Brian Engel, GM of Vegetable Oil Trading | Green Plains

EPA RFS Hearing June 25, 2015

Good afternoon and thank you for this opportunity to testify this afternoon. My name is Brian Engel and I’m the General Manager of Vegetable Oil Trading for Green Plains at its headquarters in Omaha,
Nebraska.

I have over 25 years of experience in agric ulture commodity marketing, trading, and processing and have made career, marketing and investment decisions based on the very first passage of
Renewable Fuel Standard.

Needless to say those decisions have not been easy to make with the constant delays, changes, and lack of clarity through the EPA’s proposal to change the law from what Congress had established.

In 2000, I started a company that launched the first biodiesel plant in the state of Indiana in 2005. The plant was located in Hammond,
which i s in the furthest northwest corner of the state near Chicago, and was also located adjacent to a large petroleum refinery. The investment created jobs in a very high unemployment and economically depressed area. Unfortunately with the uncertainties
around RFS, that facility has closed and employees were laid off.

I bring this up, because within Green Plains, I am responsible for the group that markets and trades corn oil extracted from the ethanol

process. Along with corn oil, my group also trades other fats and oils, both domestically and internationally.

In 2007, I developed markets for some of the first production of corn oil recovered from the ethanol process. Thus as a group, we can closely relate to what our corn oil biodiesel customers have been going through year after year.Within Green Plains we continually develop markets for corn oil, as

well as other fats and oils, across fuel, feed, food, and industrial applications.

Thus I wanted to relay my thoughts on the impact of the proposed RFS

RVO from the perspective of a supplier to each of these industries.

As a feedstock for biodiesel fuel, corn oil has been one of the key supplies that has helped generate investments in new biodiesel processing technologies, driving efficiencies and capaci ty in the industry.

One of the key aspects of the proposed RVO is not only the volumes themselves, but the fact that the volumes for biodiesel will be set through 2017.

Having firm volumes established at least 2 years out is very helpful for
our corn oil biodiesel customers. This gives our customers the ability to make better forecasts and thus make longer term investments. In return, giving the fuel industry a consistent biodiesel supply. In addition to consistent supplies, California recognizes a very l ow carbon index value for corn oil. Thus generating a good alternative to meet there carbon reduction target. We expect other west coast states will
follow California’s lead.

One of the major concerns for our biodiesel customers is the 70 to 75
cents per gallon export incentive that Argentina has for biodiesel relative to soybean oil. We are starting to see the very negative impact to our customers caused from Argentine biodiesel vessels arriving at United States ports. Another on

- going concern for our
b iodiesel customers has been the very slow response from the EPA regarding requests for clarification and guidance on many issues. Some requests, for what would appear be strait forward points of clarification, have taken up to one year to receive guidance on. And many times the guidance generated more requests for clarification.Feed

– In regard to our feed customers , t he meat industry is starting

to recognize the benefits and customer preference for meat produced from all natural or all vegetable based diets. Corn oil from the ethanol industry has been a go to replacement for animal fats in feed rations. Without a viable biodiesel market, the animal fats produced in the meat industry would struggle to find a ready market.

Food

– In regard to food customers, corn oil from the ethanol industry is competitively priced into the biodiesel and feed market, thus replacing soybean oil as a biodiesel feedstock and making it available
for the food market.

Industrial

– In regard to our industrial customers

, corn oil gives them more pricing certainty for the products they produce. Corn oil is priced and traded out to 12 months or longer in comparison to animal fats which price 30 to 45 days forward .

As I have quickly outlined, it is easy to see that c orn oil from the ethanol industry is bringing value to consumers across fuel, feed, food and industrial applications. It also outlines how creative, resourceful,
and flexible we have been in developing new markets and uses. So why can’t they be as creative , resourceful, and flexible in utilizing the fuels we produce?

On behalf of myself, and Green Plains, I would like to thank you for taking my testimony and for your attention this afternoon.