The Renewable Fuels Association, U.S. Grains Council and Growth Energy submitted joint comments Thursday to Environment and Climate Change Canada, regarding its proposed Clean Fuel Regulations published in the Canada Gazette last December.
“The proposed regulation takes a market-based approach to driving carbon reductions in the Canadian fuels market, providing an attractive model for other countries to follow,” the organizations said. “Canada should be applauded for showing global leadership on the implementation of a clean fuel standard, and it is encouraging to see both the United States and Canada taking steps to slash greenhouse gas emissions from transportation. Renewable fuels have already played a crucial role in jump-starting decarbonization efforts in both countries, and policy initiatives like Canada’s clean fuel standard will further accelerate those efforts.”
In their comments, the organizations noted the importance of allowing renewable fuel producers to account for carbon capture and sequestration in their carbon intensity scores, regardless of whether the fuel is produced in Canada or the United States.
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.
This regulation, coupled with the recent announcement in the United Kingdom that it is moving from E5 to E10 by September, shows that more countries are committed to expanding the role of biofuels in meeting their Paris Agreement commitments and their long-term environmental goals, the groups noted.
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.