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The Brazilian Sugarcane Industry Association (“UNICA”) appreciates the opportunity to comment on the proposed rule entitled Renewable Fuel Standard Program: Standards for 2019 and Biomass-Based Diesel Volume for 2020, 83 Fed. Reg. 32,024 (July 10, 2018) (hereinafter “Proposed Rule” or “Proposal”).

Meeting in Geneva today the Global Sugar Alliance called on Pakistan, India the European Union to eliminate the subsidies that have created a glut of sugar and caused a world price collapse.

To enhance America’s energy security and improve the environment, Congress created a program requiring increasing volumes of renewable fuel in the U.S. energy supply. The law – known as the Renewable Fuel Standard (RFS) – calls for Americans to use more renewable fuel each year, incrementally growing the requirement to 36 billion gallons by 2022.

To enhance America’s energy security and improve the environment, Congress created a program requiring increasing volumes of renewable fuel in the U.S. energy supply. The law – known as the Renewable Fuel Standard (RFS) – calls for Americans to use more renewable fuel each year, incrementally growing the requirement to 36 billion gallons by 2022.

The Brazilian Sugarcane Industry Association (“UNICA”) appreciates the opportunity to provide comments on the California Air Resources Board’s proposed amendments to the LCFS, which was posted for comments on March 6th, 2018.

Brazilian sugarcane ethanol has among the best GHG emission savings of all biofuels produced at scale: over 70% fewer than petrol.

A low-carbon future for Europe needs more ambitious renewables targets in transport

With respect to the ongoing EU-Mercosur trade negotiations, the above associations call for full tariff elimination on bio-ethanol, for use as feedstock in the chemical industry only. Access for bio-ethanol to be used in the transport sector should be done through tariff-rate quota.

The Brazilian Sugarcane Industry Association (“UNICA”) appreciates the opportunity to provide these comments on the proposed rule, entitled the “Renewable Fuel Standard Program: Standards for 2018 and Biomass-Based Diesel Volume for 2019; Proposed Rule,” 82 Fed. Reg. 34,206, published by the U.S. Environmental Protection Agency (“EPA”) on July 21, 2017 (“Proposed Rule”).

I write to you concerning the press release you issued on 03 July as one of four co-signatories (the European Association of Sugar Manufacturers, the Confederation of European Beet Growers, the European Federation of Food, Agriculture and Tourism Trade Unions and the European Renewable Ethanol Association) “EU-Mercosur negotiations: Stand up for EU sugar and ethanol!”.

The Brazilian Sugarcane Industry Association – UNICA – welcomes some of the recommendations of the European Parliament ITRE and ENVI Committee reports on the European Commission’s Renewable Energy Directive proposal, but regrets that neither goes farenough.

The Brazilian Sugarcane Industry Association – UNICA – welcomes the EU’s continued efforts to promote sustainable renewable energy but regrets the proposed reduction of sustainable conventional biofuels in Europe’s energy future, as well as the European Commission’s apparent lack of ambition in terms of the proposed proportion of renewables in the energy mix.

The Brazilian Sugarcane Industry Association (“UNICA”) appreciates the opportunity to provide these comments on the proposed rule, entitled the "Renewable Fuel Standard Program: Standards for 2017 and Biomass-Based Diesel Volume for 2018; Proposed Rule," 81 Fed. Reg. 34,788, published by the U.S. Environmental Protection Agency (“EPA”) on May 31, 2016 ("Proposed Rule").