December 18, 2023 RE:…

December 18, 2023

RE: Greenfield Global Feedback on Proposed Technical Guidelines Update for Facilities with Non-Fuel Products

ERO #019-7732

* Submitted electronically*

Greenfield Global appreciates the opportunity to provide feedback and recommendations on the proposed technical guideline updates.

By way of introduction, Greenfield Global is Ontario’s largest producer of low-carbon fuel ethanol and a leading producer of high purity alcohols, specialty solvents, custom blended solutions. Proudly head-quartered in Mississauga/Toronto, Greenfield operates 18 facility locations around the world. Known for our emphasis on quality, innovation, and state-of-the-art production and packaging, Greenfield employs over 700 employees. Every year, Greenfield manufactures, and ships over 1,600 products to more than 5,000 customers in almost 50 countries worldwide. The majority of these products are manufactured from locally-sourced corn in Ontario and Quebec.

Executive Summary

Greenfield supports Ontario's efforts to strengthen the economy while protecting the environment. A crucial way to achieve this is to increase the usage and production of cleaner transportation fuels within the province. Greenfield sees Ontario's Cleaner Transportation Fuels regulation as a vital part of the province's overall decarbonization strategy. The following recommendations are submitted with the intention to reduce transportation emissions while ensuring that Ontario consumers continue to benefit from environmentally-friendly, economical biofuels that support local jobs and growers.

One aspect that distinguishes Greenfield as a unique and essential producer in Ontario is its operation of multiple facilities which manufactures both Fuel grade ethanol and High-Purity ethanol (utilized in medical and beverage industries). It is worth noting that the conversion process from Fuel ethanol into High Purity is highly energy-intensive, demanding up to twice the energy required for Fuel grade ethanol production. This energy is primarily supplied by steam, produced via natural gas, which invariably leads to a significant increase in emissions.

As a result, Greenfield faces a unique and critical challenge as the methodologies employed in Life Cycle Assessments often lack the means to accurately apportion Greenhouse Gas (GHG) emissions between Fuel and High Purity ethanol.

Recommendations

Existing allocation methodologies usually apply on a facility-wide basis, failing to consider equipment functionality distinctions. Consequently, Greenfield's Carbon Intensity (CI) score for Fuel seems disproportionately high when compared to facilities that solely produce Fuel. Simultaneously, the emissions attributed to our High Purity ethanol are understated.

To ensure Ontario's Cleaner Transportation Fuels regulation accurately distributes GHG emissions, Greenfield suggests including Section 3.6 in the proposed changes. This addition is crucial for the Technical Guideline and adeptly balances flexibility and the need for rigorous standards to ensure result accuracy.

Moreover, by employing the proposed Method 1 and Method 2, Greenfield can precisely allocate emissions to Fuel ethanol. This will achieve a GHG reduction that fulfills the regulation’s climate objectives without overlooking the unique attributes and benefits of Ontario production.

Lastly, recent amendments to the GHG Reporting Regulation and Guideline have paved the way for utilizing Renewable Natural Gas (RNG) to mitigate emissions via contractual supply agreements. Recognizing the potential of this development, Greenfield strongly advocates for the integration of RNG within the Cleaner Transportation Fuels regulations. We acknowledge that this will necessitate a comprehensive effort to ascertain the life cycle emissions of RNG producers. However, we are confident that such an inclusion can be accomplished in future updates and will significantly contribute to our shared environmental goals.

Conclusion

In closing, Greenfield is supportive of the suggested changes. Please do not hesitate to reach out to me with any questions and comments you may have.

Sincerely,

Andrea Kent
Vice President, Industry and Government Affairs
Greenfield Global Inc.
andrea.kent@greenfield.com
+1 (613) 698-0116