**COST BENEFIT ASSESSMENT**

Date: June 19, 2013 Contact: Barbara Fecso

Dairy and Sweeteners Analy sis Group Economic and Policy

Analy sis Staff Farm Service Agency United States Department of Agriculture Washington, DC 202
- 72 0
- 4146 I. Title. Feedstock Flexibility Program (RIN 0560
- AH86) II. Executive Summary The Food, Conservation, and Energy Act of 2008 (2008 Farm Bill) modifie d the sugar loan and sugar marketing allotment program , mandated b y Title Iof the 2008 Farm Bill, and added the Feedstock Flexibility

Program (FFP) for Bioenergy Pro ducers provision under Title IX of th e 2008 Farm Bill
. This c ost b enefit a ssessment onl y addresses the economic impacts of the rule that implement s FFP. An earlier CBA accompanied the rule that implemented the Title I Sugar Program changes (74 FR 15359
- 67) 1

. The rule changes to the sugar loan program and the marketing allotment program were completed when the Title Irule was published in 2009. U.S. Department of Agriculture (USDA ) projections as of early 2013 indicate that, over the 10
- ye ar baseline period, the FFP will be needed in only one ye ar, . USDA assumes that 300,000 of Commodity

Credit Corporation ( CCC ) sugar loan collateral wil l be forfeited in FY 2013 if FFP is not implemented
. F FP is expected to cost CCC an estimated $ 53.4 million more than using the least
- cost surplus management option, which, in the current sugar market, is the use of Re
Export Program exchanges
. 2 Despite this cost , FFP has at least one benefit that is not available with other sugar suppl y reduction methods . Specifically , FFP will allow the generation of Renewable Identification Numbers (RINs), which will help gasoline and diesel blenders meet their Renew able Fuels Standard (RFS) mandates in 2014. USDA does not expect sugar loan forfeitures or CCC purchases of sugar for ethanol from FY 2014
- 23 because projected raw cane and refined beet sugar prices are above the minimum prices that would result in forfei ture s . As a comparison, the Organization for Economic Co
- Operation and Development ( OECD ) baseline projects world prices above U.S. forfeiture level s over th at same period
. Further, the 2013 Food and Agriculture Policy Research Institute (FAPRI) baseline also has FY 2014
- 23 sugar prices substantially above FY 2013 prices. In short , FFP is projected to be unneeded after FY 2013 because the domestic market is no longer project ed to be in surplus and the world market is supporting domestic prices above the Sugar Program ’s price support level. There are several factors underlying this projection of higher prices. Expe cted growth in U.S. beet and cane sugar production over the next decade is very modest

—less than 5 percent over the 10
- ye ar projection period
. Further, s ugar use is projected to grow about 0.7 percent a year , or 7

1 The CBA for the rule that implemented the 2008 Farm Bill Title I changes to the Sugar Program is available through regulations.gov. It is listed under the same RIN, 0560
- AH86, as this FFP rule. 2 USDA announced the use of Re
- Export Program exchanges on June 17, 2013. The Federal Register notice can be found at: http://www.fsa.usda.gov/Internet/FSA_Federal_Notices/sugarpurchase_2013.pdf
.2

percent over the decade
. Mexican imports make up the U.S. shortfall and are expected to average 12. 8 percent of U.S. domestic sugar use. Tariff
- rate quota (TRQ) sugar imports from the current U.S. commitments made to the World Trade Organization (WTO) and to several Free Trade Agreements (FTAs) average 1.444 million short tons, raw value ( STRV ) annuall y . W orld raw sugar price s forecast b y the OECD are used in the following analy sis . These prices average 21.58 cents per pound through the projection period , which is above the U.S. Sugar Program ’s support price of 20.9 cents per pound
. III. Need for Action The 2008 Farm Bill revised three ma jor Sugar Program provisions

