The Region of Peel…

The Region of Peel appreciates the opportunity to respond to the Province’s posted questions on the 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.
PUBLIC CONSULTATION OPPORTUNITIES
Blending Requirements
1.In setting requirements, what factors should be considered, e.g. technology investment and planning cycles? a.Provide infrastructure incentives to fuel industry to support the availability for higher ethanol blends for those who have fleets of flex fuel capable vehicles and want to adopt more aggressive GHG reduction targets.
2.How can the adoption of emerging clean fuel technologies be encouraged? Are there further measures to support compliance flexibility? a.Subsidize clean fuels with a higher petroleum based content; consider appropriating funding from the cap and trade fund (for example a similar program to dyed diesel) b.Raise awareness on safety, environmental, and reliability advantages of clean fuels and mass market to general public while accompanying the release of an incentive program c.Consider ethanol feedstocks that do not conflict with food supplies (for example, consider the use of brownfields or otherwise unusable land for feedstock growth if certain criteria can be met and won’t contaminate the feedstock) d.Set targets and legislation that effectively move the Province to be able to meet the targets with clear timelines that are communicated very early e.Increase the blending opportunities in other fuels (e.g. biodiesel beyond a 4% blend and consider seasonality options and opportunities for higher blends) f.Consider engaging with stakeholders both during the EBR comment period and beyond. If incentive programs are to become available ensure that ongoing and early dialogue is present so that businesses and municipalities and others have more opportunity to consider how the incentive programs will fit within vehicle lifecycles and capital budget planning
Lifecycle GHG Emissions
1.What should be considered in assessing lifecycle GHG performance (a-h) and recognizing and assigning environmental performance values (i-k) of biofuels? a.Fertilizer use to grow crops b.Water use (energy to treat potable water) to grow crops c.Fuel use by farm equipment for harvesting d.Transportation of crop yield (fuels (gas or diesel)) e.Energy and other emissions (CACs) from processing f.Crop bi-product decomposition emissions from organic waste g.Transportation of actual fuel h.Carbon absorbed by bio-material that is actually processed into fuel i.Sustainable farming accreditation + practices (low pesticide use, diversity in crop growth) j.How arable the land was that was used to grow the crops and could other land use opportunities be explored (e.g. brownfields) k.Was the bio-fuel produced from a waste product (non-edible)
Complementary Program Support
1.What design considerations are recommended for a possible Blenders Support Program (BSP) to encourage the long-term use of biocrude and other high-biofuel blends? a.Gather and distribute the required evidence to evaluate the hypothesis “Consumers will pay more and show more loyalty to fuel retailers that take care of the environment” b.Government will pay for infrastructure to blend fuels if company proves that sales are sustained and increasing year over year c.Training / certification courses / accreditations available for chemists at refineries, and sales representatives (similar to CNG groups)
2.What other renewable fuel program opportunities exist for further GHG reductions from fuels in the transportation sector? a.Hydrogen refuelling infrastructure b.Drone transportation – start the pilot projects c.Work with airport and aviation industry to reduce idling and lifecycle GHGs from airplane and service vehicle engines
Questions for the Ministry 1.Regarding amendment #4, whose responsibility is it to calculate the CI using GHGenius? 2.Is there any proposed amendment to the 4% bio-based diesel by volume and/or the bio-based diesel component of this blend having a 70% lifecycle GHG performance improvement vs. petroleum diesel?

[Original Comment ID: 212239]