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04 May 2009
On April 23, California’s Air Resources Board (CARB) adopted regulation that will U.S. Machinery
implement Governor Schwarzenegger’s low carbon fuel standard (LCFS) starting in AC
Ann Duignan
2011. This standard is intended to reduce CO2 emissions from the state’s
(1-212) 622-0381
transportation fuels by 10% by 2020, and establishes a declining threshold of carbon ann.duignan@jpmorgan.com
intensity. In our view, this could potentially have a devastating impact on the ethanol
Philip Shen
industry. What is unusual about the regulation is that it requires biofuels—and only
(1-212) 622-1345
biofuels—to meet declining carbon intensity standards while also meeting an “indirect philip.shen@jpmorgan.com
land use change,” or ILUC, to determine the carbon intensity of ethanol’s potential
J.P. Morgan Securities Inc.
indirect effects, such as deforestation. Not surprisingly, using this analysis, corn-based
ethanol from the Midwest is more carbon intensive than gasoline, and, consequently,
would not meet California’s low carbon fuel standard.
• The CARB ruling increases the risks to the ethanol industry: (1) corn-based
ethanol producers may have limited access to the California ethanol market; (2)
other states may adopt the ILUC methodology; and (3) the ruling may influence the
EPA and its rulemaking on RFS2.
• 35 million acres of land for corn-based mandate will have to come from
somewhere. The ultimate mandate for corn-based ethanol in the U.S. is 15BGY,
which, at current corn yields and a conversion ratio of 2.7 gallons of ethanol from
one bushel of corn, suggests that about 35 million acres of land will need to be
shifted from food/feed production to fuel production. The ILUC argument is that the
loss of these acres will drive crop prices up and eventually lead to crop expansion in
areas of the world where forest or grassland can be converted to cropland, which
ultimately increases GHG.
• It sounds logical, but it is hard to measure. The ethanol industry is up in arms over
the proposal by CARB to include ILUC in its LCFS as it is hard to actually measure
the real GHG impact from “indirect” land use. As a result, CARB has committed to
further study the issue and has pledged to look at the indirect effects of all other
fuels, not just ethanol. Additionally, the ethanol industry believes that CARB is not
giving baseline ethanol sufficient credit for its GHG reduction as it is using a 30%
direct greenhouse gas benefit compared with gasoline, whereas recent studies show
that “modern ethanol plants decrease greenhouse gas emissions by 59% in
comparison with gasoline.”
• The EPA must also publish its interpretation of GHG for RFS2. While RFS2
took effect January 1st this year, the EPA has yet to publish its definition of the new
rule included in RFS2, which requires that new ethanol and biodiesel capacity meet
GHG requirements. Corn-based ethanol must reduce GHG by 20% vs. gasoline and
biodiesel by 50%. If the EPA chooses to include ILUC in its calculation, then no
new capacity is likely to be built, and the mandate likely will not be met.
• Impact on ag machinery. The uncertainty of the ethanol industry and its use of corn
contribute to deteriorating sentiment in the farm sector. As a result, we remain
cautious on DE, AGCO, and CNH.
What is unusual about the regulation is that it requires biofuels—and only biofuels—
to meet declining carbon intensity standards, while also meeting an indirect land use
change, or ILUC, to determine the carbon intensity of ethanol’s potential indirect
effects, such as deforestation. The idea is that as more land is used for ethanol in the
U.S., less is available for food, and lands elsewhere must be deforested or used to
secure food sources for the local population. Not surprisingly, using this analysis,
corn-based ethanol from the Midwest is more carbon intensive than gasoline, and,
consequently, would not meet the California’s low carbon fuel standard.
Figure 1: Low Carbon Fuel Standard to Reduce Carbon Intensity by 10% by 2020
Low Carbon Fuel Standard (LCFS)
Compliance Schedule
98 0%
96
-2%
Grams Of CO2 Emitted Per Megajoule
92 -4%
90
-6%
88
86 -8%
84
-10%
82
80 -12%
Gasoline
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
Average
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Ann Duignan North America Equity Research
(1-212) 622-0381 04 May 2009
ann.duignan@jpmorgan.com
What are indirect land use changes (ILUC)? Indirect land use changes describe
the utilization or displacement of land as a result of acreage expansion due to corn-
based ethanol. The idea is that as more land is used for ethanol, less is available for
food. This leads potentially to deforestation and expansion of farmland elsewhere as
local populations attempt to secure food sources. In pursing ILUC, CARB is
attempting to account for the carbon intensity of corn-based ethanol’s indirect
effects.
