Document KRJbEDvVb1VLELgpV341Znqw0

Message From: Sent: To: CC: Subject: Wehrum, Bill [/0=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=33D96AE800CF43A3911D94A7130B6C41-WEHRUM, WIL] 7/17/2018 11:47:28 PM Bob Casper [bobcasper@poetep.com] Sahay, Shailesh [Shailesh.Sahay@POET.COM]; Walther, Robert [Robert.Walther@POET.COM]; Gunasekara, Mandy [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=53dla3caa8bb4ebab8a2d28ca59b6f45-Gunasekara,] Re: Meeting on Friday Bob - This looks like a good list. Look forward to seeing you on Friday. Bill Wehrum Assistant Administrator Office of Air and Radiation U.S. Environmental Protection Agency (202) 564-7404 On Jul 17, 2018, at 12:28 PM, Bob Casper <bobcasper@poetep.com> wrote: Bill, Slook forward to our meeting on Friday. To make best use of our time, I would propose we cover only a few of the items below. Doing so should give us time to comprehensively review each subject. From Poet's perspective we would like to focus on the following: 1. Ful! E15 CAA Waiver (Word doc. attached). 2. Win:Win E15 RVP and RiN reform. 3. Full E15 Waiver-T h e current partial waiver for E15 use in 2001 and newer vehicles should be expanded to include all vehicles. Over 90% of cars on the road today meet this requirement. This change would eliminate or significantly reduce the following regulatory burden for E15: a. Dispenser Labeling-T h e EPA's labeling requirements for E15 could be eliminated or modified for other non-automotive use. b. <!--[if !supportLists]-x!--[endif]->Fuel Survey Sampling Plan - The fuel survey sampling plan imposed on stations selling E15 as part of the Mis-fueling Mitigation Plan is costly, onerous and would be unnecessary with a full E15 waiver. 2. < ! --[if !supportListsl-x!-|endifl->Underground Storage Tank Systems - The EPA requirements for fuel dispensing systems are more stringent for fuels above 10% ethanol than below. This limit needs to be moved up to 15% for equal treatment of E10 and E15. Ethanol Regulation Deficiencies 3. <!--[if !supportListsl-x!-|endifl->Emissions Modeling - A number of items within the MOVES model need to be revised to more accurately reflect the favorable attributes of ethanol blended fuels. 4. <!--[if !supportListsl-x!-[endifl->Flex Fuel Vehicle Incentives - EPA should update R-Factor calculations and provide long-term F-Factor guidance to automakers. These simple administrative actions would remove regulatory uncertainty and restore reliable CAFE compliance value to automakers for flex-fuel vehicles. 5. <!--[if isupportLists1-xi-|endif1->Greenhouse Gas Scoring - The lifecycle greenhouse gas scoring calculations need to be revised to reflect the latest research from USDA and Argonne National Laboratory showing significant improvements in GHG score for ethanol blends. Other Regulation Considerations 6. <!--[if isupportLists1-xi-|endif1->Proposed REGS Rule a. <!--[if !supportLists]-x!-[endif]->DFE as Blend Component - assuming approval by Authority Having Jurisdiction (e.g. fire marshal), denatured fuel ethanol should be allowed as a blending component for E15 as well as other higher level ethanol blends. b. <!--[if !supportLists]-x!-[endif]->Regulations for Ethanol Flex Fuel - There are a number of elements in the regulation for Ethanol Flex Fuel (E16-E85) that are problematic including natural gasoline sulfur and benzene limits, limitation on maximum amount of natural gasoline in EFF, and product transfer documentation. c. <!--[if !supportLists]-x!-[endif]->Regulatory Treatment of E16-E50 - The current treatment of E16-E50 as gasoline should be eliminated and this blend range should be treated as flexible fuel as proposed by the EPA in the REGS rule. 7. <!--[if !supportLists1-x!-|endif1->Bio-lntermediates- Poet supports the ability to partially process renewable feedstock at one facility and further process or denature at another facility. 8. <!--[if !supportLists1-x!-[endif1->Carbon Capture/Sequestration - POET Ethanol Products supports the ability to generate lifecycle GHG credit using C02 from ethanol plants if it displaces CO2 removed from geologic reservoirs. I will give you a call to discuss these items and how we may be of assistance. Thank you, Bob Casper POET Ethanol Products Sierra Club v. EPA 18cv3472 NDCA Tiers 8&9 ED 002061 00184350-00002 Direct: [ x. 6 Cell: !..... x 6... ---- Original Message----From: Wehrum, Bill <Wehrum.Bill@epa.gov> Sent: Monday, March 12, 2018 6:20 AM To: Bob Casper <bobcasper@poetep.com> Subject: RFS Follow Up Hi Bob. It was nice to meet you on Friday at the RFS meeting. My contact info is listed below. Feel free to contact me if you need anything. Bill Wehrum Assistant Administrator Office of Air and Radiation U.S. Environmental Protection Agency (202)564-7404 Confidentiality Notice: The Information contained in this e-may message, including any attachments, Is for use by the Intended recipients) only end contains information that may be legally privileged, confidential, rraoe scorer, proprierary in namm or oopyriprrrso nnoer appuoaose save n you are nor me irrrenoeo recipients), yon are hereby formally notified that any use, disclosure, copying, distribution or the taking of any aonon in reliance ee me oonrenrs or rare e-roass sransrrsssion, in venose or m parr, is srncuy prohibited Tins e-mail transmission does not constitute a consent to the use of sender's contact information ror oinsor rnao<soog purposes or rer rransrers or ears re rnsro parses, n you are nor me Intended recipient(s), please promptly notify the sender by reply e-mail and destroy ail copies of the engmas message <EPA Letter Sent 07 17 2018 Full Waiver.docx> Sierra Club v. EPA 18cv3472 NDCA Tiers 8&9 ED 002061 00184350-00003