### Provide r	of	Ag	Labor	and	Food	Safety	Solutions	for	you	to	be	successful! www.beiintl.com
01. 269.637.8541	Office

01. 269.637.4233	Fax 

## BEI	International,	LLC

1375	Kalamazoo	St. South	Haven,	MI	49090 From	the	desk	of Max	Lint January	9,	2014

U.S.	Environmental	Protection	Agency
Office	of Transportation	and	Air	Quality

Re:	Jatropha	RFS2	Pathway	Petition Insights	Into	Jatropha	Projects	Worldwide

To	Whom	It	May	Concern: Richard	Palmer,	CEO	of	Global	Clean	Energy	Holdings,	asked for	BEI’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	an d	Indonesia.	Due	to	confidentiality	reasons	we	understand	the primary	investigator	is	unable	to	provide	specific	names	or	precise	details	of	the	projects	that constitute	the	over	1	million	hectares	referenced	in	their	published	findings.	With	this
informat ion	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 BEI	International	is	a	global	leader	in	specialized Ag	Labor	Solutions, harv esting	equipment	and has	developed	the	only	mechanical	harvester	suitable	for	Jatropha.	We	have	participated	in	pilot projects	throughout	the	world	and	are	very	familiar	with	industry	trends,	project	developers	and regional	producers.

As	a	leading	supp lier	of	technical	services	to	commercial	Jatropha	operations	globally,	and	the producer	of	the	only	mechanical	harvester	for	Jatropha	available	in	the	marketplace,	we	have	a far	reaching	network	of	contacts	and	are	intimately	familiar	with	global	industry trends	and activity.	From	this	unique	market	leading	position,	we	are	able	to	participate	in	many	stages	of planning,	implementation	and	operation	of	large

- scale	farming	operations,	the	type	where mechanical	harvesting	is	economical. In	2013,	we	had	appro ximately	15	sales	inquiries	for	BEI Jatropha	Harvesters.

Feedback The	survey	indicates	that	China,	India,	Malaysia	and	Indonesia	combined	have	approximately 1.1mm	hectares	under	cultivation	spread	across	approximately	20	projects.	While	several	very large projects	were	in	preliminary	development	several	years	ago,	due	to	lack	of	funding,	most of	them	were	either	cancelled	or	drastically	scaled	back	to	pilot

- sized	projects.	Projects	of	the size	estimated	in	the	survey	would	be	readily	known	to	industry	part icipants	like	BEI	because they	would	generate	a	significant	benefit	from	our	products. Our	BEI	Jatropha	Harvesters	have the	capability	of	harvesting	efficiently	1	hectare	per	hour	with	1	worker	per	harvester. We	truly feel	the	potential	Jatropha	industr y	growth	can	be	very	substantial	and	economically	beneficial. Large	hectare	farms	must	mechanically	harvester	to	be	financially	viable.

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	not	accurate.	Currently	producing	area	is	likely	only	a	very	small fraction	of	the	area	reported	in	the	study,	and	each	of	those	projects	are	relatively	s mall, representing	a	few	thousand	hectares.	Any	substantial	projects	would	be	widely	known	in	the

### Provide r	of	Ag	Labor	and	Food	Safety	Solutions	for	you	to	be	successful! www.beiintl.com
01. 269.637.8541	Office

01. 269.637.4233	Fax 

## BEI	International,	LLC

1375	Kalamazoo	St. South	Haven,	MI	49090 From	the	desk	of Max	Lint 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.	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	in	which	we	are	actively	engaged.

Please	advise	if	we	can	be	of	more	service.

Sincerely,

Max	Lint

P resident	&	CEO BEI	International,	LLC
Cell	616

- 204

- 8274 http://www.beiintl.com/