October 11, 2018 Cap and…

October 11, 2018

Cap and Trade Branch
77 Wellesley Street West
10th Floor, Ferguson Block
Toronto ON M7A 2T5
Canada

Re: ERO number 013-3738 — Bill 4, Cap and Trade Cancellation Act, 2018

We appreciate the opportunity to provide our comments on the Province’s consultations with respect to the Cap and Trade Cancellation act, 2018.

Advanced Biofuels Canada/ Biocarburants avancés Canada (ABFC) — Our national organization promotes the production and use of low carbon advanced biofuels in Canada, which our members supply to Ontario, and across North America and to global markets. Our members have invested in advanced biofuels processing and supply chain operations in Canada and are actively bringing to market the next generation of low carbon biofuels.

Our organization has supported provincial mitigation action on climate for a decade, specifically Ontario’s regulations to require renewable content in transportation fuels.

We encourage Ontario to develop a robust climate action plan to achieve the greenhouse gas reductions that had been anticipated under the Cap and Trade program. To the extent that auction proceeds remain after the program is cancelled, we encourage Ontario to re-invest these funds in activities that will complement the objectives of a new climate plan.

With respect to a new climate plan:

- Transportation emissions will continue to require attention as they are rising (in contrast to other sectors) and the sector is generally understood to need specific regulatory measures to decarbonize.

- Ontario can strengthen its existing renewable fuel regulations. While regulations for the gasoline pool have been recently updated, the diesel pool remains arguably more challenging and has not seen a regulatory update since 2015.

- We perceive the opportunity to move towards a broader clean fuels approach that would bring gasoline, diesel, aviation etc fuel pools under a comprehensive plan that has both a lower carbon element and a renewable content requirement. This would enable advanced biofuel project developers in Ontario to qualify their fuels in an aligned federal program.

- Ontario has the opportunity to align the objective of its northern development economic development strategy and its strategies to add value to its agricultural, forestry, and waste sectors by supporting the development of an advanced biofuel industry in the province that would complement its existing renewable fuel industry and also support these other strategies. For a full description of the capacity of ABFC’s members to utilize a wide array of sustainable feedstocks to produce a range of low carbon intensity biofuels, see our website www.advancedbiofuels.ca

- Ontario also has the opportunity to increase the consumption of low carbon biofuels with programs that provide economic incentives to fuel distributors to incorporate renewable fuels