January 23, 2018…

January 23, 2018
EBR Registry Number: 013-1929
Rebecca Tan, Policy Advisor Ministry of the Environment and Climate Change Climate Change and Environmental Policy Division Air Policy Instruments and Programs Design Branch 77 Wellesley Street West, Floor 10 Ferguson Block Toronto, Ontario M7A 2T5
Greenfield Global's submission regarding 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
Greenfield Global Inc. (formerly Greenfield Specialty Alcohols Inc.) congratulates the Ministry of the Environment and Climate Change (MOECC) on its ambitious proposal to amend Ontario's Ethanol in Gasoline regulations and Greener Diesel regulations. In our view, the build-out of Ontario's renewable fuels industry was accomplished with the leadership of the provincial government. The proposed amendments to ethanol in gasoline confirm that government continues to pay careful attention Ontario biofuels producers, and remains steadfast in capitalizing on the known environmental and economic benefits of mandated ethanol blending in the province.
We are committed to working in partnership with the government on a modern renewable fuel standard that achieves the province's objectives for GHG reductions and supports the long-term competitiveness and diversification of Ontario's robust, domestic biofuels industry. To succeed in increasing production of ethanol and incent emerging renewable fuel technologies in the province, Greenfield believes amendments to the Ethanol in Gasoline Reg. 535/05 should incorporate the following principles:
1.Add a market-based approach that monetizes the carbon intensity to heighten demand for lower carbon ethanol. 2.Do not allow trading of compliance credits between pools. 3.GHG reductions should be based on a company average and increase over time. 4.The target of the regulation should be to the total adjusted volume of gasoline rather than referencing "88 octane and less". 5.The most current version of GHGenius (5.0) should be used to determine the CI of ethanol. 6.Compliance values of emerging products such as co-processed vegetable oil and bio crude should be based on CI and calculated using GHGenius. 7.Support the adoption of E15 and mid-level blends of ethanol for flex fuel vehicles through a public awareness campaign.
Ontario's Largest Ethanol Producer
Greenfield is an Ontario-based ethanol and specialty alcohol company that has been in business since 1988. The Company owns and operates three distilleries in Ontario (Chatham, Johnstown, and Tiverton) and one in Quebec (Varennes). Collectively, these facilities produce more than 500 million litres of fuel-ethanol and 200 million litres of high purity beverage, pharmaceutical, and industrial grades of alcohol each year. Greenfield is the country's largest ethanol producer and the only producer of industrial and specialty alcohols in Canada. The Company employs approximately 275 staff in Ontario and has annual sales in the range of $700 million. Greenfield sources much of its feedstock from Ontario's grain growers.
In 2016, Ontario's biofuel industry had an economic impact of $1.75 billion per year. An independent economic impact assessment has indicated that an expanded ethanol mandate would add another $778 million per year of economic activity to the province, bringing the total impact of this sector to roughly $2.5 billion once the new regulation is in force. As Canada's largest ethanol producer, Greenfield is particularly enthusiastic about Ontario's continued foresight and leadership in helping renewable fuel producers to innovate, and produce a product with an even lower carbon intensity (CI). It's policy planning that will not only spur green economic development in Ontario; it will ensure further GHG reductions in the years to come.
Recommendations
Greenfield is pleased to offer the following comments amendments to the Ethanol in Gasoline (O. Reg. 535/05). It is also worth noting that Greenfield supports the policy recommendations put forward by Renewable Industries Canada as part of this process.
Recommendation 1: Market incentives to produce lower CI ethanol
Monetizing carbon intensity sends a market signal to renewable fuels producers to continue to invest in innovations that reduce the lifecycle CI of ethanol, both in a fuel's production and its carbon content. Greenfield welcomes the opportunity to contribute its expertise for practical, achievable ways to increase the market value of low carbon ethanol in Ontario.
As a leading producer of low carbon ethanol, innovation is already underway at Greenfield. Policy support to help de-risk private investment will help accelerate it. For example, Greenfield Global currently supplies a greenhouse run by Truly Green Farms with excess biogenic CO2, as well as waste heat from our neighbouring ethanol facility in Chatham Ontario. The first project of its kind in North America, the greenhouse energy costs have been cut in half in half while reducing the steam and odour intensity from Greenfield's ethanol production. The project has generated 200 new jobs since 2012.
