### 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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### 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

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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