NTC - Optimus Technologies Biodiesel Trucks FINAL · 2020-03-23 · 6" "...

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BIODIESEL POWERED TRUCKS

A Non-‐Market Strategy Report for Optimus Technologies

CATHERINE FULLERTON | KATIE LIN | SRIRAM BHARADWAJ

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BIODIESEL POWERED TRUCKS

By: Catherine Fullerton, Katie Lin, and Sriram Bharadwaj

Faculty Advisor: Dr. Deborah D. Stine

May 6, 2015

Acknowledgements

We thank the following people for sharing their knowledge and expertise with us over the course of this project:

Ian Winner – Business Analyst at Optimus Technologies

Prof. W. Michael Griffin – Associate Research Professor, Engineering and Public Policy and the Tepper School of Business and Co-‐Director and Executive Director, Green Design Institute, Carnegie Mellon University

Dr. Sonia Yeh – Research Scientist, The Institute of Transportation Studies, University of California, Davis

Warning and Explanatory Note

This report is part of a student project, and thus is not meant to be quoted, cited or referenced as it has not been subject to a rigorous level of critical review. The following report, completed for our client, Optimus Technologies, is the culmination of six-‐weeks of work for the course, New Technology Commercialization: Public Policy Strategies, administered within the Department of Engineering and Public Policy at Carnegie Mellon University.

© Copyright 2015 -‐ Catherine Fullerton, Katie Lin, and Sriram Bharadwaj

Report Design by Catherine Fullerton

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Table of Contents I. Executive Summary ........................................................................................................................................ 3

II. Technology Overview .................................................................................................................................... 4

Challenges and Opportunities ................................................................................................................. 5

Challenges ........................................................................................................................................ 5

Opportunities ................................................................................................................................... 6

III. Policy Analysis Framework ............................................................................................................................. 8

Status Quo ............................................................................................................................................... 8

Issue ........................................................................................................................................................ 9

Policy Context ......................................................................................................................................... 9

Key Actors and Interests .................................................................................................................. 9

Policy Arena and Forums ............................................................................................................... 11

Information and Assets ................................................................................................................. 12

IV. Policy Options and Analysis ........................................................................................................................ 13

Criteria for Analysis .............................................................................................................................. 13

Range of Outcomes .............................................................................................................................. 13

Bargaining Context ............................................................................................................................... 15

V. Strategy and Arguments ............................................................................................................................. 17

Short Term Strategy (1-‐3 years) ........................................................................................................... 17

Medium-‐ to Long-‐Term Strategy (3-‐10 years) ...................................................................................... 17

Policy Considerations ........................................................................................................................... 18

Conclusion ............................................................................................................................................ 18

VI. References .................................................................................................................................................. 19

List of Figures Figure 1: Optimus Technology Vector System ...................................................................................................... 4 Figure 2. Map of biodiesel stations nationally. ..................................................................................................... 6 Figure 3. Map of states that have adopted or considered adopting the Low Carbon Fuel Standard. ............... 11 Figure 4. Option analysis criteria ....................................................................................................................... 13 Figure 5: EPA new fuels pathway petition process ............................................................................................ 17

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List of Tables Table 1. Range of outcomes analysis for each policy option. ............................................................................ 15 Table 2: Bargaining context analysis for each policy option. ............................................................................. 16

Executive Summary Optimus Technologies, a company incorporated in 2010 offers a patent-‐pending EPA-‐approved biofuel conversion system, called the Vector System, which offers a host of benefits including emissions reductions, fuel savings, and easy maintenance. The company currently sells its kit individually in the Midwest & Northeast and through its fuel partner based in Florida. In the short run, the company plans to establish itself as a dominant player in the region. Over the long run, Optimus plans to cover the entire US market by leveraging laws such as the Renewable Fuel Standard (RFS) and Low Carbon Fuel Standard (LCFS), which are intended to reduce emissions by providing incentives for renewable energy. As part of its business expansion plan, Optimus also aims to increase the number of fuel providers it partners with, i.e. companies that would not only sell the Vector System as a licensed retailer but also produce and supply biofuels to prospective clients.

In evaluating the non-‐market landscape of the biofuels sector, the project team focused on the following considerations:

● Issues: Understanding and optimizing dividends from the Low Carbon Fuel Standard and the Renewable Fuel Standard, creating a fuel pathway to meet the standards, conducting a life cycle assessment of the system and the fuels, understanding and analyzing policy trends in the biofuels space.

● Interests: Environmental Protection Agency, California Air Resources Board, biofuel producers, Petroleum Companies and the various congressional committees, namely the House Energy & Commerce Committee and Senate Committee on Environment and Public Works.

● Institutions: The City of Pittsburgh, Environmental Protection Agency, California Air Resources Board, Advanced Biofuels Association, Argonne National Laboratory, University of California, Berkeley, and University of California, Davis.

● Information: Life cycle analysis of Vector System, California Air Resources Board pathway application process, feedstock process pathway for Renewable Identification Numbers, current and future price of fuels, congressional members’ stance on current and future fuel legislation.

In order to facilitate greater sales and ensured success of the Vector System, it is imperative to provide direct incentives to fuel producers, attract more fuel partners, and to understand regulatory uncertainty at both the state level and federal levels. Based on literature review and expert interviews, the most effective option for Optimus Technologies is for the company to apply for its own fuel pathway through EPA so that fuel producers may receive Renewable Identification Number (RIN) credits on Optimus-‐grade fuel.

