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                  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
§ V^TTy ?                     WASHINGTON, D C 20460

 July 17.2009
                                                                            Office of
                                                                       Cooprative Environmental
 Karen She Her                                                              Management
 ASRC Management Services
 EPA Headquarters Repository (Library)
 MC: 3404T
 Washington, DC 20460

 Dear Ms. Shcffer

 Enclosed arc copies of reports prepared by or for the National Advisory Council for
 Environmental Policy and Technology (NACEPT) under the Federal Advisory Committee Act
 (1;ACA)  NACEPT is managed by EPA's Office of Cooperative Environmental Management

     I   NACEPT Advice Letter. NACEPT's Role (April 2009)
     2   NACEPT Report Hncoui aging Regional Solutions to Sustaining Water Sei-ioi  Utilities
        (March 2009)
     3   NACEPT Report: Outlook /oi the EPA (March 2009)
     4.  NACEPT Advice Letter  EPA's Draft 2009-2014 Strategic Plan Change Document
        (December 2008)
     5   NACEPT Advice Letter to the Administrator on Biofuels (December 2008)
     6   NACEPT Review of EPA's Strategy for Improving Access To Environmental
        Information (November 2008)r
     7   NACEPT Advice Letter  Integrated Modeling (September 2008)

 11'you have any questions, please contact me at 202-564-0243 or alticn.soma(fr),cpa gov

                                        Sincerely,

                                                 "\ X\
                                            -
                                         oma ATtTerr
                                        Designated Federal Officer
                                        NACEPT
                                Internet Address (URL) • hrtp //www epa gov
          Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer. Process Chlorine Free Recycled Paper

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                              NACEPT
                              Shaping the Nation's Environmental Policy
                             National Advisory Council for
                         Environmental Policy and Technology
December 15,2008
The Honorable Stephen L. Johnson
Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460

Re:    NACEPT's Fourth Advice Letter to the Administrator on Biofuels

Dear Administrator Johnson,

In January, 2007, NACEPT requested that EPA start an "Agency-wide dialogue on EPA's role in
the biofuels mission and develop an integrated, collaborative, multi-media biofuels strategy."
We have now reviewed the Draft  Biofuels Strategy and wish to express our sincere appreciation
for the work done by so many people. This Strategy exceeds our expectations. It is an important
achievement in itself,  and  one which will serve as a model of intellectual and programmatic
integration.  The  ability  of over  ninety people throughout the agency  to form this consensus
using sustainability as  the unifying concept bodes well for a new approach to the environmental
challenges of today.

The Draft Biofuels Strategy  provides an excellent primer for EPA's legal and programmatic
responsibilities. In doing so it identifies key research and important management issues for the
Agency and current and  potential demands on EPA if it is to carry out  it responsibilities.  The
intertwined relationships  of the federal agencies working on biofuels and EPA's proper place in
this group are aptly defined.

The most important contribution of the Strategy is  to provide an  intelligent guide on  how
biofuels  related  issues  should be identified and reviewed.  This Biofuels  Supply Chain
framework supports the entire Strategy and provides a lengua franca to all who work on biofuels.
It is already being used by other agencies and the biofuels industry to facilitate communication
and coordination across organizations with very different structures and roles.

We do have some relatively modest recommendations to make with respect to the format of the
document. We would suggest that the five principle recommendations be moved to the front of
the document, along  with the 22  specific  recommendations.  With  the  integration of the
Executive Summary,   this  will make  a proper  stand-alone  "strategy" document.   Then the
remainder of the document can be condensed as background.  There are several very informative
charts, easily used by many, which should be  included. We especially like "The Biofuels Supply

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Chain," "EPA Mandates Related to Biofuels" and "Key Agencies" involved in each portion of
the supply chain.

The Biofuels Strategy would be greatly enhanced with the setting of priorities and deadlines.
This part, of course, could be updated and reviewed over time.  In any event, there are deadlines
in statutes, and more importantly, internal deadlines for biofuels sustainability  related issues
which should be set now for the shorter term to keep pace with developments in industry and
other parts of government.

We call your attention to NACEPT's report on Integrated Modeling which calls for increased use
of and improvements in full life cycle modeling (hup epa uov ocenvnacept'reports pdf naccnt-
im-final-ad\ icc-lottci-092208 pdl).  Biofuels is an ideal place  to apply this approach and EPA
has already developed extensive life cycle modeling of greenhouse gas emissions, air emissions
and  other factors  as  a foundation  for the soon to be  proposed  Renewable  Fuel Standard
rulemaking (RFS2).  We recommend that  EPA expand  its ability to conduct further life cycle
analyses related to other environmental sustainability parameters being developed  in interagency
discussions (e.g., water quality and  quantity, biodiversity, etc.).    Such an effort would be
relevant to the EISA Section 204 Report to  Congress that EPA is required to submit by 2010 and
every three years thereafter, other EISA mandated studies, and would be of great interest to EPA
programs and regions, and the federal inter-agency Biomass Research and Development Board.

The next  large scale effort for the  Biofuels  Strategy  will  be to  develop  a  thorough
Implementation Strategy.  The  current effort should outline how this  will be done, and be a
milestone in the work suggested above.  We will be looking for the  Biofuels Strategy to be
incorporated in the EPA Strategic Plan and the 2010 budget.

With the  change of Administration,  it will be  important to convey  to  the Agency's new
Administrator the importance of the initiative EPA has been taking in this area, both for assuring
the sustainability of the nation's biofuel program and as a model for a more integrated, cross-
media approach to environmental challenges.

Once again, we congratulate EPA for this rapid and serious beginning to a world class biofuels
program.

                                         Sincerely,
                                        //Signed//

                                        John L. Howard, Jr.
                                        Chair
cc:     Robert Olson, Working Group Co-Chair
       Frank Stewart, Working Group Co-Chair
       Marcus Peacock, Deputy Administrator
       Charles Ingebretson, Chief of Staff

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Ray Spears, Deputy Chief of Staff
George Gray, Assistant Administrator, Office of Research and Development
Robert J. Meyers, Acting Assistant Administrator, Office of Air and Radiation
John B. Askew, Regional Administrator for EPA Region 7
Sally Shaver, Acting Counselor to the Administrator for Agricultural Policy
Rafael DeLeon, Director, Office of Cooperative Environmental Management
Sonia Altieri, NACEPT Designated Federal Officer
Megan Moreau, NACEPT Staff

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