1 Response to Interagency Comm ents on U.S. Environmental Protection Agency’s draft Final Rulemaking, “Regulation of Fuels a nd Fuel Additives: 2012 Renewable Fuel

Standards”

• Page 8 - Table I.A.3-1 lists the four component s of the Renewable Fuels Standard. Shouldn’t

the actual volume of advanced biofuel should be lower than the ethanol-equivalent volume, due to the presence of biomass-based diesel and cellulosic biofuels other than ethanol in the pool?

Response: Modified table to clarify that actual volumes of advanced biofuel are expected to be less than ethanol-equivalent volumes.

• Page 12 – One commenter also suggested that EPA provide a discussion of the historical production volumes of the four categories of renewable fuels listed in Table I.A.3-1. Providing the historical pr oduction volumes will provide an indication of the current production capacity and the ability of the market to meet production goals established in the

statute.

Response: The requested data wa s added as a new Section I.A.4.

• Page 16 – On page 15, EPA refers to the January 2011 USDA loan guarantee of $75 million for the INEOS Bio’s first commercial facility in Vero Beach, Florida. This project was also awarded up to $50 million in financ ial assistance from DOE in January 2010. Other projects mentioned that are receiving DOE financial assistance are ZeaChem (up to $25 million) and API (up to $18 million) announced January 2010.

Response: References to the DOE awards to the INEOS Bio, ZeaChem, and API facilities were

added to the text.

• Page 23 – One commenter suggests that EPA pr ovide additional discussion of the differences between EPA’s (Table I.A.1-1) and EIA’s (Table II.B.4) name plate capacities identified for each cellulosic biofuel plant. In addition, the commenter requests clarification on the start-up dates EPA assumed for each plant and the produc tion as a percentage of nameplate capacity assumed by EPA to develop the estimates for cellu losic biofuel production in Table 1.A.1-1.

Response: A paragraph was added discussing the differences between th e nameplate capacities of the Fiberight and KiOR facilties. In info rmation on the start up dates EPA assumed for our calculations can already be found in the discussions of each company. We intentionally do not list the expected production as a percentage of th e nameplate capacity as we believe that this could be confusing and imply that we used these "utilization factors" in the same way EIA did to determine the production volumes. This was not the case - our volume projections are based on2 data provided by the companies, including but not limited to the start up dates and capacities of their facilities.

• Page 29, last paragraph – The commenter stated that Brazil would not likely increase exports to the U.S. just because increasing demand would re-establish the need for imports. It is requested that EPA provide further economic r easoning for why Brazil would want to export ethanol to the U.S., when they could export it to other countries, or use the sugarcane for sugar production.

Response: Added description of the connec tion between the advanced biofuel mandate, RIN prices, and the resulting incentive to import sugarcane ethanol from Brazil.

• Page 30, 1st full paragraph - Is the projection of Brazilian exports solely based on the FAPRI report? According to FAS GAIN reports, total Brazilian exports of ethanol decreased from 2010 to 2011, but FAPRI projects them as increasing; thus the commenter draws into question the validity of the FAPRI projections . Sugarcane-based imports are an important part of the RFS2, especially when there is very little cellulosic-generated biofuels being produced. The commenter suggests that EP A further investigate this assumption.

Response: Added a statement recognizing the ex istence of projections that differ from FAPRI.

• Page 30 & 50 - The Annual Energy Outlook 2011 (AEO2011) projects ethanol imports of 0.02 million barrels per day in 2012 and in 2013, e quivalent to 307 million gallons per year. EPA appears to convert the same value to two different values in the text. Projected ethanol imports for 2012 are reported as 300 million gallo ns per year (Page 30), and projected ethanol imports for 2013 are reported as 306 milli on gallons per year. (Page 50) Please

check to make sure that th ese numbers are consistent.

Response: The projected volumes on the two re ferenced pages are for two different years, and are different in 2012 versus 2013. As a resu lt, no changes to the text were made.

• Page 30 - Electricity generation from w ood was 36.05 million megawatt-hours in 2009 as opposed to 35.6 million megawatt- hours as written. Please check the number again and revise if appropriate.