Using this central conclusion, this report proposes the following non-‐market recommendations to complement Optimus Technologies’ short-‐term and long term market strategies:

Short-‐term Recommendations: Finalize and submit a petition to the Environmental Protection Agency (EPA) for a fuel process pathway. The subsequent approval of the Optimus-‐grade fuel pathway will act as a direct incentive to attract fuel producers and fuel partners.

Long-‐term Recommendations: Leverage the EPA life cycle analysis conducted during the fuels pathway approval process of the Vector System and the Optimus-‐grade biofuel. This analysis may be used for entry to the transportation market in California and other states which may enact similar legislation.

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Technology Overview Biofuels are a broader classification for renewable fuels derived from biological materials, such as plants and animals. Biofuels include ethanol fuels, biodiesel, methanol fuel and butanol-‐based fuels. "Optimus Technologies is the market leader in high performance biofuel conversion solutions that utilize biofuel and diesel for medium-‐ and heavy-‐duty truck fleets" (Optimus Technologies, "Vector System Brochure", 2015). The company helps fleets significantly reduce costs and emissions and meet renewable fuel targets through their EPA-‐approved biofuels conversion system known as the Vector System.

The Vector System is bi-‐fuel solution that powers the engine entirely on biofuels except during startup and shutdown, although a diesel fall back option is provided in the event that no biodiesel is available for use. For start-‐up, the truck initially runs on the traditional diesel fuel until the system temperature rises to 40 degree Celsius, when the biofuel Vector System takes over. After this point, the truck runs entirely on biofuel until either the biofuel tank is depleted or the trip is complete, at which point the system converts back to diesel for startup next time. The Vector System is comprised of the Vector fuel tank, which is the biodiesel fuel tank, and the Vector manifold, which acts as a heat-‐exchanger and controls the amount of biodiesel used via the electronic control unit (Optimus Technologies, "Vector System Brochure", 2015). The information from the manifold is presented to the driver via a user interface in the truck cabin, and remote user applications allow the information to be transmitted to the client organization. This feature, the Electronic Control Unit (ECU) of the system, provides a host of remote sensing applications and it is completely automated (Optimus Technologies, "Vector System Brochure", 2015).

Figure 1: Optimus Technology Vector System (“Vector System Brochure”, 2015)

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The operation and maintenance of the system is very simple and no special training or certification is required by the operator (Optimus Technologies, “Solutions”, 2015). It facilitates seamless transition between diesel and the biofuels. The system can operate across rugged terrain over a broad range of temperatures. The system has not only an effective hardware, but also a very effective and efficient software, featuring a user-‐friendly interface for the driver. The interface for offices managing fleets also offers a wide variety of features like real-‐time system performance, GPS features, access to logged data and fuel usage metrics (Optimus Technologies, “Solutions”, 2015). The company guarantees at least 10% savings on current diesel price, and reductions in emissions, including reductions in particulate matter by up to 40% and NOx by up to 10% over diesel (Optimus Technologies, “Solutions”, 2015). The system is also fairly flexible and can work with a variety of fuels such as diesel, advanced biofuel, renewable diesel, pure biodiesel and blended biodiesel.

Currently, Optimus Technologies enjoys the advantages of being the first in market as the only system with EPA approval for a medium-‐ and heavy-‐duty truck biofuel conversion system. The company was incorporated in 2010 and has sold over 50 Vector Systems already, with target sales of approximately 145 units for the year 2015. As part of its market strategy, Optimus has a unique sales model wherein it creates partnerships with fuel suppliers. The fuel partners not only supply biofuels to Optimus’ customers but also act as licensed retailers for the Vector System. At present, there is one fuel supplier in Indiana and one fuel partner in Florida, with the company currently in talks to partner with another five biofuel producers (Winner, 2015).

Challenges and Opportunities

Challenges The first major challenge for Optimus Technologies is securing the selling appeal of the Vector System based on fuel cost savings to buyers. In its present form, the Vector System costs around $10,000 and, as an incentive, Optimus Technologies guarantees a 10% fuel cost savings to buyers. However, the current low petroleum prices have made it difficult for biodiesel to compete with diesel on price alone, thus compromising a vital component of Optimus’ market strategy.

One of the biggest strengths and a potential weakness is the fact that the Vector System can work on a host of biofuels like soy oil, corn oil, waste vegetable oil, and a host of other biofuels. Although this factor can help Optimus gain many fuel partners, it would be extremely difficult for each partner to get fuel pathways and Renewable Identification Numbers (RINs) for each fuel, and currently only a few of Optimus’ prospective fuel suppliers are generating RINs on fuels that can be used by the Vector System. Optimus Technologies is currently exploring how to develop a specific fuel pathway for a single Optimus-‐grade fuel whose process can be licensed to fuel providers to enable the provider to receive RINs for production of the fuel. Having uniformity in their fuel, at least initially, could help them obtain RINs for the fuel that could uniformly be used by fuel producers to supply the biofuel at a lower cost.

Another challenge Optimus faces is in securing fueling infrastructure for trucks equipped with the Vector System. As of right now, fueling stations that dispense biodiesel are very sparse, with a total of 268 biodiesel stations compared to the 168,000 gasoline stations in the US (Alternative Fuels Data Center, "Biodiesel Fueling Station Locations", 2012). From the map below, biodiesel stations are not uniformly distributed across the continental United States either, with clusters of stations around Chicago in the Midwest, across the South, and all along the West Coast.

