CALIFORNIA S LOW CARBON FUEL STANDARD (LCFS) REVIEW OF COMPLIANCE TRENDS

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CALIFORNIA S LOW CARBON FUEL STANDARD (LCFS) REVIEW OF COMPLIANCE TRENDS Julie Witcover Sonia Yeh Institute of Transportation Studies, UC Davis IAEE Meeting, New York, June 2014

LCFS goal: Reduce transport fuel carbon intensity (CI) by 10%, 2010-2020 (part of suite of California climate policies) Compliance Schedule Fuel B (deficits) Focus on CI, not volume or specific fuel type Technologyforcing Backloaded On hold at 1% CI reduction due to court case Fuel A (credits) 2 standards (gasoline, diesel pools) Lifecycle CI ratings generate credits/deficits (performance based), each represents 1 MT CO 2 e Each g CO2e/MJ CI point has value (market mechanism) Flexibility (fuel, CI mix for compliance; opt in fuels; new pathways; banking/trading credits) 2

Program metrics: compliance exceeded thru 2013 Available Credit Bank Up Rated CI of California Fuels Down End of 2013. 2.62 million MT CO2e excess credits systemwide 2013 deficits: 2.45 million Source: California Air Resources Board (CARB) Less CI reduction for higher volume fuels gasoline substitutes: -6% diesel substitutes: -26% 3

Compliance via shifting portfolio of alternative fuels, then higher volumes in 2013 % VOLUMES Of alternative fuels, eth 85%, CNG/LNG 9%, BD/RD 6%, elect <1% Alt fuel share 2013: 7.3% of total LCFS transport energy (avg 18.0 bgge/yr 2011-3) CREDITS Ethanol ~ 64% of credits; lower CI profile in 2013 Renewable diesel & biodiesel <10% of credits 2011-2012; 35% of credits in 2013 Source: CARB Witcover UNM 2/22/2013 4

Calculated CI for alternative fuels: two groups, different trends 2011-3 -6%, eth - 4%, CNG/LNG 2011-3 +24%, BD +63%, RD Small CI declines for higher CI-rated fuels Volatility, CI increase for lower CI-rated fuels 5 Source: CARB data

LCFS biofuels & feedstocks credits double in 2013 on 10% volume growth outside corn ethanol 2011-2013 Corn & grain mix: 67% of biofuel credits. Cornbased fuel credits up 76%, volumes drop 5% Sugar-based fuel: 11% of biofuel credits. Volumes up 3.4 times, steadier contribution Tallow, waste/uco fuels: 27% of biofuel credits, 4% of biofuel volume (due to relatively low CI) Soy contribution <0.5% of biofuel volume and credits (>50% US biodiesel) 6 Source: CARB

New pathways key to lowering CI ratings 7 Source: CARB

LCFS draws lower CI-rated fuels into CA California transport energy: roughly 10% US Sugarcane. CA sugar-based fuels as % of US sugarcane imports: 2011 33% 2012 23% 2013 69% Renewable Diesel. CA renewable diesel as % of US production+imports: 2011 3% 2012 7% 2013 21% (No cellulosics yet, little soy) Source: CARB 8

LCFS credit prices up then down NOT like Cap&Trade allowance price (price on emissions relative to standard) Volume & # of transfers increase with price 1.4million credits traded Source: CARB 2013-14 price range ~$80/t (Nov.), ~$20/t (Mar.) Effect of court case, frozen standard? Sources: Oil Price Information Service and Progressive Fuels Limited 9

LCFS, US Renewable Fuel Standard: Shifting incentives for fuel pathways RFS RIN credit & LCFS credit value additive for CA use For CA, non-soy biodiesels attractive in 2013 Policy uncertainty a factor in credit price volatility, uncertainty RFS annual mandate adjustments LCFS court cases, pending amendments 10

LCFS Looking Ahead Re-adoption (due to court ruling on environmental procedures) can alter incentives cost containment (potential price collar) land use change review streamlined pathways ( CI binning ) innovative oil credits Standard on hold at 1% til re-adoption LCFS credit prices, excess credit bank reflects policy uncertainty (price not zero) Policy interaction fossil fuel transport in Cap-and-Trade from 2015 LCFS expansion issues? (Pacific Coast Collaborative) fuel availability, shuffling, harmonization? 11

Concluding thoughts Importance of flexibility Various margins contribute to compliance (new fuels + incremental CI reduction in high volume fuels) Trading across fuel pools (reliance on diesel pool) Smaller jurisdiction Draw existing fuels in compliance at lower cost (shuffling) Learn from larger programs (cost mechanism for hi/lo prices prior to crisis?) Program Issues CI ratings v. GHG realities, now & if scaled up ( waste alternative uses, market effects from land use & beyond, e.g. fuel displacement) Administrative capacity to rate & monitor CI Technology neutral? (different treatment for reference fuels) Technology forcing? (trade-off between low-cost GHG reductions today & deeper change) Is there an innovation CI threshold? 12

Questions? jwitcover@ucdavis.edu Funding from California Air Resources Board, California Energy Commission 13