Brazil's Potential Role in Ethanol Trade

This year, Brazil’s exports have tracked at a level 50% below last year’s exports.  It is our opinion that Brazil’s participation in the international fuel ethanol market is going to be very limited over the next two years.  The following is a list of factors that will contribute to keeping Brazil off the fuel ethanol export market:

•          Dry weather conditions have reduced sugarcane yields per acre by 5% or more below forecast this harvest season.
•          The poor weather conditions during the last two years have conspired to disrupt the typical replanting share of 20% of the cultivated acreage.  This has left the industry with a substantially older crop in the field that yields less cane than younger sugarcane.  It will take at least another growing season to remedy this imbalance in the sugarcane crop.
•          Sugar prices are again at record levels, and it appears that the sugar industry will not be able to replenish stocks this year, leaving the sugar market fundamentally tight for at least another year. 
•          Higher sugar prices will continue the favoring of sugar production in Brazil, where mills can swing approximately 1 billion liters of ethanol production towards sugar.
•          High sugar prices generating copious amounts of cash, coupled with the government loan program for ethanol inventory, has allowed mills to show market discipline and not dump ethanol onto the market to generate cash.  This is evidenced by the industry holding more than 2 billion liters more of inventory than last year at this point in the harvest, allowing the mills to maintain high ethanol prices.
•          The startup of significant chemical demand to produce green plastics.  Braskem’s new polyethylene facility will consume 500 million liters per year of ethanol starting next year.
•          The continued growth of the flex-fuel vehicle (FFV) fleet by 2.7 million vehicles per year.  If these FFVs shift from E25 to 100% hydrous ethanol, they have the potential to consume an additional 3.5 billion liters per year of ethanol.  FFV fuel demand is very elastic and will respond to price quickly.   Higher prices this year have reduced ethanol demand by over 1 billion liters as the FFV fleet has responded to high ethanol prices relative to gasoline.  The overall size of the FFV fleet is estimated at 11.7 million vehicles by the end of 2010.  In our opinion, this is the single largest reason why Brazil, at least for the next several years, will not be a major exporter of ethanol due to the potential for a huge surge in demand domestically when the prices are set accordingly.

EPA E15 Decision

The EPA decision on the E15 waiver came as no surprise this week.  The EPA ruled that E15 gasoline blends were okay for 2007 and later year model vehicles in the US.  As we have stated numerous times in previous reports, a bifurcated market will not work.  For example, The National Association of Convenience Stores (NACS) told its members to exercise extreme caution on whether to sell E15 gasoline.  The NACS represents convenience stores and the petroleum retailing industry that sells an estimated 80% of the motor fuels in the US.  The NACS’s key issues with the EPA waiver is that it does not address the liability of using dispensing equipment not specifically certified to handle ethanol blends in excess of E10 and the liability exposure for engine damage and Clean Air Act emission violations caused by misfueling vehicles, even with appropriate labeling in place.  An excellent study commissioned by the American Petroleum Institute that we referenced several weeks ago sums up all the other regulatory barriers that must be dealt with before E15 can enter commerce officially.  Here is the link to that study: http://www.jordan-associates.com/Sierra%20Repor%20on%20E15%20Reg%20Hurdles_080410.pdf

The huge sticking point that is evident in the proposed rulemaking is that the 1.0 psi RVP waiver granted for E10 cannot be extended to E15 by agency rulemaking.  In 40 CFR 80.27, the law limits the waiver to gasoline containing between 9%-10% ethanol with no exception.  It can only be changed with an act of Congress.  In this week’s proposed rulemaking (here is the link - http://www.jordan-associates.com/e15-labeling-nprm.pdf), the EPA is proposing that E15-blended gasoline will not  be granted this RVP waiver, forcing the blendstock that 15% ethanol is blended with to have a reduced vapor pressure and allowing the finished blend to meet summertime gasoline RVP without a waiver.  This means a refiner will be required to produce both an E10 blendstock and an E15 blendstock.  The rulemaking goes through an elaborate process to prevent comingling of E10 blendstock with E15 blendstock in order not to violate the RVP waiver language.  It is absurd to think the gasoline industry is going to go through these contortions to deliver E15 to the consumer.  There is no economic incentive for a refiner to produce a more expensive blendstock to accommodate E15.  In our opinion, these rules are completely unworkable, and it is going to take an act of Congress (hopefully with more input from industry) to clean up this mess. 