Figure 2: Avg. Midwest Ethanol Is 28% Less Carbon Intensive vs. Gasoline Excluding ILUC
CARB Carbon Intensity Values For Ethanol From Corn And Sugarcane
Without Indirect Land Use Changes (ILUC)
120
Avg Midwest Corn-Based
Ethanol Emits 28% Fewer
100 96 gCO2/MJ Versus California Avg Brazilian Sugarcane
Grams Of CO2 Emitted Per Megajoule
40
27
20
0
CA Midwest (MW) CA CA Avg MW MW MW CA MW MW CA CA Brazilian
Gasoline Avg Dry Mill; Wet (80% MW; Dry Mill and Wet Mill Dry Mill & Wet Dry Mill & Dry Mill & Dry Mill & Wet Dry Mill & Dry Mill & Wet Sugarcane
DGS; NG 20% CA) DGS DGS DGS; NG DGS (80% DGS (80% DGS (80% DGS (80%
NG; 20% NG; 20% Bio) NG; 20% NG; 20% Bio)
Biomass) Biomass)
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Ann Duignan North America Equity Research
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ann.duignan@jpmorgan.com
75% of Midwest facilities may not meet the LCFS requirements. (See our analysis in
the Risks of the CARB Ruling section.)
Figure 3: Including ILUC, Corn-Based Ethanol Is 4% More Carbon Intensive Than Gasoline
CARB Carbon Intensity Values For Ethanol From Corn And Sugarcane
With Indirect Land Use Changes (ILUC)
120
96 99
Grams Of CO2 Emitted Per Megajoule 100
80
60
0
CA Midwest (MW) CA CA Avg MW MW MW CA MW MW CA CA Brazilian
Gasoline Avg Dry Mill; Wet (80% MW; Dry Mill and Wet Mill Dry Mill & Wet Dry Mill & Dry Mill & Dry Mill & Wet Dry Mill & Dry Mill & Wet Sugarcane
DGS; NG 20% CA) DGS DGS DGS; NG DGS (80% DGS (80% DGS (80% DGS (80%
NG; 20% NG; 20% Bio) NG; 20% NG; 20% Bio)
Biomass) Biomass)
Modern corn-based ethanol facilities are much more efficient than the average.
According to POET, modern corn-based ethanol facilities are much more efficient
than the average facility in the Midwest. These modern production facilities produce
just ~39 grams of CO2 per mega joule (vs. the average corn-based ethanol facility of
69 grams of CO2 per mega joule as assessed by CARB) and, as a result, are less
carbon intensive compared to gasoline by ~59%. Including CARB’s ILUC emissions
estimates, the modern facilities are 28% more efficient than gasoline, and, thereby,
likely meet the low carbon fuel standard.
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Ann Duignan North America Equity Research
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ann.duignan@jpmorgan.com
Figure 4: Modern, More Efficient Corn-Based Ethanol Facilities in Midwest Likely Meet LCFS
CARB Carbon Intensity Values
For Ethanol From Corn And Sugarcane
120
Excluding ILUC, Modern Including ILUC, Modern
Efficient Midwest Corn- Efficient Midwest Corn-
96 Based Ethanol Emits 59% Based Ethanol Emits 28%
100
80 69
60
39
40
20
0
CA Midwest Midwest Brazilian
Gasoline Modern Facility Modern Facility Sugarcane
Including ILUC
RFA objects to ILUC analysis. Following the CARB announcement on April 23,
the Renewable Fuels Association (RFA) published a letter to respond to the ruling.
The RFA believes that CARB’s efforts to estimate indirect land use change, as a
result of expansion of U.S. ethanol production, require further refinement and
validation. The following are some specific comments by the RFA:
• The model CARB relies upon, known as GTAP, is not a mature model for
estimating land use changes.
• The biofuels “shock” implemented in GTAP is inconsistent with USDA projected
crop yields. That is to say, the CARB ruling did not sufficiently account for
increased crop yields in the U.S. as a result of new technologies.
• Insufficient GTAP feed co-product land use credits result in overestimation of
land use changes.
• Other GHG benefits of co-products were ignored, or “are still being evaluated.”
• Missing land sets in the GTAP database result in extra forest land being
converted.
• The analysis does not consider relative costs of converting different land types,
resulting in overestimation of forest land converted.
5
Ann Duignan North America Equity Research
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ann.duignan@jpmorgan.com
Risk #1: Corn-based ethanol producers may have limited access to the
California ethanol market. In 2008, California consumed 15.5 billion gallons of
gasoline—or about 10% of the nation’s total gasoline consumption. Under RFS2, CA
would eventually consume about 1.6 BGY of ethanol (or about 10% of the mandate).
