TM 

February 3, 2014 

U.S. Environmental Protection Agency 

Office of Transportation and Air Quality 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

Re: Jatropha RFS2 Pathway Petition 

Insights Into Jatropha Projects Worldwide 

To Whom It May Concern: 

Mr. Richard Palmer, CEO of Global Clean Energy Holdings, asked for JOiI's assistance in establishing a 

more thorough understanding of 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. Due to confidentiality reasons we understand the primary investigator is unable 

to provide us the specific names or precise details of the projects that constitute the over 1 million 

hectares referenced in their published findings. With this information we could address the status of 

each project, but without it would only be speculation to estimate actual productive acreage in the 

aforementioned four countries. 

Background 

The businesses of JOiI (S) Pte. Ltd. include research on Jatropha plant biotechnology for the production 

of elite lines, development of tissue culture facilities and nurseries in Singapore and other worldwide 

locations, sale of elite Jatropha seedlings to prospective commercial cultivators, conduct breeding and 

agronomy research and advisory on the commercial cultivation of elite Jatropha seedlings. 

JOiI is supported by Temasek Life Sciences Laboratory Ltd. (TLL), Tata Chemicals Ltd, Toyota Tsusho 

Corporation and other investors. JOiI is also an active member of Jatropha Working Group of Roundtable 

for Sustainable Biofuels, and is committed to ensure sustainability. 

As the leading commercial jatropha organization in the region, and one of only a few in the world, we 

have a far reaching network of contacts and are intimately familiar with industry trends and activity, 

both regionally and globally. After being approached by Richard, we would like to provide the following 

feedback. 

~ \ 

~ 

JOiI (S) Pte . LtC7. company Reg No. 200817152Z 

1 Research Link, National University of Singapore, Singapore 117604 Tel: +65-6872 9890 Fax: +65-6872 9891 www.joil.com.sg 
TM 

Feedback 

On page 19 of the Jatropha survey a chart indicates that China has 274,559 ha (>6 projects), India 

265,422 ha (>6 projects), Malaysia 259,906 ha (1-3 projects) and Indonesia 256,545 ha (4-6 projects) for 

a total of approximately 1.1mm hectares. While several project sponsors planned very large areas 

several years ago, due to lack of funding, geopolitical obstacles, inadequate agronomic practices and 

poor business models, most projects were either suspended or abandoned. Even those that are 

surviving are very scattered and show very poor productivity of seeds per hectare. 

Estimating total project area, productive area and planted area is very difficult without specific details, 

but it is our professional opinion that the study's finding of approximately 1.1mm hectares in the region 

is inflated. Currently producing area is likely only a very small fraction of the area reported in the study, 

and each of those projects are relatively small, representing a few thousand hectares. Any substantial 

projects would be widely known in the industry and region, which they are not. 

The size of projects referenced in the study would make some of these farms the largest in the world 

with sizeable movements of finished products. Moreover, they would employ tens of thousands of 

workers while producing very large volumes of oil and meal that we would see and hear about in the 

market — a market we are involved in daily. 

Please advise if we can be of more service. 

Sincefely, 

Sriram Srinivasan ~ 

Chief Financial Officer 

JOiI (S) Pte Ltd 

+65 6872 9895 

www.ioil.com.s~ 

JOiI (S) Pte . ltG7. company Reg No. 200817152Z 

1 Research Link, National University of Singapore, Singapore 117604 Tel: +65-6872 9890 Fax: +65-6872 9891 www.joil.com.sg