Recommendation 2: No trading of credits between pools
Greenfield is not in favour of compliance credit trading between the gasoline and diesel fuel pools. If it is to happen, setting strict limits is essential. The proposed structure of the revised ethanol regulation (all fuel meets a minimum threshold) is different than the Greener diesel regulation (the average CI is quantified). Greenfield recommends that no trading between the pools be allowed as the trading parameters are not the same.
While obligated parties favor flexibility, it undermines the predictability of ethanol blending volumes in gasoline. Ultimately, it is volume mandates for renewable fuels that ensure GHG reductions are achieved in transportation.
Recommendation 3: Minimum GHG reductions should be based on a company average.
The minimum threshold of GHG reductions should be based on improving the CI of ethanol used in Ontario while incenting domestic producers to continue to innovate and improve the CI of their fuels. Greenfield supports a minimum GHG reduction threshold for ethanol and its use as a market signal that Ontario wants ethanol with an improved CI.
To best achieve this, Greenfield recommends ethanol used for compliance must emit at least 35% fewer (i.e., 55.0 gCO2e/MJ or lower) greenhouse gas (GHG) emissions on a lifecycle basis than petroleum gasoline starting in 2020 based on a company average.
Recommendation 4: Definition of regular gasoline
Greenfield is pleased with the government's acknowledgment that blending from E10-E15 is technically feasible. However, in the current draft regulatory amendment regular gasoline is defined as "88 octane or less." This definition will, in fact, preclude these blends from being considered "regular" gasoline, due to ethanol's octane boost, undercutting emissions reductions.
To avoid this problem, Greenfield recommends the formula adjusted to 9% of total gasoline. An adjusted percent of overall gasoline sales is an easier metric than solely regular gasoline sales.
Recommendation 5: Third-party lifecycle modelling
Reliable, third-party lifecycle assessment modeling is essential to ensure renewable fuel in use meets the compliance threshold. GHGenius is widely-recognized as the gold standard of lifecycle analysis. Developed with Canadian data, it is already used across the country (federally, in Ontario, Alberta, and British Columbia). Greenfield recommends using the latest version of this model, GHGenius 5.0
Recommendation 6: Compliance values of emerging products such as co-processed vegetable oil and biocrude
Developing appropriate equivalency factors for technologies not yet established in the marketplace is a complex and challenging endeavor. To ensure a level playing field between products currently in use (e.g., ethanol and biodiesel) and potential new products (e.g., biocrude), compliance values for new products should be based on CI calculations, and held to the same standards as existing products.
Applying a different model to emerging products risks giving them an unfair advantage (or disadvantage), therefore, Greenfield recommends using GHGenius to ascertain compliance values for emerging products. Equivalency factors should be developed on a case by case basis. Proponents would submit yield data and GHG emission reduction data from either GHGenius 5.0 or a modified GHGenius 4.03a to the Director for approval. The equivalency factors would be good for a specific period and would be renewable based on updated data. We note that while the 2.5 factor for cellulosic ethanol was based on the expected GHG emission performance in 2005, doing the same calculation today would generate a factor of about 1.5 as the GHG emission performance of corn ethanol has improved and our understanding of the cellulosic ethanol process has improved.
Recommendation 8: Public awareness campaign
MOECC should support the use of E15, and higher blends of ethanol for flex-fuel vehicles by implementing a public awareness campaign. For Ontarians to be able to choose a fuel with a lower CI, they have first to be aware of its availability, and whether or not their vehicle can accommodate it. At present, there are approximately half a million flex-fuel vehicles on Ontario's roads. The number of cars that can use E15 is considerably higher. Increasing the public's knowledge of E15 and higher blends will enable Ontario to tap into GHG reductions that have so far been left off the table.
Conclusion
Ontario is poised to break new ground in the creating what will be the strongest volume blending requirements for renewable fuels in the country. Properly done, amendments to ethanol in gasoline will significantly reduce GHGs, and be a building block for increasing domestic use and production low carbon fuels in Ontario for years to come.
Thank you for the opportunity to submit comments on this critical proposal. Please feel free to contact us with any questions you may have.
Sincerely,

Andrea Kent Vice President, Government and Public Relations Andrea.kent@greenfield.com T: (416) 304-1700 x8427 www.greenfield.com

[Original Comment ID: 212247]