– it increased the loan rate, provided a guaranteed domestic market share, and introduced the FFP
. The first two changes were implemented beginning with the 2008 crop ye ar ( FY 2009) . This cost benefit assessment provides the anal ys es accompanying the final rule implementing FFP
. FFP provisions re quire that CCC use FFP to purchase sugar from the domestic sugar market to avoid forfeitures of sugar loan collateral in lieu of repay ment of CCC sugar loans
. Although other mechanisms may also be used in concert , FFP is the primary tool in the event of anticipated forfeitures , as described below . C CC must sell sugar purchased under FFP to producers of bioenergy
. IV
. Background The Sugar Program is a collection of federal programs designed to support the return from raising sugarcane and sugar beets above a threshold established by the 2008 F arm B ill. The price of sugar is supported, in lieu of a price support for su gar beets and sugarcane, because farmers’ return from the crop is proportional to the price of sugar and the crops are not storable, which makes them unsuitable loan collateral for CCC price support loans. The price level supported is determined by the su gar loan program. Sugar beet and sugarcane processors can receive a loan from CCC on their sugar production that can be full y satisfied by giving CCC title to their loan collateral, also known as “forfeiture” of collateral. Thus, sugar producers always h ave the opportunity to receive at least the loan proceeds from their crop, which becomes a floor on the m arket price of domestic sugar. The 2008 Farm Bill Sugar Program mandate s that CCC avoid the federal costs associated with sugar loan collateral forfeitures. The Sugar Program minimizes forfeiture expenditures by limiting domestic supply , resulting in higher domestic sugar prices than the price support floor created b y the sugar loan p rogram. As a result , the cost of the program falls upon domestic purchasers of sugar, not the federal government. Do mestic supply is controll ed in two way s: 1) by the sugar marketing allotment program, which limits the quantity of sugar that domestic sugar beet and sugarcane processors can market , and 2) by sugar TRQ s , which allow a certain quantity of sugar to be imported at a lower tariff rate , subject to the minimum access levels establi shed by

international treaties. The USDA baseline projects costs to the Sugar Program because USDA ’s ability to limit supply was curtailed b y full implementation of NAFTA on January 1, 2008 , wh en tariffs on sweetener s3

were lifted b y both nations . The U
. S
. advantage in high fructose corn s yrup (HFCS) production has result ed in an increased flow of U
. S
. HFCS into Mexico, which h as displace d sugar in Mexico’s beverage industry
. The reduction in Mexican sugar demand has increased Mexican sugar exports to the United States
. Increased Mexican imports , along with record FY 2013 U
. S
. domestic sugar production and large FY 2013 beginning stocks, are resulting in prices below the federal support level and the potential for forfeiture s of sugar price support loan collateral. (The first forfeitures in FY 2013 can occur on August 1, 2013.) The 2008 Farm B ill addresses CCC’s options to dispose of surplus sugar in FFP , specified in Title IX
. **Surplus Sugar Management** The FFP legislative language , first appearing in the 2008 F arm B ill, affects CCC’s surplus sugar management strategy

in two significant way s. First, it establishes a program that requires CCC to proactivel y purchase sugar for bioenergy production throughout the ye ar to avoid CCC sugar loan forfeitures , which can only occur at loan maturity (9 months after a loan is placed)
. However, the FFP legislative language also prohibits CCC from storing surplus sugar for later sale for human consumption, unless there is a domestic emergency sugar shortage. Since this rule does not a ffect that prohibition, the cost of that prohibition is not included in the impacts of implementing this rule , which is limited to the cost of implementing the sugar
- for
- bioenergy program (FFP)
. General Disposition Section 9001 of the 2008 Farm Bill restricts CCC’s ability to manage inventory

acquired b y forfeiture or authorities, other than FFP, under non
- emergency conditions. CCC must dispose of its sugar inventory

using only

outlets that do not increase the net suppl y of sugar available for human use in the United States , unless CCC has determined that there is an emergency shortage of sugar in the domestic market caused b y war, flood, hurricane, or other natural disaster, or similar event
. The 2008 Farm Bill specifically allows sales under FFP ( in Subtitle F of the regulation) , the Processor Pay ment - In
- Kind Program (Subtitle G), and through buy backs of Certificate s of Quota Eligibility ( CQE s , which are identified in the 2008 Farm Bill incorrectl y as Certificates of Quota Entry)
. It also states that nothing in this section (section 9001) limits CCC’s ability

to dispose of sugar for nonfood use (or uses that do not increase the suppl y of sugar for human con sumption) under any authority
. A pay

ment - in
- kind (PIK) program was the major method used to dispose of large sugar surpluses in 2000 and 2001 . Regulations specifying USDA’s implementation of the PIK program were included in the Title 1 Sugar Program rule published in 2009. Feedstock Flexibility Program Through FFP , CCC is require d to purchase sugar to produce bioenergy , if necessary , to avoid forfeitures of sugar loan collateral under the sugar loan program. This program is located in Title IX , Section 9001 of the Farm Bill , and USDA request ed public comment through a p roposed r

ule for changes to this part of the Sugar Program
. The effect of this provision is that it should minimize, if not eliminate, the federal costs of loan forfeitures under the sugar loan program . H owever, a cost will be borne by FFP. FFP is expected to cost CCC $ 53.4 million more than if had been able to use other disposal methods in FY 2013 , as described below
.4

