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California's ~118 Mt Allowance Removal Takes Effect 1 September as EPA Grants 29 of 34 2025-Year Refinery-Exemption Petitions and Pushes the 2025 RFS Deadline to 1 October

Trading-day outlook

Three sessions since our last note. Marks and gap deltas below; where our tape carries no gap observation, we say so rather than imply a flat market.

1. North America

1a. Compliance carbon

California-Quebec (CCA) — Mark: 32.8 (2026-08-28, front-month futures settlement (Sep26), CCA V26, settlement observation), +0.2% vs prior same-basis mark. Primary print: 32.48 (August 2026 joint auction, current-vintage settlement price).

What moved: Nothing marked: our futures mark is dated 28 August, the same session as our last note, so we have no marked level for the gap window; the August joint auction results were released 26 August.

Why: The 29 May 2026 amendments take effect tomorrow, 1 September (a Tuesday), cutting California's 17 CCR 95841 Table 6-2 budgets to 225.6 Mt in 2027 (was 240) through 158.8 Mt in 2030 (was 200.5) — a 117.7 Mt reduction, CARB's "~118 million." Our forward joint rows are still pre-amendment and already show deficit throughout (2027 −12.0 Mt, widening to −42.5 Mt by 2030); they re-row on ingestion of the amended table, and they model offset-driven allowance retirement at zero, biasing supply high.

Desk view: Bullish CCA on a 2027 view — the deficit deepens mechanically tomorrow; auction settlement near the floor argues the front is not yet pricing it.

Washington (WCA) — Mark: primary print 64.56 (2026-06, current-vintage settlement (Auction #14)). No fresher mark on our tape, and no marked level for the gap window.

What moved: No development in the window we can source.

Why: Rows sit on the current statutory slope only because Ecology's post-2026 budget rule, due 1 October 2026, has not issued; balance is −12.4 Mt in 2027 deepening to −24.2 Mt by 2030.

Desk view: Constructive but untradeable on marks this stale — the October rule is the repricer, and September's APCR sale is the near catalyst.

RGGI (RGA) — Mark: 40.72 (2026-08-28, front-month futures settlement (Sep26), RGGI V26, settlement observation), −2.4% vs prior same-basis mark. Primary print: 35.0 (2026-06-03, Auction 72 clearing price).

What moved: Mark dated 28 August; no marked level for the gap window. Auction 73 lands 9 September (a Wednesday) with 1.148M CCR allowances available and Virginia standard allowances beginning.

Why: Eleven states participate; the Third Program Review ladder (69.8M in 2027, −8.539M/yr) is a ten-state cap basis excluding Virginia until DEQ's rule takes effect 1 January 2027. Balance flips to deficit in 2029, cushioned by the ~67M private bank (Potomac, Jul 2025). Our 2029/2030 rows carry a small upward adjustment the statute itself does not state — desk assumption, named.

Desk view: Neutral-to-firm into 9 September; futures already run well above the June clearing, so the auction is the risk, not the thesis.

Alberta TIER — Mark: primary print 95.0 (2025-05, TIER fund price, frozen since May 2025).

What moved: Nothing in the window.

Why: The May 2026 Canada-Alberta Implementation Agreement schedule is the repricer: $95 in 2026, $100 for 2027-2029, $115 in 2030, rising to $140 by 2040, with a credit floor ($60 in 2030 to $110 in 2040) to be enacted by 31 December 2026. Clause 1.2.3.4 grandfathers credits generated before enactment.

Desk view: Bearish pre-enactment EPC credits, bullish post-enactment vintages — the grandfathering cutoff is economically live now, not in 2030.

1b. Low-carbon fuels (LCFS / CFR)

CA LCFS — Mark: 77.19 (2026-08-17, CARB weekly volume-weighted average credit transfer price, week of 2026-08-17, range 68.50-82.50). Next weekly report tomorrow, 1 September.

What moved: Credits inched higher into the window on wire reporting (Quantum, 27 Aug) while RINs fell on exemption uncertainty.

