1. Clarification on Use of…

1. Clarification on Use of Default Values in Absence of Operating Data
We note that producers with six or fewer consecutive months of operating data may use the appropriate default values required by ECCC under the federal Clean Fuel Regulations. Could you please clarify whether this provision also applies to projects currently in the design or construction phase, which do not yet have any operating data?

2. Update GHGenius Model Requirement
It has been over seven years since GHGenius 5 was released, and it has already been adopted by other provinces. Additionally, GHGenius 4 is no longer publicly available for download. Maintaining a requirement for older versions appears unnecessary and may lead to inconsistencies between model outputs. Updating the model requirement would align better with current practices and improve consistency across jurisdictions.

3. Expanded Listing of Feedstock and Energy Inputs
With reference to Sections 3.3.1 and 3.4.1, which list feedstock and energy inputs, we recommend explicitly adding biodiesel as a fuel input. Furthermore, we suggest including wood residue and logging residue under the category “wood, grass, crop residue, MSW, RDF” to better reflect the diversity of renewable feedstock in use.

4. Consideration of Avoided Emissions
We did not find any content addressing avoided emissions. We suggest including a section to clarify the treatment of avoided emissions within the policy framework and to guide their incorporation into carbon intensity (CI) calculations.