U.S. Grains Council, Growth Energy, RFA Comment on Proposed Canada Clean Fuel Regulations

In addition, the organizations stated that the regulation should adopt an aggregate compliance approach for applying land use and biodiversity criteria for all U.S. and Canadian biofuel feedstocks.

Finally, the groups commented about the fuel lifecycle analysis model used to calculate the carbon intensity value for the regulation. The decision to create yet another new lifecycle analysis model, and how it will be different than the methods already in use, has caused uncertainty. Releasing the details of the proposed lifecycle analysis approach now—even if not complete—would be beneficial to the public stakeholder process. READ MORE

Excerpt from Renewable Fuels Association: In separate comments filed by RFA, the organization stressed its support for Canada’s technology-neutral approach to reducing carbon-based emissions and noted the important role ethanol can play. “Ethanol is already reducing climate change emissions from the transportation sector and there is room for more growth,” wrote Kelly Davis, RFA Vice President for Regulatory Affairs. “The proposed Clean Fuels Regulations will be critical in providing consumer options and spurring innovations in transportation fuels. RFA believes that renewable fuel, especially ethanol, can further decarbonize passenger cars and light-duty trucks today. Promising research and development initiatives show ethanol can also power medium-duty and heavy-duty engines in the future as well.”

RFA also reiterated the call for more information on Canada’s proposed lifecycle analysis model and for Canada to consider reciprocity, or an efficient conversion process for the ability to use other LCA models currently utilized in other jurisdictions. READ MORE

Excerpt from joint comments: Comments in brief:
1. Fair treatment regarding carbon capture and sequestration (CCS), and enhanced oil recovery (EOR): When used in the production of biofuels, ECCC should recognize CCS and EOR in the CI of the finished fuel, regardless of whether the fuel is produced in Canada or the U.S.

2. Land use and biodiversity (LUB) criteria: The U.S. and Canada have strong agricultural practices and already meet stringent sustainability practices. An aggregate acceptance of U.S. and Canadian feedstocks – for all LUB criteria – should be included in the CFR.

3. Simplify farm-level declarations: These declarations should be limited in scope to essential information only. In a jurisdiction that is deemed compliant with LUB criteria, this should be limited to farm location, farmer’s or business name, and amount of feedstock sold. Information included on existing paperwork (e.g., supply contracts) should be deemed to meet requirements for CFR declarations, and therefore eliminate the need for a new, standalone document.

4. Remove any obligation for verification through site visits at farms in jurisdictions deemed compliant with LUB criteria. The regulation currently provides for a site visit once every five years. In a jurisdiction deemed compliant with all LUB criteria, this is not necessary and could dissuade farmers from selling their crops into the biofuel market.

5. Continue to frame the CFR as integral to meeting Paris Climate Agreement commitments. Casting the CFR in this light helps to make the policy non-partisan, given that all major federal parties in Canada are supportive of the Paris targets.

6. Lifecycle Analysis (LCA) model. To enable early action by obligated parties and investments by low-carbon fuel producers, ECCC should release all available details of the LCA model immediately.

7. Recognize ethanol’s octane value. The current costing of the regulation does not take into account ethanol’s value as a provider of octane. This artificially inflates the cost of implementing the regulation and downplays the benefits consumers will enjoy with higher ethanol blends. READ MORE