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Alternate Number:
AX-13-001-0079
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Closed Date:
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Sep 27, 2013
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Sep 9, 2013
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Sep 12, 2013
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404-141-02-01_ 141_a(2) Copy of Controlled and Major Correspondence Record of the EPA
Administrator and other senior officials - Electronic.
Daily Reading File - Renewable Fuel Standard
AA-OAR-Prepare draft response for signature by the Assistant Administrator for OAR
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OEAEE - Office of External Affairs and Environmental Education
OP - Office of Policy
R6 - Region 6 -- Immediate Office
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Kay Larsen
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OAR-OTAQ-CD
Sep 23, 2013
Sep 13, 2013
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DX-Respond directly to this citizen's questions,
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Page 1of2
0)
EPA Letter
Septt:mbcr 9. 2013
Page 2 of2
It was never the intent of the RFS to cause RIN s to be a market attracting speculation and picking
winners and losers by historical position. RINs were necessary to give the industry flexibility to
meet the Renewable Volume Obligation (RVO) and as a way for tracking compliance. Obligated
parties should be blenders, not refiners and importers, as they are the party that generates the RIN
and thus, since they are marketing a finished fuel, meeting the obligation.
E-10 is widely accepted. Advance ethanol, which requires sugar cane based ethanol, is actually an
import mandate. Though significant money has been invested in cellulosic ethanol, including
money by Valero, it is still basically nonexistent with only very small volumes expected.
Concerning biodiesel and renewable diesel, supply is coming to the market, including Valero's new
JV renewable diesel plant in Louisiana.
Because of the mandated volume vs. the actual gasoline demand, E-10 consumption and lack of
cellulosic supplies, the program is infeasible. The mandated volume cannot be met by the
marketplace. The financial penalty the high RINs is causing is huge for those that are not integrated
with controlled retail volumes and huge for consumers. In a way, the program is hurting
competition and helping supplies that certainly do not need it.
We support E-10, biodiesel and renewable diesel at the B-2 and B-5 levels depending on blending
and seasonality, some incentive for cellulosic, but we do not support an import mandate for
advanced or higher ethanol percentages than E-10, except E-85. High RINs prices are not a fair or
acceptable way to force higher ethanol volumes.
You have the flexibility to waiver volumes which will lower the price of RINs now, will lower the
cost to the consumer and make the marketplace fair. We need the waiver now. Congress, with the
Administration, should develop an alternate RFS that encourages the development of the business,
but also represents the real world.
Sincerely,
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AX-13-001-0082
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Sep 11, 2013
Sep 12, 2013
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404-141-02-01_141 _b Controlled and Major Corr. Record copy of the offices of Division
Directors and other personnel.
Daily Reading File - Support for increasing the 2014 volume requirement for Biomass-based
Diesel under the Renewable Fuel Standard
DX-Respond directly to this citizen's questions, statements, or concerns
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OEAEE - Office of External Affairs and Environmental Education
OP - Office of Policy
R7 - Region 7 -- Immediate Office
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Page 1of2
at
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AX-13-001-0131
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Sep12,2013
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401_127_a General Correspondence Files Record copy
Daily Reading File - Support for increasing the 2014 volume requirement for Biomass-based
Diesel under the Renewable Fuel Standard
For Your Information -- No action required
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OEAEE - Office of External Affairs and Environmental Education
OP - Office of Policy
R1 - Region 1 -- Immediate Office
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lattice
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IJacqueline Leavy
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Page 1of2
Moritz, Brigette
From:
Sent:
To:
Cc:
Therefore, we are requesting a reasonable Biomass-based Diesel volume increase above the estimated actual
production for 2013, or at least 1.7 billion gallons.
r.~--~--~--~--~-~-~-;.~~~--~~--~~~~~-~~~-~~x~~.fI~~~~Y.~.-~.-~.-~.-~.j
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