In Support of RFS

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Mr. Bob Sather, President of the WBIA, wrote the following letter to the EPA in support of RFS. Thanks Bob for your support!

June 16, 2008

The Honorable Steven L. Johnson
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460

EPA Air Docket
Environmental Protection Agency, Mail Code: 6102, 1200
Pennsylvania Avenue, NW.
Washington DC 20460

Re: Comments on the Request from the State of Texas for a Waiver of a Portion of Renewable Fuels Standard, 73 Fed. Reg. 29,753 (May 22, 2008)

Dear Administrator Johnson:

On behalf of the Wisconsin Bio-Industries Alliance and Ace Ethanol located in Stanley Wisconsin, I am urging you to deny the request for a waiver of the Renewable Fuels Standard as recently submitted by the State of Texas.

Our Rational for this is:

1) The American ethanol industry is a job creating enterprise by creating over 238,541 jobs in all sectors of the economy during 2007 and additional jobs will be created with new plants coming online according to economist John Urbanchuk of LECG, LLC dated February 20, 2008.

2) Texas Governor Perry has given you erroneous conclusions without empirical data to support the conclusions.

3) A recent study by Texas A&M University shows that substantial benefits that ethanol is providing to the Texas Economy. This is counter to the very reason that must be demonstrated under the Clean Air Act. There is no cause and effect evidence in the assertion for the waiver that ethanol production has caused livestock production industry to experience severe harm.

4) Finally, Texas has not shown that reducing the RFS would alleviate the alleged impacts.

The RFS is part of the fuel for this economic growth and any evaluation of a waiver request must consider not only the impacts of the waiver on Texas – alleged impacts that we dispute – but also the negative impacts on jobs that would be created by a waiver. The RFS and its expansion in 2007 provide the incentives needed to promote advanced biofuels. If EPA sends a signal that the government is not committed to implementing the RFS fully – by wavering at the first inclination of any increased in price regardless of whether the RFS is the cause of the severe harm standard has been satisfied – the investment markets could react and thus jeopardize the ability to meet the goals of the legislation.

I urge you to deny the Texas request.


Robert D Sather, Board Chair-Ace Ethanol &
President of Wisconsin Bio-Industries Alliance

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