Dear Ms. Tan;…

Comment

Dear Ms. Tan;
This submission from Avatar Group comes in response to the EBR posting: Low Carbon Transportation Fuels in Ontario: Amendments to Ethanol in Gasoline (O. Reg. 535/05) and Greener Diesel – Renewable Fuel Content Requirements for Petroleum Diesel Fuel (O. Reg. 97/14) Regulations
Avatar Group distributes a Canadian made vegetable based fuel catalyst. This is a renewable product that when added to gasoline, diesel and bio-diesel fuels, produces a higher energy output while reducing combustion emissions. This product is EPA registered, biodegradable, non-toxic, non-flammable and classified as a bio-fuel in compliance with Canadian Premium Fuel Specifications.
In December of 2016, Avatar Group was granted conditional funding through NRC- IRAP for the advancement and commercialization of Canadian made EuroAd. With the assistance of this funding Avatar Group has successfully advanced sales in Ontario.
The manufacturer, Emission Particle Solution, has successfully marketed and commercialized the product in Sweden since 2006. Currently they are constructing a 10,000 square foot production facility in Markham Ontario, to meet expansion needs for exports to Europe, China and South American markets.
Our intent with this product is to assist the Ontario government to achieve it’s proposed goals of increased availability and use of lower carbon fuels in the transportation sector. Through increased ethanol blending, improved performance of fuels and providing a proven clean fuel technology, we can help the Ontario government achieve their target of 15% emission reduction from gas and diesel by 2020 as mandated by the Climate Change Action Plan.
Our fuel catalyst addresses many of the issues identified with higher ethanol use. Notably; lower energy density therefore lower mileage, attraction of water into the fuel system, damage to rubber, plastic and some metals and phase separation of the fuel.
As a catalyst (enzyme), EuroAd counteracts ethanol's moisture robbing properties through emulsification; it stabilizes the fuel, adds lubrication, and vastly improves combustion, while maintaining pH of bio- fuel.
It is very important to highlight an additional benefit for transportation fleets powered by petroleum diesel. Many of these vehicles are equipped with DPF or diesel particulate filters. These filters capture unburned carbon (black soot) from the combustion process and must be cleaned through a process called regeneration. The soot is burnt off at high temperature (around 600°c) to leave only a residue of ash, effectively renewing or regenerating the filter. If this is not done, it can lead to lowered mileage and engine problems. This process is particularly important for urban trucks and would require the operator to stop driving for 30-50 minutes to perform this maintenance. Implementation of EuroAd reduces the frequency of “regens” as well as filter and injector problems due to better combustion. This would represent an enormous benefit for the transportation sector.
Introducing other forms of fuel and new technologies like hybrid and electric vehicles will require immense amounts of investment into new infrastructure and equipment for fleets. Our product can play a vital role in achieving the desired Climate Change Action Plan results without enormous capital expenditure and without delay. Integrating our product into the overarching fuel delivery system would benefit every Ontarian two fold; Firstly through improved combustion and ignition properties, drivers immediately save 5-7% on mileage and secondly, through an immediate reduction of emissions by the same percentage. An added benefit demonstrated by our studies, is a 50 – 75% reduction in particulate matter.
A provincial government investment of $155 million into infrastructure to support biofuel blending, paired with Avatar Group’s fuel catalyst, will improve overall fuel efficiency province wide.
Based on the provinces Regulator Impact Statement, there is an anticipated increased cost of .03 cents per litter for fuel to the end consumer. The impact of the implementation of EuroAd into the blending of all fuel types would provide a net benefit and a win – win for the consumer and the province.
In the foreseeable future, Renewable Fuel Content regulations could increase the blend in standard fuels to a higher percentage of biofuel, which would make the need for this catalyst even greater. The 2015 Lund University Study demonstrates faster ignition of RME and more recent test results consistently demonstrate a greatly improved combustion with the introduction of our product. Blending EuroAd into biodiesel will improve cold weather starts, allowing for a broader application to northern regions and for unpredictable climate change as we are now experiencing in southern Ontario.
The following additional documents are available upon request. Testimonial from local Ontario Trial Press Release EuroAd Overview White Paper outlining Sweden’s Secret to Reducing GHG University of Lund Study
We look forward to your feedback and continued dialogue.
Thank you, President, Avatar Group Environmental Solutions

[Original Comment ID: 212113]