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.

T he 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 need s to be increased
to align with the f uture 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 fore cast , this will encourage the producti on 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. c ould finally boast a consistent and aligned energy and environmental policy for the transportation sector.
Conventional, advanced , and cellulosic biofuel productions analyse s continue to demonstrate reduc tions in greenhou se 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 transition al period as the industry works collectively towards the optimization of the on
- road vehicle fleet in syn chroniz ation with making available the fuel of the future

- which the agri cultural 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 e thanol and gasoline demand project ion levels in the EPA calculations 2. Use E

- 10 blends as the base and include any ethanol beyond that as part of E

- 8 5 usage 3. Incorporate more accurate FFV projection s 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 f arm ing community and the ethanol industry responded to and delivered the supply t o meet the

d emand put into place by the Renewable Fuel Standard (RFS)

- this was achieved through increas ed 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 market place to allow consum ption of the renewa ble fuel volumes mandated by the RFS.
Again, thank you for meeting with us. We believe in cooperation, col laboration, and coordination and would welcome the opportunity to continue these meetings and discussions with you and the EPA staff as we work tog ether to make a better future . Soon, w e will be forwarding you additional relevant E

- 85 sales information. Please feel free to contact me at 309

- 557

- 0912 for further discussion s or clarifications.
Sincerely,
Dave Loos, Illinois Corn Growers Association

P am 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