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Figure 2. Map of biodiesel stations nationally. (Alternative Fuels Data Center, "Biodiesel Fueling Station Locations", 2012)

Looking at the map above, it may be better for Optimus to target expansion to regions with high clusters of biofuel stations, physically supplying the fuel is the biggest issue in getting fleets to adopt the Vector System in many of the cities and regions where Optimus already has a market presence, such as Pennsylvania. This lack of infrastructure can drive up the cost of Vector System implementation, but grant funding may help in some cases. For example, one of Optimus’ current clients, the City of Pittsburgh, is building their own fueling station with grant funding. Overall, however, fueling infrastructure considerations limit the geographic markets available to Optimus, as only fleets that utilize a return-‐to-‐base fueling structure will be able see the full benefits of the Vector System.

While the biofuels industry experienced steady growth due to the Energy Independence and Security Act (EISA) and the RFS, the EPA’s reduction in standards in 2013 caused the industry to contract some (Advanced Biofuels Association, "For Next-‐Generation Biofuels, Time to Strengthen the RFS", 2015). Per the Advanced Biofuels Association (ABFA), biofuel producers are threatened by low oil prices and by the EPA’s decision to allow the oil industry to opt out of requirements through waiver credits. The ABFA has advocated for a minimum RIN value for biofuels that to provide certainty and market stability for biofuels producers (Advanced Biofuels Association, "About the Advanced Biofuels Association", 2015). The current uncertainty regarding RIN values is an issue for Optimus as they are planning to leverage RINs to sell their Vector System.

Opportunities Optimus has a first mover advantage in this space as it is the only EPA approved system (Optimus Technologies Vector System Brochure, p.4). At present, Optimus is targeting sales in the Northeast and Midwest in cities like Boston, New York, Chicago, Philadelphia, Pittsburgh, as well as in the state of Florida. Their long-‐term market plan intends to include all states in the continental US. Truck transport amounts for almost 60% of total freight activity in the US (American Trucking Association, 2012). With increasing fuel costs and the company guaranteeing a 10% savings on current diesel prices, Optimus Technologies has tremendous sales potential that could be bolstered by the fact that the Vector System is the only EPA approved biofuel conversion system. Optimus is already a pioneer and a market leader in their market segment and thus could leverage the fact that the Vector System offers seamless transition between fuels,

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offering drivers and fleet managers extra security. Furthermore, the flexibility in fuels used for the Vector System may appeal to fleet owners.

Outside of the features of the Vector System itself, Optimus has several opportunities through its connections to local government and organizations promoting renewable fuels. The local government in Pittsburgh has been generally supportive of Optimus due to the government’s inclusion of sustainability into long-‐term planning. In addition, local government connections may help Optimus get the attention of members of Congress who represent districts in Western Pennsylvania and are in favor of renewable fuels policies such as the RFS. Optimus Technologies also has a good relationship with Pittsburgh Region Clean Cities (PRCC), the branch office of the US Department of Energy Clean Cities Program initiatives representing Western Pennsylvania. By providing business consulting, education, development support and management of federal and state-‐funded projects, PRCC supports the development of alternative fuel and alternative vehicle infrastructure in the region (Pittsburgh Region Clean Cities, 2014). PRCC has helped Optimus Technologies by connecting the company to national fleets and funding opportunities.

Optimus’ fuel partner model offers an interesting incentive to biofuel companies, as the companies can sell the Vector System and also supply the biofuel to the consumer, thereby creating a long-‐term customer base for fuels. In effect, Optimus is creating a two-‐sided market where it would sell the system and act as a facilitator between fuel suppliers/partners and customers. The two-‐sided market approach is a successful model practiced extensively in the information technology industry, and this approach holds tremendous potential for Optimus. Optimus Technologies currently has one fuel partner and is in talks with five other potential partners. The fuel partner model allows Optimus to enter new markets quickly without much significant investment and can help Optimus Technologies sell its Vector System throughout the United States.

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Policy Analysis Framework

Status Quo National Legislation As defined by the EISA, the revised Renewable Fuel Standard “establishes the minimum volumes of renewable fuels that must be included in national fuel supplies for transportation” (Congressional Budget Office, 2013). Despite its mandate, there has been significant uncertainty around the future of the RFS. Business groups have raised concerns about the feasibility of complying with the RFS volume goals for several years given certain constraints on supply. In 2014, the EPA responded to challenges to the RFS from industry by reducing the advanced biofuel requirement by 1.5B gallons and cutting the total renewable fuel volume requirement by 3B gallons (Congressional Budget Office, 2014). This cut has put the EPA between a rock and a hard place, as the EPA has also encountered opposition from the ethanol industry to the EPA’s proposal to cut the biofuels blending volumes for 2014 from 16.5B to 15.1B gallons (Platts McGraw Hill, 2015). With both sides fighting, the EPA has taken longer to issue the renewable fuel requirement, thus increasing uncertainty for fuel producers.

