Increasing renewable content…

Increasing renewable content in fuels

About Enbridge
Enbridge Inc. (“Enbridge” or the “Company”) is North America's premier energy infrastructure company with strategic business platforms that include an extensive network of crude oil, liquids and natural gas pipelines, regulated natural gas distribution utilities and renewable power generation. The Company safely delivers an average of 2.9 million barrels of crude oil each day through its Mainline and Express Pipeline; accounts for approximately 62% of U.S.-bound Canadian crude oil exports; and moves approximately 18% of all natural gas consumed in the U.S., serving key supply basins and demand markets. The Company's regulated utility, Enbridge Gas Inc. serves approximately 3.7 million retail customers in Ontario, Quebec, and New Brunswick. Enbridge also has interests in more than 1,700 MW of net renewable generating capacity in North America and Europe.
Introduction

Enbridge has a long history of projects that improve our customer’s energy efficiency, reduce greenhouse gas (GHG) emissions, and lower energy costs for our customers. We are already working to develop the nascent renewable natural gas (RNG) industry in Ontario. Enbridge recently obtained approval from the Ontario Energy Board to inject RNG into its distribution system. In 2019, we expect to invest and build a number of RNG facilities to make RNG a reality for our customers in Ontario.
We are pleased to provide our comments on increasing renewable content in fuels. Our comments will focus on suggestions for the Ontario ethanol and greener diesel regulations to support innovation for Ontario businesses.

Comments
i. Flexibility in compliance
The current compliance mechanisms for the Ethanol in Gasoline Regulation (Ontario Regulation 535/05) and Greener Diesel Regulation (O. Reg. 97/14) provide little flexibility in how obligated parties can achieve compliance. Enbridge recommends the introduction of a compliance unit trading system into the Ontario regulation(s) to create greater compliance pathway flexibility and could allow for voluntary participation from alternative biofuels, such as RNG to be used in transportation. The monetary value of a compliance unit should be based on its abatement potential and not be impacted by its origin or how it is consumed. Further, aligning the compliance unit and trading system with the Federal Renewable Fuel Regulation should reduce the administrative burden for Ontario businesses.

Additionally, Enbridge recommends that the generation and trading of compliance units between regulations should be unrestricted. This includes the ability to stack credits between provincial and federal programs to enhance biofuel value and lower costs for customers.

ii. Renewable Natural Gas
While conventional natural gas remains the cleanest-burning conventional fuel, RNG presents an important first step in providing natural gas consumers with the opportunity for ‘greening’ the existing natural gas system.

RNG used in transportation should be recognized as a cellulosic biofuel (as it is in the US Federal Renewable Fuel Standard), and allowed to participate in renewable fuel programs on a voluntary basis.

Conclusion
Enbridge appreciates the opportunity to provide input on increasing renewable content in fuels. If you have any questions or require additional information please do not hesitate to contact Brad Lattanzi, Government Affairs Strategist (brad.lattanzi@enbridge.com).