Scott Irwin Profile picture
Oct 15, 2019 11 tweets 3 min read Read on X
1. Just finished reading the EPA Supplemental proposal for 2020 RVOs. I have to give credit where credit is due to the influence of the oil refiners over at the EPA. After reading this over, I am officially declaring the #Grassley rule as dead.
2. The cleverness of those oil refinery lobbyists and lawyers is truly impressive. So, now we get the supplemental rule with the much ballyhooed moving average reallocation. Straightforward right? Wrong Buddy Ruff.
3. To understand the clever way that the refiners limited their losses in this front of the #RFSwars, it helps to start with what I would call the common sense interpretation of the history of EPA SRE waivers. Column (4) shows the SRE exempted gasoline and diesel vol over 16-18 Image
4. These are not my numbers. These are drawn exactly from the EPA's own website. The key is that the average of of exempted gasoline and diesel volume under SREs is 12.77 billion gallons for 2016-2018. So, you would think that is the number EPA would project for 2020. Wrong. Image
5. The EPA now says that they are going to maybe possibly give partial SREs starting in 2020 despite their policy of forever not doing this. And these means they need to go back and revise the history of SREs as if they followed this policy in the past.
6. EPA even states in the proposal that in the Aug 9, 2019 Memorandum on SRE petitions that they granted no partial exemptions even when DOE recommended partial exemptions. Oh well. Guess that's all changed now.
7. So, the EPA went back and said here are the SRE exempted volumes over 2016-2018 if we had followed DOE guidance on giving partial exemptions. Now compare my earlier table with this one from the EPA proposal. Their 3-yr avg. is now magically 7.26BG instead of 12.77BG. Image
8. The result is that that the reallocation of 2020 RVOs is only 7.26BG instead of the 12.77BG that any reasonable analysis would have anticipated. The reallocation is 56.9% of what it should have been based on SREs ACTUALLY AWARDED OVER 2016-2018.
9. Here are the proposed % standards for 2020 now. To see how much difference this little trick makes, note that the total renewable RVO is 11.46% (or 11.35% even lower). It would have been 12.74% if actual SRE levels had been used. Image
10. So what to make of all this? If EPA does grant partial SREs for 2020 (sometime in 2021) as projected today, then it could be said that the RFS mandates for 2020 will be fully enforced. But that is missing the forest for the trees.
11. The reality is that the reallocation of gallons for 2020 will be a little more than half of what was lost on average over 2016-2018. Plus, the EPA has to be trusted to grant partial waivers far in to the future that match projections today for this to work at all.

