Stillwater Policy

The Problem of Invalidated RINs in the Renewable Fuel Standard

November 14, 2018 ,

November 14, 2018 by Mike Newman of Parhelion Underwriting Under the Renewable Fuel Standard (RFS), the Environmental Protection Agency (EPA) imposed a “buyer beware” approach to the purchase and sale of Renewable Identification Numbers (RINs). This creates a liability for any buyer of RINs, making them responsible for purchases of invalid RINS, even if done inadvertently.[1] The liability includes the...
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Stillwater Benchmark for Refinery Stationary Source Cap & Trade Costs

November 9, 2018 , ,

November 9, 2018 1.4 cpg   This benchmark represents the cost in cents per gallon of CARBOB gasoline and CARB diesel incurred by the refining sector under of the stationary source provision of California’s Cap and Trade program (Stationary Source Cap and Trade or SSC&T). Stillwater’s Benchmark for Refinery SSC&T Cost is calculated using the following formula: Actual Refining Sector...
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IMO 2020: A presentation to the U.S. Coast Guard and Shell

October 31, 2018 ,

On October 31st, 2018, Stillwater Senior Associate Ralph Grimmer presented comments on IMO 2020 – the International Maritime Organization’s mandated reduction in the maximum sulfur content of marine fuel (bunker fuel oil) from 3.5% to 0.5% on January 1, 2020 – at the U.S. Coast Guard/Shell “Navigating the Future” Seminar in Martinez, California. IMO 2020 will have a significant impact on the shipping and...
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California Carbon Info: Future Supply and Demand of California Carbon Offsets

October 17, 2018

As the passage of AB 398 has strengthened and extended California’s Cap and Trade program, we think our readers will benefit from a spotlight on the trends in the carbon credit market. As such, we periodically feature guest articles on California’s Cap and Trade program from our friends at CaliforniaCarbon.info. CaliforniaCarbon.info is a comprehensive information service covering the Western Climate Initiative...
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War Story: “Go figure it out”

October 15, 2018 , , , ,

by Brian Conroy When Stillwater Associate Brian Conroy worked for BP in 2006 as Global Sales and Market Development Manager of Specialty Chemicals, he was offered an opportunity to try something new. With a background in chemicals, beginning in research and progressing to various roles in business, he was ready for the change. BP’s CEO had mandated the launch of...
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War Story: California’s Lengthy Multi-Media Evaluation Process

September 12, 2018 , , ,

September 12, 2018 By Jessica Loomis Twenty years ago, methyl tert-butyl ether (MTBE) was a common additive used to oxygenate and raise the octane number in gasoline, but when incidents of MTBE leaking occurred from underground storage tanks at gas stations in California, groundwater contamination became a growing issue. MTBE isn’t particularly toxic, but its taste and odor can render...
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California Cap and Trade 101

September 7, 2018 , ,

September 7, 2018 By Jim Mladenik and Kendra Seymour Following the publication of our LCFS 101: Beginner’s Guide and LCFS 101: Update, we have received requests for a similar overview of California’s Cap and Trade (C&T) Program. To that end, here we cover what C&T is, how it works, and how it’s performing so far. What is Cap and Trade?...
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The Renewable Fuel Standard – Part 3: Where to from here? 

September 1, 2018 , ,

September 1, 2018 by Brian Conroy  This is the third and final segment in a series of articles on the Renewable Fuel Standard (RFS). In part one, we discussed the context around the passage of RFS. Part two covered the program’s primary goals and the progress to-date toward each goal. Today we conclude our series by looking down the road to discuss a new way to think about...
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California Stationary Source Cap and Trade Benchmark

August 8, 2018 , ,

August 8, 2018 BACKGROUND California’s Global Warming Solutions Act of 2006 (AB 32) put in place a series of policies and programs across all major sectors with the goal of returning California emissions to 1990 levels by 2020. The California Air Resources Board (CARB) is tasked with developing regulations and market mechanisms to meet this goal. To help achieve the...
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The Renewable Fuel Standard – Part 2: Performance Over Time

August 7, 2018 ,

August 1, 2018 by Brian Conroy In Part 1 of this series, we discussed the background and drivers for the implementation of the U.S. Renewable Fuel Standard (RFS). In Part 2, we will look at how RFS has performed against each of its three primary goals: Increase energy security Provide a mechanism for higher demand for U.S. agriculture Reduce greenhouse...
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Projecting the Costs of California’s Cap & Trade and Low Carbon Fuel Standard Programs

