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California works to rebalance LCFS market

  • Spanish Market: Emissions
  • 20/12/23

California Low Carbon Fuel Standard (LCFS) credits plunged early in the trading session before backtracking as the participants digested a long-awaited proposal to rebalance the market.

New carbon-reduction targets, new obligated fuels, new market mechanisms and revisions to existing credit generators that will be discussed in a rulemaking next year helped to swiftly swing trades for first quarter 2024 credits lower by more than 10pc compared to the end of Tuesday's session early in the trading day. Credits then traded back up to nearly recover to where they ended the previous session, all in the first half of the session.

Participants are digesting a largely expected proposal to toughen program targets by 50pc by 2030 and a new, proposed mechanism to advance to tougher targets when the supply of renewable transportation fuels to California create far more credits than deficits. But the pace of both the rulemaking and implementation of tighter market provisions may mean the program continues to pile more unused credits onto record volumes already weighing on one of the most important US markets driving renewable fuel investment.

LCFS programs require yearly reductions to transportation fuel carbon intensity. Conventional, higher-carbon fuel that exceeds the annual limit incurs deficits that suppliers must offset with credits generated from approved, lower-carbon alternatives.

The California Air Resources Board (CARB) proposal would require a 30pc reduction from revised 2010 fuel carbon intensity benchmarks by 2030. Previous targets have lowered the carbon limit by 1.25pc/yr, but the proposal would include a 5pc drop in 2025 and roughly 2.25pc reductions for each remaining year.

A deluge of available credits, led by renewable diesel and renewable natural gas supplied for transportation, led CARB staff to pursue tougher targets. Participants had more than 18mn metric tonnes of unused credits available by the end of June — nearly enough to satisfy all obligations generated in 2021. These credits remain available until they are used, and do not expire.

This credit supply has helped slash the spot credit price by more than half since January 2021, from around $200/metric tonne to less than $80/t so far this month.

The agency has for the first time proposed a mechanism to automatically toughen targets when such conditions arise. An Automatic Adjustment Mechanism (AAM) would, beginning in 2028, trigger if the credit bank more than triples the number of new deficits generated in a quarter, and if credits exceeded deficits in the prior year. New credits have exceeded new deficits since 2021.

Regulators proposed other methods to rein in credits without eliminating incentives to transition to lower- or zero-carbon transportation. Limits on credits from forklifts, future renewable natural gas (RNG) and tighter requirements for crop- and forestry-based feedstocks could slow the flood of new credits. A proposal to include jet fuel supplied in the state for flights between California destinations — an estimated 23,000 b/d in 2022 — would provide a new source of deficits.

But concessions needed to maintain confidence in the ongoing buildout of lower-carbon infrastructure may limit the speed and effectiveness of this rebalancing. None of the proposed restrictions on RNG for transportation would apply to projects that break ground by the end of this decade. A revision to the calculated nitrous oxide and carbon content in the baseline for 2010 ultra-low sulfur diesel effectively softens the 2030 target to a 26pc reduction from today's levels. The change would grant more credit-generating runway for renewable diesel supplies.

Credits meanwhile continue to pour in to the program while the rulemaking winds toward a vote. Public comment will begin early next year, with a CARB hearing in March. The proposed steep reduction remains out in 2025, with automatic tightening years further away. The bank of unused credits increased by more than half in the first six months of this year compared to the same period of 2022, and has doubled since 2021. The wobbly first half of today's trading session suggests participants remain unsure of the program's balance.


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