Response: The numbers were checked and the co rrect number (36.05) was added into the text

• Page 31, last paragraph - There are many reports that note that the U.S. cannot completely consume 10 percent of ethanol as an additive due to differing state regulations (and other reasons); thus the statement that 14.3 billion ga llons of ethanol could be consumed may not be accurate. Certainly, increasing the additive regulation to 15 percent ethanol would help3 with the blend wall; however, if all ethanol produced can be consumed in the U.S., what the 2nd sentence from the end is alluding to, then et hanol exports from the U.S. would be almost zero (versus the 106 million gallons exported in September 2011, according to RFA).

Response: Added a footnote recognizing that ot her gasoline-ethanol blends are also possible.

• Page 31 - EPA states that electri city used in transportation coul d count as advanced biofuels if the electricity was generated from bioma ss. EPA writes that 6.8 million megawatt-hours of electricity were used in transportation in 2009, citing AEO2011 Table 46 as the source of the data. The data on transportation use of electr icity are actually found in Table 36, and the number is given as 0.23 trillion Btu. The comment er was able to conf irm EPA’s conversion; however, it is recommended that EPA note in th e footnote that 1 megawa tt hour is equivalent

to 3.412 million Btu.

Response: The citation was corrected to refere nce Table 36 and the conversion factor listed was added to the foot note.

• Page 31 - EPA calculates that 14.3 billion gallons of ethanol could be used in 2012 if every gallon of gasoline contained 10 percent etha nol. They cite AEO2011, Tables 10, 45, and 46 as the source of projected gasoline energy demand. The commenter states that these tables do not contain projections of gaso line demand. It is suggested that EPA clarify the reference. In addition, it is requested that EPA provide th e details of how this calculation was made in order to be transparent.

Response: The referenced tables represent pr ojected consumption of gasoline, which is an appropriate representation of demand. No change was made to the text.

EPA cites AEO2011 projected highway and nonr oad diesel consumption for 2013 in their

discussion of the biomass-based diesel requirement. EPA attri butes to Table 10 a projection of 46.65 billion gallons year; however EPA should reference Table 11 as it reports projected total diesel consumption. The 2013 diesel c onsumption projection in Table 11 is 3.64 million barrels per day, equivalent to 55.8 billion gallons per year.

Response: Footnote was amended to clarify that the diesel fuel at issue is that consumed in the transportation sector.

• Page 32 - EPA estimates bioma ss-based diesel production of 380 million gallons in 2010. One commenter was not able to replicate this number using data publicly available from the EPA-Moderated Transaction System. It is re quested that EPA provi de additional details concerning how the 380 million gallon production number was derived.4 Response: Added language clarifying the source of the data from which the 380 mill gallons was

derived.

• Page 33, and following pages - The report seem s to imply that because biodiesel production rose to meet demand “when it existed”, and that it will therefore be able to do so over the next couple of years. The commenter requests EPA to provide some economic justification. The discussion rests on the assumption that the capacity exists to produce near-sufficient

biodiesel to meet the standar d, but there is little discussion of economic drivers that will induce produces to actually produc e biodiesel at near -capacity over the next few years.

Response: Added clarifying language describi ng the connection between the biomass-based diesel mandate, demand, RIN prices, and incentives to expand biodiesel production.

• Page 34 - EPA cites AEO2011 as their sour ce for biodiesel production between 2006 and 2010. (Figure II.D-2, page 34). The commenter recommends using the Monthly Energy Review, Table 10.4, found at http://www.eia.gov/totalene rgy/data/monthly/pdf/sec10_8.pdf

. In particular, the reported biodiesel production for 2010 in AEO2011 is an estimated quantity, due to differ ing publication schedules.

Response: Graph was updated with data from MER.

• Page 36 – One commenter suggests EPA use more recent data on USDA short term projections on the use of soybean oil for methyl esters at: http://usda.mannlib.cornell. edu/MannUsda/viewDocumentInfo.do?documentID=1288 In Table 3, the current (November, 2011) projection for the 2011/12 soybean marketing year is 469 million gallons.

