January 26, 2023 Attention:…

January 26, 2023

Attention: Environment Registry of Ontario

RE: Comment on Proposed Lifecycle Analysis Models and Technical Guideline Updates for the Cleaner Transportation Fuels Regulation

The British Columbia Renewable Low Carbon Fuels Standard (BC RLCFS) is currently in the process of changing from using GHGenius v4.03a to v5.02 effective January 1, 2024. Effective July 1, 2023 the Federal Clean Fuel Regulation (CFR) is proposed to use the Fuel LCA Model along with OpenLCA tool for defining pathways and quantification of approved carbon intensity. Other clean fuel standards developed in California, Washington and Oregon currently use the LCA Model GREETS v.2.0 or v3.0. One of the overarching issues for finished fuel and renewable fuel suppliers is that each jurisdiction within Canada and the United States have similar clean fuel standards, but utilize different LCA methodologies and models. This results in a defined renewable fuel pathway having to be quantified for carbon intensity using multiple LCA models unique to each jurisdiction. We strongly urge the Ontario government to lessen the burden on industry by adopting the same version (latest version v5.02) of GHGenius as the BC RLCFS, to promote the utilization of a common LCA methodology and model at the Provincial level across Canada.

Thank you for the opportunity to provide our feedback for your consideration.

Mike Wilchewski, BSc EnvMgmt, EP
Regulatory Specialist
Environment & Regulatory
Safety & Operations Technical Services
Office: 1.403.298.6738 | Cell: 1.403.506.8617
Mike.Wilchewski@cenovus.com
Calgary, Alberta