USDA collected comment s on methods to administer FFP and , since the comments support ed the use of a flexible approach, finalized regulations to allow CCC the greatest possible flexibility in program administration. FFP will be administered by contracts for the purchase and sale of sugar, or products that yield sugar, when CCC determines that sugar loan collateral is likely to be forfeited under the sugar pric e support loan program. The contracts will include the specific terms and conditions associated with each purchase from sugar suppliers and sale to bioenergy producers . CCC intends to amend its contract terms through time as it learns how to most efficientl y remove sugar deemed surplus to the domestic market and facilitate its conversion to e thanol or other bioenergy products
. Surplus determination As specified in the 2008 Farm Bill, CCC must estimate the likelihood of sugar forfeitures b y September 1 fo r the following fiscal year, and announce the expected quantity of sugar to be purchased and sold for biofuel production. Due to unfolding market conditions , earl y USDA estimates of the following fiscal year’s sugar market are unavoidabl y subject to signi ficant error. Domestic sugarcane and sugar beet harvest s do not normally commence until after September 1 and production forecasts can vary greatly until the end of the crop processing campaign
. As a result , production forecasts can change significantly after USDA make s its initial estimate of sugar surplus. The se uncertainties are aggravated because Mexico ’s harvest does not begin until December. Another major source of error is the fact that a given fiscal year does not end until September 30

—and thus , later than S eptember 1. Any changes to the current year automatically alter the current ye ar’s ending stocks and next year’s beginning stocks and supply
. Due to this large degree of uncertainty surrounding USDA’s sugar market projections on September 1 of a given ye ar, purchase s and sale s may materialize later in the year, even though earl y- season projections provide a different indication. CCC did not strictly

define surplus in the final rule , providing maximum flexibility
. Because s ugar used to make ethanol cannot be recovered for the sugar market later if needed, CCC can be expected to be more conservative in purchasing sugar for ethanol earl y in the year than later, when market factors are better known. Eligible sugar CCC is permitted to purchase forms of raw, refined, or in
- process sugar that can be marketed for human consumption in the United States or that can be used for the extraction of sugar marketed for human consumption in the United States. Thus, in
- process sugar products such as beet th ick juice or cane s yrup are eligible. However, since the program objective is to reduce forfeitures of CCC sugar loan collateral, the in
- process sugar products will be reduced to their refined crys talline sugar yi eld in determini ng CCC’s unit purchase pri ce. Likewise, raw sugar w ill be evaluated in terms of its refined equivalent to determine CCC’s unit purchase prices
. To meet the FFP mandate, CCC will only purchase sugar for FFP if it determines that the purchase of that sugar would result in a reduced likelihood of s ugar forfeitures. CCC, in the final rule, has therefore restrict ed purchases to sugar eligible for loan, which means sugar produced from domestically raised sugarcane or sugar beets.5

Renewable Identification Numbers (RINs) A specific and secondary benefit to purchasing and selling surplus sugar to bioenergy producers is to help fulfill Renewable Fuels Standard (RFS) levels mandated in the 2007 Energy Independence and Security Act for various types of renewable fuels to be blended with U.S. gasoline and diesel fuels. In2008 through 2011, production and use of ethanol in the U.S. exceeded the ethanol mandate, causing the suppl y of Renewable Identification Numbers (RINs) to exceed demand. (RINs are proof that gasoline and diesel fuel blenders have met the RFS mandates)
. The market for RINs changed in 2012 when drought pushed corn prices higher and gasoline demand fell. Both events drove down the production of ethanol, which reduced the availability

of RINs to meet the 2012 mandated levels. While carryover of 2012 RI Ns somewhat helped meet mandates in 2013, without an increase in ethanol production, there will likely not be enough RINs generated to fill the 2014 mandates. If surplus sugar can be sold to bioenergy producers in 2013, RINs wi ll be generated to help gasoline and diesel blenders meet their RFS mandates in 2014. Because of this benefit, RINs have market value and create an inducement to participate in FFP. The Environmental Protection Agency (EPA) has confirmed that ethanol pro duced from U.S. sugarcane would qualify