The update draws on the most recently publishe d projections made by USDA on the use of soybean oil for methyl esters for the 2011/12 ma rketing year. The data is published in USDA’s November World Agricultural Supply and Demand Estimates (WASDE): http://usda.mannlib.corne ll.edu/MannUsda/viewDocumentInfo.do?documentID=1194

This information was provided simply to provi de the latest USDA projections for comparison purposes with the information provided in the EPA document. The USDA projection suggests that 490 million gallons of soybean o il based biodiesel will be produced in 2011/12 (note correction from above estimate of 469 milli on gallons). This number is generally consistent with the information provided by EPA on p.36 of the document and, in fact, is above some of the estimates pr esented (e.g., Iowa State’s pr ojection of 470 million gallons). Thus, the update will not make any dramatic difference for th e EPA analysis. EPA could note that Iowa State’s projections are ge nerally supported by the most recent USDA projections from November 2011.5 Response: We used the most recent data availabl e at the time the text was written, and the use of

more recent data would not alter the conclusions drawn from it as the commenter states. No change was made to the text.

• Page 36 - EPA cites the biodiesel forecast in the August 2011 Short-Term Energy Outlook. The Outlook recommended updating to the November 2011 STEO, which includes a

biodiesel forecast that was revised to 940 million gallons based on production growth in the

first half of 2011. Will the RINS for 60 million gallons of production in 2011 will be carried

over to 2012?

Response: We used the most recent data availabl e at the time the text was written, and the use of

more recent data would not alter the conclusions drawn from it. No change was made to the

text.

• Page 36 – One commenter disagrees with EPA’s statement about qualifying renewable diesel being able to be produced at existing refineries with little or no modification to processing equipment. Qualifying renewable diesel 1 production at refineries requires dedicated units, since coprocessing of petroleu m and biomass-based streams doe s not generate RINs. Batch production is generally not feasib le, due to the small volumes of biomass-base d streams and the need to bring the hydrotreater down for a catalyst change when switching between petroleum and biomass-based streams. The co mmenter recommends striking the sentence and reducing the associated 150 million ga llons of potential production to 100 million gallons.

Response: Text was modified to acknowledge the fact that co-processing of fats/oils with petroleum would disallow the generation of bioma ss-based diesel RINs. The estimate of 150 mill gallons of renewable diesel was not changed since it is not quantitatively based on renewable diesel production at refineries.

• Page 45 - EPA estimates the fraction of gasoline, diesel, and ethanol use in Alaska based on EIA’s State Energy Data System. It is recommended that EPA include a reference to the source tables, which appear to be Tables C2 and C8. EPA calculates that ethanol use in Alaska as 8.4 percent of gasoline consumpti on in 2009, while the commenter calculated an ethanol share of 9.0 percent by volume using Table C2. The commenter requests that EPA verify the calculation.

1 Section 211(o)(1)(D) of the Clean Air Act states: Biomass-based diesel. The term "biomass-based diesel" means renewable fuel that is biodiesel as defined in section 312(f) of the Energy Policy Act of 1992 ( 42 U.S.C. 13220(f) ) and that has lifecycle greenhouse gas emissions, as determined by the Administrator, after notice and opportunity for comment, that are at least 50 percent less than the baseline lifecycle greenhouse gas emissions. Notwithstanding the preceding sentence, renewable fuel derived from co-p rocessing biomass with a petroleum feedstock shall be advanced biofuel if it meets the requirements of subparagraph (B), but is not biomass-based diesel.6 Response: Addressed. Comments were made on an old version of the preamble. We had since moved the Alaska data discussion from a foot note to a paragraph which addressed the first part of this comment (table names /numbers in the EIA data changed so we did adjust those accordingly). The ethanol fraction they calcul ated, 9.0%, differed from the one we calculated, 8.4%, because of the data sets used (significant figures, etc).

• Page 48 – The commenter requests EPA to provi de economic analysis in the discussion of soybean acreage available for biofuel use. It is suggested that the economic analysis take into account competition of corn for soybean acreage . In addition, the lack of analysis of the price of soybeans and its impact on profitab ility of biodiesel producers leads draws into question the economic feasibility of the 2013 mandate.

While EPA has established that the capacity to produce 1.28 billion gallons of biodiesel exists and that there is precedent for large a nnual increases in biodiesel production, it should be recognized that uncertainties remain rega rding economic and policy incentives to produce the quantity established by EPA. Specifically, it is likely that the very low projected ending stocks for corn will create greater competiti on between corn and soybean acres in 2012/13, which could increase soybean prices. In a ddition, the quantity of soybean oil that EPA suggests would be available in 2013 for bi odiesel production (600 million gallons [Table IV.B.2-1]) would likely represent a larger share of soybean oil use than is currently projected

