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# 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,

Voice: (651) 201-3400 or (800) 657-3717 Fax: (651) 797-1850 MN Relay (800) 627-3529 Website: http: // governor.state.mn.us An Equal Opportunity Employer Printed on recycled paper containing 15% post consumer material and state government printedMs. 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 requireshardwood (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 inMinnesota 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 theMs. Gina McCarthy

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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, 

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A Mark Dayto Governor cc: David Frederickson, Commissioner, MDA Molly Pederson, Sr. Policy Advisor, Office of the Governor