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September 5, 2013

The Honorable Gina McCarthy Administrator 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 may reduce the advanced biofuel volumetric requirement for 2014. If pursued, this course of

action could have significant negative impacts on the biomass

biomass-based diesel volumetric requirement is embedded within the overall advanced b requirement.

-based diesel industry, as the


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 continue the success of this program. In addition, we continue to invest in research and 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.

-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

With respect to the 2014 annual volumetric requirement for biomass

diesel and renewable

CREW FOIA 2014-006851-0001912

diesel producers and feedstocks. This request for a 2

billion gallon level assumes that no new

pathways are approved by the EPA for production in 2014 in the biomass


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

production, worker layoffs and a pull

the 2 billion gallon level will result in decreased domestic

back from new investment in capacity in this sector of the RFS.

-based diesel make eligible significant

IfEPA anticipates approving additional pathways that will

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

Heuvelen of Van Heuvelen Strategies at 202-534-4920.

do not hesitate

to contact us or Bob Van


do not hesitate to contact us or Bob Van Sincerely, John Plaza CEO, Imperium Renewables Jonathan

John Plaza CEO, Imperium Renewables

us or Bob Van Sincerely, John Plaza CEO, Imperium Renewables Jonathan Phillips COO, Renewable Biofuels Martin

Jonathan Phillips COO, Renewable Biofuels

Renewables Jonathan Phillips COO, Renewable Biofuels Martin D. Beirne, III CEO, Green Earth Fuels of Houston

Martin D. Beirne, III CEO, Green Earth Fuels of Houston


CREW FOIA 2014-006851-0001913