July 25, 2018 , ,

July 25, 2018 By Jim Mladenik and Kendra Seymour Showing the line-item cost to consumers of carbon-reduction programs assists legislators in crafting effective policy and helps fuel consumers make informed decisions. To that end, Stillwater’s carbon policy team recently conducted an analysis of the potential impact of California’s Low Carbon Fuel Standard (LCFS) and Carbon Cap & Trade (C&T) programs...
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Expected Pricing and Economic Impacts of the IMO 2020 Rule

July 10, 2018 , ,

July 11, 2018 by Ralph Grimmer The International Maritime Organization (IMO) will make a significant change to the maximum allowed sulfur content of marine fuel consumed on open oceans beginning January 1, 2020. This global change (via IMO revision of its MARPOL VI rule) was triggered by an IMO decision in 2008. Over the past year, Stillwater Associates has offered...
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Bio-Isobutanol – Overview and Challenges 

July 8, 2018 , ,

July 8, 2018 by Adam Schubert  On June 12th, 2018 the U.S. Environmental Protection Agency (EPA) announced that it had granted to Butamax Advanced Biofuels, LLC (Butamax) registration of blends of up to 16 volume percent (vol%) isobutanol in gasoline. Prior to granting this registration, EPA took the unusual step of seeking public comment due to, as EPA put it, the significant possibility that such isobutanol-gasoline blends had the potential for widespread use.   Overview  Butamax and its competitor, Gevo, have...
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LCFS Successes and Challenges

June 20, 2018 , ,

On June 19, 2018, Stillwater’s President, Dave Hackett, participated as a panel member in an informational hearing on the Low Carbon Fuel Standard (LCFS) held by the California State Assembly’s Select Committee on California’s Energy Future. The panel included an overview of the LCFS offered by the Legislative Analyst’s Office followed by comments from regulated parties and interested stakeholders. Dave...
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IMO 2020 & Crude Slate Pricing: Choose Your Own Adventure

June 5, 2018 , ,

June 5, 2018 by Kendra Seymour Contributors: James Ahrens, John Faulstich, Ralph Grimmer, Jim Mladenik, and Arshad Sheikh Let’s go back in time, to the late 1970s when sulfur regulations for fuel oil were less stringent and heavy San Joaquin Valley (SJV) crude was priced extremely low. This SJV was often minimally processed then dumped into the bunker fuel market...
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California Carbon Info: Regulatory Round-up – Informal Workshop on Potential Amendments to Cap-and-Trade Regulation

May 15, 2018

As the passage of AB 398 has strengthened and extended California’s Cap and Trade program, we think our readers will benefit from a spotlight on the trends in the carbon credit market. As such, we periodically feature guest articles on California’s Cap and Trade program from our friends at CaliforniaCarbon.info. CaliforniaCarbon.info is a comprehensive information service covering the Western Climate Initiative...
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LCFS 101 – An Update

May 2, 2018 , ,

May 2, 2018 by Megan Boutwell Exclusive LCFS CCM Analysis – Available to paid Premium newsletter subscribers beginning November 8, 2018 The Credit Clearance Market (CCM) provision of the LCFS program aims to match LCFS credit holders with Regulated Entities (REs) who have insufficient credits to meet their obligation at the end of the compliance year. The CCM price cap...
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The Trans Mountain Tangle

May 2, 2018 , , ,

May 2, 2018 by Stillwater Staff There’s a battle brewing between two provinces in Canada over a pipeline, and it may cause transportation fuels prices to spike at least in the short-term. Here we offer the backstory to get you up-to-date. In 2013, Kinder Morgan filed an application with the Canadian National Energy Board to essentially twin the existing 1,150...
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IMO 2020: A Sea Change is Coming

April 25, 2018 ,

On April 24, 2018, at The Sulphur Institute’s Sulphur World Symposium in Philadelphia, Stillwater Senior Associate Ralph Grimmer presented comments on IMO 2020 – the International Maritime Organization’s mandated reduction in the maximum sulfur content of marine fuel (bunker fuel oil) from 3.5% to 0.5% on January 1, 2020. Ralph’s presentation offers an IMO 2020 overview, a look at the perspectives of...
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FLASH ANALYSIS: CARB’s Latest LCFS Rulemaking – Are the goalposts moving?