Ethanol Tax Credit Renewal

The impressive juggernaut called the ethanol lobby seems to be losing their grip on the political landscape – at least for the moment.  After spending almost the entire year staking out the position that renewal of the VEETC (Volumetric Ethanol Excise Tax Credit) and import tariff were a must-have from the US government, with no compromise, the ethanol lobby received little to no traction on this position.  In response to no movement by lawmakers on renewing ethanol’s tax credit, the key lobbying groups - RFA, Growth Energy and ACE - are now floating a compromise position.  The form of the compromise is outlined as follows:

· Reduce the existing 45 cpg blending tax credit by up to 50% for 2011

· Create a refundable producer tax credit to start in 2012 to last four years – there are no details available on how this would be calculated

· Reward ethanol producers who reduce their carbon footprint with higher producer credit levels – there are no details available on how this would be calculated

· Eliminate the import tariff, starting in 2012

· Accelerate deployment of flex-fuel vehicles by mandate and provide government grants for blender pumps at fueling stations

· Allow cornstarch ethanol to be considered for “Advanced Biofuels” status

· Suppress indirect land use penalties on cornstarch ethanol

Being a keen observer of today’s political environment, it is becoming highly unlikely that a lame duck session of the US Congress is going to deal with the ethanol industry tax credit issues.  A new Republican-controlled Congress in 2011 has the potential to be politically hostile to any attempt for an ethanol tax credit renewal.  We think our subscribers should at least prepare for expiration of the VEETC and the import tariff moving into 2011. 

The key impact will be pressure on discretionary ethanol blending that depends on ethanol/gasoline economics, and not mandated volumes.  We can estimate discretionary ethanol blending by calculating how much ethanol is used to produce ethanol-blended gasoline from the EIA, and compare that to a simple 12 billion gallons mandate divided by 365.  Using last week’s EIA production figures, 34 million gallons of ethanol were blended into gasoline.  This compares to the daily average the RFS2 mandates requires of 32.8 million gallons per day, which means only 1.2 million gallons per day of ethanol are discretionary.  The chart titled “Ethanol Blended vs Mandate” below uses this analysis and calculates the amount of ethanol blended into gasoline that is discretionary, i.e. more than mandated through September of 2010.  The total amount blended exceeding the mandate is 142 million gallons through September.  These numbers would suggest that losing the VEETC will have little impact, if any at all, on ethanol prices for next year.  A negative impact assumes that ethanol prices are higher than gasoline prices as they are today.  In addition, the mandate increases to 12.6 billion gallons, or 34.5 million gallons per day, of ethanol blending next year, and expands the available gasoline pool to include all the gasoline blended by small refiners that lose their exemption from RFS2 mandates starting in 2011. 

The expiration of the import tariff will have little or no effect, particularly due to the high prices in Brazil.  The LCFS in California may create demand for sugarcane-based ethanol, but that remains to be seen, and market participants do not anticipate any action until 2012 if the LCFS is still in place.

Brazil's Inventory Bubble

As we noted in last week’s newsletter, the increase of ethanol inventory in Brazil this harvest season is surpassing last season’s inventory build substantially.  The following chart clearly illustrates the dramatic change in the inventory profile between the two harvest seasons:

  

How much inventory does the Brazilian ethanol market need to cover the inter-harvest period when sugarcane processing and ethanol production are at minimums?  To determine the answer, we have forecasted monthly consumption for the inter-harvest period as follows:

                   Monthly Consumption

Fuel Use                 1,875

Non-Fuel Use             210

Exports                  __150

Total                      2,235 million liters

Fuel use is based on average consumption this year, according to data published by the National Petroleum Agency (ANP).  Fuel demand is lower than last year’s consumption by 160 million liters per month.  Non-fuel use is predicted to be approximately 50 million liters per month higher than last year due to the startup of new chemical (non-fuel) demand for ethanol.  This new demand is anticipated to come on line in the 4^th quarter.  Exports are forecast to follow last season’s pattern. 

With the drier harvest season this year, December ethanol production will fall off to inter-harvest levels due to the poor quality of the late harvest sugarcane, which was impacted by dry weather.  This results in an estimated ethanol production of 400 million liters per month for the period of December of 2010 through March of 2011. 

These numbers indicate a market that is short by 1,835 million liters per month for the December 2009 - March 2010 time period, yielding a total shortfall of 7,340 million liters leading up to the start of the 2011 harvest.  As of August 15, Brazil’s physical inventory was 5,673 million liters and building monthly by 1,500 million liters.  Assuming this inventory build rate continues through October, and the carryout inventory at the end of the harvest season is 1,000 million liters, the Brazilian ethanol industry will meet this inventory level by mid-October.  If nothing changes in the supply/demand balance, inventory levels by the end of November could reach 10,000 million liters, assuming the industry has the storage capacity to hold this quantity.

Brazil’s ethanol prices have been remarkably stable this harvest season, due in large part to the industry’s ability to finance the increased inventory.  The ethanol market in Brazil is moving into some uncharted waters as this inventory level continues to reach new heights.  Going into October, it would not be surprising to see weaker prices in Brazil that would stimulate demand to slow down the inventory growth.  A countervailing force for lower prices is the anticipated increase in European ethanol prices.  The European ethanol market is suffering significantly from higher feedstock costs due to the poor wheat harvest, which could result in sizeable export demand for Brazilian ethanol.