for 2011/12. Current estimated use for 2011/12 is 19 percent of total soybean oil use which would produce approximately 490 million gallons of biodiesel. Supplies are expected to continue to be tight through 2012/13 with c ontinued competition for land between corn and soybeans. These factors could also place upward pressure on soybean oil prices and reduce economic incentives to produce biodiesel base d on market conditions. As the spread between the soybean oil price and the biodiesel price narrows, the profitability of marginal biodiesel producers could shrink and some may c onsider discontinuing production. Finally, the biodiesel tax credit is slated to expi re at the end of 2011, which creates further uncertainty about the economic climate for biodiesel producers. If biodiesel production is not profitable, decisions on th e use of biodiesel may be contingent on tradeoffs between economic margins and enforcement mechanisms (e.g. RIN prices).

Response: This comment will be addressed dur ing the process of finalizing the applicable volume of biomass-based diesel for 2013.

• Page 49 – One commenter suggested that EPA in clude the reference to historical production

of biomass-based diesel in or der to provide additional inform ation concerning the suggested 1.28 billion gallon standard for 2013. The commenter stated that it is uncertain that biodiesel demand will reach or exceed 1 billion gallons as demand has been quite small recently (Figure II.D-1). The commenter requests a dditional clarification fro m EPA concerning the premise underlying the assumptions for the 1.28 billion gallon standard.

Response: This comment will be addressed dur ing the process of finalizing the applicable volume of biomass-based diesel for 2013.7 In addition, another commenter requested EP A to provide the incremental impacts of increasing the Biomass diesel standard from 1.0 billion gallons set in the statute for 2012 to 1.28 billion gallons that EPA is proposing for 201 3. The statute requires an assessment of the impacts of the standards on the environment, energy security, infrastructure, cost to consumers, and other factors. The commenter suggests that EPA provide a comparison of these impacts for the 1.0 billion gallon scenario and the 1.28 billion gallon scenario. By providing the comparison, it will allow EPA to determine which option provides the most

benefit for the estimated cost increase.

Response: This comment will be addressed dur ing the process of finalizing the applicable volume of biomass-based diesel for 2013.

• Page 52 (and 68-70) – The commenter points out th at much of the information and analysis supporting EPA’s decision on Biomass-Based Di esel volumes for 2012 and 2013 were very selective and that there were inconsistencies in EPA’s interpretations, particularly with regard to market impacts. For example, comments asserting that a higher biomass-based diesel volume requirement suppor ts or enhances energy security and independence are tenuous (p.52, pp. 68-70). The U.S. is a large ne t importer (approximate deficit of $4 billion annually) of vegetable oils (the main feedstock for biomass-base d diesel); so, to the extent that domestically produced vegetable oil is dive rted to biodiesel production, the U.S. is likely to export less soybean oil and/or import more vegetable oil. Imports may come from countries that are not traditional petroleum ex porters to the U.S., and therefore perhaps diversify our sources of fuel (petroleum or biodiesel feedstock). However, the commenter suggests that EPA not charact erize an increase in domestic biodiesel production as reducing import dependence or risks from market disruptions.

Response: This comment will be addressed dur ing the process of finalizing the applicable volume of biomass-based diesel for 2013.

• Page 53 – One commenter suggested that EPA provi de a description of the analysis that EPA

conducted to confirm the f eedstock quantities listed in Table IV.B.2-1.

Response: This comment will be addressed dur ing the process of finalizing the applicable volume of biomass-based diesel for 2013.

• Page 58 – Assuming 2.5 billion gallons of soyb ean oil production and 1.9 billion gallons of domestic consumption leads to the conclusion that 600 million gallons will be available for biodiesel. Just note that U.S. exports of so ybean oil have traditionally far outweighed the use of soybean oil for biodiesel. The commenter points out that under EPA’s assumptions, U.S. soybean oil exports would fall to zero.8 Response: This comment will be addressed dur ing the process of finalizing the applicable volume of biomass-based diesel for 2013.

• Page 66 – It appears that the text incorrectly portrays the differences in annual growth rates of biodiesel consumption between the RFS fina l rule (projecting 1.82 billion gallons in 2022) and the one year increase from 2012 to 2013 in the current document. The annualized growth rate of 0.14 billion gallons under the RFS final rule is not “about twice as high as the single-year growth from 2012 to 2013...” It is one-half the rate. EPA could acknowledge that the market impacts of a 28 percent one year increase would be greater than proportionally smaller annual percentage chan ges considered in the RFS final rule.

