I am commenting on behalf of…

I am commenting on behalf of Verbio Diesel Canada Corporation ("Verbio"). Verbio operates a 170 million liter-per-year biodiesel production facility in Welland, Ontario.

It is true that subsidies for U.S. biofuel producers, specifically the 45Z tax credit under the U.S. Inflation Reduction Act, threatens to shut down Ontario’s biodiesel production. 45Z provides significant subsidies to American producers of biodiesel ("BD") and renewable diesel ("RD"), while these subsidies are not available to Canadian producers. This means that USA-based producers can effectively produce BD and RD at lower costs than Canadian-based producers. This will have the effect of eventually driving the Canadian-based producers, like Verbio, out of business.

From 2019 through 2024, Verbio sold 100% of its biodiesel production into the USA. Since the launch of the 45Z credit on 1/1/2025, Verbio has sold exactly zero gallons of biodiesel into the USA. 100% of gallons are being sold into Canada. However, as the 45Z credits gains more regulatory clarity, we see that commercial options for Verbio to continue selling BD into Canada are also drying up, as USA-based production is now at a competitive advantage. If this trend continues, it is likely Verbio will need to cease production at this location, eliminating dozens of good Canadian jobs and a significant source of tax revenues for the region.

Verbio would strongly support the policy proposal to require (at least) 3% of the renewable content required in diesel fuel to be produced in Canada.

-Rand Dueweke
Head of Regulatory Compliance & Business Development
Verbio North America
rand.dueweke@verbio.us