U.S. Grains Council, Growth Energy, RFA comment on proposed Canada Clean Fuel Regulations

In Washington, D.C., the U.S. Grains Council, Growth Energy and the Renewable Fuels Association submitted joint comments to Environment and Climate Change Canada, regarding its proposed Clean Fuel Regulations, noting 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.

“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.”