E85 - Is It the Solution?

During the last several months, the key advocacy groups for ethanol have been split on the long term policy they want to advocate for ethanol in the face of the looming expiration of the tax credit and import tariff.  Growth Energy took the lead and changed directions from the drum beat of tax credit renewal exclusively to advocate Flex Fuel Vehicles (FFV) and the construction of E85 fueling stations.  The argument is that the ethanol industry, once provided its own fuels market via E85 that is not controlled by the US refining industry, will then control its own destiny and profitability.

On the surface, this idea has substantial appeal in that it gives the ethanol industry the opportunity to compete with hydrocarbon gasoline on an equal playing field.  In our opinion, for E85 to be successful long term, it must be cost competitive to the consumer on an energy-delivered basis compared to gasoline.  The simple facts are that a gallon of ethanol contains 75,700 btu/gallon, whereas hydrocarbon gasoline contains 115,000 btu/gallon, which calculates as a 35% disadvantage for ethanol.

The three keys to E85’s success are:

•          Expand the FFV fleet substantially to create demand density

o   Legislation has been introduced to force the auto industry to produce more FFVs

•          Build E85 Fueling stations

o   The industry estimates that it needs 200,000-300,000  stations

o   Currently, there are 2,500 stations

o   Legislation has been introduced to provide tax credits to build E85 fueling stations

•          E85 price meets or beats gasoline parity

o   This is the issue

 

The price parity issue is the one piece of the E85 puzzle that is not falling into place. We have analyzed the price parity issue from two perspectives using Chicago physical prices for gasoline and ethanol.  This analysis assumes no ethanol tax credit is available.  The first perspective is comparing gasoline prices to market ethanol prices and plotting them against the hypothetical E85 energy content parity price.  The following graph shows that the price of ethanol has never dropped low enough to value E85 below the energy parity line during the last 2 ½ years.

The second perspective is to see if E85 can be competitive from a cost-of-production basis, which removes ethanol market influences. The value of ethanol in this analysis is based on CBOT corn plus 30 cpg.  We used this value for ethanol in the following graph and, once again, E85, using this ethanol value, is never less expensive than the E85 parity line.

These results are startling from the perspective that ethanol is unable to compete against hydrocarbon gasoline on an energy content basis without government incentives.  The difficulty is the relationship between agricultural prices and crude oil prices. The question becomes, will the corn price versus crude price separate enough in the future to overcome this differential?  In the near term, the differential is actually going in the opposite direction, with a corn/crude margin squeeze that we will discuss in our next segment.

Ethanol Tax Credit- $4 CORN - $75 Crude

Recently, the price of unleaded 87 gasoline in the USGC and NYH has fallen below the price of ethanol in those markets. The 45 cpg ethanol tax credit (VEETC) and RFS2 mandate have now become the driving force for blending ethanol into gasoline.  The VEETC will become the primary economic driver for blending ethanol into gasoline as the ethanol/gasoline differential becomes negative.  Ethanol blending is exceeding RFS2 mandates of the obligated parties, as evidenced by very low RIN prices in the 1.0-1.25 cpg range.

Corn, at $4 per bushel with a 30 cpg crush margin, yields an ethanol price at $1.75 per gallon FOB Chicago and 180-185 cpg ($75-$78 per barrel) in the major market areas.

Crude is now in the $75 per barrel range, and gasoline cracks of $8-$10 per barrel are falling, having lowered by almost $4 per barrel to $79 per barrel last week, and continues to go lower.

Corn prices are being driven by issues in the wheat market due to the projected wheat shortfall in Europe and Russia.  China continues to be a large importer of numerous agricultural products, thereby supporting agricultural prices. Corn prices appear to have solid fundamentals that endure into 2011.

The economic drivers in the corn market (feedstock costs) do not appear to have a relationship with the price of ethanol as a transportation fuel.  The economic drivers for inputs and outputs for an ethanol plant are disconnected and headed for a possible collision.

If you take away the VEETC by not renewing it for next year, and with crude/gasoline prices deteriorating to $70 per barrel or less, the ethanol producer is going to be put into a margin squeeze.  With no VEETC to incentivize blending and lower crude/gasoline values, ethanol demand will drop sharply as non-obligated parties discontinue discretionary blending, and obligated parties minimize blending to their specific RFS2-mandated volume. The market will eventually correct itself in one of two ways: either a significant number of ethanol plants will shut down to affect corn’s supply/demand balance and drive the price of corn down, allowing ethanol production at a lower price, or, there will be a shortage of RINs, driving their price up to motivate obligated parties to pay an ethanol premium to gasoline.  RIN prices will move up accordingly, providing an incentive to blend ethanol to the obligated parties, even though the actual physical price is uneconomic.