Despite this uncertainty, a 2014 evaluation of the RFS by the Congressional Budget Office, as well as recent developments at the EPA, suggest that RFS volume requirements will be adjusted to current levels of production, rather than the aggressive targets outlined in EISA. Two main points stem from these developments:

1. There is high certainty around a timeline for RFS standards for 2014, 2015, and 2016. A consent decree issued by the EPA in April 2015, the result of a lawsuit settlement with two petrochemical industry groups, has committed the EPA to proposing the 2015 and 2016 volume requirements by June 1, 2015. In addition, the EPA will also issue biomass-‐based diesel RFS requirements thru 2017 on the same schedule (EPA, "Renewable Fuels Volume Standards Timeline Released", 2015).

2. There is some uncertainty around the volume requirements. Currently, it is not clear how the RFS volume requirements proposed by the EPA will affect the biofuels market. The proposed requirements will likely reflect actual 2014 renewable fuel volumes, which may do little for the biofuels industry now that the year has passed. The volumes of biomass-‐based diesel in 2014 were about 1.75 billion gallons (EPA, "Renewable Fuels Standard", 2015).

The RFS uses Renewable Identification Numbers (RINs) as way of tracking progress towards the standards set yearly. Each obligated party is assigned a renewable volume obligation (RVO) or the "volume of renewable fuels it is obligated to sell, based on a percentage of the company's total fuel sales" (Alternative Fuels Data Center, "Renewable Identification Numbers", 2014). RINs are assigned to the physical gallon of the fuel produced. Companies that are able to produce more renewable fuels than mandated in their RVO are able to sell the RINs associated with the excess fuels to companies who were unable to meet their RVO, thus being able to partially offset the higher cost of production.

State Level Legislation The California Low Carbon Fuel Standard: The LCFS may also present some major challenges to the biofuels producers and biofuels technologies due to its emphasis on reducing emissions throughout the entire life cycle of a fuel. While the just the product of a biofuel itself generally emits fewer greenhouse gasses (GHGs) than a petroleum-‐based fuel, the production of certain biofuels, namely corn-‐based ethanol, produces additional GHGs, and can cause the producer to exceed the state's benchmark of about 86 grams of GHG emissions per mega joule (Baker, 2015). This has already presented some issues with the law, as Midwestern ethanol producers have protested the LCFS while Brazilian sugar cane-‐based biofuel producers have lauded it (UNICA, 2011). Overall, however, LCFS likely presents more benefits than obstacles to Optimus over the long-‐term, as it is unlikely to be repealed at this point.

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Northeast/Mid-‐Atlantic Low Carbon Fuel Standard: In 2009, following California’s implementation of the LCFS, environment and energy officials from 11 states in the Northeast and Mid-‐Atlantic began formal discussions on a low carbon fuel standard for the entire region, dubbed the Northeast/Mid-‐Atlantic Low Carbon Fuel Standard. In 2011, officials from the 11 states, including Pennsylvania, New York, New Jersey, and Massachusetts, announced that a program framework for the proposed fuel standard would be developed upon completion of an economic impact analysis (Center for Climate and Energy Solutions, 2015). Since then, the state leaders tabled the fuel standard discussions indefinitely, with New Jersey eventually opting out. However, a recent initiative to create a carbon fuel calculator has helped renew some interest among the remaining 10 states involved (Gallucci, 2014).

Issue With this report, our thrust area is centered on developing a non-‐market strategy for Optimus Technologies to incentivize biofuel producers to become fuel providers for Optimus Technologies’ Vector System. Given this focus, our main question is:

What actions, if any, should Optimus Technologies take so that fuel partners are able to supply Optimus-‐grade biofuels to current and potential customers interested in or currently converting their trucks to biodiesel in Optimus' target geographical markets?

Policy Context Key Actors and Interests

Regulatory Agencies United States Environmental Protection Agency (EPA): The EPA is the regulatory agency responsible for creating the renewable fuel volume requirements each year. The agency is also responsible for reviewing and approving new fuel pathway petitions as well as granting RIN credits. The EPA is neutral on most options as the agency’s role will not change due to Optimus Technologies’ actions.

California Air Resources Board (CARB): CARB is a regulatory agency responsible for approving fuels and fuel providers under the Low Carbon Fuel Standard. Like the EPA, they are neutral on most options as their role will not change due to Optimus Technologies’ actions. See Policy Arenas and Forums for more information on this agency.

Organizations likely to support action Optimus Technologies established and prospective fuel partners: Optimus has several prospective fuel partners and one established partner throughout the United States. Relevant fuel partners include:

● Fuel partner in Florida: Optimus has established a full partnership with one fuel supplier and is pursuing a marketing strategy with them.

● Fuel supplier in Indiana: Optimus is beginning a partnership with this fuel supplier, which has received an EPA pathway approval for their own fuel. Optimus has asked for their help in applying for an Optimus-‐grade fuel pathway, as Optimus is not a fuel provider.

● In Pennsylvania, Optimus is in talks with several fuel producers: three biodiesel companies, one of which specifically works with waste oil recycling, and an ethanol biofuel company. The Pennsylvania biofuels companies are concerned about the upfront costs with producing Optimus-‐grade fuel and so have not become full fuel partners.

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● The Renewable Energy Group (nationwide): This prospective fuel partner has “a nationwide production, distribution and logistics system as part of an integrated value chain model to focus on converting natural fats, oils and greases into advanced biofuels and converting diverse feed stocks into renewable chemicals” (Renewable Energy Group, 2014). This prospective partner has ten refineries across the country, develops its own biofuels, and holds patents on the fuels it has developed.

