Dear Mr. Under Secretary:

Imperial Sugar Company (“ISC”) is one of the cane sugar refiners in the United States that depends on imported
raw sugar to sustain its operations. ISC employs approximately 500 direct and contract workers at our facilities in
Port Wentworth, Georgia and Ludlow, Kentucky and at our supporting offices. We also support many additional
jobs in the Georgia community related to logistics, warehousing, river services, as well as the expenditure of
related disposable income. Our role as an import-based cane sugar refiner allows us a unique insight into the U.S.
sugar market and the impact of USDA policy decisions on that market.

For the last 18 months, the U.S. sugar market has been challenged with an ongoing shortage of raw sugar. That
shortage emerged during 2020, when USDA gave a higher priority than normal to refined sugar imports in
response to a severe reduction in beet sugar production from the 2019 harvest. This policy stance left the country
with an ending stock of raw sugar on September 30th, 2020 that represented slightly less than one month of raw
sugar use. Despite a significant contraction in U.S. cane sugar refining activity since then, the raw sugar situation
has not improved.

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