Loading...
HomeMy WebLinkAbout9 Attachment - 2 Monetize LCFS Credits TRUCKEE � � AGENDA ITEM #16 Public District MEETING DATE: February 2, 2022 TO: Board of Directors FROM: Steven Keates, Conservation & Customer Service Senior Analyst SUBJECT: Monetization of Current Low Carbon Fuel Standard (LCFS) Credits APPROVED BY Brian C. Wright, General Manager RECOMMENDATION: A. Authorize the General Manager to execute an agreement (Attachment F) with Northern California Power Agency (NCPA) to enter into NCPA's Market Purchase Program. B. Authorize the General Manager to sell District owned Low Carbon Fuel Standard (LCFS) credits in the LCFS market of a quantity up to 1,100, which is estimated to result in unbudgeted revenue and restricted cash funds to the District for year 2022 and annually thereafter. BACKGROUND: In March of 2017 the District established an account with the California Air Resources Board's (CARB) Low Carbon Fuel Standard Reporting Tool Credit Bank & Transfer System (LRT-CBTS). The original staff report summarizing this process is provided here as Attachment A. Having been established as a low carbon fuel supplier with CARB, the District received Low Carbon Fuel Standard (LCFS) credits on a quarterly basis. The credits represent "Tons of CO2" conserved through the pathway. TDPUD has been accruing credits since Page 1 of 10 our registration in 2017. Credits are received through two sources: 1) CARB provides credits to the District based on new Electric Vehicle registrations in Truckee (verified through the DMV) on a quarterly basis. These are termed "base credits" by CARB. 2) The District receives LCFS credits for all electricity sold through District owned EV charging stations (located at Meadow Park, the Downtown Train Depot, and at Pioneer Center). Credits generated by the charging stations are negligible relative to the base credits. LCFS Credits: Current Balance and Forecasted Accruals The District has not sold any credits since it started accruing them in 2017. As seen in Table 1, our current credit balance is 1,047 which includes all credits accrued through Q3 of 2021. Note that credits are issued on a quarterly basis for the previous quarter. Therefore, credits for Q4 of 2021 will be issued at the end of Q1 2022. Table 1 Summary of TDPUD LCFS Credits Year Credits Received Credits . . Cumulative Credits 2017 147 0 147 2018 196 0 343 2019 254 0 597 2020 171 0 768 2021 279 0 1,047 Total Current Credits: 04 The historical LCFS credit aggregation is shown at a quarterly resolution in Figure 1 . Here it can be seen that the quantities have varied significantly over the period from 2017 through 2022 and no obvious trend can be observed. The blue line indicates the cumulative aggregation of District credits. Page 2 of 10 Figure 1 LCFS Credits Earned by Quarter 140 1,200 L � i 120 1,000 -p Cf 100 U L $oo (n 0 80 LL u V) 600 J 60 0) 400 *" u 40 3 u20 200 3 J U Q 0 a a a a a a a a a Cr a a a a a a a a a a r1% r. r. r. W W M M M M m M o o c 0 �4 ri ri ri ri ri ri ri ri ri ri ri ri rl N N N N N N N N O C O O O C O O C G O O O O C O O O C O N N N N N N N N N N N N N N N N N N N N CARB provides a description on how the number of credits accrued in a given quarter are derived (Included as attachment C). Reviewing the calculation steps, it can be seen that credit amounts are predicated on several factors for which future estimates can be developed: 1) The number of Plug in Electric and Hybrid vehicles (PEVs) operating within Truckee during the quarter (determined by CARB based on registration data supplied by the DMV and other data sources). 2) The grid average carbon intensity (Also determined by CARB on an annual basis). In practice, staff found limited correlation with the dispensed credits and PEV registrations in Truckee.' The best correlation (albeit still limited) was found between credits issued and the number of new PEV registrations in the preceding quarter (shown in Figure 2). 1 Data on PEV registrations can be found by county and zip code here: https://www.energy.ca.gov/data- reports/energy-insights/zero-emission-vehicle-and-charger-statistics. Note that limited data exists to develop this correlation as TDPUD only registered as a Fuel Pathway with CARB in 2017 and the CEC tool provides EV sales data at annual resolution. Page 3 of 10 Figure 2 LCFS vs EV Sales(Lagged) 350 300 r cn 250 "" R2 =0.6992 200 u p LL 150 u J 100 5a 0 0 20 40 60 80 100 120 EV Sales in Truckee in Previous Quarter Sufficient correlation exists in the data to allow the District to develop reasonable forecasts of its future LCFS distributions as a function of local PEV registrations. Developing those forecasts however requires one more model which examines the trend of PEV sales in Truckee. Figure 3 plots data from the California Energy Commission (CEC) for PEVs in Truckee zip codes. Two trend lines are plotted which represent two potential modes for growth — linear and exponential.2 While, in the near future, the market is likely to follow more closely with the exponential fit, it is difficult to forecast disruptive events such as seen in 2020 which would dampen the overall trend. Thus, a linear extrapolation is also provided as a "conservative" lower bounds for forecasted LCFS credits. 2 In this case the trend line uses a second order polynomial model which, in the short term, approximates an exponential extrapolation. Note that a true exponential fit would predict a significantly steeper adoption rate than what is shown or supported by the data. Page 4 of 10 Figure 3 New EV Registration Projections in Truckee 350 300 a M 250 R' = 0.90861 L 200 aU dC 150 r _ — W 100 r R' 0.703 �y r r•r �W 50 r �. '• L r r i r Q ir •'� 2009 2011 2Q13 2Q15 2a17 2019 2021 2023 2025 2027 • Zip Poly.