Response: This comment will be addressed dur ing the process of finalizing the applicable volume of biomass-based diesel for 2013.

• Page 68 – Perhaps it’s true that diversifying the source of imported transportation fuel or feedstocks (e.g., sugar based ethanol or vegeta ble oils) improves energy security, but it does not necessarily reduce financial risks associated with a supply disruption or spike in the cost of particular energy sources (a s witnessed by the increased prices of sugar, and dramatic fall in U.S. imports of ethanol from Brazil). As st ated earlier, the U.S. is already a large net importer of vegetable oils, so increased pr oduction of biodiesel from domestically produced soybean oil is likely to reduce U.S. soybean oil exports, and increase vegetable oil imports (whether used for human consumption or as a feedstock for biodiesel).

Response: This comment will be addressed dur ing the process of finalizing the applicable volume of biomass-based diesel for 2013.

• Page 69 – The commenter questions the conclusion “ that soybean production will outpace non-biofuel demand in 2013. Therefore, EPA does not project that the price of soybean oil should increase as a result of this rule. ” A mandated increase in biodiesel production is a demand shifter, meaning that all else equal, the equilibrium price for biodiesel feedstocks will be higher. This statement contradict s information given immediately above on FASOM

results.

Response: This comment will be addressed dur ing the process of finalizing the applicable volume of biomass-based diesel for 2013.

• Page 69 - Similarly, the FASOM model projects an increase in soybean oil price (1st paragraph), yet further down (3rd paragraph) EPA does not project the “price of soybean oil

should increase as a result of this rule.” Even though soybean production may “outpace nonbiofuel demand,” productivity changes for s ubstitutes and changes in complementary demands also factor into the price.9 Response: This comment will be addressed dur ing the process of finalizing the applicable volume of biomass-based diesel for 2013.

• Page 71 – One commenter expressed concern with the way information is presented in the emissions impacts Table IV.C.4-1. Unlike GHGs, am bient air pollutants can create local air quality issues. For example, 1,346 tons of dow nstream NOx emissions could have an impact on local airsheds. The upstream PM10, PM 2.5, SO2, NH3, and HAPS emission increases are also locality-pertinent. Likewise, emission reductions are also locality-specific. Due to the issue of local airshed affects, it is suggested that some caveats be provided to the table in light of the column that shows small percentage effects on the total U.S. emissions inventory.

Response: This comment will be addressed dur ing the process of finalizing the applicable volume of biomass-based diesel for 2013.

• Page 72 – The commenter was not able to verify the biodiesel and dies el prices for 2013. For diesel, EPA cites AEO2011 and that the pri ce will be $2.97 a gallon in 2009 dollars, but EPA did not provide a cite to the table or price series used to arrive at the pr ice (retail, wholesale, etc). For the biodiesel price EPA cites the FAPRI Outlook ( http://www.fapri.org/outlook/2011/tables/5_biofuels.pdf ), and the commenter assumes that EPA’s stated price of $3.72 in 2009 dollars co rresponds to the nominal 2013 price of $3.95 in the FAPRI outlook, but that price represents the Bi odiesel Plant price, as opposed to the retail price. In the absence of the current tax credit (which expires at the end of this year), it is reasonable to assume the retail pr ice would be higher than the plan t price. We also note that

retail biodiesel plant prices have not been below $4.00 gallon for all of 2011, when biodiesel volumes have been at levels necessary to m eet these increased RFS mandates, and for much of the year have been well above $5.00 a gallon.

Response: This comment will be addressed dur ing the process of finalizing the applicable volume of biomass-based diesel for 2013.

• Page 72 - EPA attributes a total diesel pr ojection of 46.85 billion gallons to AEO2012 Table 2. This figure is actually transportation distillate only.

Response: This comment will be addressed dur ing the process of finalizing the applicable volume of biomass-based diesel for 2013.

• Page 73 - Similarly, the commenter was not able to verify the prices used in Figure IV.C.5-1, that compares Biodiesel prices in 2008-2011 from the Alternative Fuel Price Report. This is a report that surveys retail sites, so it is not surprising that 2011 prices do not increase given

the re-enactment of the biodiesel tax credit.10 Response: This comment will be addressed dur ing the process of finalizing the applicable volume of biomass-based diesel for 2013.