In summary, there is a danger of a severe margin squeeze in 2011 if the VEETC is not renewed and the corn-to-crude relationship shrinks further below today’s price relationship.  This margin squeeze will result in plant capacity shutdowns to cope with the negative market signals.

Ethanol Market Commentary - August 11th

The agriculture markets have calmed down from last week's volatility caused by the Russian ban on wheat exports.

Corn futures in the US remain in the $4/bushel range for front month futures.

The EIA stats this week for ethanol are neutral.  Production remained essentially unchanged.  Inventories fell another 200,000 bbls but remain 1,000,000 bbls higher than the first week of June.

Gasoline production continues to decline dropping 350,000 bpd over the last two weeks.  Gasoline blended with ethanol declined slightly.  The ethanol blending penetration was 84.5%.

Wheat prices in Europe have backed off the peaks reached last week.

The USDA WASDE report is due on Thursday - this has the potential to stir up agriculture price volatility.

European T1 prices have paused for the moment as shipments from the US begin to appear in the market.  The arbitrage from the US to Europe has tightened.  T2 prices have caught up with the big rise in T1 prices but there is noise in the market about the high cost of wheat pushing T2 prices further.

Brazil prices remain steady.

Wheat Rally to Affect Ethanol Price

The big news in the grains markets has been the big shortfall in wheat production from Russia and the Ukraine.  The extent of the heat damage to the crop is not clear but there are strong rumors in the market that Russia is going to ban exports.  How does this impact ethanol?

Corn prices in the US are being pulled by the wheat markets.  The wheat futures are up 60 cents/bushel in early trading today in response to developments in Europe.  Corn has pushed into $4.10/bushel range for the September contract in response to the wheat move.  The ethanol/corn crush margins are falling back into the 27-29 cpg range from 32 cpg earlier this week.

In Europe, approximately one third of the fuel ethanol production is wheat based.  The incremental gallon in Europe is produced from wheat.  This is going to drive prices in Europe which will translate into continued demand for US ethanol to fill Europe's ethanol requirements. 

Ethanol prices will need to move up in the US to keep pace with corn prices and the tug of exports to Europe.

EIA Ethanol Data - August 4th

The cut in ethanol production did not last long with production rebounding from its recent low of 816,000 bpd to 876,000 bpd, a 6.5% increase in one week.  Total ethanol stocks stayed essentially flat.  PADD II, which covers the Midwest producing area, showed a small increase of 50,000 barrels.  The PADD I, which covers the USEC, showed a drop from 8,445,000 to 8,271,000 barrels.  The drop on the USEC is supportive of the strong price differential for NYH material over Chicago that has been a feature of the ethanol market during the last 10 days.

No significant change in gasoline production using ethanol.  Gasoline blended with ethanol fell slightly from 7,911,000 bpd to 7,983,000 bpd yielding a 84% ethanol blending penetration rate.

The large increase in ethanol production is a bearish sign for the ethanol market.  ADM annouced that their expansion at Cedar Rapids, Iowa is coming on line this month, which if it produces at nameplate will add 20,000 bpd to production.   

On the bullish side, the export arbitrage to Europe is still open albeit a little tougher to capture.  The European market continues to move up on price for T1 product to draw more material to a net short European market.  Latest T1 deal was $585/cbm FOB Rotterdam for Aguust delivery.  EN spec grade material in the US is somewhere in the 25-30 cpg premium to CBOT delivered to a coastal terminal,

Prompt CBOT corn/ethanol crush margins had moved from 22 to 32 cpg over the last two weeks. The December crush margin falls to 22 cpg.  This margin differential will continue to support a backwardated shaped market.

Ethanol Market Volatility

So what is going in the ethanol markets? What is driving the recent surge in ethanol prices and will it continue?

1)Agriculture prices are up. The US corn crop looks like it is going to meet market expectations but the potential shortfall in the wheat harvest across Europe and Russia due to heat stress this summer is driving corn prices higher as an alternative feed grain. The extent of the impact on wheat in Europe/Russia will become clearer over the next few weeks with the harvest just getting started.

2)Brazilian ethanol producers are exhibiting much greater discipline this year by holding onto inventory and not participating in panic selling to raise cash in the early part of the sugarcane harvest. Brazilian exports of ethanol are 50% lower than same time last year. Sugar prices are also strong adding to financial strength to hold ethanol inventory

3)European prices are being pressured by wheat prices that have increased 35% in the last 45 days due to potential crop yield problems mentioned earlier. Europe also is net short ethanol and must import to meet its biofuel requirements. In the past Brazil has filled that role but with anhydrous ethanol at $600/cbm FOB Santos and European T1 prices at only $565/cbm FOB Rotterdam, Europe is turning to US material to fill the gap.

