My name is Jim Nussle and I am the President and Chief Operating Officer for Growth Energy and I welcome this opportunity to present comments today on EPA’s Proposed Renewable Fuel Standards for 2012. I will be making a brief statem ent and we will be submitting our full, written comments to the docket.

Growth Energy is the leading trade association for America’s ethanol producers and supporters. Growth Energy promotes expanding the use of ethanol in gasoline, decreasing our dependence on foreign oil, and creating American jobs here at home.

The American renewable fuel industr y remains critical to the success of the RFS program, and to achieving its dual objectives of reducing petroleum fuel use and greenhouse ga s emissions. In 2010, renewable fuels successfully displaced nearly 10 percent of US transportation fuel, and reduced greenhouse gas emissions by 23 million metric tons. Due to our considerable experience and success in the fuel market, Growth Energy’s producers are poised to be among the first to produce cellulosic
ethanol and advanced biofuels in or der to meet the future requirements of the RFS program.

As part of its proposed standards for 2012, EPA has requested comments on its proposal to reduce the statutory cellulosic biofuel volume, and
whether the advanced biofuel and th e renewable fuel volumes should be reduced as well. Given the continued state of the economy and the lack of commercial volume, EPA’s proposal to reduce the cellulosic biofuel
volume to an intermediate value between 3.55 and 15.7 million gallonsis reasonable. Growth Energy also strongly supports EPA’s proposal not to adjust the 2012 statutory volumes for advanced biofuel and total
renewable fuel. The advanced biofuel volume would remain at 2 billion gallons and the total renewable fuel volume would remain at 15.2 billion gallons.

We believe that total renewable fuel volume should remain at the statutory required level to continue to support the market for renewable fuels and to provide certainty for investors and producers.

Growth Energy continues to request that EPA take all appropriate “demand side” actions to support the goals of the RFS program to allow the market to use 36 billion gallons of renewable fuel by 2022. We very much appreciate EPA’s approval of Growth Energy’s Green Jobs Waiver earlier this year for E15 and believe it will go a long way towards growing the market and attr acting investment in the further development of cellulosic ethanol and other advanced biofuels.

To further the goal of increasing demand, Growth Energy continues to advocate its “Fueling Freedom” plan that would promote the development of key infrastructure for intermediate ethanol blends through the rapid deployment of flex-f uel pumps and flex-fuel vehicles throughout the United States. Only by increasing the availability of higher ethanol blends to consumers can the ambitious goals of the RFS be achieved in future years.We do, however, have a couple areas of remaining concern. One area of
continued concern is the exclusion of corn-based ethanol from competition under the advanced biofuel pathway. When the Energy Independence and Security Act (EISA) was enacted, it included an arbitrary “corn discrimination clause ” that explicitly prohibits corn ethanol from even attempting to qua lify as an advanced biofuel – no matter what technological breakthr oughs may be achieved into the future. We believe that excluding corn ethanol risks many unintended consequences, such as increased cost, reduced supply pressures and market uncertainty. We would urge EPA to support any legislative changes that would allow conventiona l corn ethanol to qualify as an
advanced biofuel.

Another significant concern that faces not only Growth Energy members, but a high number of regulated parties as well is the issue of transfer date required to be used on RINS. This issue was brought to the attention of the EPA a year ago. I have copies of letters signed collectively by Growth Energy, the Renewable Fuels Association, the
National Petrochemical and Refiners Association, and the American Petroleum Institute, all pleading for relief from the EPA on its reversal of interpretation on the RINS tran sfer date from RFS1 to RFS2.

I will not belabor the details of the s ituation, but want to state that our primary goal is to define an accepta ble compliance scenario whereby a
seller can construct a Product Transfer Document based on information in their possession rather than having to exchange actual delivery dates, on a transaction by transaction basis, with the buyer. While we
understand there are some concerns about enforcement of the RFS program if changes are made to the existing regulations, the 2012 RFS standards rulemaking provides a me chanism to address a technicalamendment on this issue. We enc ourage EPA to reconsider the stance you have taken on the RINS transfer date issue and continue to stand ready to work with you to find a reasonable compromise to satisfy all parties.

I appreciate your consideration of my statement and of Growth Energy’s written comments and we look forward to working with you to continue to meet the goals of the Renewable Fuels Standard.