This represents about 5% of total current corn production. In the CARB ruling, the
average Midwest producer had a carbon intensity of 99 gCO2e/MJ, or 4% greater
than California gasoline. Of the 11 ethanol pathways the committee evaluated, seven
appear to meet the LCFS requirements. Notably, four of the seven pathways are
based in California, with the remainder in the Midwest. Thus, unless Midwest
producers make investments to reduce their carbon footprint via co-generation or sell
wet instead of dry DDGS, many facilities may not be able to access the California
market in the years to come.
Ethanol fuel pathways that meet LCFS requirements employ co-generation, sell
wet DDGS, or do both. Of the 11 ethanol fuel pathways, only three from the
Midwest met the LCFS requirements according to the CARB ruling. All were dry
mills. Two pathways generate power via natural gas and biomass, while the other
sells wet distiller grains. As a rough estimate, our sources believe less than 10% of
ethanol plants in the Midwest have invested in the co-firing technology.
Additionally, while our sources estimate that 50% of producers sell wet distiller
grains, not all of their DDGS are sold wet. They believe that 15-20% of total DDGS
are sold wet. Thus, using these rough figures, we optimistically estimate that 25-30%
of the ethanol production in the Midwest could qualify for the LCFS. (We recognize
that our estimate assumes even distribution, no overlap between facilities that co-fire
and sell wet DDGS, and that some facilities will sell a mix of wet and dry DDGS.)
This leaves the remaining producers with the choice of exiting the California market
or investing in co-generation technologies and creating wet DDGS markets.
Risk #2: Other states may adopt ILUC. In our view, an equally large risk is that
additional states adopt the ILUC rules. According to Chad Hart, an agricultural
economics professor at Iowa State University, other states are now considering
CARB’s methodology to account for indirect land use changes. These states include
Massachusetts and Connecticut. If enough states begin to adopt stringent ILUC rules,
then the rules may force existing facilities to make additional capital investments in
technologies to reduce their carbon footprint. This could result in yet another
challenge facing the ethanol industry.
Risk #3: The CARB ruling may influence the EPA when drafting the rules for
the RFS2. In a letter to General Wesley Clark, Co-Chairman of Growth Energy,
Mary Nichols, Chairman of CARB, highlighted that CARB will work with the EPA
to “harmonize where possible the data, modeling, and values used for life-cycle
analysis and land use change.” OPIS reported last week that the EPA is expected to
announce the long-awaited results of its preliminary rulemaking, potentially
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Ann Duignan North America Equity Research
(1-212) 622-0381 04 May 2009
ann.duignan@jpmorgan.com
sometime this week. The RFS2, which became law in December 2007, requires that
new ethanol production facilities be 20% less carbon intensive than gasoline on a full
life cycle basis. The EPA officially completed its analysis for the RFS2 rulemaking
on April 29th according to its website. OPIS sources report that the EPA will likely
include indirect land use change in its analysis, but it is not clear which model(s) it
will use and whether it will apply indirect effects to all fuel pathways. Some sources
are indicating that the EPA ILUC ruling may only apply to changes to domestic
lands—and not international lands—which would be more favorable to the industry.
A key difference between the EPA’s rulemaking and the recent CARB ruling is that
the EPA rules will apply only to new facilities, whereas the CARB ruling applies to
all fuel produced regardless of when the facility was constructed.
Ethanol prices are down 39% from peak, but remain at a premium to gas. Since
Jul’08, ethanol prices have fallen 39% vs. wholesale gas prices, down 55% from its
peak. Currently, based on an average U.S. rack prices (i.e., the price the blender pays
which is higher than spot prices which is what the producer is paid), ethanol is
trading at a $0.24/gallon premium to gasoline, which is below the blender’s credit of
$0.45/gallon.
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Ann Duignan North America Equity Research
(1-212) 622-0381 04 May 2009
ann.duignan@jpmorgan.com
Figure 5: Ethanol & Wholesale Gas Prices Figure 6: Ethanol Premium Reduces Discretionary Blending
Historical Ethanol And Regular Unleaded Gasoline Spread Between Ethanol And Regular Unleaded Gasoline
Wholesale Prices (U.S. Rack Rates) (U.S. Rack Rates)
$2.00
$4.00
$3.75 $1.50
$3.50
$3.25 $1.00
Blender's credit changed from
$3.00 $0.51 to $0.45 per gal on 1/1/09.
