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September 5, 2013

The Honorable Gina McCarthy

United States Environmental Protection Agency
William Jefferson Clinton Federal Building
1200 Pennsylvania Avenue, NW
Washington, DC 20460

Dear Administrator McCarthy:

As three of the largest independent biodiesel producers in the United States, we are writing to
express our concern about the Environmental Protection Agency's recent announcement that it
If pursued, this course of
may reduce the advanced biofuel volumetric requirement for 2014.
action could have significant negative impacts on the biomass
-based diesel industry, as the
biomass-based diesel volumetric requirement is embedded within the overall advanced b iofuel
Our three companies alone have a combined annual name -plate biodiesel production capacity of
over 350 million gallons in both Washington State and Texas . As early movers in the industry,
we have weathered the regulatory cycles and outside pressure as this industry matures.
Throughout this process, each of us has continued to reinvest money to further enhance our
production capabilities, provide local jobs and enhance key critical infrastrncture necessary to
In addition, we continue to invest in research and
continue the success of this program.
development for the next generation of advanced biofuels.
As a result of the hundreds of million of dollars we and others have invested in our facilities,
domestic production of biomass-based diesel is one of the most significant success stories of the
RFS. The domestic biomass -based diesel industry is currently producing over 166 million
gallons of fuel per month -- an annual rate of nearly two billion gallons -- and the industry has
far more available capacity for increased demand in 2014 and beyond. This current production
rate translate s to over three billion advanced biofuel -equivalent Renewable Identification
Numbers (RINs) available to enable obligated parties to meet their volumetric requirements from
domestic production and feedstocks . This success demonstrates that domestic biomass-based
diesel and other advanced biofuels can meet the current and future growth of the RFS2 's broader
advanced biofuel volumetric requirements, as they are currently doing to meet the 2013 volume
requirement despite shortfalls in the cellulosic fuel category.
With respect to the 2014 annual volumetric requirement for biomass
-based diesel: we
recommend that the EPA require at least 2 billion gallons, based upon current production levels
and a realistic assessment of the available capacity of current domestic bio diesel and renewable

CREW FOIA 2014-006851-0001912

diesel producers and feedstocks. This request for a 2 billion gallon level assumes that no new
-based diesel
pathways are approved by the EPA for production in 2014 in the biomass
category. IfEPA anticipates approving additional pathways that will make eligible significant
new volumes of imported fuel for the biomass-based diesel category during 20 14, we urge EPA
to adjust the volume upward from this request to accommodate these anticipated new
volumes. Further, we would like to highlight our concern that setting a 2014 requirement below
the 2 billion gallon level will result in decreased domestic production, worker layoffs and a pull
back from new investment in capacity in this sector of the RFS.
It is imperative to our nation's clean energy future, and to preserving the important gains made

by this new industry, that the Obama Administration maintain the vigorous support for the RFS2
that it has shown to date. We appreciate your leadership on this issue, and the efforts you have
made during your tenure to implement and expand the RFS2.
Thank you for your consideration of our concerns about the program going forward. If you have
any questions regarding these concerns, please
do not hesitate to contact us or Bob Van
Heuvelen of Van Heuvelen Strategies at 202-534-4920.

John Plaza
CEO, Imperium Renewables

Jonathan Phillips
COO, Renewable Biofuels

Martin D. Beirne, III

CEO, Green Earth
Fuels of Houston

CREW FOIA 2014-006851-0001913