Pennsylvania Avenue, NW
Washington, DC 20460

Recommendation Against Extension of Comment Period
Regulation of Fuels and Fuel Additives:
Changes to Renewable Fuel Standard Program
Docket EPA-HQ-OAR-2005-0161

To Whom It May Concern:

The Brazilian Sugarcane Industry Association (“UNICA”) urges the Environmental Protection
Agency (“EPA”) not to extend the comment period for the proposed rule implementing changes
to the Renewable Fuel Standard program (the “RFS2 Proposed Rule”). See Notice of Proposed
Rulemaking, Regulation of Fuels and Fuel Additives: Changes to Renewable Fuel Standard
Program, 74 Fed. Reg. 24903 (May 26, 2009).

UNICA is the largest organization representing sugar, ethanol, and bioelectricity producers in
Brazil. UNICA members are responsible for more than 50% of all ethanol produced in Brazil and
60% of overall sugar production. UNICA’s priorities include serving as a source for credible
scientific data about the competitiveness and sustainability of sugarcane ethanol. The
association works to encourage the continuous advancement of sustainability throughout the
sugarcane industry and to promote ethanol as a clean, reliable alternative to fossil fuels. In fact,
gasoline is now alternative fuel in Brazil, with sugarcane ethanol using about 1% of Brazil’s
arable land and reducing greenhouse gases (“GHG”) by 90% compared to conventional
gasoline. Moreover, as a result of our innovative use of ethanol in transportation and biomass
for power cogeneration, sugarcane is now the number one source of renewable energy in
Brazil, representing 16% of the country’s total energy needs. And this industry is expanding
existing production of renewable plastics and, with the help of innovative companies here in
the United States, soon offering bio-based hydrocarbons that can replace carbon-intensive
fossil fuels.

Some entities have requested that EPA extend the 60-day comment period on the RFS2
Proposed Rule. Because the existing comment period is sufficient and because we believe

Brazilian Sugarcane Industry Association (UNICA) • 1711 N Street NW • Washington, DC 20036
Phone +1 (202) 506-5299 • Fax +1 (202) 747-5836 • •
UNICA Recommendation Against Extension of Comment Period Page 2

changes to this important program that incorporate critical renewable resources such as
sugarcane should be implemented without delay, UNICA and its members respectfully request
that EPA deny these requests and the comment period not be extended.

In addition to a public comment period, EPA has provided members of the public the
opportunity to testify at EPA’s hearing on June 9, 2009, and to participate in EPA’s workshop on
the proposed lifecycle GHG analysis on June 10-11, 2009. At the workshop, EPA explained its
proposed lifecycle analysis, identified major issues, and heard from panels of experts and
interested parties. UNICA representatives attended the hearing and workshop and expressed
our concerns that some of the methodologies used, particularly as it related to the indirect land
use change calculations, needs to be updated and based on the best available data and latest
research. At these events and in congressional testimony, however, EPA demonstrated that it
has been working hard to advance its approaches to the RFS2 program and to find the most
reasonable methodology and assumptions for calculating the GHG emissions impacts of fuels
for the final rule.

UNICA believes 60 days provides sufficient and adequate opportunity for interested
stakeholders to provide their input on EPA’s proposal and that, with this input, EPA will be well
positioned to finalize regulations implementing changes to the renewable fuel standard
program without delay. In contrast, extending the comment period would make it more
difficult for EPA to begin implementing the RFS2 regulatory program on January 1, 2010, as
proposed. The program, which is mandated under the 2007 Energy Independence and Security
Act, will help the United States increase its use of renewable fuels and, in turn, reduce its
dependence on foreign oil and lower GHG emissions. See The White House Office of the Press
Secretary, President Obama Announces Steps to Support Sustainable Energy Options,
Departments of Agriculture and Energy, Environmental Protection Agency to Lead Efforts (May
5, 2009).

For these reasons, UNICA respectfully requests that the comment period not be extended. The
association looks forward to submitting its comments on the proposed rule during the 60-day
time frame and to communicating further with EPA about this important program.

Respectfully Submitted,

Joel Velasco
Chief Representative - North America