(lip) — — Linear(Zip) By combining these models staff has developed a forecast of LCFS credit aggregation for the 2022-2023 budget cycle (note that uncertainties in the model become much more exaggerated farther out such that the estimates for a 2024-2025 budget cycle are less useful for planning purposes). Table 2 Forecasted LCFS Credit Accrual ForecastedBudgetYear Max Sales Min Sales Max Credits Min Credits Credits 2022 150 85 300 253 2023 188 94 340 263 2024 229 102 385 273 2025 275 111 435 283 Staff estimates that the District will continue to accrue LCFS credits at a rate of roughly 317 per year assuming (1) no significant changes are made to the LCFS legislation and (2) existing trends continue with respect to PEV adoption in Truckee.3 LCFS Credit Valuation The actual valuation of District owned credits is time-sensitive and subject to prevailing market conditions. One market report dated November, 2021 indicated that credits were at that time valued at $152 each (included in Attachment B). This report also 3 Note that the rate at which the District earns credits will drop as the grid carbon intensity continues to improve. CARB has the prerogative to determine what value they will use to derive credit volumes. Page 5 of 10 demonstrated a downward trend in the value of LCFS credits — something that has been observed by other market participants and expressed in a recent workshop with CARB staff. Based on existing market trends, staff estimates that the market value is currently $142 and likely to continue declining. This is one impetus for this staff report and the recommendation to sell District credits at this time. Table 3 shows the current estimated value of District LCFS credits and forecasted revenue from LCFS credits (assuming current market conditions persist). Table 3 Estimated LCFS Revenue through Current Budget Cycle Existing Credits 1,047, Forecasted Credits (per Year) 317 •. Total for 2022-2023 Budget Cycle 1,364 Assuming a value of $142 per credit, the Districts current credits are valued at $148,674 and future credits would represent approximately$45,000 per year. This combines to total a forecasted revenue of$193,363 for the 2022-2023 budget cycle. Note that it is very difficult to predict the future market for LCFS credits. As the intention of the program is to accelerate the reduction of carbon content in transportation fuels, the value of LCFS credits will continue to drop if the program is successful. However; many market participants have expressed concern with CARB over the volatility and recent drops in value relative to other carbon cap-and-trade frameworks. CARB may decide to implement some interventions to provide market stability though CARB has not expressed any opinions on the matter to date. Spending Requirements In its LCFS guidance document 20-03 (included as Attachment E) CARB provides guidance on its requirements for spending proceeds from the sale of credits. The District is considered a Load Serving Entity (LSE) within the LCFS framework and its associated spending requirements are defined starting on page 4 of the guidance document. The overarching requirement for spending LCFS credit proceeds are that expenditures must advance Transportation Electrification within the LSE's service territory. The LSE is provided some discretion regarding how this is accomplished and some of the examples provided by CARB include: 1) Providing incentive support for purchasing/leasing EV's or other electrification transportation equipment 2) Providing incentive or direct investment for installing EV charging infrastructure 3) Providing rate options or incentives to encourage EV charging during off-peak hours to provide grid benefits 4) Providing on-bill credit or other incentives to promote the use of electric Page 6 of 10 transportation 5) Marketing, education, outreach programs to provide information and material it inform the public on the benefits of EV transportation. While the above represent the general spending requirements for the LCFS proceeds, CARB also provide more specific requirements under two categories: Category Description Clean Fuel Reward (CFR) Small publically owned utilities(POUs) must contribute a minimum of 2% Program4 of base credits to the CFR beginning in 2023 Starting January 1,2022 a minimum of 30%of the credits not contributed to CFR must be used to support transportation electrification for the Holdback Credit Equity primary benefit of(or primarily serving) (1) Disadvantaged communities, Requirements (2) Low-income communities, (3) Low-income individuals, (4) Rural area. The minimum percentage increases to 40% in 2023 and then finally to 50% in 2024 and beyond. Finally, CARB places strict limits on the percentage of proceeds which can be spent on Administrative costs. Per the guidance document no more than 10% of total annual spending on holdback credit equity projects may be spent on administrative costs which are the defined on pages 10-11. In the following section staff demonstrates how the District programs through which the LCFS proceeds will be spent comply with the spending requirements outlined above. PURPOSE: The purpose of this staff report is to provide the Board with sufficient information regarding the Districts participation in the LCFS program as to make a decision on whether or not to sell the District's accumulated LCFS credits. General information regarding the scope of the sale and the spending requirements levied by CARB on its proceeds are provided in the previous section of this staff report. In this section staff provides details on the process of the sale and the planned expenditures for which the proceeds are budgeted (including demonstration on how the expenditures are compliant with CARB spending requirements). 