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.
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.
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.
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.
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.
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.
These claims were challenged by the factcheck and are settled on the record. The rulings live in the desk's adjudication store, not in this note.
EPA decided 34 small refinery exemption petitions for the 2025 compliance year on 31 August 2026 — OVERTURNED
Read from EPA's own decision page on 31 August: 34 petitions from 34 refineries for the 2025 compliance year - 18 full (100%) exemptions, 11 partial (50%), three denied, two ineligible - plus one 2024 partial reissued from the 3 August set.
The checker reported that EPA's page 'still listed the Aug 3, 2026 action as its latest SRE decision' and cited AgBull of 27 August saying the decision was expected but not yet announced. That is a secondary describing the position four days BEFORE the action, which is B48's shape exactly: it is evidence about an earlier stage, not about the adopted position. EPA's announcements index carries the 31 August entry and the decision page states the breakdown verbatim. A search index that has not caught up with a same-day action is a fact about the index (B45).
Adjudicated 2026-08-31 by Kiran. Raised 0 time(s) before this note. Sources: EPA, 'August 31, 2026 Decisions on Petitions for RFS Small Refinery Exemptions', epa.gov/renewable-fuel-standard/august-31-2026-decisions-petitions-rfs-small-refinery-exemptions; EPA final rule, 'RFS Program: Extension of 2025 Compliance Reporting Deadline', EPA-HQ-OAR-2026-7195, RIN 2060-AX06, epa.gov/system/files/documents/2026-08/frn-2025-compliance-date-extension-2026-0831.pdf; EPA RFS news, notices and announcements index, entries dated 31 August 2026.