• Page 78 – In reference to some NASS estimates in the document, it currently states:

In 2006, USDA’s NASS estimated that nitrogen and phosphorus fertilize rs were applied to 18 percent and 23 percent of soybean acreage, re spectively, with an average of 16 pounds of nitrogen and 46 pounds of phosphate applied per acre fertilized (NASS, 2007).

The commenter recommends modifying it slightly to say:

Nitrogen was applied to 18 percent of the 2006 so ybean planted acres in the Program States at an average rate of 16 pounds per acre per year. Phosphate was applied to 23 percent of the planted acres, at an aver age rate of 46 pounds per acre.

Response: This comment will be addressed dur ing the process of finalizing the applicable volume of biomass-based diesel for 2013.

• Page 81 – the statement “that there would be sufficient sources of feedstock to produce 1.28 bill gallons of biomass-based diesel without usi ng any fats” appears to be contradicted by the table (IV.B.2-1) that grease and rendered fa ts would be needed under either scenario presented (RFS2 or IHS Global Insight).

Response: This comment will be addressed dur ing the process of finalizing the applicable volume of biomass-based diesel for 2013.

• Page 85 - “Therefore, we proposed to amend the current definition for “annual cover crop” to clarify that for purposes of the RFS progr am the term only includes crops that have no existing market to which they can be sold exce pt for the use of the feedstock for renewable fuel. This will ensure that no unintended land use or significant indirect effects result from the use of annual cover crops as feed stocks for renewable fuel production.”

If an annual cover crop is sold as a feedst ock for biofuel production, then it represents a cover crop not plowed under for the purpose of increasing soil fertility. Thus, it seems that allowing cover crops for biofuels could have so me sort of land use impact, such as requiring

the farmer to use more commerc ial fertilizer in compensation, or in decreasing yield of food crops. In addition, soil erosion could increase du e to harvesting of the cover crop. It is suggested that EPA discuss these potential impacts in this section of the preamble.

Response: Text was modified to clarify these po ssible impacts, discussing this as the difference between direct and indirect impacts.11 • P. 104 - The “XX” acreage values should be s ubstituted with actual numbers. Concerning the 396 million acre number for the amount of ag ricultural land in 2012, the commenter did not see the USDA file in the EPA docket upon whic h this number is based. It is requested

that EPA include this document in the docket. If one looks at the land use values posted on the ERS website (http://www.ers.usda.gov/Brie fing/LandUse/majorlandusechapter.htm), it may not be evident how this estimate was ma de. For instance, “cropland” in 2002 was 441 million acres and “cropland used for crops” was 340 billion that year” (from http://www.ers.usda.gov/data/MajorLandUses/ ).

Response: Text has been updated. All suppor ting documents from USDA and Canada for the aggregate approach has been docketed here: # EPA-HQ-OAR-2010-0133.

Editorial Comments:

• Page 3 – It is suggested that the title of Sec tion II be inclusive of Advanced Biofuel and Biomass-Based Diesel. It currently refers to just “Cellulosic Volume Production.”

Response: Secti on title was modified.

• Page 12 - In contrast to statements made by sever al obligated parties, meeting the dual goals of predictability and reduce d uncertainty does not require EPA to specify an applicable volume for cellulosic biofuel that is as lo w as possible, or based only on demonstrated production.

Response: Edit was made to the text.

• Page 13 – In the first full paragraph, the suggests the following revision: “ While the cellulosic biofuel standard that we set should be within the range of what can be attained based on projected domestic production and import potential, the standard that we set in large part determines helps drive the production of volumes that will be made available ”. The commenter agrees that the standard c ontributes; however, as the actual production has fallen short of the statutory goals it may be more appropriate to rephrase.

Response: Edit was made to the text.

• Page 21, Table II.B.4 – The INP Bioenergy projec t appears to be the same project as the INEOS Bio project described above, but the name used is different. It is suggested that the

names be consistent to avoid confusion.

Response: Added a footnote to this table maki ng it clear that INP Bi oenergy and INEOS Bio are the same company. Table from EIA was not m odified since it is shown as received from EIA.12 • Page 29 - Using EIA data, EPA reports monthl y ethanol imports of 71 thousand barrels in June 2011 and 305 thousand barrels in July 2011. Annual ethanol imports, which EIA also reports in barrels, are converted to gallons. It is suggested EPA convert the monthly figures to gallons for easier comparison.

