COSMO BIOFUELS GROUP 

February 7, 2014 

U.S. Environmental Protection Agency 

Office ofTransportation and Air Quality 

Re: Jatropha RFS2 Pathway Petition 

Insights Into Jatropha Projects Worldwide 

To Whom It May Concern: 

Richard Palmer, CEO of Global Clean Energy Holdings, asked for Cosmo Biofuels Group's assistance in 

clarifying the status of several large-scale Jatropha curcas projects referenced in a recently published 

survey of global jatropha projects, specifically those located in China, India, Malaysia and Indonesia. 

We understand the primary investigator sourced its data by requesting industry players and consultants 

to estimate jatropha hectarage which constitute their basis for concluding that there were jatropha 

projects that constitute the over 1 million hectares, the bulk of which are in Asia in the above mentioned 

countries. As there are no official and primary statistics from which to estimate actual productive 

acreage in the aforementioned four countries, such conclusions remain speculative. 

Background 

Cosmo Biofuels Group/ Ark Bio Sdn Bhd which is actively engaged in South East Asia establishing 

integrated rubber, oil palm and jatropha curcas plantations, biodiesel downstream processing and 

trading activities in the Asia Pacific region; use of oil palm biomass for second generation biofuel and 

biofertiliser, including biogas capture for electricity generation. 

Ark Bio Sdn Bhd is the research, development and commercialisation arm of the Group and is currently 

developing a regional network of Green Resources Organic World (GROW) Centres for integrated 

organic farming. The company also develops algae projects through its proprietary Applied Licencing for 

Production and Harvesting Algae (ALPHA) platform and other agricultural projects in South East Asia. 

The Cosmo Biofuels Group as a biofuels project developer supplies both the upstream and downstream 

technological know-how and monitor the quality aspects so as to adhere to local and international 

standards of the products and by-products in the market. 

Unit 8-3, 3'd Mile Square, Jalan Kelang Lama, 

58200 Kuala Lumpur Malaysia. 

enquiries@cosmobiofuels.com 

Tel +603 7451 6877 
Feedback 

The survey indicated that China, India, Malaysia and Indonesia combined have approximately l.lmm 

hectares under cultivation spread across approximately 20 projects. We can safely say, being active in 

this region in jatropha for the last 8 years that such large scale hectarages, although once planned and 

discussed were never brought to bear for several reasons, among which is the lack of sufficient 

productivity in jatropha especially in comparison to existing crops like Oil Palm. 

A number of these projects were also politically driven with ulterior motives and they fell flat after 

receiving governmental support when supply chains were never effectively established to make the crop 

viable to the farmer. Nevertheless existing jatropha hectarage may still reside mainly in mixed farming 

and in small scale holdings for in-situ uses for fuel and other applications such as biofertilizer 

production. 

We know for sure that Malaysia does not have the numbers cited and as for for China, India and 

Indonesia, there could still be substantial hectarages but only in the thousands of hectares, not 

the hundreds of thousands as cited. 

Sincerely, 

Khoo Hock Aun 

CEO/Managing Director 

Cosmo Biofuels Group 

Unit 8-3, 3"' Mile Square, Jalan Kelang Lama, 

58200 Kuala Lumpur Malaysia. 

enquiries@cosmobiofuels.com 

Tel +603 7451 6877