UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON. D.C. 20460 


FEB 1 7 lOll 

THE AOMINISTRATOR 

Ms. Julie M. Sibbing 

National Wildlife Federation 

901 E Sireel, NW. Suite 400 

Wasrungton, D.C. 20004 

Dear Ms. Sibbing: 

This letter is in response to your May 24, 2010, petition to the U.S. Envirorunental 

Protection Agency for reconsideration of the final Regulation of Fuels and Fuel Additives: 

Changes to Renewable Fuel Standard Program, 75 FR 14670, March 26. 2010, and request for a 

stay for a ponion of that rule pending reconsideration. 

In yo ur petition, you requested reconsideration on the issue of the EPA's adoption of the 

"aggregate compliance approach" as part of implementing the requirements for renewable 

biomass for certain feedstocks gro\VJl in the United States. 

The EPA considers the renewable biomass provisions to be an important part of the 

renewable fuel standard program and has carefully reviewed the arguments and infonnation 

provided on this issue. For reasons discussed in detail in the enclosed response, the EPA is 

denying your petition for reconsideration and also denyi ng the request for an administrative stay 

pending reconsideration. 

We thank you for your interest in these issues, and the EPA looks forward to working 

with all stakeholders to implement the RFS2 program. Should you have any questions. please 

contact Paul Arg)'Topoulos in the EPA's Office of Transportation and Air Quality at (202) 564­

1123 or argyropoulos.paul@epa.gov. 

~ 

Sincerely, 

Lisa P. Jackson 

Enclosure 

Inlernel A(ldress (URL) • hl!p;lIwwN.epa gov 

Aeey<:iedl'Recyel.bI • • Printed Wl1h Vegetable Oil Based Inks on 100% PoslCOOsume •. Process Chionne Free Recycled Paper 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460 


FEB 1 7 2011 

THE ADMINISTRATOR 

Mr. Jonathan F. Lewis 

Ms. Helen D. Silver 

Clean Air Task Force Inc. 

18 Tremont Street, Suite 530 

Boston, Massachusens 02108 

Dear Mr. Lewis and Ms. Silver: 

This letter is in response to your May 24, 2010, petitions to the U.S. Environmental 

Protection Agency for reconsideration of the final Regulation of Fuels and Fuel Additives: 

Changes to Renewable Fuel Standard Program, 75 FR 14670, March 26, 2010, and requests for a 

SlaY pending reconsideration. 

In your petitions you raised concerns with two issues associ ated with the final RFS2 rule: 

the exclusion of the global "rebOW1d" effect in the lifecycJe analysis used in detennining 

compliance with the required greenhouse-gas-emissions thresholds for various renewable fuels 

and the adoption of the "aggregate compliance approach" as part of implementing the 

requirements for renewable biomass for certain feedstocks grown in the United Slates. 

The EPA considers the renewable biomass provisions and the lifecycle greenhouse-gas· 

emissions threshold requirements to be important parts of the RFS2 program and has carefully 

reviewed the argwnents and information provided on these tv..'o issues. For reasons discussed in 

detail in the enclosed response, the EPA is denying your petitions for reconsideration and also 

denying your requests for a stay of the rule pending reconsideration. 

We thank you fo r your interest in these issues, and the EPA looks forward to working 

with all stakeholders to implement the RFS2 program. Should you have any questions, please 

contact Paul Argyropoulos in the EPA's Office of Transporlation and Air Quality at (202) 564­

1123 or argyropoulos.pau1@epa.gov. 

Sincere ly, 

Lisa P. Jackson 

Enclosure 

Inlemet A!kress (URL) _ http:lMw"lY.apa.gov 

RecycledlRecye l.bI. _ Plinled wilh VlIgelabie 011 Based Inks 00 100% POSlconsumer. Process Chioline Free Recycle(! Paper 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON , D.C. 20460 


FEB 1 7 1011 

TI-£ ADMINISTRATOR 

Ms. Gina De Ferrari 

World Wildlife Fund 

125024'" Slreel, NW 

Washington, D.C. 20037 

Dear Ms. De Ferrari: 

This letter is in response to your May 24, 2010, petition to the U.S. Environmental 

Protection Agency for reconsideration of the final Regulation of Fuels and Fuel Additives: 

Changes to Renewable Fuel Standard Program, 75 FR 14670, March 26, 2010, and request for a 

stay for a portion of that rule peoding reconsideration. 

In your pelition, you requested reconsideration on the issue of the EPA's adoption of the 

"aggregate compliance approach" as part of implementing the requirements for renewable 

biomass for certain feedstocks grown in the United States. 

The EPA considers the renewable biomass provisions to be an important part of the 

renewable fuel standard program and has carefully re viewed the arguments and infonnation 

provided on trus issue. For reasons discussed in detail in the enclosed response, the EPA is 

denying your petition for reconsideration and also denying the request for an administrative stay 

pending reconsideration. 

We thank you for your interest in these issues, and the EPA looks forward to working 

with all stakeholders to implement the RFS2 program. Should you have any questions, please 

contact Paul Argyropoulos in the EPA's Office of Transporta tion and Air Quali£), at (202) 564­

1123 or argyropoulos.paul@epa.gov. 

Sincerely, 

Lisa P. Jackson 

Enclosure 

lnlamet Adc:Ires$ (URl) _ nnp:llwww epa.goy 

RacveledlRacy.:;lebie _ Ptinled with VegetaDleOll Based Inks on 100% POSlCOnsumer. Process Chionne Flee Recyc\«I Paper 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


WASHINGTON, D.C. 20460 


FEB 1 7 2011 

THE AOIo4 INISTRA TOR 

Mr. David Hirsch 

Managing Director 

Friends of the Earth 

1100 15th Street, NW, 11th Floor 

Washington, D.C. 20005 

Dear Mr. Hirsch: 

This lener is in response to your May 24, 2010, petitio n to the U.S. Environmenta l 

PrOlection Agency for reconsideration of the final Regulation of Fuels and Fue l Additives: 

Changes to Renewable Fuel Standard Program, 75 FR 14670, March 26, 2010, and request for a 

Slay for a portion of thaI rule pending reconsideration, 

[n your petition, you requested reconsideration 0 0 the issue of the EPA 's adoption ofthe 

" aggregate compliance approach" as part of implementing the requirements for renewable 

biomass for certain feedstocks grown in the United States, 

The EPA considers the renewable biomass provisions to be an important pan of the 

renewable fuel standard program and has carefully reviewed the arguments and information 

provided on this issue. For reasons discussed in detail in the enclosed response, the EPA is 

denying your petition for reconsideration and also denying the request for an administrative stay 

pending reconsideration. 

We thank you for your interest in these issues, and the EPA looks forward to working 

with all stakeholders to implement the RFS2 program. Should you have any questions, please 

contact Paul Argyropoulos in the EPA's Office of Transportation and Air Quality at (202) 564­

1123 or argyropoulos.paul@epa.gov. 

Sincerely, 

Lisa P. Jackson 

Enclosure 

Internet Address (UAL) . hc1pJ"-w.epa.gov 

Fleoeye~ecyc:l b4• • Prinled with Vegetable Oil Based Inks on 100"4 POSlCOnSurner. Process ChIoI"ine Free Aec:yc1eO Paper