for an advanced fuel RIN, and that ethanol produced from U.S. sugar produced from U.S. sugar beets would qualify for a conventional RIN , subject to certain grandfathering provisions. EPA estimates that more than 200 U.S. ethanol facilities are "grandfathered , " and that they have a combined capacity of over 15 billion gallons
. Eligible sugar sellers and buyers The 2008 Farm Bill requires that the entity selling sugar to CCC under the FFP be located in the United States and that eligible buye rs be bioenergy producers. Eligible sugar buyers must produce bio energy

products, including fuel grade ethanol, or other biofuels, but do not have to be located in the United S tates
. However, d ue to the cost of transporting sugar, buyers will likely make purchases for delivery to plants located in the United S tates
. Competitive procedures CCC will announce tenders to the public outlining the terms and conditions of the sugar purchase and sale c ontracts , and is expected to try several contracting strategies to learn the best strategy for operating FFP in the most cost
- effective manner , given the restrictions specified in the 2008 Farm Bill
. CCC is required by the 2008 Farm Bill to store the sugar for no more than 30 day s after the date of CCC purchase. Thus, the purchasing biofuel producer must be identified before CCC purchases surplus sugar. CCC could identify biofuel producers willing to take sugar or sugar products under specific terms, inc luding price, and tender for the purchase contract at the identified delivery

points. Alternativel y, CCC could require the sugar seller to identify the purchasing biofuel producer and incorporate a contract of sale between CCC and the biofuel producer spe cifying terms, including price, in their offer to sell sugar to CCC. There is no basis, at this time, to expect the costs of these alternative strategies

—and the inherent level of competition among buye rs and sellers associated with each

—to be different. CCC wants to maximize the competitive nature of FFP to maximize potential program participation and minimize cost, but has no basis , at this time, to determine which one of these strategies would6

encourage more competition in the program. Thus, CCC expect s to try several contracting strategies
. Resale to Ethanol Producers In this analy sis, CCC purchase s sugar that would otherwise be f o rfeited at the min i m

um price
to - avoid forfeiture. This sugar is intended f o r resale to ethanol p rodu c ers at a price that makes e thanol p rodu c ers indifferent between using sugar and other feedstocks , primarily corn. T o derive a CCC unit outl ay amount , the f irst step is to calculate equivalent amounts of raw cane sugar and corn needed to p rodu c e the same amount of ethanol. O n e gallon of ethanol can be p roduced fro m 14.77 pound s o f raw sugar or 20. 3 6 p ounds of corn , with the resulting co rn - to sugar ratio at 1. 3 8. Next, USDA raw sugar and corn price projections corresponding t o the forfeiture period are used to co m p are feedstock purchase cos t s for ethanol producer s . For this analy sis, a projec t ed corn price of $ 6.79 per bushel , as indicated by recent cash bids for mid
- summer 2013 corn, is adjusted by s ubtracting out Dried Distillers Grains and corn oil by product credits and then converting t o a dollar per p ound basis that c o m p ares th e cost of a p o und of sugar needed t o pro d uce the same amount of eth anol. The sug ar cost is 2 2.70 cents and th e corn cost is 11.70 cents

– for a difference of 11. 00 cents. The third step factors in the the cost s incurred by switch ing the production process from corn to sugar, which is esti m at ed at 40 percent of the net corn costs, or 4.68 cents per pound
. A small offset, used in this an al y sis, is the advantage of raw cane su g ar in quali f ying as an advanced
- fuel ethanol source relative to corn as a conventi o nal source. Based on the recent narrow margin between an advanced versus conventional RIN, the raw sugar cost advantage amounts to only .03 cents per p ound. (It is i m portant to note that beet sugar does not y et quali f y for th e advanced
- fuel source designation)
. The final adjusted CCC unit outlay is calculated at 15.20 cents p er pound
. This is m ultiplied by th e amo unt of sugar that CCC would sell to bioenergy producers to derive the total cost associated with FFP of $ 91.2 million (300,000 tons x 2,000 lbs x 15.20 cents per lb = $91
. 2 million)
. V. Alternatives to FFP Considered It was assumed above that implementation of FFP i s used exclusively to manage the sugar surplus , which i s defined as the quantity of sugar that is expected to be acquired by CCC had FFP not been implemented
. This cost can be compared to the cost s expected to be incurred if CCC doe s not implement FFP and , instead, receives forfeited sugar upon loan maturity , and uses other , non - FFP, authorities to manage the surplus
. Section 9001 of the 2008 Farm Bill, which amends Title IX of the Farm Security and Rural Investment Act of 2002 (T itle 9, Sec. 9010 (b)(3)(A) Dispositions ) , specificall y authorizes CCC to dispose of its inventory through sale to bioenergy producers , to compensat e sugarcane and sugar beet growers for reducing acres planted or harvested (known as pay ment - in
- kind or PIK) , or to compensate holders of CQEs to not export to the United S tates. Itfurther grants CCC the right to use other authorities as long as the results of its actions do not cause a net increase in the supply of sugar available in the United7

