Document M4zb7JjJ8EM3q9r7VMq6aMkKx

Ouestions/Comments for EPA Administrator Scott Pruitt Sorghum Oil Biodiesel Pathway When can we expect a final rule approving sorghum oil as a biodiesel feedstock? Small Refiner Waivers/Exemptions So far at least 1.5 billion gallons of ethanol demand destruction has resulted from EPA's waivers for profitable refiners while my son struggles through three years of negative margins on the farm. How does EPA plan to remedy the lost gallons to make good on the President's promise to ensure blend levels match the statute? When can the reallocation o f lost gallons start? How are you going to protect 2019 RVOs against future waivers? Have you reallocated any gallons as directed by the President? If not, when w ill you? So far the only way we know about the Small Refinery Waivers is through publicly traded company SEC reports and media stories. How many small refinery exemptions has EPA granted and how w ill the exemptions impact ethanol blending? Although EPA typically publishes its proposed actions and fin al decisions fo r the public to see in the Federal Register, EPA has not followed those protocols for small refinery waivers; nor has EPA even informed the public by any means th a t it had received or acted on such carve-out requests. Why has EPA consistently rejected attem pts to bring greater transparency to the small refinery exemption extension process and ignored demands from members of Congress for the same essential facts? RINs Underyour leadership (and previously under A dm inistrator McCarthy), EPA has stated tha t refiners o f all shapes and sizes recover RIN costs through the prices they charge for the gasoline and diesel product they make. Your EPA and the Obama EPA also both publicly stated th a t RIN prices are not a cause o f economic harm to refiners. Does EPA still stand behind these statements or has the Agency changed its mind? If you've changed your mind, why? What facts led you to change your mind? When Donald Trump was elected president ethanol RIN prices were $1.00, after a couple of White House meetings on changingthe RFS they fell to 40 cents, and today they've collapsed to around 20 cents What is the ideal RIN price for EPA? When RIN prices fall it becomes less economically attractive for retailers to sell blends such as E15, E30, and E85. Data from the Energy Department indicate ethanol blending has indeed fallen in 2018 as a result of the Small Refinery Waivers and RIN price collapse. How does this not break your promise and the President's promise to uphold the RFS as the law o f the land and to ensure blending volumes match the statute? On October 19, you sent a letter to Midwest Senators th a t EPA w ill not pursue regulations to allow RINs on exported renewable fuel. This export RIN idea surfaced again recently as part o f an `indefinitely delayed" White House plan. Is the Adm inistration still considering allowing RIN credits on exports? If yes, why have you gone back on your w ritten promise from October 19? RVP relief for E15 and higher blends [PAGE] Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00070971-00001  On April 12, President Trump publicly stated he was going to allow E15 sales year-round, he repeated th a t promise at a May 8 meeting at the White House. Why has EPA not made good on the President's repeated promise and when w ill EPA finally carry out the President's commands to extend RVP relief to E15 and higher blends? Gas prices are clim bing to the ir highest levels since 2014, exceeding $3 per gallon in some parts of the country already, yet EPA w on't let most Americans fill up on E15 which costs about a nickel per gallon less than regular. Allowing E15 year-round would also help spurdem and for farmers who are suffering from low prices and surplus crops. Why w o n 't EPA act on this issue? It seems like a lost opportunity to do something to help Americans. Will EPA stream line/fast-track the rulemaking process to provide RVP relief to E15 w ith an interim final rule so retailers w ill be able to sell the fuel fo r part o f the current summer ozone season? Rural America deserves and needs immediate action. Com biningthe Issues of Waivers. RINs, RVP Granting RVP relief for E15 in exchange w ith export RIN credits for refiners would have unquestionably been a loss for rural America and consumers because the benefits of selling E15 year-round would have been wiped out by export RINs. How do you see it? In EPA's opinion, how would RVP relief fo r E15 and higher blends im pact RIN prices? Other Biofuel-Related Issues How does EPA intend to com ply w ith the 2016 calendar year statutory requirem ent o f 15 billion gallons o f conventional biofuel as remanded by the U.S. Appeals Court for the DC Circuit (Americans for Clean Energy et al vs. EPA)? Has EPA begun preparing fo r a Reset o f RFS volumes (total, cellulosic, and advanced)? If so, when do you expect the Reset to go into effect? Do you believe EPA has the legal authority to increase the m inim um octane of gasoline or would that require an Act of Congress? You've asked fo r input on the im pact o f GHG standards " on advanced fuels technology, includingthe potential fo r high octane fue l." What plans does EPA have fo r high octane fuel? What does EPA th in k about E25-30 blends as a potential source o f high octane fuel? According EPA analysis, biodiesel reduces greenhouse gas emissions by 57-86 percent compared to petroleum diesel, so why is n 'tth e EPA further expanding the volumes fo r biomass-based diesel and advanced biofuel under RFS since the market can support a much larger volume? Doing so would not only foster a cleaner environment and stronger, more robust economy, but benefit the livestock industry by reducing costs fo r inputs such as soybean meal, as well. Pesticide Registration and Re-registration Why does EPA use laboratory data instead of real data submitted by pesticide registrants? (For example, atrazine.) Why does EPA not take the advice of the Scientific Advisory Board? (For example, atrazine.) [PAGE] Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00070971-00002  Why is EPA more precautionary with bees and other species then they are with humans? (For example, neonicotinoids.) Gene Editing and Plant Incorporated Pesticides (PIPs) Will the exemption for conventional breeding apply to gene editing under FIFRA? Sierra Club v. EPA 18cv3472 NDCA Tier 1 [PAGE] ED 002061 00070971-00003