•t^,+„ F 'Y 4 STATE OF MINNESOTA 

Office of Governor Mark Dayton 

130 State Capitol ♦ 75 Rev. Dr. Martin Luther King Jr. Boulevard ♦ Saint Paul, MN 55155 

December 4, 2013 

Ms. Gina McCarthy 

Administrator 

U.S. Environmental Protection Agency 

William Jefferson Clinton Building 

1200 Pennsylvania Avenue, N.W. 

Mail Code: 1101 A 

Washington, DC 20460 

Dear Ms. McCarthy: 

Thank you for this opportunity to comment on U.S. Environmental Protection 

Agency proposed Renewable Fuel Standard (RFS), Docket Number EPA-HQ-OAR2013-0479. If the provisions of this proposed rule were to take effect as published, 

Minnesota would find itself punished for public and private investments that have been 

made to promote and implement previously published EPA policies. 

Last spring, I signed into law a state renewable fuels policy, which is aligned with 

the federal Renewable Fuels Standard (RFS), and guides Minnesota to 25 percent 

renewable content by 2020, and 30 percent by 2025. Despite today's contentious 

political atmosphere, this policy received bipartisan support in the Minnesota Legislature. 

As Governor of a state that is proud of its history in pioneering the use of 

renewable fuels and maintaining healthy, sustainable, and third-party, certified forests, I 

urge the United States Environmental Protection Agency (U.S. EPA) not to reduce the 

RFS targets and let the federal policy function as it was intended. The RFS is working 

and I support maintaining strong targets, which also allow sustainable forest resources to 

contribute to our nation's renewable energy goals. 

Minnesota is a state that hosts an abundance of both agricultural and forest-based 

biomass, and depends on healthy, renewable fuels industries to maintain economic and 

environmental prosperity. 

With respect to our forestlands, as currently written, federal limitations on eligible 

wood used for biofuels in the RFS restrict economically hard hit forested regions of 

Minnesota, Wisconsin, and Michigan from contributing biomass feedstocks, by 

disqualifying wood that is neither hand-planted nor logging residue. The result of this 

limited definition is that roughly 5.6 million acres (in Minnesota alone) of state-owned, 

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Ms. Gina McCarthy 

December 4, 2013 

Page 2 

sustainably managed, and dual, third-party certified wood are ineligible for use in 

renewable fuels development. 

The majority of the cellulosic biofuels industry that uses woody material requires 

hardwood (aspen, birch, maple) pulpwood, which naturally regenerates and is not handplanted. By restricting eligible forest resources to logging residue (which is disperse and 

lacking in availability) and plantation material, the RFS rewards past conversion of 

natural forests to plantations and penalizes working forestry programs, which have 

sustained natural forests and local economies for decades. 

With respect to our agricultural markets, widespread renewable fuel use in 

Minnesota dates back to the 1980s, when our largest cities were deemed to be in nonattainment status for carbon monoxide pollution. Use of ethanol in the form of a 

10 percent blend (E 10) was a tool, which allowed us to improve the urban air and quality. 

Minnesota farmers have since invested in biofuel production and our feedstock 

crops boost the entire state's economic outlook, especially in once-struggling rural areas. 

A 2012 study by the Minnesota Department of Agriculture found that the Minnesota 

ethanol industry contributes $5 billion annually to our state's economy and supports more 

than 12,600 jobs. We also have several next generation renewable fuels under 

development, including two commercial-scale biobutanol production facilities. 

Farmers also look to biofuels as a dependable market during times of low prices. 

American farmers are currently harvesting one of the largest crops in history and 

commodities like corn are already below $4 per bushel. Today's prices are lower than 

when the Energy Independence and Security Act was signed in 2007. A cut to the RFS 

today would be devastating for those who grow the food, fiber, and fuel to meet the 

demands of an increasing world population. 

Presently, Minnesota E15 is priced 15 cents per gallon less than E10 gasoline and 

several of our largest retail chains are selling E85 at 80 cents less than gasoline. 

Motorists are demanding less expensive and cleaner alternatives at the pump and we are 

meeting that demand here in Minnesota. If the U.S. EPA acts to reduce the Renewable 

Fuels Standard, it will be pulling the rug out from under Minnesota's renewables 

industry, our farmers and loggers, our next generation renewable fuels development 

projects, and our fuel station network. 

Minnesota's farmers, loggers, and landowners, both public and private, need new 

industries and markets to manage and preserve their lands. Minnesota's mills need 

opportunities to leverage bioindustrial synergies to remain globally competitive for the
Ms. Gina McCarthy 

December 4, 2013 

Page 3 

years to come. Strong RFS targets and a broadened definition of eligible woody biomass, 

will allow Minnesotans the opportunity to prosper and contribute toward achievable 

renewable energy goals. 

In the strongest terms possible, I urge you to allow the RFS to function as it was 

intended. Weakening the RFS would cost Minnesotans tens of millions of dollars each 

year, and stall progress toward achieving renewable energy goals. 

Thank you for your consideration. 

Sincerely, 

AtoMark Dayto 

Governor 

cc: David Frederickson, Commissioner, MDA 

Molly Pederson, Sr. Policy Advisor, Office of the Governor