Why: 2026Q1 (published 31 July) showed credits 6.93M MT against deficits 9.77M MT — net −2.84M MT, bank 36.86M MT. On the federal side, industry participants briefed by the administration told Reuters they expect EPA to approve 1.2-1.8 billion RINs in small refinery exemptions, against 2026 standards set at a record 26.81 billion RINs , and D6 RINs traded at $1.75 on that expectation, per Argus. Both legs of it resolved on 31 August. EPA announced decisions on 34 small refinery exemption petitions from 34 refineries for the 2025 compliance year — 18 full (100%) exemptions, 11 partial (50%), three denied and two ineligible, plus one 2024 partial reissued from the 3 August set — and finalised a rule moving the 2025 compliance reporting deadline from 1 September to 1 October 2026, expressly to give participants time in light of those decisions. The 2025 attest engagement deadline (1 June 2027) and the 2026 reporting deadline (31 March 2027) are unchanged — unmarked on our tape; our D4/D6 prints are 4 June historic levels, not current.

Desk view: Mildly bullish LCFS credits — a large SRE grant weakens RIN-side renewable-diesel economics, slows incremental RD into California, and slows credit generation against a bank still drawing down.

Canada CFR / BC — Mark: BC LCFS 135.8 (2026-07, monthly average credit transfer price). CFR credits carry no citable mark on our tape; ECCC's credit-retirement data is unpublished.

Desk view: Neutral, structurally firm — BC transfer prices are the only clean read until ECCC publishes.

1c. RECs

What moved: Pennsylvania's GRID Project consent order (reported 30 August) sets new obligations on data-centre developers — a load-growth story that pulls Tier 1 demand forward.

Why: Compliance REC demand is a function of load and power prices; no traded REC price is on our tape, and per-class figures (California PCC, Northeast Class I/Tier 1, SRECs) do not average.

Desk view: Bullish PJM Tier 1 on data-centre load; SRECs neutral, carve-out-supply driven.

2. Voluntary carbon (VCM)

SBTi: As context, the Corporate Net-Zero Standard v2.0 was published 11 June 2026; validations against V2.0 open 1 February 2027, V1.3.1 submissions close 31 January 2028, and V2.0 becomes mandatory 1 February 2028. Nothing new in the window.

Removals: Our monitors flag a change to the Puro Standard General Rules — version 4.4 is approved and dated 07 May 2026, effective on its issue date ; ICVCM's CCP-eligibility approval covers version 4.2 of the General Rules and later, so v4.4 sits inside it . Read: neutral CORC pricing, positive for supply integrity.

Article 6 / CORSIA: From 2027 all international flights are subject to offsetting requirements, with exemptions for LDCs, SIDS, LLDCs and states below 0.5% of 2018 international RTK , and major markets including China, absent from Phase 1, are required in from 2027 . Read: bullish authorised, CORSIA-labelled units into 2027.

3. International

EU ETS (EUA) — Mark: primary print 82.39 (2026-08-31, latest EEX auction clearing price).

What moved: A fresh clearing today; we have no marked level for the gap window to measure against.

Why: Supply falls 1101.4→843.4 Mt across 2027-2030 against demand 987.7→943.9; the surplus narrows and flips to deficit in 2029 under Directive (EU) 2023/959. COM(2026) 616 remains a proposal and re-rows nothing yet.

Desk view: Bullish structurally; supply cuts of 86 Mt/yr do the work.

UK ETS (UKA) — Mark: 58.68 (2026-07, official monthly average UKA settlement price (Dec futures), CCM table, monthly-final observation), +2.9% vs prior same-basis mark. Monthly basis, so no gap observation exists.

Why: Deficit throughout (−6.5 Mt 2027 to −20.6 Mt 2030) under SI 2020/1265 Table B as amended by SI 2026/392 (maritime extension in force 1 July 2026); linkage talks are the live driver.

Desk view: Bullish, discount-to-EUA compression the cleaner expression.

NZ ETS / Australia — NZU 54.77 (2026-08-13, secondary spot scrape of broker marks, close observation), −2.2% vs prior close; ACCU 37.5 (2026-05-15, generic ACCU spot, CER QCMR March quarter 2026). No marked level for the gap window in either. NZ's quarterly auction is 8 September (a Tuesday), the first with Xpansiv CBL as operator; our rows assume zero clearing below the NZD 71 floor. Both balances are deficit throughout. Read: bullish NZU, bullish ACCU on baseline decline of 4.9%/yr.

Standing US federal context: EPA's rescission rule was published in the Federal Register on 18 February 2026 and took effect 20 April 2026 ; it rescinds only the motor-vehicle endangerment finding, not the separate stationary-source or aircraft findings . State programmes carry the compliance load regardless — supportive of RGGI/WCI scarcity value.