MEMORANDUM

TO: EPA Docket ID No. EPA-HQ-OAR-2015-0111

FROM: Paul Argyropoulos, Office of Transportation and Air Quality, US EPA

DATE: Meeting Date was October 22, 2015

SUBJECT: Meeting with representatives UNICA and Dentons

EPA Attendees: Paul Argyropoulos

Dallas Burkholder

David Korotney

Paul Machiele

NBB Attendees: James Rubin, Dentons

Leticia Phillips, UNICA

Meeting Summary:

The representatives provided general comments on their positions on the proposed RFS Volume 

Rule and some additional verbal updates on Brazilian sugarcane crop reports and projections for 

ethanol export volumes. A follow-up email was submitted later and is included in the text of this 

memo to the docket.

Text from 10-17-15 Email from Leticia Phillips to Paul Argyropoulos

Dear Paul,

As promised, please find attached the document that reflects the numbers I gave you in regards 

to Brazilian sugarcane ethanol production for this harvest. We have also included information 

regarding exports to China. In regards to the INDC proposal of Brazil to the UN, and the 

numbers the government was projecting for ethanol production by 2030, I have found the video 

of the Minister of Mines and Energy, Eduardo Braga, confirming the 50 billion L mark for 2030. 

President Dilma was also present in the event - that took place last week in Piracicaba- and she 

reconfirmed Brazil's commitment to increase ethanol production and participation in the fuel mix 

as part of the country's commitment at COP21 in Paris. I tried to translate the passages of the 

speech, but it seems like president Dilma confused billion liters to million tons, when repeating 

what Minister Braga said. In any case, below the link to the video and my attempt translation of 

these moments.

Please let me know if you have any questions or need any additional clarification.

Best regards,

Leticia

https://www.youtube.com/watch?v=jxBnQ0ZAeA4&feature=youtu.be
Minute 22:32 Minister Eduardo Braga: “and today, here, we saw, Beth something that nurtures 

and justifies the speech and commitment that our country, through our president Dilma made of 

going from 30 billion liters of ethanol to 50 billion liters of ethanol. Governor, this is not a small 

challenge, but the pioneer model that CTC implements here...

Minute 44:08 President Dilma Rousseff: In December we will participate in the COP21, in 

December we need to show how we will meet our goal, that it is a ambitious goal, the goal of, 

based in 2005, reducing our GHG emissions in 43%. One of the basis of this reduction is of 43% 

is for sure in the fuel matrix, which is the most difficult segment to promote GHG emissions 

reduction in the world. We have one advantage here, no car in Brazil move in this country 

without ethanol. We built this along the years. We are committing ourselves to an ambitious goal 

for ethanol, like Minister of Mines and Energy said from (30 to 50 million tons) of ethanol in our 

fuel matrix. I am sure that, after July when I saw the production of cellulosic ethanol, and also 

after seeing all the technological innovation here today, we are able to meet and probably exceed 

this goal. We know this conference will be an important moment for us to show the world how 

we produce ethanol here and what is the future we map for this area of activity. Be sure that we 

will make this clear in December in Paris, we will make clear that our goals are not only 

achievable but Brazil will show, once more, that this renewable energy is, without a doubt, what 

the world expects from us in this area.

Attachment
Updated Information on Brazil’s Sugarcane Production – October 2015

1. 2015/2016 Harvest estimate - Brazil

Source: UNICA. Note: 1thousand ton; 2million liters. 3ATR is equivalent to TRS - acronym used to "Total Recoverable Sugars". Note: corn 

ethanol production by the Center-South region is considered.

2. Sugarcane crushing history and ethanol and sugar production in Brazil – 1990/91 to 

2015/16 (estimate)

Source: UNICA and MAPA. 2015/16 – estimate.

The 2015/2016 harvest will reach a new record of ethanol production in Brazil, and should 

exceed the 30 billion-liter mark – an increase of more than 1.5 billion liters if compared to the 

previous harvest (2014/2015), which reiterates the existence of a high production capacity 

installed in the country.

2014/2015 2015/2016-e

 632.127 657.100 3,95%

 35.548 34.100 -4,07%

 12.095 12.002 -0,76%

 16.300 18.062 10,81%

 28.394 30.064 5,88%

 85.640 86.746 1,29%

135,48 132,01 -2,56%

sugar 43,56% 41,26% -5,30%

ethanol 56,44% 58,74% 4,09%

Hydrous ethanol 2

Total ethanol 2

ATR 1

ATR/ ton of sugarcane 3

Share (%)

Crop year

Products

Var. (%)

Sugarcane 1

Sugar1

Anhydrous ethanol 2
The sugarcane crushing should reach its historical record on the current agricultural cycle. In 

contrast, the projected sugar production for the 2015/26 harvest shows the lowest result of 

the last 5 harvests (i.e. from the 2010/11 to 2014/15 harvest, the manufactured amount of 

sugar was superior than the estimate value for the current agricultural cycle – 2015/16). This 

behavior reflects the permanence of a production mix that favors ethanol production, 

following the historical pattern (graphic 3). 

3. Historical evolution of the destination of the sugarcane processed by the CenterSouth region. Values in %

Source: UNICA.

It is estimated that the quantity of left over sugarcane (“bisada” cane)1 may reach 30 million 

tons, leading the expectations of an early start to the next harvest (2016/2017). These 

characteristics refer to a probable bigger offer of ethanol and sugarcane for the 2016/17 

harvest, when compared to the current harvest results (2015/16), even if the canefield is 

aging. 

With regards to the Brazilian exports of ethanol, it is estimated that it will exceed in up to 0.5 

billion liters the volume commercialized in the previous cycle (2014/2015) of 1,39 billion 

liters. From April (beginning of the crop) to September (last month for which statistical data is

available), Brazil exported 786 million liters. Today is projected the total volume exported in 

the current harvest add to about 1,8 billion liters. 

																																																							 1 Sugarcane unmilled in the current harverst and, therefore, available for harvest in the next agricultural cycle 

(2016/2017)
4. Ethanol exports from Brazil. Values in millions of liters. 

Source: SECEX – Brazilian Secretariat of Foreign Trade

The volume exported from Brazil to China in September 2015 reached unprecedented 73 

millions of liters. In the accumulated of April 2015 to March 2016 there are indications that 

the total exports to the Chinese market will total 180 million liters – i.e., more than 100 million 

liters remain to be exported. It is believed that this peak export to China is an one-off event; 

a window of opportunity that arose, as shown in the historical data below. China does not 

appear as a traditional destination to Brazilian ethanol.

Along these lines, it is noteworthy that the arbitration between prices charged defines the 

commercialization of biofuels between market agents.

5. Ethanol exportation from Brazil to China. Values in m3

Harvest Brazilian Exports (a) Brazilian Exports to China (b) Percentage (b/a)

Source: SECEX. *accumulated April to September

Safra Exportação Brasil 

(a)

Exportação Brasil 

para China (b)

Participação 

(b/a)

2005/06 2.615.622 0 0,000%

2006/07 3.691.610

2007/08 3.624.823 47 0,001%

2008/09 4.721.898 4.046 0,086%

2009/10 3.165.592

2010/11 1.905.621 24 0,001%

2011/12 1.892.026 14.944 0,790%

2012/13 3.482.800

2013/14 2.605.640

2014/15 1.393.891

2015/16* 786.024 89.567 11,395%
Additionally, there is a regulation in China that restricts the use of imported ethanol as fuel. 

Only government agencies (SOE) are authorized to import fuel ethanol and, even then, 

these imports are commonly performed only as a test to check the country’s viability to 

import biofuel. 

In the current line up of ethanol there is no chartered ship to China.