Comment submitted by Captain T. A. Ike Kiefer

The one and only commercial sale of cellulosic ethanol to date acknowledged in EMTS and awarded RINs by EPA was from Blue Sugars Inc (formerly KL Energy). Their wholly-owned subsidiary Western Biomass Energy, refiner of that sugar cane bagasse ethanol, is now in Chapter 11 ( http://www.ethanolproducer.com/articles/9549/western-biomass-energy-in-chapter-11-reorganization ). That sale appears to have been an internal one to Blue Sugars' joint venture partner Petrobras in Brazil. If not an open market sale, how did EPA rule this a commercial sale eligible for RINs? If EPA cannot provide oversight of even a single transaction, how can it oversee the great RIN giveaway of taxpayer money that has already proven to be rife with fraud? Here is the story of the train to nowhere that also bilked taxpayers of RIN money. http://reason.com/blog/2013/01/08/the-biofuels-train-to-nowhere-no-governm ). Several biodiesel RIN fraud cases are so well known that they prompted Congress to pass the RIN Fraud Act. The answer to RIN fraud is to end the RIN program. Attached is a paper that argues that the GHG reductions claimed by corn ethanol, cellulosic ethanol, biodiesel, and other biofuels are not supported as valid claims by current research. It is actually much more likely that biofuel cultivation and production is increasing both fossil fuel use and GHG emissions. The EPA is on the wrong side of both science and climate change on this. The scientists at EPA should review studies and reengage with Congress. Specifically, the EPA should review recent studies by the US and German National Academies of Science, the US National Research Council, RAND National Defense Research Institute, and the Institute for European Environmental Policy among many others referenced within the attached paper. These studies argue that biofuels are not so clean and green and that European and US biofuel mandates are achieving the opposite of their intended purposes and should be repealed.