Proposed Lifecycle Analysis Models and Technical Guideline Updates for the Cleaner Transportation Fuels Regulation

Overview

The Ministry of the Environment, Conservation and Parks regulates:

1. the amount of bio-based content in gasoline and diesel fuel used or sold in Ontario
2. the greenhouse gas (GHG) performance of this bio-based content

These bio-based content requirements help reduce greenhouse gas emissions from the transportation sector.

As part of the GHG performance requirement, fuel suppliers must calculate the lifecycle GHG emissions intensity of the bio-based content in blended gasoline or blended diesel fuel (in this case, lifecycle emissions are the cumulative emissions associated with creating and using a fuel, from extraction or cultivation to feedstock processing, fuel production, distribution and end-use combustion).

Lifecycle analysis models are available to estimate the lifecycle GHG emissions of renewable content and fossil fuels. In Canada, GHGenius 4.03 is an accepted lifecycle analysis model and it is also the model that must be used in British Columbia’s Renewable & Low Carbon Fuel Requirements Regulation to determine a lifecycle GHG emissions intensity. In Ontario, the following versions of GHGenius 4.03 are the approved models that fuel suppliers must use:

1. 4.03a
2. 4.03b

GHGenius 4.03 can calculate the lifecycle GHG emissions intensity of renewable content derived from many types of typically used feedstocks.. However, GHGenius4.03 is not updated to include lifecycle models for new renewable content, which may emerge over time.

To enable new renewable content to be used for compliance, the Cleaner Transportation Fuels regulation allows fuel suppliers to submit proposed lifecycle models for new renewable content to the Ministry for approval. This process encourages emerging technologies and increases compliance flexibility, potentially lowering the unit cost of compliance.

The regulation requires that the Ministry base its approval of proposed models submitted by fuel suppliers on the following three factors:

1. Whether the data and results in the proposed model are verifiable
2. Whether the emission factors, input data, background data sets and methodologies used in the proposed model are appropriate and would not result in an under-estimation of the carbon intensity value
3. Whether the model is consistent with two lifecycle standards from the International Organization for Standardization (ISO 14040 and ISO 14044)

Once approved, the proposed model can be used by all fuel suppliers to comply with the regulation provided that its lifecycle GHG emissions intensity has been determined.

In this policy proposal, we are seeking feedback on:

1. four proposed models for new bio-based content (and proposed directions for those models)
2. updates to the Cleaner Transportation Fuels: Technical Guideline that the ministry is proposing, which includes approval of a new version of GHGenius 4.03

Proposed four models for bio-based content

The Ministry is considering an application submitted by a proponent requesting approval of four proposed models for new bio-based content. The four proposed models are:

1. Model for biodiesel from brown grease

   Brown grease is used to describe the fats, oils, and grease (FOGs) materials that are collected in grease traps or waste traps. A grease containing 8–12 percent by weight free fatty acids (FFA) is generally categorized as a yellow grease, while grease containing above 35 percent by weight FFA is categorized as brown grease (yellow grease is typically used cooking oil left over from deep fat fryers and industrial-sized griddles). Brown grease can be used to produce biodiesel.

2. Model for biodiesel from fatty acid distillates

   Some biodiesel plants strip away fatty acids from their feedstock (via distillation) prior to processing the feedstock in the production of biodiesel. These fatty acid distillates (FADs) can be used to produce biodiesel in plants that have the capacity of converting these FADs to biodiesel.

3. Model for renewable diesel from non-rendered cooking oil

   Rendering is the process of using energy to remove water and solids from used cooking oil before it is used for the final end use. Non-rendered used cooking oil is processed by non-energy means, e.g. gravity. Some plants can produce renewable diesel from non-rendered cooking oil.

4. Model for renewable diesel from biodiesel distillation bottoms

   Distillation bottoms are a waste product from biodiesel production that can be used to produce renewable diesel.

Updates to the Technical Guideline

We are also proposing to make updates to the Technical Guideline, including:

1. Incorporating GHGenius model version 4.03c

   The Technical Guideline currently requires fuel suppliers to use either GHGenius model version 4.03a or 4.03b to calculate the greenhouse gas intensity of bio-based content. Currently, only Environment and Climate Change Canada (ECCC) distributes GHGenius model version 4.03c.

   The ministry is proposing that GHGenius model version 4.03c be an approved GHGenius model and listed in the Technical Guideline.

2. Update to the Technical Guideline

   An update to the Technical Guideline directions for calculating the lifecycle GHG emissions intensity of biodiesel from yellow grease using the GHGenius 4.03 model is also being proposed. The update would list additional cells within the model related to calculating the GHG emissions intensity of the biodiesel production stage, where yellow grease is used as the feedstock.

   We are proposing that cell values for the following cells are based on source measurements: the base year cell (AR234), energy type cells (AR236–AR239), and material input cells (AR240–AR241).

Analysis of impact

The proposed models and updates outlined would not result in additional administrative costs for fuel suppliers. Using any of the proposed models is voluntary and should provide a net benefit to them.