Price ($/Gallon)
$2.75 $0.50
$/Gallon
$2.50
$2.25 $0.00
$2.00
$1.75 ($0.50)
$1.50
$1.25 ($1.00)
$1.00
Dec-04
Feb-05
Apr-05
Aug-05
Oct-05
Oct-06
Oct-07
Jun-05
Dec-05
Feb-06
Apr-06
Aug-06
Jun-06
Dec-06
Feb-07
Apr-07
Aug-07
Jun-07
Dec-07
Feb-08
Apr-08
Aug-08
Oct-08
Jun-08
Dec-08
Feb-09
Apr-09
($1.50)
Jan-04
Apr-04
Jul-04
Oct-04
Jan-05
Apr-05
Jul-05
Oct-05
Jan-06
Apr-06
Jul-06
Oct-06
Jan-07
Apr-07
Jul-07
Oct-07
Jan-08
Apr-08
Jul-08
Oct-08
Jan-09
Apr-09
Ethanol Regular Unleaded Gasoline
Source: Bloomberg and J.P. Morgan. Source: Bloomberg and J.P. Morgan.
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Ann Duignan North America Equity Research
(1-212) 622-0381 04 May 2009
ann.duignan@jpmorgan.com
Companies Recommended in This Report (all prices in this report as of market close on 01 May 2009)
AGCO Corp. (AG/$25.51/Neutral), CNH Global (CNH/$17.16/Underweight), Deere & Co. (DE/$42.88/Neutral)
Analyst Certification:
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responsible for this report, the research analyst denoted by an “AC” on the cover or within the document individually certifies, with
respect to each security or issuer that the research analyst covers in this research) that: (1) all of the views expressed in this report
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research analyst(s) in this report.
Important Disclosures
• Lead or Co-manager: JPMSI or its affiliates acted as lead or co-manager in a public offering of equity and/or debt securities for
AGCO Corp., Deere & Co. within the past 12 months.
• Director: A senior employee, executive officer or director of JPMorgan Chase & Co. , JPMSI, and/or its affiliates is a director
and/or officer of Deere & Co..
• Client of the Firm: AGCO Corp. is or was in the past 12 months a client of JPMSI; during the past 12 months, JPMSI provided to
the company investment banking services and non-securities-related services. CNH Global is or was in the past 12 months a client of
JPMSI. Deere & Co. is or was in the past 12 months a client of JPMSI; during the past 12 months, JPMSI provided to the company
investment banking services, non-investment banking securities-related service and non-securities-related services.
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banking services in the next three months from AGCO Corp., CNH Global, Deere & Co..
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services other than investment banking from CNH Global, Deere & Co..
0
May Aug Nov Feb May Aug Nov Feb May Aug Nov Feb May
06 06 06 07 07 07 07 08 08 08 08 09 09
Source: Reuters and J.P. Morgan; price data adjusted for stock splits and dividends.
Break in coverage May 31, 2008 - Jun 02, 2008. This chart shows J.P. Morgan's continuing coverage of this stock; the
current analyst may or may not have covered it over the entire period.
J.P. Morgan ratings: OW = Overweight, N = Neutral, UW = Underweight.
9
Ann Duignan North America Equity Research
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ann.duignan@jpmorgan.com
23
0
May Aug Nov Feb May Aug Nov Feb May Aug Nov Feb May
06 06 06 07 07 07 07 08 08 08 08 09 09
Source: Reuters and J.P. Morgan; price data adjusted for stock splits and dividends.
Break in coverage May 31, 2008 - Jun 02, 2008. This chart shows J.P. Morgan's continuing coverage of this stock; the
current analyst may or may not have covered it over the entire period.
J.P. Morgan ratings: OW = Overweight, N = Neutral, UW = Underweight.
0
May Aug Nov Feb May Aug Nov Feb May Aug Nov Feb May
06 06 06 07 07 07 07 08 08 08 08 09 09
Source: Reuters and J.P. Morgan; price data adjusted for stock splits and dividends.
Break in coverage May 31, 2008 - Jun 02, 2008. This chart shows J.P. Morgan's continuing coverage of this stock; the
current analyst may or may not have covered it over the entire period.
J.P. Morgan ratings: OW = Overweight, N = Neutral, UW = Underweight.
Coverage Universe: Ann Duignan: AGCO Corp. (AG), Bucyrus International (BUCY), CNH Global (CNH), Caterpillar
Inc. (CAT), Commercial Vehicle Group (CVGI), Cummins Inc (CMI), Deere & Co. (DE), Eaton Corp. (ETN), Illinois Tool
Works (ITW), Joy Global (JOYG), Manitowoc Co. (MTW), Navistar Int'l (NAV), PACCAR Inc. (PCAR), Parker Hannifin
(PH), Terex Corp (TEX)
10
Ann Duignan North America Equity Research
(1-212) 622-0381 04 May 2009
ann.duignan@jpmorgan.com
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