PLEASE REFER TO THE ATTACHED…

PLEASE REFER TO THE ATTACHED LETTER FOR OUR FULL COMMENT

Summary of comments and recommendations:

Having carefully considered the proposed amendments to the fuel regulations, Global Automakers of Canada offer the following summary of comments and recommendations:

• Ontario should avoid establishing an E15 pool average requirement for 2025, but instead look toward 2030 to establish a pool average of 15% in regular grade. While new vehicles are increasingly E15 compatible, the legacy fleet is more than 5 years away from the majority being E15 compatible and many vintage vehicles will remain wholly incompatible.

• We are opposed to any policy or regulation that may lead a fuel producer or supplier to market mid-level blend gasoline between 15% and 85% by volume ethanol content for the purposes of satisfying their renewables requirements. Ethanol blends above 15% are not approved by OEMs for use in vehicles that are not manufactured to operate on gasoline and ethanol blends up to 85% by volume (“flex fuel” vehicles). With the advent of blender pumps, which dispense multi-blend fuels on demand at retail stations, there is a significant risk of misfuelling by Canadian vehicle operators not accustomed to fueling with higher higher-level blends which have, to date, been nearly absent from the market.

• Ontario should seek to align with the policy objectives of the federal Clean Fuels Standard (CFS) proposed by Environment and Climate Change Canada in respect of the lower-carbon fuels objectives.
o An Ontario E15 mandate will increase the compliance burden on the regulated parties, could distort local fuels markets particularly in sparsely populated areas, may disrupt the business models of many smaller retail owner/operators, and may lead to unnecessary confusion amongst drivers at the pumps facing multiple blend options for ethanol-containing gasoline.
o The CFS will result in an in increase in lower-carbon intensity gasolines while also providing fuel producers and distributors with a compliance path option to purchase credits from voluntary credit generators (non-regulated parties) that will ultimately support the build-out of zero emission infrastructure that is critical to the transition of the transportation industry to increasingly electrified powertrains.
o Pacing the growth in supply of E15 fuels such that it mirrors the pace of change in automotive technology while also accounting for the fleet turnover is the preferred approach.

• Ensure the availability of E0 and E1-10 blends in all markets
o In rural markets, the capital cost of converting whole and retail operations to be E15 compatible may not be economically viable.
o Many luxury and performance-oriented brands will be reliant on continued availability of E0 and low-level ethanol blends for many years to come.

• Work with the fuels industry to ensure that there is adequate consumer education and awareness of E15 and vehicle compatibility at the pump, online and instore. Consumer information should always refer to the vehicle owners’ manuals when referring to ethanol blends above E10.