As alternative fuels producers, all of the stakeholders mentioned above are in support of policies which provide more regulatory certainty with regard to the RFS, increase the value of RINs to make biofuels competitive with petroleum-‐based fuels, and expand transportation technologies using biofuels.

Pittsburgh Region Clean Cities: The PRCC, part of a nation-‐wide program supported by the US Department of Energy, “advances the nation's economic, environmental, and energy security by supporting local actions to reduce petroleum use in transportation” (Pittsburgh Region Clean Cities, 2015) by engaging stakeholders at the local level. Pittsburgh Region Clean Cities is a chapter of the Clean Cities program, and, like other cities, this chapter promotes “1.) Building and supporting the infrastructure needed for a strong alternative fuel and alternative vehicle market in Western Pennsylvania; 2.) Serving the needs of its member organizations through education, business consulting, development and grant writing and management of Federal and State-‐funded projects; and 3.) Serving as the designated regional organization for all US Department of Energy Clean Cities initiatives, including project funding” (Pittsburgh Region Clean Cities, 2015). Optimus Technologies is a bronze member of this organization.

Advanced Biofuels Association (ABA): Per their website, the ABA is an industry lobbying group comprised of “nearly 40 member companies, representing a wide range of technologies, feed stocks, and processes within the advanced biofuels industry….The ABA supports and advocates for public policies that are technology neutral,” and “engage(s) government at all levels to secure support for the advanced biofuels industry, allowing our member companies to commercialize their technologies and bring products to market that are competitive and compatible with petroleum based fuels and byproducts” (Advanced Biofuels Association, "About the Advanced Biofuels Association", 2015). Optimus Technologies is not currently a full member, but has been aided by the ABA’s knowledge of the RFS.[1]

Organizations likely to oppose action The American Petroleum Institute (API) & American Fuel and the Petrochemical Manufacturers (AFPM): These organizations, which represent the petroleum industry, have generally been hostile to the RFS. In 2015 the API and APFM sued the EPA over delays in setting the RFS volume requirements (Vougele, 2015). In 2013, the API launched an anti-‐RFS ad campaign in several states and lobbied congress to repeal the RFS (Podkul, 2013). While these organizations may include some companies which are friendly to biofuels, for the most part they appear to strongly oppose the RFS.

Members of Congress hostile to the RFS and the renewable fuels industry: In February 2015, Representative Bob Goodlatte (R-‐Va.), with support from 30 lawmakers from both parties, introduced a new bill, the Renewable Fuel Standard Reform Act, which is meant to repeal the corn ethanol mandate from EISA. Overall, the 113th Congress has had “over 218 lawmakers in the House either co-‐sponsored major bills to repeal the RFS or went on record expressing serious doubts about the mandate” (National Retail Federation, 2015). In January 2015, Senators Toomey (R-‐Pa.) and Feinstein (D-‐Calif.) also offered an amendment to RFS legislation that would repeal the corn ethanol mandate (Feed Food Fairness, 2015). While the Vector System uses non-‐ethanol biofuels, these two developments may be concerning for future advanced biofuels legislation.

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Policy Arena and Forums

EPA Office of Transportation and Air Quality This division of the EPA protects “public health and the environment by regulating air pollution from motor vehicles, engines, as well as the fuels used to operate them” (EPA, "Transportation and Air Quality", 2015). As part of the EPA’s mandate under the Clean Air Act, the Office of Transportation and Air Quality "encourages travel choices that minimize emissions from cars and light trucks, heavy trucks and buses,[...]equipment, and other vehicles” (Environmental Protection Agency, "Transportation and Air Quality", 2015). Through this office, the EPA has established a process for companies to petition for new fuels pathways to qualify for the RFS program through an evaluation of three components of a given fuel: (1) feedstock, (2) production process and (3) fuel type and the fuels greenhouse gas (GHG) emissions (Environmental Protection Agency, "What is a fuel pathway?", 2015).

California Air Resources Board (CARB) CARB is a department within the California Environmental Protection Agency which acts to “promote and protect public health, welfare and ecological resources through the effective and efficient reduction of air pollutants” (California Air Resources Board, "Mission and Goals", 2012). As part of this mandate, CARB is in charge of setting the Low-‐Carbon Fuel Standard which requires fuel producers, namely oil refineries and the like, to ensure that the fuel blends they sell complies with the state’s emissions targets by gradually reducing the carbon intensity of the fuels they produce. In estimating the carbon intensity of fuels, the California LCFS evaluates emissions at every stage of fuel production, from feedstock to gas pump, in estimating the efficiency of transport fuels.

California is unique in that it is the “only state vested with the authority to develop its own emission regulations. Other states have a choice to either implement the federal emission standards, or else to adopt California requirements” (Diesel.net, 2010). There are several states that have adopted California Clean Car Standards, including Pennsylvania, New York and Massachusetts (Environmental Defense Fund, 2011), but the LCFS has been slower to catch on, with only a few states considering legislation to instate the LCSE, as the map below from the Center for Climate and Energy Solutions demonstrates (Center for Climate and Energy Solutions, 2015).

