COST BENEFIT ASSESSMENT

Date: June 19, 2013

Contact: Barbara Fecso

Dairy and Sweeteners Analysis Group

Economic and Policy Analysis Staff

Farm Service Agency

United States Department of Agriculture

Washington, DC 202-720-4146

I. Title. Feedstock Flexibility Program (RIN 0560-AH86)

II. Executive Summary

The Food, Conservation, and Energy Act of 2008 (2008 Farm Bill) modified the sugar loan and 

sugar marketing allotment program, mandated by Title I of the 2008 Farm Bill, and added the 

Feedstock Flexibility Program (FFP) for Bioenergy Producers provision under Title IX of the 

2008 Farm Bill. This cost benefit assessment only addresses the economic impacts of the rule 

that implements 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 I rule was published in 2009.

U.S. Department of Agriculture (USDA) projections as of early 2013 indicate that, over the 10-

year baseline period, the FFP will be needed in only one year,. USDA assumes that 300,000 of 

Commodity Credit Corporation (CCC) sugar loan collateral will be forfeited in FY 2013 if FFP

is not implemented. FFP 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 ReExport Program exchanges.

2 Despite this cost, FFP has at least one benefit that is not available 

with other sugar supply reduction methods. Specifically, FFP will allow the generation of 

Renewable Identification Numbers (RINs), which will help gasoline and diesel blenders meet 

their Renewable 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 forfeitures. As a comparison, the Organization for Economic Co-Operation 

and Development (OECD) baseline projects world prices above U.S. forfeiture levels over that

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 projected 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. Expected growth in U.S. 

beet and cane sugar production over the next decade is very modest—less than 5 percent over the 

10-year projection period. Further, sugar 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) annually. 

World raw sugar prices forecast by the OECD are used in the following analysis. 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 major 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 year (FY 2009). This cost benefit assessment 

provides the analyses accompanying the final rule implementing FFP. FFP provisions require

that CCC use FFP to purchase sugar from the domestic sugar market to avoid forfeitures of sugar 

loan collateral in lieu of repayment 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. CCC 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 Farm Bill. The 

price of sugar is supported, in lieu of a price support for sugar 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 sugar loan program. Sugar beet and sugarcane processors can 

receive a loan from CCC on their sugar production that can be fully satisfied by giving CCC title 

to their loan collateral, also known as “forfeiture” of collateral. Thus, sugar producers always 

have the opportunity to receive at least the loan proceeds from their crop, which becomes a floor 

on the market price of domestic sugar.

The 2008 Farm Bill Sugar Program mandates 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 by the sugar loan program. As a result, the cost of the program falls upon domestic 

purchasers of sugar, not the federal government. Domestic supply is controlled in two ways: 

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 TRQs, which allow a certain 

quantity of sugar to be imported at a lower tariff rate, subject to the minimum access levels 

established by international treaties.

The USDA baseline projects costs to the Sugar Program because USDA’s ability to limit supply

was curtailed by full implementation of NAFTA on January 1, 2008, when tariffs on sweeteners 
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were lifted by both nations. The U.S. advantage in high fructose corn syrup (HFCS) production 

has resulted in an increased flow of U.S. HFCS into Mexico, which has displaced 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 forfeitures of sugar price support loan collateral. (The 

first forfeitures in FY 2013 can occur on August 1, 2013.) The 2008 Farm Bill 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 Farm Bill, affects CCC’s surplus sugar 

management strategy in two significant ways. First, it establishes a program that requires CCC 

to proactively purchase sugar for bioenergy production throughout the year 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 affect 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 by 

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 supply 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 by 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 Payment-In-Kind Program (Subtitle G), and through buybacks of 

Certificates of Quota Eligibility (CQEs, which are identified in the 2008 Farm Bill incorrectly 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 supply of 

sugar for human consumption) under any authority. A payment-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 required 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 requested public comment through a 

proposed rule 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. However, 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.
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USDA collected comments on methods to administer FFP and, since the comments supported 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 price 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 

efficiently remove sugar deemed surplus to the domestic market and facilitate its conversion to 

ethanol or other bioenergy products.

Surplus determination

As specified in the 2008 Farm Bill, CCC must estimate the likelihood of sugar forfeitures by 

September 1 for the following fiscal year, and announce the expected quantity of sugar to be 

purchased and sold for biofuel production. Due to unfolding market conditions, early USDA 

estimates of the following fiscal year’s sugar market are unavoidably subject to significant error. 

Domestic sugarcane and sugar beet harvests 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 makes its initial estimate of 

sugar surplus. These 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 September 1. Any changes to the current year automatically

alter the current year’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 year, purchases and sales may materialize later in the year, even though early-season 

projections provide a different indication.

CCC did not strictly define surplus in the final rule, providing maximum flexibility. Because 

sugar 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 early 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 thick 

juice or cane syrup 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 

crystalline sugar yield in determining CCC’s unit purchase price. Likewise, raw sugar will 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 sugar forfeitures. CCC, in the final 

rule, has therefore restricted purchases to sugar eligible for loan, which means sugar produced 

from domestically raised sugarcane or sugar beets.
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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. In 2008 through 2011, production and use of ethanol in the U.S. 

exceeded the ethanol mandate, causing the supply 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 RINs 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 will 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 produced 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 buyers be bioenergy producers. Eligible sugar buyers must 

produce bioenergy products, including fuel grade ethanol, or other biofuels, but do not have to be 

located in the United States. However, due to the cost of transporting sugar, buyers will likely

make purchases for delivery to plants located in the United States.