4)In the US, the EIA reported that ethanol producers had slowed down their production by approximately 5% to 816,000 bpd and traders consummated export deals that will soak up another 10,000 bpd over the next 20-30 days. This caused NYH prices to blow out and trade at 18 cpg over Chicago versus typical differentials of 10 cpg over Chicago.

5) The US market has moved into a 3-5 cpg backwardation that appears to have staying power as a market feature if producers maintain production discipline and exports continue at a 10,000 bpd pace. Record gasoline production is also helping on the domestic demand side and it remains to be seen if this level of production will continue for the summer driving season.

The Wednesday release of EIA data will be very interesting to see if these trends continue in both ethanol (down) and gasoline (up) production.

Brazil’s Import Barriers

Brazil made a big show of reducing their ethanol import tariff to zero earlier this year in order to spark the debate about the US ethanol import tariff that is up for renewal at the end of this year. Brazilian representatives cast themselves as supporters of free trade.

In today’s global ethanol market, Brazilian ethanol prices are very high relative to the US and Europe. Brazilian producers are holding onto inventory where in past harvest seasons they would be selling ethanol aggressively as the harvest gets into full swing. Recent consolidations in the ethanol industry, government inventory loan programs for producers and strong sugar prices all have lead to a more disciplined ethanol market in Brazil leading to the high prices.

Now that a price arbitrage is open to Brazil, US exporters are attempting to ship material to Brazil to capture these prices.

Brazil has imposed non- tariff barriers in two ways. One, the ethanol specification used for import requires that non-sugarcane produced ethanol must be 99.6% ethanol by volume while standard fuel anhydrous ethanol produced from sugarcane be 98% ethanol by volume (actual measurement is alcoholic degree of 99.3 that translates into 98% volume percent). There is no valid scientific reason to make this distinction for ethanol that is to be blended into gasoline.

Obviously, high purity(99.6%) ethanol produced in the US is a small fraction of the total ethanol produced and what is produced commands a 10-15 cpg premium over standard denatured ASTM specification ethanol.

The second non-tariff barrier has been extended bureaucratic delays in issuing import licenses. Traders trying to import ethanol into Brazil report frustrating delays in getting import licenses to take advantage of the wide open arbitrage. It is hard to determine the exact delays but with a strong price arbitrage to export to Brazil and reports of limited smaller cargos being shipped to Brazil, the bureaucratic delays are real.

Ethanol 4th Quarter 2010 – Is it a Train Wreck?

By the 4th quarter of this year, the industry is scheduled to bring on another 550 mln gallons of annual capacity. This represents another 36,000 bpd of new production. By October of this year, the driving gasoline demand bump with have dissipated reducing overall gasoline demand by 250,000 bpd resulting in the loss of another 26,000 bpd of ethanol demand. This assumes that ethanol blending penetration stays in the low 80’s% through the balance of the year. We think the blending penetration staying in this range as a good assumption based on the very low price for 2010 ethanol RINs tracking in the 1.5-2.0 cpg range.

Export opportunities will be limited because of certification requirements for renewable fuels into Europe go into effect in December and it is uncertain if US producers will go to the trouble of getting their supply chain certified. Brazil may be an export outlet, but with very strict ethanol specification for imports, it is difficult to produce and move significant quantities of this type of ethanol to Brazil to relieve length in the US ethanol market.

On the positive side, if we assume $4/bushel corn and $75/barrel crude oil, there will still be a 20-40 cpg blending incentive for ethanol even without renewal of the VEETC. The EPA will issue a ruling on some type of E12 or E15 waiver by September. This will be good news psychologically for the ethanol market but the higher blends could not be realistically implemented until the middle of 2011 offering no physical relief to the market in the 4th quarter. Renewal of the VEETC prior to its expiration again is psychological but will not affect demand in the 4th quarter.
The market is paying a 6.4 cpg premium for Q1-2011 swaps over prompt pricing. The market sees the E12/E15 waiver, the higher RFS2 mandate of 12.6 bln gallons, the elimination of the small refiner exemption as all changes that will kick in for Q1. It should be noted that during the 1st quarter of any year, gasoline demand falls another 250,000 bpd below demand levels experienced in the 4th quarter due to winter weather. Even though there is good news for the 2011 market, Q1 may be too soon for this good news to physically impact the market resulting in higher ethanol prices and plant margins.

The corn crush margins for Q4-2010 and Q1-2011 are in the 24-26 cpg range which are not sustainable for the industry.

With an industry at a nameplate capacity of 14 bln gallons in the 4th quarter and demand softening or at best staying flat, ethanol plant margins are going to come under strong pressure resulting in some temporary plant slowdowns or shutdowns to balance supply and demand.

CBO Study – BioFuel Tax Credit

The Congressional Budget Office (CBO) recently published a report entitled “Using Biofuel Tax Credits to Achieve Energy and Environmental Policy Goals” that focused on the cost to the US taxpayer of biofuels tax credits. The report focused on two policy goals: displacing the use of petroleum fuel and reducing greenhouse gas emissions. We have taken a quick look at the CBO’s analysis on the displacing of petroleum fuels by ethanol.