Figure 3. Map of states that have adopted or considered adopting the Low Carbon Fuel Standard. (Center for Climate and Energy Solutions, “Map of the Low Carbon Fuel Standard States”, 2015)

State Legislatures in the Northeast/ Mid-‐Atlantic Region

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Currently, states in the Northeast/Mid-‐Atlantic may develop their own fuel standards, but none have done so. Out of the 11 states, Vermont may be the most eager to adopt a fuel standard, as it has been very vocally in favor of a regional fuels carbon calculator, which is seen as a precursor to the regional carbon fuel standard (Gallucci, 2014). The states of interest to Optimus Technologies, namely Massachusetts, New York and Pennsylvania have tax incentives and grant programs to support the production of biofuels, but do not have any fuel standard legislation in the works. Overall, the outcome of the Northeast/Mid-‐Atlantic Low Carbon Fuel Standard is uncertain but gained some traction when the Supreme Court refused to hear a case challenging the California LCFS (Gallucci, 2014), indicating that state (and regional) fuel standards are unlikely to be challenged at the federal level.

Information and Assets The following items highlight key information and assets available to Optimus Technologies in their market and non-‐market strategies.

• Current opposition and support from Congressional members for the RFS: One of the key pieces of information that Optimus Technologies is able to access is the stance of the various congressional members on the RFS, of which there are many shades. Some legislators completely oppose the RFS, while others support the RFS entirely in its current form. In between are legislators who oppose the ethanol mandate of the RFS but support other biofuels with lower carbon intensities, such as advanced biofuels. Understanding the supporters and opponents of the RFS is key to understanding the resources available to Optimus in terms of congressional support, particularly for those members of congress representing areas where Optimus operates. For example, Pittsburgh Congressman Mike Doyle and Pennsylvania Senator Bob Casey have fairly consistently voted in favor of alternative energy and biofuels-‐related legislation, while Pennsylvania Senator Pat Toomey has been more hostile to the RFS, and the ethanol mandate in particular (Vickers, 2013).

• Life cycle analysis of the Vector System: The life cycle analysis (LCA) is a requirement for both the EPA and CARB to approve of a fuel pathway. While an LCA analysis by a reputed firm costs somewhere around $30,000, the EPA conducts its own LCA of new fuel pathways submitted for review and approval.

• CARB application process: Information on registering new and existing fuel pathways through the California Air Resources Board, including applications, information on the application procedure and requirements, and contact information can be found on their website.

• RFS pathway application process: The RFS application process is available online and is a prerequisite for obtaining approval of a new fuels pathway and thus RIN credits on Optimus-‐grade biofuel.

• Current diesel and biodiesel prices: This data is available online and can be used by Optimus to evaluate current trends in the market and forecast fuel prices.

Some of the key advantages Optimus has to maneuver these challenges include:

• Relationship with City of Pittsburgh as current client: The City of Pittsburgh has been more than just a client of Optimus. They have been very helpful in establishing contacts, giving grants and have helped Optimus in planning for the future.

• First to market advantage for fuel conversion system: Optimus has a distinct first mover advantage and, at present, does not have a direct competitor. This is gives Optimus the advantage of being able to shape its market segment as it is technically the first major market entrant.

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Policy Options and Analysis Given the current policy environment, Optimus has the following options for immediate action and for longer-‐term business development.

Option 1: Status Quo – Optimus Technologies continues to expand through fuel partners without its own fuels pathway and focuses solely on market strategy.

Option 2: Optimus works with an academic institution or consultant to perform LCA on fuels in preparation for California Air Resources Board approval and entry into California market.

Option 3: Optimus targets expansion to western states with more market certainty around biofuels, specifically California, by getting approval through California Air Resources Board.

Option 4: Optimus applies for an EPA Fuels Pathway for its own fuel that can be licensed to fuel providers/partners or sold on its own.

Option 5: Optimus partners with a biofuel producer with a presence in multiple states to expand its fuel production abilities and franchise system.

Criteria for Analysis

Figure 4. Option analysis criteria

Effectiveness and efficiency are used to evaluate the range of outcomes on whether the option is able to meet the requirements of the issue. Equity and ease of political acceptability evaluates how each option is likely to be received by stakeholders.

Range of Outcomes The effectiveness of each option is assessed based on how well the policy option is able to ensure supply of Optimus-‐grade fuel. The effectiveness also takes into consideration the timeframe of the option being analyzed. Options with shorter or better laid out timelines receive higher scores than those that do not. The option’s efficiency is how much financial investment is needed to implement an option or make an option successful.

Opuon Analysis

Effecuveness

Efficiency Equity

Ease of Poliucal Acceptability

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The status quo, where Optimus Technologies continues to expand through fuel partners without a fuel pathway is ineffective. There is no current concentrated effort on ensuring supply of fuel to suppliers within the nonmarket framework. This may also be a positive in terms of effectiveness given the current Congressional stance on the Renewable Fuels Standard, in that no action is better than action that won’t last if the RFS is struck down. This option is cost-‐efficient for the time being as no additional costs are needed and enables Optimus to focus solely on market strategy and profit. However, by not ensuring fuel partners will want to produce Optimus-‐grade fuel, they may lose opportunities to expand, which would mean lost future revenue/profit.