States for human consumption. CCC has extensive authorities to manage surplus agricultural commodities, including provisions under the CCC Charter Act ( 15 U.S.C. 714b and c) , the c ost reduction o ptions of the Food Security Act of 1985 ( Pub. L . 99
- 198, also referred to as the 1985 Farm Bill, section 1009 , 7 U.S.C. 1308a) and the CCC general sales authority under section 16 5 of the Federal Agriculture Improvement and Reform Act of 1996 (Pub. L. 104
- 127, also referred to as the 1996 Farm Bill, 7 U.S.C. 72 85 (a) )
. CCC can use its general authorities to sell sugar for non - food uses. It is unlikel y that any particular solution will always be the most cost
- effective in every market situation, as many

factors affect the cost
- competiveness of alternative disposal options. For example, the net cost of FFP will be sensitive to the revenue that CCC can obtain upon sale of the surplus sugar to bioenergy producers. The cost of a Re
- Export Program exchange or CQE buy back is a function of the margin between the U.S. price and the world price. The cost of a PIK program is sensitive to the expec ted length of duration of the surplus : a PIK can be most cost - effective in a multi
- ye ar surplus situation. F or this anal ys is, USDA chose to estimate the cost of the FFP rule relative to the exchange of CCC sugar for Re
- Export Program license credits. On June 1 7 , 2013 , CCC invoked the Cost Reduction Options under the 1985 farm bill to purchase sugar and then offer that sugar to refiners in exchange for import credits under the Refined Sugar Re
- export Program. These exchanges are expected to be less cos tly to the government than acquiring sugar through loan collateral forfeiture. Given the narrow price differential between domestic and world price s at th e time of th is anal ys is , and the reliance on the OECD forecast that w orld raw sugar price s would average 21.58 cents per pound through the projection period , Re
- Export Program exchanges w ere deemed the least expensive of the 2008 Farm Bill Title IX alternatives for disposing of surplus sugar in the immediate future
. It is assumed that as long as world prices remain above the U.S. Sugar Program ’s support price , import access rights purchased by CCC will not be backfilled b y other countries , as countries will find it more profitable to ship to the world than to the United S tates
. The PIK alternative w as not used as the alternative scenario due to experience using the program in 200 0 and 200 1. S ugar must be acquired either through purchase or forfeiture before it can be swapped, through a bid process, with producers’ rights to harvest or plant acres to sugar crops. Results from the PIK tender performed in 2001 showed that USDA was only able to swap 1 ton of sugar in return for a 1
- ton reduction in production. With Re
- Export Program exchanges , CCC should be able to receive a greater reduction in supply in exchange for every 1
- ton of CCC inventory
. VI
. Impacts

– Costs and Benefits Costs FFP is expected to cost U.S. taxpayers $ 91.2 million in FY 2013 f o r the remov al of surplus sugar from the marketplace, or $ 53.4 million more than it would have cost were CCC not required to implement FFP and instead used Re
- Export Program exchanges
.8

