Document MGOJ0e2vyk7ENnBQ878GY7vvV

To: Jackson, Ryan[jackson.ryan@epa.gov] From: Chris Hessler Sent: Fri 8/4/2017 7:16:36 PM Subject: 170804 RVO backtest.pptx 170804 RVO backtest.pptx Ryan, Attached is the summary of our test of the proposed year-to-date method for the cellulosic biofuel RVO. Using the proposed methodology: The proposed growth rate is 9.3% Adding the (now-available) June data nearly doubles that rate to 17.5% Back-testing the proposed approach using 2016 data would have produced a growth rate of 55.6% Based on what is happening in the market, I suspect the rate would look much higher than you expect using the full 9 months of data called for in the proposal. There are probably some good strategies for building off the proposal to use historical data and get more consistent results. I would be happy to talk with you and/or Mandy further about this. Hessler Christopher J. Hessler | Partner | AJW, Inc. 2200 Wilson Blvd, Suite 310, Arlington, VA 22201 O: 202.296,8086 ext.101 / C: 202,460,0945 Chessler@ajw-inc.com @AjwHessler Enhancing market opportunities for innovative technologies. 17cv1906 Sierra Club v. EPA ED_001523_00001403-00001 17cv1906 Sierra Club v. EPA ED_O01523_00001403-00002 Data for 2017 RVO Projections Data for 2018 RVO Projections YTD/YTD (EPA s proposed methodology) 56.5% (EPA s proposed methodology) 9.3% (EPA s proposed methodology) 17.5% 17cv1906 Sierra Club v. EPA ED_OO1523_00001404-00001