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diesel producers and feedstocks. This request for a 2 billion gallon level assumes that no new
-based diesel
pathways are approved by the EPA for production in 2014 in the biomass
category. IfEPA anticipates approving additional pathways that will make eligible significant
new volumes of imported fuel for the biomass-based diesel category during 20 14, we urge EPA
to adjust the volume upward from this request to accommodate these anticipated new
volumes. Further, we would like to highlight our concern that setting a 2014 requirement below
the 2 billion gallon level will result in decreased domestic production, worker layoffs and a pull
back from new investment in capacity in this sector of the RFS.
It is imperative to our nation's clean energy future, and to preserving the important gains made
by this new industry, that the Obama Administration maintain the vigorous support for the RFS2
that it has shown to date. We appreciate your leadership on this issue, and the efforts you have
made during your tenure to implement and expand the RFS2.
Thank you for your consideration of our concerns about the program going forward. If you have
any questions regarding these concerns, please
do not hesitate to contact us or Bob Van
Heuvelen of Van Heuvelen Strategies at 202-534-4920.
Sincerely,
John Plaza
CEO, Imperium Renewables
Jonathan Phillips
COO, Renewable Biofuels