To date, few producers of ethanol in the United S tates have experimented with sugar as a feedstock, as corn has been a much cheaper , more readil y available alternative. Itis estimated that CCC w ill have to pay 22.70 cents per pound 3 to acquire surplus sugar in FY 2013. Given recent cash bids for mid
- summer 2013 corn at $ 6.79 per bushel , it is further estimated that CCC w ill receive 7
. 50 cents per pound upon its sale for ethanol , incurring a 15.20 cent per pound loss
. In contrast, i t is estimat ed that the FY 2013 surplus could be ameliorated by exchanging import access rights for sugar acquired through forfeiture and held in CCC inventory
. At the time of this analy si s, U.S. raw sugar prices were several cents above world prices and many sugar exporting countries had marketing opportunities that involve d lower transportation costs than would be the case if they shipp ed their sugar to the United S tates
. As a result, this analy sis assumes that CCC could exchange 3.6 tons of world sugar import access rights for every 1 ton of sugar held in inventory
. At this ratio, CCC would exchange 83,333 tons of CCC inventory t o remove 300,000 tons of import access rights
. CCC is as sumed to use inventory from August forfeitures to avoid September forfeitures. Assuming a 100 percent likelihood of CCC having to rid the market of 300,000 tons of surplus sugar in FY 2013 , CCC’s expected cost of FFP in FY 2013 is $ 91
. 2 million . ( 1 (prob ability) x 300,000 tons x 2 , 000 lb/ton x ($ 0
. 227
- $ 0
. 075 ) ) . This estimate is higher than the expected $ 37.8 million cost of removing the same surplus b y purchasing sugar import access rights under the Re
- Export Program exchange , which is calculated as 83,333 tons x 2,000 lbs x $. 227 x 1
. Thus, FFP has a net cost of $ 53.4 million ( calculated as $91.2 million
- $37.8 million)
. Stocks do not reach surplus levels that require federal action to avoid program costs in the remainder of the baseline period because suppl y and use remain in balance without CCC sugar removals. P rojected growth in U.S. beet and cane sugar production over the next decade is modest. Beet sugar production in 2022/23 is projected at 5.319 million short tons, raw value ( STRV ) , about 4 .2 percent higher than in 2012/13. Cane sugar production in 2022/2 3 is projected at 3.864 million STRV, about 3. 9 percent higher than in 2012/13. Furthermore, over the projection period, s ugar use is projected to grow at about 0.7 percent a ye ar . Production levels in both the cane and beet sugar sectors remain below th eir overall allotment quantity ( OAQ ) shares. Sugar imports from Mexico , projected to average 1.516 million STRV over the next decade, grow to absorb the deficiency between U.S. production and demand. Despite the continuation of beverage and food manufacturers in Mexico to substitut e lower
- cost HFCS (except for the first two years of the projection period) for domestic sugar , and also remunerative prices in Mexico favoring modest expansion of sugarcane area and increased sugar production , i t is assumed that Mexico will not import sugar from third nations to replenish low sugar supplies caused b y large exports to the U.S. market. Finally , i t is projected that TRQ import levels will remain at WTO and FTA minimum access commitments. The projected increase in use over supply results in no likelihood of sugar loan forfeitures and n o CCC purchases of sugar for ethanol in the remaining baseline period as

3 Minimum forfeiture price calculation used in the baseline projections analysis.9

projected raw cane and refined beet sugar prices remain above the minimum prices that would result in forfeiture s . Benefits The main benefit to removing surplus sugar from the domestic market is to provide cane and beet processors with high enough prices to cover their production costs. Since companies cannot stay in business unless they

cover their cost s of production, the U.S. Sugar Program ’s price support and supply

control mechanisms mitigate attrition in the domestic sugar industry , protecting jobs and reducing reliance on foreign supplies. A specific secondary

benefit to purchasing and selling surp lus sugar to bioenergy producers is to help fulfill RFS levels mandated in the 2007 Energy Independence and Security Act for various ty pes of renewable fuels to be blended with U.S. gasoline and diesel fuels. At the time of this anal ys is, the marginal val ue of the RIN in using sugar as a feedstock in the production of ethanol versus corn was onl y .03 cents per pound. The availability of advanced RINs on sugarcane
based ethanol added $ 1.8 million to the government’s expected revenue. Note that RI N values are increasing due to their shortage relative to 2013 and 2014 RFS mandates. This trend is expected to continue, which will enhance the benefits to bioenergy producers associated with purchasing surplus sugar from CCC in 2013 in order to generate RIN s required by gasoline and diesel blenders to meet their RFS mandates in 2014. VII. Summary

of Impacts Results from th is analy sis indicate that, over the 10
- ye ar baseline period, FFP is likely to be onl y needed in one ye ar , FY 2013
. I f FFP were the only sugar sur plus management option available to CCC , the cost to CCC is expected to be $ 53.4 million higher than the use of Re
- Export Program exchanges
. However , if surplus sugar can be sold to bioenergy producers in 2013, RI N s will be generated to help gasoline and diesel blenders meet their RFS mandates in 2014.