February 22, 2018 , ,

February 22, 2018 On February 20th, the California Air Resources Board (CARB) released Unofficial LCFS Rulemaking Documents for public review. These proposed amendments will be considered at a CARB Board hearing in April 2018 and voted on at a second hearing in mid-to-late 2018. In the past, CARB has released draft rulemaking documentation before public workshops, but this release –...
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IMO 2020 Part 5: Enforcement

February 15, 2018 ,

February 15, 2018 By Ralph Grimmer The International Maritime Organization (IMO) is moving forward with a marked reduction in the maximum sulfur content of marine fuel (bunker fuel oil) from 3.5% to 0.5% on January 1, 2020. In the first four articles of our series on this “IMO 2020 Rule,” Stillwater provided an overview of the rule followed by assessments...
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Policy trends we’ll be watching in 2018

January 17, 2018

January 15, 2018 By Megan Boutwell Stillwater’s transportation energy policy experts closely follow federal, state, and international policy developments and their impacts on industry and consumers. As 2018 begins, there are a number of policy trends that we will be following and for which we’ll provide expertise to clients. The following are of some of the biggest policy trends we...
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What’s New in California’s Final 2017 Climate Change Scoping Plan?

January 17, 2018 , ,

January 10, 2018 By Miriam Stern Last month, the California Air Resources Board (CARB) approved the final version of California’s 2017 Climate Change Scoping Plan, a blueprint for reducing Greenhouse Gas Emissions (GHGs), bolstering clean energy, and improving air quality. We previously summarized the proposed Scoping Plan (drafted early last year), and, while the overall framework in the final plan...
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IMO 2020 Part 4: Bunker Suppliers’ and Blenders’ Perspective

January 15, 2018 , ,

January 15, 2018     By Ralph Grimmer of Stillwater Associates, and Adrian Tolson of 20|20 Marine Energy The International Maritime Organization (IMO) is moving forward with a marked reduction from 3.5% to 0.5% in the maximum sulfur content of marine fuel (bunker fuel oil) on January 1, 2020. In our November 2017 newsletter, Stillwater provided Part 3 of our...
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IMO 2020 Part 3:  Refiners’ Perspective

November 16, 2017 , ,

November 16, 2017 by Ralph Grimmer, James Ahrens, and Leigh Noda The International Maritime Organization (IMO) is moving forward with a marked reduction from 3.5% to 0.5% in the maximum sulfur content of marine fuel (bunker fuel oil) on January 1, 2020. In our October newsletter, Stillwater provided Part 2 of our series on this “IMO 2020 Rule”, focusing on...
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California Carbon Info: California Emissions Decline Faster than Cap in 2016

November 6, 2017 , , , ,

As the passage of AB 398 has strengthened and extended California’s Cap and Trade program, we think our readers will benefit from a spotlight on the trends in the carbon credit market. We will be featuring guest articles on California’s Cap and Trade program from our friends at CaliforniaCarbon.info. CaliforniaCarbon.info is a comprehensive information service covering the Western Climate Initiative...
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IMO 2020 Part 2: Shipowners’ Perspective

October 11, 2017 , ,

October 12, 2017 by Ralph Grimmer and Michael Myers Stillwater is following the progress and impact of the International Maritime Organization’s Global Maximum Sulfur Content of Marine Fuel Rule, or IMO 2020. Our first article, IMO 2020 Part 1: The evolution of the marine sulfur regulation, appeared on the website in September 2017.  The International Maritime Organization (IMO) is moving...
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Jones Act 101: Maritime protectionism and transportation fuels

October 10, 2017 , ,

October 10, 2017 by Kendra Seymour As often happens in the aftermath of natural disasters, there has been increased coverage in the last month debating the merits of a 97-year-old law which affects delivery of goods to U.S. shores. You’ve likely heard talk about the Jones Act, but do you know what it is and how it affects disaster-struck areas...
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IMO 2020 Part 1: The evolution of the marine sulfur regulation

September 14, 2017 , ,

September 13, 2017 by Ralph Grimmer Stillwater is following the progress and impact of the International Maritime Organization’s Global Maximum Sulfur Content of Marine Fuel Rule, or IMO 2020. This is our first article in the series. Our second article, IMO 2020 Part 2: Shipowners’ Perspective, appeared on the website in October 2017.  The International Maritime Organization (IMO) is moving...
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California Carbon Info: Analyzing California’s offset demand

September 13, 2017 , , , ,

As the passage of AB 398 has strengthened and extended California’s Cap and Trade program, we think our readers will benefit from a spotlight on the trends in the carbon credit market. Starting this month, we will be featuring guest articles on California’s Cap and Trade program from our friends at CaliforniaCarbon.info. CaliforniaCarbon.info is a comprehensive information service covering the...
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The RFS Point of Obligation Part 3: Will moving the point of obligation significantly increase the use of renewable fuels?

