“We are submitting these comments in support of this petition because the new, elevated ethanol mandates, enacted by Congress in December 2007, are and will continue to severely harm the economy of Texas, our members, and the United States of America if the EPA does not grant this waiver,“ wrote J. Patrick Boyle, President and CEO of the American Meat Institute.

“The rapid increase of this diversion of corn severely impacted and will continue to harm our member companies, their investments, employees, and most immediate suppliers, producers of livestock and poultry that are competing against this government mandate,“ added Boyle.

Within its comments, AMI cites multiple reasons the waiver should be granted, including a number of economic harms caused by the corn-ethanol mandates which are already apparent, severe and imminent. Reasons include:

• Substantial losses to be incurred by meat, livestock and poultry producers in Texas and elsewhere as a result of significant, artificial increase in the prices of corn and other crops since 2005;
• Extreme weather and flooding have negatively impacted corn and feed growing regions;
• Undue hardships on U.S. households during a time of financial stress;
• Feed and food-price inflation across many sectors;
• The severity of economic impact is greater than anticipated and is evident;
• Insignificant benefits relative to severe costs incurred;
• Inability to be flexible during a crop failure or flooding in remaining growing season;
• Foreseen price distortions that will continue to materialize;
• Adversely impacting investment and employment in food security;
• Stifling of the next generation of biofuels;
• The ‘Twenty in Ten’ goals are achievable with the waiver.