The CBO states that biofuels tax credits cost the US Treasury approximately $6 billion per year.

The CBO takes a reasoned approach in determining the cost of the tax credit per gallon of gasoline displaced by ethanol. The CBO converts the tax credit from a volumetric basis to an energy content basis. A gallon of petroleum based gasoline contains 125,000 btu/gallon and a gallon of ethanol has 85,000 btu/gallon energy content. Consequently, the 45 cpg tax credit for each gallon of ethanol is the same as paying blenders 67 cents for every 125,000 btus of ethanol blended with gasoline. Adding an addition correction for the 11,000 btus of petroleum fuels used to produce 125,000 btus of energy from ethanol yields a tax credit value of 73 cents per 125,000 btu of energy produced. This is a fair and reasoned approach to placing a value on the tax credit granted the ethanol industry.

The CBO report then attempts to assign a cause and effect relationship to the tax credit by using the results of a 2008 study by the Food and Agriculture Policy Research Institute (FAPRI) at the University of Missouri that concluded that if no other biofuels policies were in place, removing the tax credit would reduce ethanol production by 32%. The CBO then applied the entire $5.2 billion ethanol portion of the annual $6.0 billion tax credit cost and applied it to the 32% quantity identified in the FAPRI report yielding a final cost of 178 cpg. So in effect, the CBO report concludes that the government is paying $5.2 billion per year for approximately one third of US ethanol production. The size of this number is eye catching and will influence the tax credit renewal debate, but it is not an honest depiction of the regulatory landscape for ethanol in the US.

This is a faulty approach because there is a long term biofuels policy. The Energy Independence and Security Act of 2007 (EISA) with its RFS volumetric mandates will be government policy that remains in place until 2022. Congress is now questioning whether volume mandates take away the need for a tax credit by guaranteeing the industry a market for its product. The VEETC tax credit is paid to the blender of ethanol/gasoline and not paid to the ethanol producer making the effect an indirect incentive at best.

The debate is now being framed in Congress - does an industry that has a tax credit, a mandate carving out 10% of the gasoline market and a protective import tariff; does it still need this much support - or should it stand on its own or decline less government monetary support?

Proposed 2011 Renewable Fuel Standards

This week, the EPA issued a notice of proposed rule making to address Renewable Fuel Standards (RFS) for 2011 that, pursuant to RFS2 regulations, need to be determined by November of each year for the upcoming year. The table titled “Proposed Percentage Standards for 2011” indicates the percentages that obligated parties need to meet for 2011. The numbers are lower than last year due to the inclusion of small refiner volumes in 2011, even though the total mandate increases.

Cellulosic ethanol continues to be a large failure. The 2011 mandate calls for 250 million gallons, and the EPA is anticipating a range of available cellulosic ethanol of 6.5 million to 25 million gallons.

What is to be done about the shortfall, and how will both the Advanced Biofuels and Total Renewable Fuel requirements for 2011 be adjusted to address this shortfall? The EPA is proposing not reducing the totals, but just adjusting the Cellulosic mandate and anticipating that biodiesel and sugarcane ethanol will pick up the slack. The adjacent table titled “2011 EPA Proposed Rule Changes” describes the 2011 mandate. The Advanced Biofuels mandate consists of three types of biofuels based on feedstock minimum 50% GHG reduction performance: cellulosic biofuels, biodiesel, and undifferentiated advanced biofuels. A renewable fuel meeting cellulosic requirements can satisfy the cellulosic and advanced biofuels requirements, but not biodiesel. Biodiesel can satisfy the biodiesel and advanced biofuels requirements, but not cellulosic. The only approved pathway for undifferentiated advanced biofuels is sugarcane ethanol, and a gallon of this material can satisfy the advanced biofuels requirement, but cannot satisfy either the cellulosic biofuels or biodiesel requirements. One gallon of physical biodiesel generates 1.5 RINs because of biodiesel’s higher energy content.

The EPA also admits that the biodiesel industry has been struggling and is currently not producing enough biodiesel to meet the mandate. They also believe there is enough idle biodiesel capacity that can be restarted to produce a minimum of 800 million gallons in 2011. The adjacent bar chart titled “United States Biodiesel Production” indicates that the most the industry has produced in any calendar year is 670 million gallons in 2008. The EPA shrugs off the lack of a biodiesel tax credit and an industry that today is producing at a 360-million-gallons rate for 2010. The EPA blithely mentions that there are 2.2 billion gallons of capacity just ready to restart. They, however, do not address the numerous bankruptcies and facility abandonments since Congress’s failure to renew the biodiesel production tax credit; this makes estimating what capacity is left to surge production in a short time frame next to impossible. The EPA also makes no mention of the $1.00-per-gallon price premium for biodiesel over regular diesel that exists in today’s market. We are extremely skeptical that 800 million gallons of biodiesel will be produced at today’s feedstock prices without a significant change in tax policy to support the industry, which, in today’s political climate in Washington, appears to be next to impossible.

