Message Information 

Date 08/10/2012 05:14 PM 

From Kristin Wilcox <kwilcox@affi.com > 

To LisaP Jackson/DC/USEPAIUS@EPA 

The Honorable Lisa P. Jackson Administrator 

U.S. Environmental Protection Agency 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

Dear Administrator Jackson: 

On behalf of America's food and beverage producers and consumers, we urge you to waive the amount 

of renewable fuel that must be produced under the Renewable Fuels Standard (RFS), as the U.S. is 

expected to experience a significant drop in corn yields due to historic drought conditions across 

America's heartland. 

The undersigned organizations represent the nation's food, beverage and consumer products makers, 

who are responsible for $2.1 trillion in annual sales, employ 14 million workers and contribute $1 trillion in 

added value to the economy every year. 

EPA's RFS requires that an estimated 13.8 billion gallons of domestic corn ethanol be blended into the 

nation's motor fuel supply in 2013. This mandate, which diverts food stock for the production of fuel, will 

exacerbate the global economic impact of the devastating drought occurring in U.S food producing 

regions. Congress delegated to the EPA administrator the authority to waive, in whole or in part, that 

requirement if the RFS "would severely harm the economy," according to the Clean Air Act, Sec. 

211(o)(7). 

Already, approximately 40 percent of all corn grown in the U.S. is dedicated to ethanol production. Corn is 

an important feedstock for the meat, milk and poultry production that feeds America and the world. Our 

exports of corn, soybean and meat products - the items most at risk from the drought - totaled $53 

billion in 2011, according to the Census Bureau. The increasing demand for corn needed to produce 

ethanol, combined with a significant reduction in overall available corn supplies due to the prolonged 

drought, may lead to an insufficient amount of corn available for food production. 

More than half of the nation's counties have now been declared disaster areas and the U.S. Department 

of Agriculture (USDA) has reported that more than half of the corn crop is listed as poor to very poor. 

This has resulted in higher demand relative to the available supply and led to a 45 percent jump in corn 

prices in the two month period ending July 31. 

The extreme losses to grain yields, and other food crops, because of the most severe U.S. drought in fifty 

years is already having a ripple effect throughout the food supply chain both in the U.S. and around the 

globe. USDA's latest forecast for retail food prices predicts the drought will drive up the cost of beef and 

poultry as much as four to five percent this year. 

Granting a waiver, or partial waiver, from the RFS mandate would significantly reduce the harm food 

makers and consumers will feel because of the drought. A recent study by the United Kingdom's 

Department for Environment, Food and Rural Affairs found that reducing the RFS by one-half would 

reduce the magnitude of corn price spikes by as much as 40 percent.
As American consumers continue to cope with a period of pro-longed economic turmoil, and U.S. food, 

beverage and consumer products makers from farm to fork struggle with record high commodity prices, 

we believe it is EPA's duty to grant a waiver for the applicable volume of corn ethanol required by the 

RFS. 

We stand ready to assist you in ensuring that consumers of U.S. food, beverage and consumer products 

have access to an abundant and affordable supply. Thank you for the immediate consideration and action 

on our request. 

Sincerely, 

American Bakers Association 

American Beverage Association 

American Dairy Products Institute 

American Feed Industry Association 

American Frozen Food Institute 

Associated New York State Food Processors 

Association for Dressings and Sauces 

California League of Food Processors 

Canned Food Alliance 

Food Marketing Institute 

Grocery Manufacturers Association 

Independent Bakers Association 

International Dairy Foods Association 

Maine Food Producers Alliance 

Michigan Food Processors Association 

Midwest Food Processors Association 

National Association of Margarine Manufacturers 

National Council of Chain Restaurants 

National Confectioners Association 

National Fisheries Institute 

National Frozen Pizza Institute 

National Restaurant Association 

Northwest Food Processors Association 

Ozark Food Processors Association 

Seafood Products Association 

Snack Food Association 

Texas Food Processors Association RFS AFFI-GMA FINAL.doc 

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Processed Date: 

Processed By 

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Message Count
The Honorable Lisa P. Jackson 

Administrator 

U.S. Environmental Protection Agency 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

Dear Administrator Jackson: 

On behalf of America's food and beverage producers and consumers, we urge you to 

waive the amount of renewable fuel that must be produced under the Renewable Fuels 

Standard (RFS), as the U.S. is expected to experience a significant drop in corn yields due 

to historic drought conditions across America's heartland. 