4 A statewide program overseen by the California Air Resources Board which provides rebate incentives for EV purchases through dealerships at the time of sale (upstream buy down of cost to purchase). More info can be found at https://cleanfuelreward.com/california-ev-rebate-program. Page 7 of 10 Sales Process NCPA provides a service to its member utilities under the Market Purchase Program which enables NCPA to buy and/or sell certain commodities on behalf of its member utilities. In order to participate in this program TDPUD would need to sign an agreement with NCPA. This agreement is provided as Attachment F to this staff report. The LCFS specific language can be found in Exhibit K of the document. With the agreement in place between the District and NCPA, TDPUD can allocate its existing LCFS credits to NCPA through the LRT-CBTS (online tool) to sell on its behalf. NCPA is currently preparing to pool together LCFS credits from its member utilities to aggregate to a large enough scale as to improve the potential sale price. Once credits are sold, NCPA pays TDPUD the proceeds and the District reports the final sale volume and revenue amounts to CARB in our end-of-year reporting. Planned Usage of Proceeds In past years incentives were provided for residential and commercial EV charging infrastructure out of the Public Good Charge (PBC) budget.5 For the 2022 and 2023 budget cycle staff expanded the budget for such programs in part due to the expectation that LCFS credits would need to be monetized in the near future to comply with CARB rules. As such, the existing expense budget for Department 4 (Conservation) included the necessary spending for CARB approved LCFS programs. For each budget year the District will implement customer programs which provide rebate incentives for several transportation electrification measure (which are also consistent with the District's decarbonization efforts) Table 4 Listing of Transportation Electrification Rebate Offerings —W!VlleasureM�� Incentive Amount(per) Residential EV chargers (Base Charger) $500 Residential EV chargers (Smart Charger) $700 Commercial EV Chargers $2,000 Main Panel Upgrade (Residential)' $1,000 In addition to the rebates offered above, District staff will be actively working with community partners to identify potential transportation electrification projects which will 5 Public Goods Charge do regulations allow for spending on such categories. 6 The final incentive level for this measure is still under review and may be revised upwards. Page 8 of 10 benefit disadvantaged members of our community. Examples of such projects could include: 1) Multilingual marketing, education, and outreach regarding electric transportation options and benefits 2) Rebates towards purchase of new or used EVs 3) Contributions towards electrification of local public transit buses, school buses, or drayage trucks. While there exists some overlap between the PBC programs and LCFS programs (for example EV chargers, and main panel upgrade rebates), a total of$186,888 is budgeted to be spent on LCFS specific transportation electrification projects. Error! Reference source not found. summarizes the budgeted LCFS specific expenditures in the 2022-2023 budget cycle. Table 5 Summary of Planned LCFS Expenditures by Year for 2022 and 2023 Budget Cycles • 1 CFR Contribution $0 0% CFR spending requirement starts in 2023 Hold-Back Credits $62,521 67% Income Qualified $30,637 33% Consistent with 30%requirement for 1st year Total Expenses $93,158 100% • CFR Contribution $1,000 1% -2%of the forecasted$45,000 Revenue for 2023 Hold-Back Credits $56,238 59% Income Qualified $37,492 40% Consistent with 40%requirement for2nd year Total Expenses $94,730 100% Table 6 Overall Budgeted LCFS Expenditures for'22- '23 budget cycle Total Implementation Costs $168,199 90% Only 10%of total expenditures are allowed to be Total Admin Costs $18,689 10% spent on Administrative overhead $186,888 - — It can be seen that the planned expenditures for 2022 and 2023 ($186,888) fall just under the expected revenue from the LCFS credits for the same period ($193,636). This is largely due to intentional conservative planning given the uncertain value of LCFS Page 9 of 10 credits at the time of sale. The program expenses will be managed actively throughout the budget cycle to adapt as necessary to actual revenue from the LCFS credits. FISCAL IMPACT: The monetization of the District's LCFS credits will create unbudgeted revenue and the funds will be deposited in a restricted cash account, similar to AB32 auction sale proceeds. While their sale will result in additional unbudgeted revenue to the District; this revenue comes with strict spending requirements per the California Air Resources Board. Staff have already developed programs which will meet CARB requirements and worked the associated expenses into the budget for the 2022-2023 budget cycle. To the extent qualifying program expenditures are made, funds can be transferred from the LCFS restricted account to general fund operating account. For 2022 and 2023, the recommended transfers would be the qualifying expenditure amount in excess of the budgeted expenditure amounts, if any. The remaining balance in the LCFS restricted account would be available for 2024 and thereafter. Indirectly, the District will see incremental increases in revenue due to the load growth associated with transportation electrification. ATTACHMENTS: Several attachments are provided in support of this staff report: %ttachment Attachment Attachment A 2017 Staff report to the Board requesting registration into the LCFS program Attachment B LCFS Market Update Report for November 2021 Attachment C CARB Base Credit calculation methodology for PEVs Attachment D CARB Base Credit calculation methodology for forklifts Attachment E CARB guidance document on LCFS spending requirements Attachment F NCPA Market Purchase Program Agreement for sale of LCFS Credits Page 10 of 10