Biofuels Consulting Canada…

Biofuels Consulting Canada applauds the Government of Ontario’s proposal to increase renewable content in gasoline to 15% as early as 2025.

Summary
Across Canada, blending ethanol in gasoline has reduced greenhouse gas (GHG) emissions by a remarkable 3 megatonnes annually – that’s the equivalent of taking one million cars off the road. Ethanol is also affordable and averages 20 cents less per litre than gasoline.
Today, approximately 90% of the volume of ethanol blended in Ontario is made in the province. Increasing ethanol blending requirements ensure that a local, Made-in-Ontario product is used to reduce GHG emissions from fossil fuels. It’s also a regulatory approach that fairly y balances a healthy environment with a healthy economy.

Ontario’s ethanol industry purchases approximately 110 million bushels of Ontario corn (39% of the crop) and produces 1.1 billion liters annually. In 2016, the total economic impact of from Ontario’s ethanol producers was $1.16 billion, representing 502 jobs. If you factor in the value displaced crude oil imports, the economic impact is even higher at $1.43 billion.

An economic analysis found that a 550 million litre per year expansion in Ontario ethanol production would create 264 new jobs. Going to E15 could require 2.15 billion litres and create 530 ongoing jobs and approximately 5000 construction jobs.

Biodiesel is also an Ontario success story. Biodiesel production supports farmers through the use of feedstocks like soybean oil, but it also repurposes waste oils and fats. For example, today restaurants get paid for their used deep fryer grease which is used to make biodiesel, thereby supporting local small businesses.

The Greener Diesel regulation provides a modest but important market for Ontario’s biodiesel producers. Currently requiring a 4% blend of biodiesel with an average GHG emission reduction of 70% in the diesel pool, this policy allows made in Ontario biodiesel to displace imported petroleum products. In addition to jobs at production facilities, Greener Diesel has brought investments to Ontario for infrastructure to blend the product with diesel fuel. More investments can be expected as the volume of biodiesel blended increases. In this submission, Biofuels Consulting Canada recommends building on this success by increasing the Greener Diesel mandate.

Biofuels Consulting Canada respectfully submits the following recommendations to the MECP:

Policy:
1. Gradual implementation, starting in 2023. In 2023, renewable fuel content should be moved to 11%, increase one percentage point each subsequent year until the mandate reaches 15%.
2. 45% GHG reduction, increasing over time. As of the implementation of the policy, the average GHG reduction required should be set at 45%, increasing to 50% in 2028, and 55% in 2030.
3. Made in Ontario policy and GHG reductions. Policy uncertainty makes it hard to invest in renewable fuels. A clear regulation from Ontario will help unblock funding for new projects in the province.

Compliance Models and Credits:
4. Use GHGenius 5.0. This lifecycle analysis (LCA) model has all the required data to model biofuels in Ontario and is the easiest way to update the current model in use.
5. Avoid including unproven hypotheses. The indirect land use change (ILUC) hypothesis has time and time again been proven wrong. MECP should avoid the use of ILUC modelling due to it being unreliable and inaccurate.
6. Transparent credit trading. In order to have a fungible credit market, as much information as possible should be published regarding the number of compliance credits traded, value, etc.

Public Education:
7. Labelling and public education. Clear labelling should be provided at retail locations to ensure that consumers know what they are buying.
8. Public awareness. More information should be made available to Ontarians to increase awareness that ethanol is a reliable, high-octane performance fuel that is made in the province.

Greener Diesel:
1. Increase the Greener Diesel regulation to 6% biomass-based diesel by 2023, increasing one percentage point each subsequent year until it reaches 10%.
2. Use GHGenius 5.0. This update would streamline the life cycle analysis tool used for the gasoline pool.

It is evident through the consultations for this proposed regulation that there is some misinformation about the impacts to the proposed regulation and some other questions raised that the attached response will seek to address.