Postell-Glover, Eliska 

From: Nanette Miller [NMiller@nclasvegas.com] Sent: Thursday, December 05, 2013 5:55 PM 

To: Group A-AND-R-DOCKET; Mccarthy, Gina 

Cc: oecc@who.eop.gov ; agsec@usda.gov ; dmancini@omb.eop.gov ; hshelanski@omb.eop.gov ; Brandon Buff 

Subject: Proposed 2014 RFS standard 

Attachments: EPA RFS letter 12.05.2013.pdf

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C:-» Nanette Miller

Accounting Manager

Biodiesel of Las Vegas ^' • 

5233 East EI Campo Grande ^ rNv


N Las Vegas, NV 89115 

main; 702.942.4395 ext 207 

fax: 702.543.5981 

nmiller@nclasvegas.com

www.biodieseloflasvegas.com

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4

,,:iodiesel OF LAS VEGAS 

Re: Docket ID No. EPA-HQ-OAR-2013-0479 

Air and Radiation Docket and Information Center 

Environmental Protection Agency 

Mailcode: 2822T 

1200 Pennsylvania Ave. NW 

Washington, DC 20460 

Email: a-and-r-docket c^i?.epa.gov 

Administrator Regina A. McCarthy 

Environmental Protection Agency 

William Jefferson Clinton Federal Building 

1200 Pennsylvania Ave., NW 

Room 3000 

Washington, DC 20460 

Email: Mccarthy.gina(a)epa.gov

Dear Administrator McCarthy: 

I'm writing to urge the Administration to reconsider the proposed 2014 Renewable Fuel Standard (RFS) 

volumes for both Biomass-Based Diesel and Advanced Biofuel. As a supporter of the growing U.S. 

biodiesel industry, I am particularly concerned that this proposal would result in an immediate and 

dramatic drop in U.S. biodiesel production, causing dozens of plants to close and thousands of people to 

lose their jobs. I believe this is contrary to this Administration's strong position over the past five years 

supporting the development of Advanced Biofuels as part of an all-of-the-above energy approach for 

domestic energy production. 

As you know, biodiesel and the RFS are working successfully. Biodiesel is currently the leading EPAdesignated Advanced Biofuel in the country and the only Advanced Biofuel to reach 1 billion gallons of 

annual production. The industry has exceeded RFS requirements in every year of the program, topping 

the 1 billion gallon mark in each of the past three years. In 2013, the biodiesel industry is on pace for 

record production, with total volumes expected to reach at least 1.7 billion gallons. Further, since July, the 

5233 E. EI Camp Grande Ave. I N Las vegas. Nv 89115 1 Phone: 702.942.4395 1 www.biodieseloflasvegas.com
iodiesel 

OE LAS VFGAS 

industry has been producing at an even stronger pace of about 170 million gallons per month, or an 

annualized production rate of about 2 billion gallons. 

This production is helping to achieve our bipartisan goals for creating a stronger energy economy, 

strengthening energy security, reducing harmful emissions, and helping consumers by diversifying fuel 

supplies. However, the proposed RFS rule would set the industry back significantly by limit'ng production 

to 1.28 billion gallons. And because some excess 2013 production could be carried over in , o 2014 for 

RFS compliance purposes, the actual 2014 production would likely be even lower than the 1.28 billion 

gallon proposal. Further, the biodiesel proposal is particularly damaging because it would limit production 

for two years, in both 2014 and 2015. 

That is a severe cut that would have devastating effects on the industry. A recent study fou id that 

employment supported by the biodiesel industry would drop by almost 8,000 jobs. Smaller ,ompanies 

would be particularly hurt, many of them built by entrepreneurs who invested their time and resources into 

growth based on the promises of the RFS and the unequivocal support that the Obama Ad,ninistration 

signaled over the past five years. 

The biodiesel industry has made great strides in recent years. Increased production has been fueled by 

an increasingly diverse mix of feedstocks, and the industry's growth is fueling the developrr ent of new 

feedstocks like camelina and algae. The industry is now supporting more than 62,000 jobs, with plants in 

almost every state in the country. And according to EPA's own calculations, each gallon of oiodiesel that 

displaces a gallon of petroleum diesel reduces greenhouse gas emissions by 57 percent to 86 percent. 

This is an unmitigated success story, and I strongly encourage you to continue the momen=.um by 

approving a modest volume increase for biomass-based diesel. Specifically, I urge you to establish a; 

2014 volume that is at a minimum consistent with this year's projected production of 1.7 billion gallors, 

and to postpone any 2015 proposal because EPA does not have enough information at this time to 

reasonably make that determination. 

Best Regards, 

Brandon Buff 

Biodiesei of Las Vegas 

5233 E. EI Campo Grande Ave. 

Las Vegas, NV 89115 

CC: 

Dan Utech 

Director for Energy and Climate Change 

White House Domestic Policy Council 

1600 Pennsylvania Avenue NW 

1 5t Floor, West Wing 

5233 E. EI Camp Grande Ave. I N. Las vegas. Nv 89 i I S I Phone: 702.942.4395 1 Www•biodieseiottcsvegas.com
4

iodiesel 

OF t A$ vFrAS 

Washington DC 20500 

Email: oecc(a)who.eop.gov

Administrator Howard A. Shelanski 

Office of Information and Regulatory Affairs 

Office of Management and Budget 

Eisenhower Executive Office Building 

1650 Pennsylvania Ave., NW 

Room 262 

Washington, DC 20503 

Email: HShelanski(cDomb.eoD.qov; dmancini(a)omb.eop.gov

Secretary Thomas Vilsack 

US Department of Agriculture 

Office of the Secretary 

Jamie L. Whitten Building 

1400 Independence Ave. SW Room 200-A 

Washington DC 20250 

Email: agsec^?a usda.qov 

5233 E. EI Camp Grande Ave I N. I as vegas, NV 891 1 5 1 p hone: 102 94?A395 1 www bioaieseloFlasvegas.com