I am making this request because I do not believe any decision made at this late date will be based on a rational technical analysis of the real effects of this waiver. Over the past year, there has been an abundance of technical information introduced into the record demonstrating the adverse effects that will result from granting the waiver. This analysis suggests that the waiver would worsen air quality in California, increase the cost of gasoline in California, increase the imports of foreign-refined gasoline into California and threaten the integrity of the entire reformulated gasoline program. In addition, there would be adverse economic effects resulting from the waiver outside of California. Thousands of farmers in rural communities throughout the Midwest have invested millions of dollars in farmer-owned cooperative enterprises that are engaged in ethanol production.
Ethanol is the biggest success story in the value-added agriculture movement.
A precipitous decision by the EPA will jeopardize that investment and the future of value-added agriculture.