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October 16,2017
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The Honorable Scott Pruitt Administrator Environmental Protection Agency Office of the Administrator 1101A 1200 Pennsylvania Avenue, N.W. Washington D C. 20460
Dear Administrator Pruitt:
Thank you for taking the time to meet with me, the other biodiesel producers, and representatives of the National Biodiesel Board (NBB) on Friday morning of October 13'\
I was very encouraged by your comments regarding the Notice of Data Availability (NODA) dated September 26, 2017 that the intent of the NODA was not to suggest additional reductions in advanced biofuels or reductions in the biomass-based diesel (BBD) volume obligations, but to just get input on the F.PA's authority regarding the use of waivers and the consideration of imports when setting renewable volume obligations. While we believe the advanced fuels and BBD volumes proposed by EPA on July 2 Ist were too low. we are comforted that they will be no lower in the final rule. As discussed, we know the U.S. biodiesel industry is capable of producing significantly greater volumes of biodiesel than we have been producing. One of the big challenges has been trying to compete with highly subsidised imports of biodiesel.
President George W. Bush championed the RES to promote the growth of renewable fuels. 1 he D.C. Circuit Court said this year about the RFS, "Congress adopted a market forcing policy intended to overcome constraints in the market by creating demand pressure to increase consumption of renewable fuels." The U.S. biodiesel industry, not counting the idled plants, has the capacity today to produce 2 6 billion gallons of biodiesel and when setting volume obligations, biodiesel imports must also be included I his is why we agree with NBB's previous recommendation that the advanced biofuels volumes for 2018 should be at least 4.75 billion gallons and the 2019 BBD volumes should be at least 2.5 billion gallons.
T hank you again for taking the time to meet last Friday I very much enjoyed meeting you and the group discussion about biodiesel and the RFS. Next time you are in the Oklahoma Panhandle we invite you to tour our biodiesel plant in Guymon.
Sincerely,
Mel Davis Vice President. Hog Procurement & Bioenergy Cc: Ryan Jackson
9000 W. 67* Street, Suite 200 | Shawnee Mission, KS 66202 | (913) 261-2600 j www SeaboardFoods com
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The Honorable Scott Pruitt Administrator Environmental Protection Agency Office of the Administrator 1101A 1200 Pennsylvania Avenue, N.W Washington D.C. 20460
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