Low Carbon Fuel Standard “Crude Shuffle” Greenhouse Gas Impacts Analysis

Barr Engineering for the National Petrochemical and Refiners Association

[From executive summary] A low carbon fuel standard (LCFS) policy requiring a reduction in the carbon content of transportation fuels is intended to reduce greenhouse gas (GHG) emissions from the transportation sector by setting a performance standard based on the total amount of carbon emitted per unit of fuel energy. A major challenge to the effectiveness of LCFS is the possibility of ―shuffling‖ or ―leakage.‖ The market will tend to promote solutions to meet LCFS that are the least costly, potentially shuffling production and sales in a manner that meets the requirements of LCFS but does not necessarily produce the desired outcomes for GHG emissions., This analysis illustrates that implementing LCFS in the U.S. could encourage ―shuffling‖ that would double the greenhouse gas emissions associated with crude oil transport to and from regions directly and indirectly impacted by the policy.

A LCFS implemented in the U.S. results in a notable increase in greenhouse gas emissions due to the displacement of Canadian crude imports to the U.S. and re-routing of crude imports and exports to accommodate this displacement. The policy is likely to discourage U.S. imports of Canadian crude produced from oil sands because of the higher-lifecycle GHG impacts1, instead encouraging imports of crude from areas that produce light sweet crude, most notably from the Middle East. Nearby Canadian crude sources would be diverted to regions not affected by LCFS and replaced with supplies from distant parts of the world. This study provides an evaluation of the net GHG impacts of implementing LCFS in the United States by focusing on resulting shifts in crude oil transport to isolate the net change in GHG emissions. The analysis compares a ―base case,‖ developed to  assess transport emissions associated with current crude import/export patterns between Canada and the U.S. and the Middle East and China, to a ―crude shuffle case,‖ with Middle Eastern crude replacing Canadian imports to the U.S. and with Canadian crude exports routed instead to China… [H/T: E&E News]

Michael A. Levi’s rebuttal at CFR: The National Petrochemical and Refiners Association (NPRA) has released a study showing that a “nationwide low-carbon fuel standard would increase global greenhouse gas emissions”. It is a distorted and misleading piece of work.

Here’s their basic argument: A low-carbon fuel standard (LCFS) would not have any impact on global oil production. It would, however, exclude high-emissions Canadian oil from U.S. markets. The United States would thus import more oil from the Middle East, and Canada would send its oil to China. This “shuffle” would increase emissions associated with crude oil transportation by 9-19 million tons of CO2 each year (with the exact amount depending on how much Canadian oil was shut out). That would also be the net impact on global emissions.

This is wrong. An LCFS affects oil consumption by increasing the price paid in the United States for fuels derived from oil in an amount proportional to their associated emissions. (It also increases the price of alternatives, but by less.) It thus reorders global oil consumption and decreases it. Lower U.S. oil consumption results in a mix of lower production and increased consumption elsewhere (through a slightly lower world oil price).

What is the net impact on emissions? The NPRA study argues that blocking all Canadian imports would increase transport emissions by 19 MtCO2 each year. Lifecycle emissions for a barrel of crude oil are about 0.5 MtCO2. Total U.S. consumption is currently about 20 million barrels per day. That leads to total annual emissions of about 3.7 billion MtCO2 per year. A decrease in that amount by 0.5% (net of any offsetting increases elsewhere) would completely offset the increased transportation emissions that NPRA identifies. And this analysis is generous to the NPRA: an LCFS would also increase the use of alternative fuels and promote greater efficiency in oil operations, which would also reduce emissions; I have, however, completely ignored those effects.

For the overall NPRA conclusion that an LCFS increases global emissions to be correct, the LCFS must be strong enough to shut out all Canadian crude, but too weak to result in an 0.5% decline in U.S. oil consumption (or perhaps 1% to be generous – there will be some offsetting consumption increases outside the United States). This is implausible.

The NPRA will argue that “LCFS implemented in the United States is not expected to change overall trends in energy use and demand for crude resources throughout the rest of the world”. This is probably true to a first approximation. But the 19 MtCO2 increase that they identify is also a rounding error – and an even smaller one.

I am not a big fan of an LCFS. But debate over one should be based on facts rather than nonsense.


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