The second option, in which Optimus works with an academic institution or other consultant to perform an LCA on its fuel in preparation for CARB approval and entry into the Californian market, receives a slight positive effectiveness. The academic institutions that Optimus would partner with are those that are partnered with CARB to work out the LCFS program objectives. Thus they are very familiar with the requirements that a fuel must meet, as well as influential in that they can help restructure the requirements. A consulting firm should also theoretically be very familiar with the requirements that must be met. However, for either the academic institution or consulting firm, the timeline is not known and may take longer to achieve. In addition, there may be additional costs to working with either an academic institution or consulting firm that could be avoided by working in-‐house to get the fuels approved. Consulting firms charge between $30,000 to $40,000 in addition to possible percentages of the credits acquired for Quality Assurance Programs and RIN-‐certification (WINNER comments, 2015). These costs may be similar for LCFS applications as well. This additional cost may be outweighed by the possibility of avoiding unforeseen costs by ensuring the proper processes are followed as per the knowledgeable recommendations of the academic institution or consulting firm. Travel expenses may also be incurred depending on where the institution or firm is located.

The third option removes the middleman of either academic institution or consulting firm in favor of Optimus Technologies working directly with CARB to receive approval of fuels for the California market, Oregon (which just passed LCFS legislation) and, potentially the states involved in the Northeast/ Mid-‐Atlantic LCFS, including Pennsylvania. This option is effective in that it directly works with the regulatory institution to achieve fuel approval. However, similarly to the second option, the timeline is uncertain as the government does not have a set timeline for approval processes, but rather general guidelines (California Air Resources Board, 2010). In addition, as noted earlier, possible costs may be incurred if Optimus does not follow proper processes and must redo the application process. Again, another possible downside is that California is far from the current Optimus Technologies headquarters, so there may be additional travel expenses.

The fourth option is to apply for a new fuel pathway under the RFS for an Optimus fuel that can be licensed to fuel providers/partners or sold on its own. It is similar to the third option in that Optimus works directly with the regulatory agency to apply for recognition of its fuel. This option is effective in that it would provide Optimus with a RIN for the Optimus-‐grade fuel that can be licensed to other fuel partners for production. In addition, the RIN would apply nationally, as it was obtained through the national standards. Like option 2 and 3, though, this option has an uncertain timeline as the EPA only provides general guidelines for timing of the application process (Environmental Protection Agency, “EPA Proposes 2014 Renewable Fuel Standards, 2015 Biomass-‐based Diesel Volume”, 2014). This option is cost effective as the only incurred costs would be the cost of obtaining an LCA (similar to option 2 and 3). Again, it is possible to have to redo part of the application process if processes are not followed correctly. However, as Washington, D.C. is closer to Pittsburgh, travel expenses are minimized.

The fifth option is that Optimus partners with a biofuel producer with a presence in multiple states to expand its fuel production abilities and franchise system. This would be extremely effective as it would directly increase the supply of Optimus-‐grade fuels. Granted, there is some uncertainty regarding how quickly the producer could begin producing the fuel and whether the producer wants to partner with Optimus at all. This option could prove to have high efficiency as the biofuel producer would be partnering as a fuel partner, thus no payments would necessarily be needed as both parties would be benefitting.

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The following chart displays each option’s effectiveness (whether the option solves the problem in a timely manner) and efficiency (the financial investment needed for each option).

Table 1. Range of outcomes analysis for each policy option.

Yellow (0) is neutral response, red (-‐) is negative response, and green (+) is positive response. Darker shades represent values farther from neutral, lighter shades represent values closer to neutral.

Bargaining Context The equity of each option is assessed based on how fair the policy option is to all the possible stakeholders. We chose to do an overall equity rather than breaking out equity into public and competitors as we felt this would be a more accurate assessment of the option’s overall fairness. The equity looks at the winners and losers at the end of each policy option. The ease of political acceptability is how likely the option is to be accepted by the stakeholders and/or policy actors. The ease of political acceptability includes the likelihood of passage or adoption of a given policy given the support and opposition of stakeholders.

The status quo is unequitable -‐ without guaranteed fuel for customers to purchase, the customers will purchase an expensive Vector System and not be able to recoup the cost through fuel savings. In addition, the one or two fuel partners that currently exist will be able to mark up their prices as there is no competition. In addition, existing fuel partners are not necessarily centrally located to where Optimus has current markets or is looking to expand. This option has low political acceptability as most major stakeholders would prefer additional fuel providers to be able to produce and distribute Optimus-‐grade fuels.

The second option, in which Optimus works with an academic institution or other consultant to perform an LCA on its fuel in preparation for CARB approval and entry into the Californian market, receives a slight positive equity and ease of political acceptability. The consulting firms and academic institutions are unbiased towards one company or another and theoretically would provide the same level of service to any company. Major stakeholders, such as fuel partners as well as the ABFA, are not likely to oppose Optimus Technologies working with either an institution or firm and may support this action as additional credits would benefit the partners and will help ensure stability.

The third and fourth options, in which Optimus Technologies working directly with CARB and working directly with the EPA to receive approval of fuels, also receives slight positive equity and neutral ease of political acceptability. This option depends on CARB or EPA approval of the system and as approval depends on the data behind the application, the processes are fair to all applicants. This option is also politically acceptable as major stakeholders are not likely to oppose Optimus Technology working with either regulatory body to receive approval, but may support their efforts. Organizations that would support this action include fuel partners and the ABFA as well as the Pittsburgh Region Clean Cities. The RFS would provide recognition for fuel incentives in Pennsylvania, but the LCFS, at this point, would not.

The fifth option is that Optimus partners with a biofuel producer with a presence in multiple states to expand its fuel production abilities and franchise system. This option receives a neutral equity score. While Vector

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System customers would benefit from increased access to the cost savings of using Optimus-‐grade fuels, existing fuel partners may lose customers as they transition to a refiner nearer to their location. The ease of political acceptability is slightly negative as existing fuel partners may oppose an Optimus partnership with a national producer if there is a partner refinery located near their existing market.