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More from @ScottIrwinUI

Jul 12
1. We keep getting rain around here. About a half an inch last night. We are pushing 7 inches this week in Champaign County. I went out to what I call the Field of Dreams to walk our dog this morning and it is still hard to believe how good the corn and beans look. But, call me paranoid, this got me thinking about whether we were starting to get too much rain this month?
2. So, you know me, I ran back to my computer and starting digging out the data to check out the relationship between July precip and corn yields. I was relieved to see that, no, we are not in the territory of too much July precip. Image
3. Note that the y-axis is deviation from a simple linear trend over 1980-2023 for the Illinois state average yield. Precip is the average for the state too. The data scatter shows that there is no real dip in trend deviations all the way out to about 8 inches. I know the quadratic regression I used shows the yield deviation turning down above six inches of July precip but that is more the result of forcing this functional form on the data, which probably is better modeled by a linear function up to around 5 inches and then going flat.Image
Read 5 tweets
Jul 8
1. Man, I really hate to do this tonight after a day like this in the grain market. But we gotta start talking about the potential scale of financial losses for producing corn and soybeans in 2024. This is an updated budget from this FDD: farmdocdaily.illinois.edu/2024/06/revise…
Image
2. I am going to use the following yield/price combinations just to get the convo started. Corn: 240 bu./$3.70. Soybeans: 75 bu./$10.30. I use higher yield expectations based on the expectation that Beryl rains will go a long ways to improving prospects. Mr. Market sure thinks so. Without taking into account LDP and crop insurance proceeds, this results in estimated farmer returns of -$244/acre for corn and -$98/acre for soybeans. For farms with 50/50 rotations that results in average farmer returns for all acres of -$171 per acre.Image
3. We are getting close to where 85% crop insurance policies will trigger based on price alone. Feb price was $4.66. For the 85% policy, Dec 24 futures have to drop to $3.96 to trigger payments at APH yields. With the increased yields I used, looks like still aways to seeing insurance payments. But need to wait for my colleagues who are much more expert in this regard to chime in. My sense is that crop insurance right now is not likely to help much. I am not sure about ARC/PLC payments. Maybe more help there.
Read 5 tweets
Mar 20
1. I guess today is the day to talk about corn yields. Just received an email from @aaea announcing a new Choices article "A Slowdown in US Crop Yield Growth" by David Boussios. Here is the link: choicesmagazine.org/choices-magazi…
2. The author of the Choices article argues: "The statistical evidence of a productivity slowdown in crop yield growth builds each year. The linear yield growth trends since 2013 for corn, soybeans, and wheat are all statistically lower than one starting in 1988. Models, forecasts, market participants, and policy makers should consider that yields in the future will probably be lower than forecasted by the USDA and that extrapolating trends into the future without revision is problematic."
3. This argument is especially interesting because I have seen similar arguments in the grain trade in the last few years. We can all agree that the US average corn yield has been relatively flat since around 2013. That is obvious looking at a chart of corn yields. But one has to be extremely careful in then leaping to the conclusion that productivity growth in corn yields has also slowed. The reason is that runs of poor or good weather can mask the true underlying trend in small samples of years.
Read 7 tweets
Nov 1, 2023
1. Recommended Reading for the Day: Fascinating new FDD from my colleagues on the farmdoc team, led by Carl Zulauf. Long-term look at real crop prices. farmdocdaily.illinois.edu/2023/10/the-po…
2. It has long been a staple of economic thinking that real (inflation adjusted) commodity prices have a strong tendency to decline over time. Probably the most famous example of in this regard is the bet about real commodity prices between Julian Simon and Paul Ehrlich in 1980. See the details here:
3. Carl and team put together the data for a USDA index of real crop prices going back to 1912. This is the chart shown below. Lots of interesting history here, but the 30 year period of stable real crop prices that began around 1990 is unmistakable. The question is whether this is a pause in a very long run downward trend or something new.
Image
Read 8 tweets
Sep 28, 2023
1. Excited to announce that the band is back together! Actually, talked Darrel Good into coming out of retirement to work on this FDD: "The New Era of Crop Prices: A 15-Year Review." farmdocdaily.illinois.edu/2023/09/the-ne…
2. When crop prices started to take off in 2006-07, a huge question was whether this was just another spike like we had seen so many other times, or was this the beginning of a permanent jump in the level of average prices, like in 1973. Image
3. For some reason (temporary insanity?), Darrel and I decided to stick our necks out and predict that a new era in crop prices was afoot AND make specific predictions for the average price and trading range in the new era. As this chart shows, we did not have much data to go on.
Image
Read 8 tweets
Jun 1, 2023
1. Ok, I have hopefully convinced you that the RIN cliff scenario is a logical possibility. Now what are the chances of it actually happening? The first step is to estimate QM in the graph below. Turns out the proposed RVOs released by EPA last December are the place to start. Image
2. We can use the proposed RVOs to come up with a defensible estimate of the maximum demand for biomass-based diesel (BBD) for 2023, 2024, and 2025. We can do this because we know mandates are and will be binding. Image
3. I will leave the details of the computations to the article. Suffice it to say that under the EPA's preliminary rulemaking, the max amount of BBD needed is about 4BG each year. That is national demand for sum of RD and BD. Image
Read 11 tweets

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