In proposing no change to the total Advanced Biofuels mandate, the EPA is also assuming that sugarcane-based ethanol, essentially from Brazil, will be available to fill the gap left unfilled by cellulosic biofuels and biodiesel. The EPA assumes 144 million gallons, or 544 million liters, of ethanol will be available for export to the US in 2011. They further point out, more specifically, that the California Low Carbon Fuel Standard (LCFS), which begins in 2011, should attract sugarcane-based ethanol, and that can be applied to the Advanced Biofuels mandate. With government regulators in the US, California, Europe, and Japan all wanting to use sugarcane-based ethanol to meet their GHG reduction goals, colliding with the hard facts of weather-related negative pressure on Brazil’s sugarcane production and expanding Brazilian domestic demand, will force importers to bid ethanol away from Brazil’s domestic market. So far this year, Brazilian exports are 665 million liters, which are 50% below previous year’s exports, and the outlook for 2011 is not any better for material available for export. None of Brazil’s exports this year have come to the US for use in the transportation fuels market. If the import tariff on Brazilian material is left in place, CBI hydrous ethanol dehydration plants may start processing again by being able to offer a 10-20 cpg discount to direct shipped anhydrous ethanol from Brazil.

In summary, the Advanced Biofuels portion of the RFS2 is struggling. The hard taskmaster of economics is proving to be a difficult hurdle. With a highly efficient cornstarch ethanol industry producing cost-competitive ethanol, it will require strong government support and a long-term financial incentive to bring high-cost cellulosic ethanol to market. The biodiesel industry is in the same situation, with a product that is not cost competitive. We question the ability of the government to follow through with the needed financial and market support to make cellulosic ethanol a reality. The EPA is counting on imported sugarcane ethanol to meet a portion of the US renewable fuels mandates, even when there are significant quantities of US-produced cornstarch ethanol available. It appears that US environmental policy is promoting the importation of transportation fuels, which is diametrically opposed to stated policies of promoting energy independence. Conflicting government policy on Brazilian sugarcane ethanol has the EPA promoting the importation to meet renewable fuels goals, while the same US government continues to impose a 54 cpg import tariff on Brazilian ethanol to protect the US cornstarch ethanol industry in the name of energy independence.

More E15 News

The EPA confirmed in a status update, hidden on their website on Friday afternoon before a three-day weekend, (brave bureaucrats) that an E15 waiver for 2007 model cars and younger would be decided on in late September. For automobiles in the 2001-2006 model years, a decision will be issued in November. Assuming that, at some point in the future, some portion of the automobile fleet in the US will be able to use E15, let’s consider the confusion at the pump for the average consumer. The consumer will approach a fuel dispenser and be faced with a big ugly label indicating that it is unsafe to use E15 in cars in the appropriate model years. The consumer will then think that if E15 is unsafe for some cars, why take the risk and will decide not to use E15, even if the car in question is actually compatible with E15. The price differential will be minimal at best, so an economic incentive will not exist to motivate the consumer to make the choice of filling up with E15. A bifurcated E10/E15 gasoline market will not work. With no economic incentive to purchase E15 while E10 sits next to E15 at the same gasoline pump, E15 is going nowhere. As we suggested in last week’s newsletter, getting full E10 penetration in the gasoline market and pushing FFV’s, along with E85, is going to be the route to expanding ethanol demand. E85 will work for the consumer when he sees the lower cpg price, even though, on a miles per gallon basis, it won’t be any better; consumer self-interest will kick in. The FFV/E85 strategy faces a density of demand issue, with FFV’s scattered across the US and not concentrated enough in one area to support numerous E85 station conversions. Look for lobbying to kick into high gear to expand FFV production, as well as government (federal and state) monetary support to install E85 dispensers.

E15 Update

The EPA announced last week that the agency was delaying the decision on whether to grant a waiver to allow E15 in gasoline, citing the agency’s desire to wait until the DOE has completed its engine testing in September. The DOE engine testing is focused on late model Tier II emission control vehicles that went into production in 2007. In announcing this delay, the EPA intimated that it may only approve a waiver for these types of vehicles, and older vehicles may not be part of the waiver. The ethanol industry was hoping for a minimum waiver that included vehicles 2001 or younger that would have made more than half the existing fleet eligible for E15. Backing up the waiver to 2007 or younger will shrink the available vehicles to approximately 20% of the fleet. This type of waiver will do little for the ethanol industry. As we have discussed previously, a bifurcated market will have gas station liability issues, product labeling issues, and distribution issues for the gasoline marketer offering clear unleaded 87, E10, E15, E85, and premium gasoline.