July 12, 2017 ,

July 12, 2017 by Michael Leister As we continue our RFS Point of Obligation series, we look at the RIN obligations calculated in the simple example last month using 100,000 gallons of gasoline and 50,000 gallons of diesel, we need to remember typical refineries produce much larger volumes of these products.  A typical refinery processes around 150,000 barrels per day...
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Forecasting LCFS Credit Prices

June 22, 2017 ,

Dave Hackett’s presentation to CARB’s June 22, 2017 board meeting. Dave provided comments to the board on the forecasted rising LCFS cost, or hidden tax, in gasoline and diesel price. This analysis first appeared in Stillwater’s June 2017 Monthly LCFS Newsletter. You can download a copy of the presentation here.

The RFS Point of Obligation Part 2: How are RINs generated and RFS compliance achieved?

June 6, 2017 , ,

June 6, 2017 by Michael Leister Last month in the first edition in our RFS Point of Obligation series, we discussed the general RFS rules, this month we get more specific about RIN generation and RFS Compliance.  When a renewable fuel producer like an ethanol production facility or biomass-based diesel manufacturing plant produces a compliant renewable fuel, the renewable fuel...
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California’s 2030 Scoping Plan: Changes for the Transportation Fuels Sector

June 6, 2017 , ,

June 6, 2017 by Kendra Seymour Introduction Last week President Trump withdrew the U.S. from the historic Paris Climate Agreement, signaling a lack of commitment at the federal level to combatting climate change. Many states, municipalities, and companies, however, have voiced continued support for the Paris Agreement and have affirmed their intention to fulfill the tenets of the Agreement. Sub-national...
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RFS Point of Obligation Part 1: How Does the RFS Work?

May 16, 2017 , ,

May 1, 2017 by Michael Leister For the past year or more, there has been a lot of discussion in the transportation fuels industry on moving the current Renewable Fuels Standard 2 (RFS2) point of obligation to the point where rack blending occurs. Currently the point of obligation is with refiners and importers, however the RINs for RFS compliance are...
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IMO 2020: The Next Big Thing for the Oil Supply Chain

May 16, 2017 ,

May 1, 2017 by David Hackett The term “oil supply chain” is a way to describe the activities that are required to produce crude oil out of the ground, move it to the refinery, transform the crude oil into fuel, and move the fuel to consumers.  The chief air pollutant in crude oil is sulfur. Governments and industry have been...
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The ripple effects of the gasoline tax increase

April 24, 2017 ,

April 24, 2017 By Rob Nikolewski, The San Diego Union-Tribune In an indication of just how much California is affected by gasoline prices, at least three different groups on Monday weighed in on the ramifications of Senate Bill 1, the $52.4 billion effort passed by Gov. Jerry Brown and the Legislature earlier this month. One organization that concentrates on policy solutions...
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LCFS 101 – A Beginner’s Guide

February 28, 2017 ,

February 28, 2017 by Megan Boutwell Exclusive LCFS CCM Analysis – Available to paid Premium newsletter subscribers beginning November 8, 2018 The Credit Clearance Market (CCM) provision of the LCFS program aims to match LCFS credit holders with Regulated Entities (REs) who have insufficient credits to meet their obligation at the end of the compliance year. The CCM price cap...
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Tier 3: A quick guide to the EPA’s new gasoline sulfur standards

January 19, 2017 ,

January 17, 2017 by EJ Ledet and Mike Leister Effective January 1, 2017, the U.S. Environmental Protection Agency (EPA) began requiring all U.S. gasoline to meet an annual 10 ppm average sulfur requirement as part of their new Tier 3 vehicle and fuel regulations. The 10 ppm sulfur average applies at the refinery gate, which is the point where finished...
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Second Quarter 2016 LCFS Credit Trends

November 17, 2016 ,

November 17, 2016 Each quarter, our Stillwater LCFS Quarterly Newsletter takes an in-depth look at one aspect of California’s Low Carbon Fuel Standard and other low carbon standard efforts around the country. In our latest LCFS Quarterly Newsletter, Leigh Noda analyzes the LCFS credit trends. The following is an excerpt from the latest Stillwater Quarterly LCFS Newsletter. The credits and...
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The U.S. Side of the U.S.-China GHG Agreement: The Impossible Dream

February 25, 2015 ,

February 23, 2015 by Dave Hirshfeld, MathPro Inc. In November 2014, the Presidents of the U.S. and China agreed to new curbs on the two countries’ greenhouse gas (GHG) emissions, stating that: “The U.S. intends to reduce its emissions by 26%-28% below its 2005 level by 2025 and to make its best efforts to reduce its emissions by 28%.” “China...
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An Industrial Policy Success Story

February 28, 2014 ,

December 12, 2013 by David Hackett For a long time I’ve been concerned about the barriers that have been created to stifle industrial development in the United States. Here in California it is virtually impossible to create new industrial facilities. For example, we have a client who has been working for years to develop a new crude-by-rail unloading facility in...
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