Introduction…

Introduction

While shipping is federally regulated, CSL would like to highlight that several of our vessels are employed in the agriculture trade, transporting grain products from Thunder Bay to Montreal and Sugar to Toronto. As more ships convert to Natural Gas as a means to comply with emission regulations, their impact on the transportation sector should not be overlooked.

1.What are the best opportunities for successful agrifood RNG for transportation projects? Which businesses or organizations are best prepared to successfully deploy RNG anaerobic digesters and natural gas fuelled fleets? What other business partners and business relationships will need to be in place for projects to succeed?

There are ships doing regular voyages from Thunder Bay to Montreal carrying grain which stop in Windsor to refuel. Toronto is a frequent port of call for discharging sugar and ships will also look to refuel in Ontario for this trade. Windsor would also capture a lot of other non-agrifood trade that could utilize RNG making a stronger business case for companies to implement it. Shipping has a fast-approaching deadline to switch to a low Sulphur fuel and RNG could be a solution for ship owners where the need for this fuel and the quantities required are higher. A strong infrastructure will need to be in place to ensure that ships can be supplied with enough fuel. This will involve, gas producers, end users and distributers all working together.

2.What are the key financial opportunities that will help projects to succeed? Currently the cost to convert a ship to run on RNG would be around $10 million. The price of RNG would have to be competitive with residual fuel oil currently costing approx. 550 $/T

3.At what scale would a project have to be deployed to be successful? How much RNG production? How many vehicles? Companies that have approached CSL have typically wanted 2 ships converted and a 7-10 year commitment. This would equate to 9000T of LNG covering 1st April to December 31st.

4.Are businesses and organizations ready to develop and deploy RNG for transportation projects? Are there gaps in the supply chain? What would improve companies’ readiness? The Natural gas suppliers that CSL has spoken to have shown a strong interest. Currently, Ontario would need at least one more LNG facility to meet shipping needs.

5.What barriers to do you foresee to developing a successful project? How can these barriers be overcome?

There is a lack of Canadian specific legislation regarding the usage of natural gas as a marine fuel. Transport Canada has offered no clear direction and has been largely unresponsive to ship owners requests for clarity

6.How long would it take to deploy an RNG for transportation project from conception to successful operation?

As mentioned, for shipping a second LNG plant would be required for Ontario. This would typically take at least 2 years after planning approval has been granted.

7.Describe the types of government support needed to successfully deploy RNG for transportation projects.

Transport Canada needs to give clarity on regulations that ship owners would have to adhere to. Given the cost to ship owners and environmental benefits, shipowners would need a subsidy to convert their ships to run on Natural Gas

8.What are some criteria or project attributes that should be considered or prioritized for a project to be supported through this program? As mentioned before, clear regulations from Transport Canada and subsidies for conversion.

9.What should be included in the program to ensure broader uptake of RNG for transportation after the program is completed? Ensure it is, and remains, best option economically then industry will convert to RNG.

10.Please comment on any other requirements or considerations for the Agrifood RNG for Transportation Demonstration program.

In section 2.3 it is stated that “transportation sector is Ontario’s largest source of greenhouse gases” and that ‘trucking is the primary GHG emissions source in getting goods to market and make up 17% of food processor costs”. Do these numbers include shipping? Given that shipping is 40 times more efficient than trucking, it should form an integral part of Ontario and Canada’s goals in reducing GHG. By transferring more agricultural business to water, a significant reduction of GHG can be achieved.

Infrastructure should be located near ports as a lot of the agricultural products that are already moved by ship are transferred from ship to truck for local distribution. A refueling station near a port would allow it service 2 industries from one location.

[Original Comment ID: 209534]