Response: Edit was made to the text.

• Page 50 – It may be that most or all of U.S. ethanol imports originate from Brazil, but at times a large share were routed through Ca rribean countries under the Carribean Basin Initiative (CBI).

Response: This comment will be addressed dur ing the process of finalizing the applicable volume of biomass-based diesel for 2013.

• Page 51 - The only ne x t ethanol exporters tracked in the FAPRI report are Brazil and China, with Brazil export volumes totally nearly 20 times those from China.

Response: This comment will be addressed dur ing the process of finalizing the applicable volume of biomass-based diesel for 2013.

• Page 61 – For Table IV.B.4-1, one commenter su ggested including a summary of all of the states with mandates or incentives, and a short description of the leve l/amount of the mandate

or incentive.

Response: This comment will be addressed dur ing the process of finalizing the applicable volume of biomass-based diesel for 2013.

• Page 63 - In June of this year, Sunoco Logistics and Sprague Energy opened a new terminal facility to supply of biodiesel blended transportation fuel and heating fuel to New Jersey

.

Response: This comment will be addressed dur ing the process of finalizing the applicable volume of biomass-based diesel for 2013.

• Page 66 - Given that the RFS2 final rule analyzed the impacts of an increase in biomassbased diesel that was about five times larger than the volume increment we proposed for 2013, we continue to believe that the impacts of 1.28 bill gallons in 2013, compared to the statutory minimum of 1.0 bill gallons, will likel y be similar to or smaller than those we estimated for 2022.13 Response: This comment will be addressed dur ing the process of finalizing the applicable volume of biomass-based diesel for 2013.

• Page 69 – The commenter assumes that EPA is tr ying to make the point that the soybean oil prices wouldn’t increase as a result of this annual rulemaking but as part the RFS2 full implementation. It is suggested th at EPA make this point more clear . If this is the point that EPA is trying to make, here are some suggested revisions:

One commenter suggested that the biodiesel mandate for 2013 will result in an increase of soybean oil prices. However, as shown in Section IV.B.2.c, EPA estimates that soybean produc tion will outpace non

- biofuel demand in 2013. Therefore, EPA does not project that this annual rulemaking will increase the price of soybean oil should beyond the levels that would result from the final RFS2 rulemaking as a result of this rule , and could be lower for

the reasons cited above

.

Response: This comment will be addressed dur ing the process of finalizing the applicable volume of biomass-based diesel for 2013.

• Page 69 – Please complete Footnote 60.

Response: This comment will be addressed dur ing the process of finalizing the applicable volume of biomass-based diesel for 2013.

• Page 69 – Again, the biodiesel impacts would repres ent only a small portion of these overall impacts and would like ly be even smaller in 2013 due to the smaller volume of feedstock required.

Response: This comment will be addressed dur ing the process of finalizing the applicable volume of biomass-based diesel for 2013.

• Page 87 - Since the obligation for blenders to separate RINIn s for renewable fuel that they blend to produce a transportation fuel,

Response: Edit was made to the text.

• Page 104 - Please insert space between 396 and million, fill in XXs, and spell out the acronyms GRP and WRP.

Specifically, we started with FSA crop histor y data for 2011, from which we derived a total estimated acreage of 396 million acres. We then subtracted the amount of land estimated to be participating in the GRP and WRP by the e nd of Fiscal Year 2011, XX million acres, to14 yield an estimate of approximately XX million acres of U.S. agricultural land in 2011. The USDA data used to make this calculation can be found in the docket to this rule.

Response: Text has been updated. All suppor ting documents from USDA and Canada for the aggregate approach has been docketed here: # EPA-HQ-OAR-2010-0133.

Other editorial comments

• Comment [A6] Is this source one of the compan ies listed in Table I.A.1-1? If so, please

make the names consistent.

Response: The referenced source is not one of the companies from this table.

• Comment [A7] Please provide the date here as well as in the Footnote 7, below.

Response: Date has been prov ided in the text and footnote

• Comment [A8] Please make the name consiste nt with EPA Table I.A.1-1 if INP Bioenergy

is the same as INEOS Bio.

Response: Added a footnote to this table maki ng it clear that INP Bi oenergy and INEOS Bio are the same company. Table from EIA was not mod ified since it is shown as received from EIA.