## COSMO BIOFUELS GROUP February 7, 2014 U.S. Environmental ProtectionAgency Office ofTransportation and AirQuality Re:Jatropha RFS2 Pathway Petition Insights IntoJatropha Projects Worldwide To Whom It MayConcern: 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 ofglobaljatropha projects, specificallythose located in China, India, Malaysia and Indonesia. We understand the primary investigatorsourced its data by requesting industry players and consultants to estimate jatropha hectarage which constitute their basis for concluding that there were jatropha projectsthatconstitutetheover 1 million hectares,the bulkofwhich are in Asia in theabove mentioned countries. As there are no official and primary statistics from which to estimate actual productive acreage in the aforementioned fourcountries, 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 captureforelectricitygeneration. Ark Bio Sdn Bhd is the research, development and commercialisation arm ofthe Group and is currently developing a regional network of Green Resources Organic World (GROW) Centres for integrated organicfarming. The company also develops algae projectsthrough its proprietaryApplied Licencing for Production and HarvestingAlgae (ALPHA) platform and otheragricultural projects in South EastAsia. The Cosmo Biofuels Group as a biofuels project developersupplies both the upstream and downstream technological know-how and monitor the quality aspects so as to adhere to local and international standards ofthe products and by-products in the market.

Unit8-3, 3'd MileSquare,Jalan Kelang Lama, 58200 Kuala LumpurMalaysia. enquiries@cosmobiofuels.com Tel +603 7451 6877Feedback 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 8years 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 injatropha especially in comparison toexisting crops like Oil Palm. A number of these projects were also politically driven with ulterior motives and they fell flat after receiving governmental supportwhen supply chains were nevereffectivelyestablished 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 ofthousands as cited. Sincerely,

Khoo HockAun CEO/Managing Director Cosmo BiofuelsGroup

Unit8-3, 3"' MileSquare,Jalan Kelang Lama, 58200 Kuala Lumpur Malaysia. enquiries@cosmobiofuels.com Tel +603 7451 6877