The following chart displays each option’s equity (whether the option is fair to stakeholders) and ease of political acceptability (who is likely to support or oppose and the power they hold over the decision).

Table 2: Bargaining context analysis for each policy option.

Yellow (0) is neutral response, red (-‐) is negative response, and green (+) is positive response. Darker shades represent values farther from neutral, lighter shades represent values closer to neutral.

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Strategy and Arguments The following strategy takes into account the pros and cons of the aforementioned five options, and includes elements from those options that best complement Optimus Technologies primary market strategy of creating a fuel partner franchise system to expand the use of and support for fleets using the Vector System.

Short Term Strategy (1-‐3 years) Optimus should first focus on providing a direct incentive to fuel producers by obtaining an approved EPA fuel pathway for Optimus-‐grade fuel. By obtaining a pathway, Optimus will help incentivize its fuel producers as they acquire RINs on a fuel specific to Optimus’ Vector System. To do this, Optimus should first finalize a process for their fuel which would ideally incorporate a common feedstock and a process that would be easy to replicate. By creating a standardized process for fuel production, Optimus would be better able to safeguard the quality of Optimus-‐grade fuels produced by fuel partners. After the process is finalized, Optimus should submit a proposal to the EPA for approval of a new fuel pathway as a party who intends to own a RIN. The fuel pathway review process, per the EPA, is as follows:

Figure 5: EPA new fuels pathway petition process (US EPA, “Petition Review Process”, 2015)

This process may take 1-‐3 years to complete, depending on 1.) The time Optimus needs to develop a pathway; and 2.) The time the EPA will take to review and approve the pathway. Per the EPA, the “length of EPA's review depends on the type of analysis required to evaluate the requested pathway and the quality of the petition submitted” (Environmental Protection Agency, "EPA Petition Review Process", 2015). If the fuel pathway submitted is similar to pre-‐existing pathways, then the approval process will be relatively short, only requiring that the EPA conduct a life cycle greenhouse gas analysis on the fuel.

Medium-‐ to Long-‐Term Strategy (3-‐10 years) The LCA completed through the EPA approval process may have benefits over the long term as well. If Optimus plans to expand into other states with greater regulatory certainty, the company may be able to leverage the life-‐cycle analysis conducted by the EPA on its fuel to obtain approval in California and other states which may pass low carbon fuel standard regulation 3-‐10 years into the future. An LCA on Optimus-‐grade fuel would enable Optimus to meet the carbon intensity requirement for California Air Resources

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Board’s (CARB) approval of Optimus’ fuel under Method 2, a new fuel pathway petition (California Air Resources Board, "LCFS Method 2 Application Form", 2014). Like California, the EPA’s LCA also evaluates a fuel’s greenhouse gas emissions from “well to wheel,” providing a complete analysis of the fuels’ carbon intensity, and so Optimus may be able to repurpose the EPA LCA in California (Environmental Protection Agency,"Life Cycle Analysis", 2014).

If it is not feasible for Optimus to expand to California over the next 5-‐10 years (likely due to the high costs and time required), the company may target expansion to states that are likely to eventually instate California’s Low Carbon Fuel Standard, such as the 10 states still involved in the Northeastern and Mid-‐Atlantic Low Carbon Fuel Standard discussions. With its fuel pathway approved by the EPA, and the resulting LCA, Optimus can explore options for accelerating expansion into states with more favorable regulation through either a network of several different fuel partners or via a major fuel partner, such as the Renewable Energy Group, with its own national network of biofuel refineries.

Policy Considerations In evaluating the correct path for Optimus, there are arguments supporting and opposing the proposed strategy. The arguments opposing the proposed strategy are centered on the high regulatory uncertainty around the RFS, which may nullify any progress Optimus makes in getting its fuel approved by the EPA. In addition, Optimus may eventually need to submit multiple pathways depending on availability of feed stocks and any variation in the production process. Over the long term, there would be many logistical and cost considerations for expansion into California, a state with high regulatory certainty with regard to fuels standards. For states where Optimus already has a presence in the Northeast and Midwest, there are lower costs and fewer logistical issues associated with distributing Optimus-‐grade fuels, but there is higher regulatory uncertainty with regard to state or regional fuels standards.

Arguments supporting action are centered on the potential incentives to fuel producers through RINs collected on Optimus-‐grade biodiesel. Having an Optimus-‐grade fuel pathway approved by the EPA will provide fuel producers with some insurance in the price that they can set on Optimus-‐grade fuels they produce as well as standardize the fuel grade for potential clients. Over the long-‐term, the LCA from the EPA approval can help Optimus lay the foundation for expansion into other states which have adopted, or plan to adopt, the LCFS and thus are likely to be more pro-‐active in supporting the production and use of biofuels.

Conclusion Given the alternatives, obtaining a fuel pathway through the EPA will provide Optimus Technologies with several benefits, as it will:

• Incentivize potential and current fuel producers and installation partners; • Standardize Optimus system/package; and • Ensure the quality of fuel supplies.

Furthermore, the EPA fuel pathway strategy will pay dividends over the long term, as regulation may change in key states, providing Optimus with more regulatory certainty and its fuel suppliers with more security in the biofuels market.

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