California Energy Commission
Docket Unit, MS-4
715 P Street
Sacramento, CA 95814

RE: WSPA Comments to ICFAC on Transportation Fuels Assessment Update [Docket #23-ICFAC-01]

The Western States Petroleum Association (WSPA) appreciates the opportunity to provide comments to the Independent Consumer Fuels Advisory Committee (ICFAC) to help inform the California Energy Commission’s (CEC) triennial update of the Transportation Fuels Assessment per Senate Bill X1-2 (2023). WSPA previously submitted comments,, regarding structural issues facing California’s transportation fuels system, potential “pinch points,” and opined on policy options presented in the April 2024 “Draft Transportation Fuels Assessment” as well as preceding and subsequent workshops. Many of these same policy challenges remain and still must be meaningfully addressed by policymakers to mitigate California’s structural fuel supply shortages that can ultimately lead to consumer impacts.

California’s transportation fuels market has changed significantly since 2024. The announced closure of two California refineries within a year of release of the 2024 Draft Transportation Fuels Assessment, when also combined with constrained in-State crude oil production and resultant pipeline challenges, only heightened the fact that California does not have sufficient refining capacity to meet its own demand. Yet the State has also acknowledged that conventional fuels – including marine and jet fuels – must be supplied for decades to meet consumer demand.  

The State plays a critical role in providing holistic, long-term investment confidence necessary to stabilize its critical petroleum supply chain. We encourage the CEC to use this triennial update to evaluate real-world challenges impacting the competitiveness of California’s critical petroleum sector. This includes any statewide energy policies that fail to strike an appropriate balance between environmental protection and fuel supply reliability that consumers can still afford. WSPA respectfully directs the Committee’s attention to the following priority evaluation needs for the 2027 Transportation Fuels Assessment triennial update: 

1. Protect what remains. Comprehensive policy solutions are needed to address punitive rules and permitting challenges across multiple levels of government – including local taxation policies – that collectively contribute to a costly and uncompetitive business environment in California. This reckoning began in April 2025 when State leaders publicly acknowledged the fragility of California’s refining system: Governor Newsom directed the CEC to work closely with refiners to identify ways to both preserve refining capacity and encourage continued investment in California’s fuel supply. The CEC later acknowledged the need to address uncertainties and restore investor confidence if the State expected refiners to continue operating here. However, WSPA firmly believes that further State policy measures are needed to stabilize investments in California’s petroleum sector.
2. Marine imports represent only one supply-side strategy – which is also constrained. Minimal work has been done to assess statewide port capacity, marine terminal infrastructure and technological constraints, and cost impacts associated with the Ocean-Going Vessels At-Berth Regulation should be considered. That rule impacts tanker vessel calls at California ports that began in 2025 (for Southern California) and will expand in 2027 (for Northern California). These are critical issues if the State plans to transition California’s transportation fuel system to a marine import-first model. The State cannot hope for sufficient port capacity and affordable real-world compliance options without addressing real world constraints that simultaneously prevent compliance pathways.
3. Provide regulatory certainty beyond 2030. California’s ambitious energy and climate policies requires the production of higher quality gasoline to help reduce emissions while also directing the State to minimize “leakage” and consider affordability, technological feasibility, and cost-effectiveness impacts. Doing so necessitates long-term, consumer-driven investment signals that can stabilize California’s transportation fuel supply chain.  Yet some of the most recent, and possibly most impactful, regulatory updates left industry without any meaningful long-term signal. For example, updates to California’s Cap-and-Invest program delayed more difficult issues to 2030, forcing refiners to operate under persistent uncertainty, while still imposing programmatic tightening. Such short-term policies discourage long-term compliance strategies, undermines affordability, erodes investor confidence, and makes it harder to compete in a global commodities market. 
4. Avoid micromanaging petroleum assets. WSPA continues to have strong concerns with any attempt by the State that could raise production costs. This includes asset operations, expert-led decision making, or any effort to impose resupply or minimum inventory mandates given the potential for unintended consequences – particularly since policies that reduce energy production investments for fuel products (including jet, diesel, and marine fuels) can be very difficult to reverse in California’s already challenging business environment. 
5. Uncertainties will affect planning scenarios. Significant implementation barriers exist to transition nearly the entire transportation system onto the electric grid (e.g., California’s high electric bills, local power and charging infrastructure availability, high vehicle/equipment costs, geographic and socioeconomic constraints, etc.). The State must also consider additional uncertainty due to the revocation of federal electric vehicle tax credits and the revocation of key federal regulatory waivers (e.g., Advanced Clean Cars II, Advanced Clean Trucks, possibly Ocean-Going Vessels At-Berth, Commercial Harbor Craft). This only inserts further doubt into potential planning feasibility in the real world. The CEC must account for these known barriers, as well as any affordable alternatives. 
6. Impacts to neighboring states must be considered. WSPA is concerned that any decisions California makes could easily put the entire fuel supply chain at risk – including for Nevada and Arizona, whose fuel supplies are firmly dependent on the viability of California refineries. 

Conclusion

We appreciate this opportunity to provide comments on fuel supply issues of critical importance to consumers dependent on California’s fuel supply chain, who rely on affordable and reliable sources of transportation fuel every single day. We believe the State’s petroleum sector – especially the remaining refiners – need strong signals to have the certainty necessary to continue making significant investments in California. The entire industry has been asking for a more predictable regulatory environment to provide the transportation fuels that will remain in demand for decades to come. 

Please do not hesitate to contact me with any additional questions.

Sincerely,

Jodie Muller
President & CEO

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