The undersigned organizations represent the nation's food, beverage and consumer 

products makers, who are responsible for $2.1 trillion in annual sales, employ 14 million 

workers and contribute $1 trillion in added value to the economy every year. 

EPA's RFS requires that an estimated 13.8 billion gallons of domestic corn ethanol be 

blended into the nation's motor fuel supply in 2013. This mandate, which diverts food 

stock for the production of fuel, will exacerbate the global economic impact of the 

devastating drought occurring in U.S food producing regions. Congress delegated to the 

EPA administrator the authority to waive, in whole or in part, that requirement if the RFS 

"would severely harm the economy," according to the Clean AirAct, Sec. 211(o)(7). 

Already, approximately 40 percent of all corn grown in the U.S. is dedicated to ethanol 

production. Corn is an important feedstock for the meat, milk and poultry production that 

feeds America and the world. Our exports of corn, soybean and meat products - the 

items most at risk from the drought - totaled $53 billion in 2011, according to the Census 

Bureau. The increasing demand for corn needed to produce ethanol, combined with a 

significant reduction in overall available corn supplies due to the prolonged drought, may 

lead to an insufficient amount of corn available for food production. 

More than half of the nation's counties have now been declared disaster areas and the 

U.S. Department of Agriculture (USDA) has reported that more than half of the corn crop 

is listed as poor to very poor. This has resulted in higher demand relative to the available 

supply and led to a 45 percent jump in corn prices in the two month period ending July 

The extreme losses to grain yields, and other food crops, because of the most severe U.S. 

drought in fifty years is already having a ripple effect throughout the food supply chain 

both in the U.S. and around the globe. USDA's latest forecast for retail food prices 

predicts the drought will drive up the cost of beef and poultry as much as four to five 

percent this year.
Granting a waiver, or partial waiver, from the RFS mandate would significantly reduce the 

harm food makers and consumers will feel because of the drought. A recent study by the 

United Kingdom's Department for Environment, Food and Rural Affairs found that reducing 

the RFS by one-half would reduce the magnitude of corn price spikes by as much as 40 

percent. 

As American consumers continue to cope with a period of pro-longed economic turmoil, 

and U.S. food, beverage and consumer products makers from farm to fork struggle with 

record high commodity prices, we believe it is EPA's duty to grant a waiver for the 

applicable volume of corn ethanol required by the RFS. 

We stand ready to assist you in ensuring that consumers of U.S. food, beverage and 

consumer products have access to an abundant and affordable supply. Thank you for the 

immediate consideration and action on our request. 

American Bakers Association 

American Beverage Association 

American Dairy Products Institute 

American Feed Industry Association 

American Frozen Food Institute 

Associated New York State Food Processors 

Association for Dressings and Sauces 

California League of Food Processors 

Canned Food Alliance 

Food Marketing Institute 

Grocery Manufacturers Association 

Independent Bakers Association 

International Dairy Foods Association 

Maine Food Producers Alliance 

Michigan Food Processors Association 

Midwest Food Processors Association 

National Association of Margarine Manufacturers 

National Council of Chain Restaurants 

National Confectioners Association 

National Fisheries Institute 

National Frozen Pizza Institute 

National Restaurant Association 

Northwest Food Processors Association 

Ozark Food Processors Association 

Seafood Products Association 

Snack Food Association 

Texas Food Processors Association