August 5, 2013

Bill Charmley

EPA

Deputy Director Assessment and Standards

2000 Traverwood Dr.

Ann Arbor, MI 48105

Dear Bill Charmley, 

Thank you for meeting with us on Tuesday June 25 concerning the Guidance Letter sent to the 

automobile manufacturers regarding future credits for Flex Fuel Vehicles (FFVs). The discussions we had 

were very interesting and informative and could have easily lasted several more hours.

The group of agricultural companies, agriculture associations, and the three ethanol trade associations 

attending this meeting are all in agreement that the forecast of E85 usage in FFVs needs to be increased 

to align with the future usage of E85 in the marketplace. The FFV Guidance document as currently 

proposed will actually discourage the foreign manufacturers from introducing more FFVs into the U.S. 

market. Alternatively, by increasing the certainty of an accurate usage forecast, this will encourage the 

production of larger percentages of FFVs through 2022. In doing so, the USEPA will have aligned both 

the goals of the Energy Independence and Security Act with the goals of the CAFÉ/Greenhouse Gas 

Emissions Rules. The U.S. could finally boast a consistent and aligned energy and environmental policy 

for the transportation sector. 

Conventional, advanced, and cellulosic biofuel productions analyses continue to demonstrate reductions 

in greenhouse gas emissions compared to 2005 gasoline, with many of these processes showing more 

than 50 percent improvement. These potential reductions could be realized through more FFVs using 

higher blends of ethanol with an ultimate goal of optimizing vehicles in the future for a higher (minimum

floor) octane rated gasoline through higher ethanol blends. The FFV platform is vital to achieve success 

during this transitional period as the industry works collectively towards the optimization of the on-road 

vehicle fleet in synchronization with making available the fuel of the future - which the agricultural and 

ethanol sector are working on today.

We believe that the following changes to the FFV Guidance Letter will provide a more accurate forecast:

1. Adjust the ethanol and gasoline demand projection levels in the EPA calculations

2. Use E-10 blends as the base and include any ethanol beyond that as part of E-85 usage

3. Incorporate more accurate FFV projections

We are aligned with the domestic auto industry in proposing a more accurate F-Factor through 2019. 

This would be justifiable and, more importantly, provide an opportunity for all alternative fuels in 

meeting the goals prescribed by the 2017 GHG/ CAFE Standards.
The farming community and the ethanol industry responded to and delivered the supply to meet the 

demand put into place by the Renewable Fuel Standard (RFS) - this was achieved through increased

production of both the feedstocks and ethanol. This response increased our nations’ energy security 

and at the same time reduced greenhouse emissions. We stand ready to produce the biofuel gallons in 

the future to meet the RFS, energy security, and environmental goals. It then becomes critical for

compatible and capable vehicles to appear in the marketplace to allow consumption of the renewable 

fuel volumes mandated by the RFS. 

Again, thank you for meeting with us. We believe in cooperation, collaboration, and coordination and 

would welcome the opportunity to continue these meetings and discussions with you and the EPA staff 

as we work together to make a better future. Soon, we will be forwarding you additional relevant E-85 

sales information. Please feel free to contact me at 309-557-0912 for further discussions or 

clarifications.

Sincerely,

Dave Loos, Illinois Corn Growers Association

Pam Keck, National Corn Growers Association

William Behan, John Deere

Chris Bliley, Growth Energy

Terry Stone, Syngenta

Brian Jennings, ACE

Kelly Davis, Renewable Fuels Association

Kevin Coffman, Monsanto