ADM has petitioned the EPA to consider an E12 waiver based on the “substantially similar” concept that bypasses any engine testing by deeming the product substantially similar. This approach appears to be a long shot. The year and half delay in making any type of decision by the EPA is indicative of the difficulty in moving the gasoline market past E10 with the existing fleet of vehicles. Always keep in mind that when a difficult decision is required by a government bureaucrat that involves risk, the “make no decision” reflex will win out, as evidenced by the long delay on this E15 decision.

We believe the clear path to large ethanol consumption is to focus on moving the fleet towards E85-capable vehicles. In order to achieve the desired amount of renewable ethanol in the US gasoline pool, the solution that Brazil has embraced is the Flex-Fuel Vehicle (FFV). The FFV in Brazil has been tremendously successful in developing the ethanol fuel market in that country. It is very inexpensive to produce an FFV versus a non-FFV, so that is not an impediment. The key to unlocking the E85 market is getting the fuel dispenser infrastructure in place. There is proposed legislation to mandate the auto manufacturers to produce 90% of the fleet as FFV’s by 2013, and the legislation offers substantial federal grants for blender pump installation at gas stations.

Looking forward into 2011, the RFS mandate increases by 600 million gallons, and the small refiner exemption will be removed. These two actions will be enough to complete 100% penetration of E10 into the gasoline pool and consume all the production scheduled to come online by the end of this year. E15 is not necessary to consume all the domestically produced ethanol over the next 18 months, but the delay is having a negative impact in market psychology.

Global Ethanol Trade Flows

Global Ethanol Trade Flows

Ethanol trade has started to slow down for many producing and consuming countries.  The table on the right titled “Global Ethanol Trade Flows” examines trade flows between various regions around the world comparing year to date April of 2010 versus year to date April of 2009.  The six key trade flows that have shown significant year over year changes are evaluated as follows:

· USA => CANADA

Looking at the table on the right, according to the US Census Bureau, exports of ethanol from the US to Canada have almost doubled this year compared to the same time frame last year.  This is due to provincial ethanol blending mandates in Canada taking effect within the last year, as well as preparation for the national E5 mandate that is set to be implemented at the end of the year.  There is one new plant expansion scheduled in Canada by Suncor of 200 mln liters in Q1 2011.  With no other new capacity on the drawing board beyond the Suncor plant, this level of Canadian imports will continue into next year.

· Brazil => CBI  => USA

Brazil’s exports to the CBI nations are down 76% of what they were a year ago.  CBI nations enjoy duty-free access to the US market.  The CBI countries have essentially no indengious ethanol production and rely solely on the dehydration of Brazilian ethanol.  The dehydration arbitrage of Brazilian hydrous ethanol is closed and we expect the arbitrage to remain closed for the foreseeable future reducing this trade flow to zero.

· Brazil => USA

Due to feedstock prices in their respective countries, imports of ethanol into the US from Brazil have diminished during the last two years.  Brazil’s poor harvest last year and substantial growth in Brazil’s domestic ethanol demand by the burgeoning FFV fleet has maintained strong domestic prices reducing the incentive to export. The US import tariff of $0.54-per-gallon tariff is also a strong barrier to open trade.  Although corn prices are rising in the US at the moment and pushing ethanol with them, it is remains uneconomical to bring material in from Brazil, especially with the added tariff.

· Brazil => Asia/Pacific

Brazilian ethanol exports to Asia are somewhat lower this year compared to the same time last year.  This market represents a potential growth opportunity for Brazil.  Other than China, there are no substantial producers of ethanol in Asia, especially for export, and countries such as Japan and India have invested in sugar mills and ethanol technologies in Brazil, leading to a natural trade flow between Brazil and these countries.  South Korea is a major recipient of ethanol from Brazil, but much of this volume is for beverage-grade consumption since  South Korea does not have a fuel ethanol blending mandate.

· Brazil => EU

Exports of ethanol from Brazil to the EU have fallen by almost half of what they were last year during the same time period.  This has been due to abundant T2 ethanol supply in Europe, as well as a function of price; when adding the EU import ethanol tariff, it simply has been largely uneconomical to send undenatured EN spec ethanol from Brazil to the EU.    We expect ethanol demand to grow in Europe with increased blending penetration percentages kicking in the second half of the year.  With this increased demand, regional price spreads will widened at some point to draw in the necessary volume to cover demand.

· USA => EU

Exports of ethanol to the EU from the US have increased substantially.  This change in trade flow has been a function of price.  Ethanol prices in the US have been low relative to EU and Brazilian prices prompting the surge in exports.  Export volumes have receded recently with the narrowing of regional prices.  This week’s strengthening in corn prices due to changes supply fundamentals will keep US ethanol prices too high for further sustained exports to the EU.