866 Willow Tree Circle * Cordova, TN 38018 * Tel. 901.682.0800

June 12, 2015

Karl Simon, Director

Transportation and Climate Division

Office of Transportation & Air Quality

U.S. Environmental Protection Agency

1200 Pennsylvania Ave., NW 

Washington, D.C. 20460

Dear Director Simon:

In support of the petition for approval of a Renewable Fuel Standard (RFS) pathway for 

cottonseed oil, the National Cottonseed Products Association (NCPA) is submitting this 

information on the volumes of biomass-based diesel that would likely be produced in the United 

States if such a pathway were provided. 

As discussed over the past several years since we first submitted our petition, it is difficult to 

estimate the volumes of biomass-based diesel that would be produced from cottonseed oil due to 

the number of variables involved. The factors that will impact the volumes produced include the 

price of cottonseed oil relative the price of other biomass-based diesel feedstocks and the 

transportation costs to source the cottonseed oil versus that of other feedstocks. Other factors 

include the price of petroleum diesel and overall biomass-based diesel market and demand 

factors, such as the final RFS volume requirements, the status of the biodiesel tax credit, and

levels of imports of biomass-based diesel, particularly from Argentina where they have the 

potential to substantially increase their imports to the United States depending on market 

conditions, transportation costs, and RFS compliance factors. 

Based on the information and resources available to us, the NCPA estimates that the volumes of 

biomass-based diesel that will be produced using cottonseed oil in the near future will be 

relatively low, ranging from 3 million gallons to 30 million gallons. This view is based on the 

higher cost of cottonseed oil (see attachment), the lack of biodiesel production facilities colocated with cottonseed oil processing facilities as there are with soy and canola. A list of 

cottonseed oil processing facilities is included on the last page. 
866 Willow Tree Circle * Cordova, TN 38018 * Tel. 901.682.0800

For perspective, the volumes of biodiesel produced from canola oil in 2013-2014 ranged from 

approximately 80-130 million gallons and canola oil was typically priced lower than cottonseed 

oil during this time and there is at least one large biodiesel production facility co-located with a 

canola crushing facility. Furthermore, rather than provide blanket approval of the NCPA 

cottonseed petition, EPA has indicated it intends to require individual biodiesel producers to 

submit a separate, specific petition to obtain approval for the use of cottonseed oil for RFS 

eligible biomass-based diesel, and this will also likely depress the amount of cottonseed oil 

biodiesel production. 

The NCPA would like to reiterate that the relatively small amount of biodiesel that will likely be 

produced from cottonseed oil will make it unlikely that any significant indirect effects will occur 

as a result of EPA approval of a cottonseed oil RFS pathway. As stated and supported in our 

initial petition, cottonseed oil is a by-product of cotton and cottonseed and the utilization of 

cottonseed oil will not drive or significantly impact cotton demand or production. 

Again, the NCPA bases our views on the volumes of biomass-based diesel that will be produced 

from cottonseed oil on the current and estimated near-term price relationships of cottonseed oil 

and other RFS approved vegetable oil feedstocks, the capacity of biodiesel production facilities 

that are in close proximity to cottonseed oil processing facilities, and other market, policy and 

RFS program factors. 

We hope that this information is helpful to EPA in its consideration of a cottonseed oil pathway. 

If there is additional information or input the NCPA can provide, please let us know. 

Sincerely,

Ben Morgan

Executive Vice President
866 Willow Tree Circle * Cordova, TN 38018 * Tel. 901.682.0800

Cottonseed Oil Processing Facilities:

 Archer Daniels Midland Company

Locations: Valdosta, Georgia; Memphis, TN; Lubbock, TX; Richmond, TX

 Valley Coop Oil Mill (co-located with biodiesel facility with 3 million gallon capacity)

Location: Harlingen, TX 

 Planters Cotton Oil

Location: Pine Bluff, AR

 Hartsville Oil Mill

Location: Darlington, SC

 Producers Co-op Oil Mill

Location: Oklahoma City, OK

 Delta Oil Mill

Locations: Jonestown, MS; Greenwood, MS

 PYCO Industries, Inc.

Location: Lubbock, TX

 J. G. Boswell Company

Location: Corcoran, CA
866 Willow Tree Circle * Cordova, TN 38018 * Tel. 901.682.0800