

                                       
August 10, 2012


Mr. Karl Simon, Director
Transportation and Climate Division
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, D.C. 20004

Re:  RFS2

Dear Mr. Simon:

The record setting drought in the central part of the country is generating significant concerns across the nation and around the world regarding the price and availability of food and feed.  As a result Congress is considering what action should be taken to ensure the availability and affordability of food and feed.
There is a significant ongoing discussion regarding the impact that the use of ethanol for fuel is having on the price and availability of corn.  Much of the discussion is in regard to suspending or reducing the fuel use requirements for corn ethanol established under the Energy Independence and Security Act of 2007 (EISA).  EISA established a second set of Renewable Fuel Standards (RFS2) for use of corn ethanol and several types of "advanced biofuels" as transportation fuel.  Biodiesel is defined by the RFS2 as an advanced biofuel. It is extremely important for the members of Congress and to distinguish corn ethanol from biodiesel both in terms of the final product and the feedstock used. Biodiesel is produced from fats and oils, a significant portion of which are inedible.  Biodiesel produced by Future Fuel and other biodiesel manufacturers has no direct impact on the demand for or the consumption of corn. 
The current discussions regarding RFS2 are negatively affecting Future Fuel's customers and business.  Many of our customers are starting to question the need to continue purchasing biodiesel if a suspension of the RFS2 or a change to EISA is imminent.
It is important to FutureFuel and the biodiesel industry that discussions in Congress regarding the suspension or modification of the corn ethanol blending requirements are accompanied by statements that changes to the advanced biofuel (biodiesel) blending requirements are not being contemplated by Congress or requested of the EPA.  It must be clearly communicated that any possible suspension of or modification to corn ethanol blending requirements will not have any impact on biodiesel blending requirements.



FutureFuel is one of the largest producers in the nation.  FutureFuel produces biodiesel from inedible feedstocks such as yellow grease, crude corn oil, inedible tallow, choice white grease, and poultry fat.  
Biodiesel has been and continues to be a major component of the U.S. effort to lower its reliance on foreign oil and improve the environmental impact versus carbon based fuels. It is vital to FutureFuel and the employees of FutureFuel that the biodiesel consumption required by the RFS2 continues.
Best regards,
						
	Lee E. Mikles
	President & CEO
	LEM/mc
	

							