Competitive procedures

CCC will announce tenders to the public outlining the terms and conditions of the sugar purchase 

and sale contracts, 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 days 

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, including price, and tender for the purchase contract at the 

identified delivery points. Alternatively, CCC could require the sugar seller to identify the 

purchasing biofuel producer and incorporate a contract of sale between CCC and the biofuel 

producer specifying 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 buyers 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 would
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encourage more competition in the program. Thus, CCC expects to try several contracting 

strategies.

Resale to Ethanol Producers

In this analysis, CCC purchases sugar that would otherwise be forfeited at the minimum priceto-avoid forfeiture. This sugar is intended for resale to ethanol producers at a price that makes

ethanol producers indifferent between using sugar and other feedstocks, primarily corn. To

derive a CCC unit outlay amount, the first step is to calculate equivalent amounts of raw cane

sugar and corn needed to produce the same amount of ethanol. One gallon of ethanol can be

produced from 14.77 pounds of raw sugar or 20.36 pounds of corn, with the resulting corn-tosugar ratio at 1.38.

Next, USDA raw sugar and corn price projections corresponding to the forfeiture period are used 

to compare feedstock purchase costs for ethanol producers. For this analysis, a projected corn price

of $6.79 per bushel, as indicated by recent cash bids for mid-summer 2013 corn, is adjusted by

subtracting out Dried Distillers Grains and corn oil byproduct credits and then converting to a 

dollar per pound basis that compares the cost of a pound of sugar needed to produce the same

amount of ethanol. The sugar cost is 22.70 cents and the corn cost is 11.70 cents – for a

difference of 11.00 cents.

The third step factors in the the costs incurred by switching the production process from corn to

sugar, which is estimated at 40 percent of the net corn costs, or 4.68 cents per pound. A small

offset, used in this analysis, is the advantage of raw cane sugar in qualifying as an advanced-fuel

ethanol source relative to corn as a conventional source. Based on the recent narrow margin 

between an advanced versus conventional RIN, the raw sugar cost advantage amounts to only .03 

cents per pound. (It is important to note that beet sugar does not yet qualify for the advanced-fuel

source designation).

The final adjusted CCC unit outlay is calculated at 15.20 cents per pound. This is multiplied by

the amount 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 is used exclusively to manage the sugar 

surplus, which is 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 costs expected to be incurred if

CCC does 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 (Title 9, Sec. 9010

(b)(3)(A) Dispositions), specifically authorizes CCC to dispose of its inventory through sale to 

bioenergy producers, to compensate sugarcane and sugar beet growers for reducing acres planted 

or harvested (known as payment-in-kind or PIK), or to compensate holders of CQEs to not 

export to the United States. It further 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 United 
7

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 cost 

reduction options 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 165

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. 7285(a)). CCC can use its general authorities to sell sugar for 

non-food uses.

It is unlikely 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 

buyback 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 expected length of duration of the surplus: a PIK can be most 

cost-effective in a multi-year surplus situation. 

For this analysis, 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 17, 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 costly to the government than acquiring sugar through loan collateral forfeiture.

Given the narrow price differential between domestic and world prices at the time of this

analysis, and the reliance on the OECD forecast that world raw sugar prices would average 21.58 

cents per pound through the projection period, Re-Export Program exchanges were 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 by other 

countries, as countries will find it more profitable to ship to the world than to the United States.

The PIK alternative was not used as the alternative scenario due to experience using the program 

in 2000 and 2001. Sugar 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 for the removal 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.
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To date, few producers of ethanol in the United States have experimented with sugar as a 

feedstock, as corn has been a much cheaper, more readily available alternative. It is estimated 

that CCC will have to pay 22.70 cents per pound3to 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 

will receive 7.50 cents per pound upon its sale for ethanol, incurring a 15.20 cent per pound loss.

In contrast, it is estimated 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 analysis, U.S. raw sugar prices were several cents above world prices and many sugarexporting countries had marketing opportunities that involved lower transportation costs than 

would be the case if they shipped their sugar to the United States. As a result, this analysis 

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 to 

remove 300,000 tons of import access rights. CCC is assumed 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 (probability) 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 by 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 supply and use remain in balance without CCC sugar 

removals. Projected 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 2022/23 is 

projected at 3.864 million STRV, about 3.9 percent higher than in 2012/13. Furthermore, over 

the projection period, sugar use is projected to grow at about 0.7 percent a year. Production 

levels in both the cane and beet sugar sectors remain below their 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 substitute 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, it is assumed that

Mexico will not import sugar from third nations to replenish low sugar supplies caused by large 

exports to the U.S. market.

Finally, it 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 no 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 forfeitures.

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 costs 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 surplus sugar to bioenergy producers is to 

help fulfill 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. At the time of this 

analysis, the marginal value of the RIN in using sugar as a feedstock in the production of ethanol 

versus corn was only .03 cents per pound. The availability of advanced RINs on sugarcanebased ethanol added $1.8 million to the government’s expected revenue. Note that RIN 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 RINs required by gasoline and 

diesel blenders to meet their RFS mandates in 2014.

VII. Summary of Impacts

Results from this analysis indicate that, over the 10-year baseline period, FFP is likely to be only 

needed in one year, FY 2013. If FFP were the only sugar surplus 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, 

RINs will be generated to help gasoline and diesel blenders meet their RFS mandates in 2014.