The intention of the proposed models is to broaden the types of bio-based content that fuel suppliers can use to the meet bio-based content requirements under the Cleaner Transportation Fuels regulation. This increase in compliance flexibility could lead to lower compliance costs for fuel suppliers on a per unit volume basis.

This proposal is not expected to directly result in a significant net increase in greenhouse gas emissions as the content and GHG performance requirements for bio-based content under the Cleaner Transportation Fuels regulation have not changed.

Technical information on the four models for new bio-based content submitted by a proponent

1. Model for biodiesel from brown grease

   The proponent’s proposal is to use the existing GHGenius4.03 model for biodiesel from yellow grease (i.e. no changes to the equations in that model) as the model for biodiesel from brown grease. The key lifecycle stages of the proposed model (and the proponent’s proposed directions for entering any values in GHGenius 4.03) can be characterized as follows:

   • Like used cooking oil, FOGs are considered a waste with zero GHG emissions attributable to their creation. GHG emissions start at the collection stage.
   • Collection: like used cooking oil, collecting FOGs involves travel (whereas the Technical Guideline requires actual values to be used for average distance shipped by type of conveyance in the model for biodiesel from yellow grease from used cooking oil (cells Y78–Y82 in the ‘Input’ sheet of GHGenius 4.03), use default values where the default values are those found in that model in GHGenius 4.03, i.e. 100 km for conveyance by truck and 0km for all other types of conveyance).
   • Feedstock production: just as energy is usually required to turn used cooking oil into a usable feedstock, i.e. yellow grease, energy is required to turn FOGs into a usable feedstock (enter energy used in cells AQ236–AQ239, as applicable by energy type, in the ‘Input’ sheet of GHGenius 4.03).
   • Feedstock transportation: like yellow grease, the feedstock is transported from the feedstock production facility to the biodiesel production facility (enter average distance shipped in cells Z78–Z82, as applicable by type of conveyance, in the 'Input' sheet of GHGenius 4.03).
   • Fuel production: just as energy is required to produce biodiesel from yellow grease, energy is required to produce biodiesel from brown grease (enter energy used in cells AR236–AR239, as applicable by energy type, in the ‘Input’ sheet of GHGenius 4.03).



2. Model for biodiesel from fatty acid distillates

   The proponent’s proposal is to use the existing GHGenius4.03 model for biodiesel from yellow grease (i.e. no changes to the equations in that model) as the model for biodiesel from FADs. The key lifecycle stages of the proposed model (and the proponent’s proposed directions for entering any values in GHGenius 4.03) can be characterized as follows:

   • If FADs are to be considered a waste with zero GHG emissions attributable to their creation (like used cooking oil is in the model for biodiesel from yellow grease), the owner of the biodiesel plant that produced the FADs shall have attributed zero GHG emissions to the FADs (i.e. the owner cannot take any credit for those FADs as a co-product).
   • Unlike used cooking oil, FADs are not collected (enter zeroes for average distance shipped travelled in cells Y78–Y82 in the ‘Input’ sheet of GHGenius 4.03 to remove the collection stage from the lifecycle GHG emissions intensity calculation).
   • Unlike used cooking oil, which usually needs to be processed to turn it into a usable feedstock (i.e. yellow grease), FADs can be used directly as a feedstock in some biodiesel production facilities. If that is the case, GHG emissions start at the feedstock transportation stage (and enter zeroes for energy used in cells AQ236–AQ239 in the ‘Input’ sheet of GHGenius 4.03 to remove the feedstock production stage from the lifecycle GHG emissions intensity calculation).
   • Feedstock transportation: FADs are transported from the facility creating this waste to the biodiesel production facility (enter average distance shipped in cells Z78–Z82, as applicable by type of conveyance, in the 'Input' sheet of GHGenius 4.03).
   • Fuel production: just as energy is required to produce biodiesel from yellow grease, energy is required to produce biodiesel from FADs (enter energy used in cells AR236–AR239, as applicable by energy type, in the ‘Input’ sheet of GHGenius 4.03)
   • Note: where a zero value needs to be inputted in GHGenius 4.03 and the default value is not zero, enter a value of 0.001 instead (model loses calculation functions when a zero value is entered in some cells).



3. Model for renewable diesel from non-rendered cooking oil

   The proponent’s proposal is to use the existing GHGenius4.03 model for renewable diesel from yellow grease (i.e. no changes to the equations in that model) as the model for renewable diesel from non-rendered, used cooking oil. The key lifecycle stages of the model (and the proponent’s proposed directions for entering any values in GHGenius 4.03) can be characterized as follows:

   • Used cooking oil, non-rendered used cooking oil is considered a waste with zero GHG emissions attributable to its creation. GHG emissions start at the collection stage.
   • Collection: collecting used cooking oil involves travel (enter average distance shipped in cells Y78–Y82, as applicable by type of conveyance, in the ‘Input’ sheet of GHGenius 4.03).
   • Feedstock production: unlike how energy is used to render used cooking oil into a usable feedstock, i.e. yellow grease, no energy is used here to process the used cooking oil (enter zeroes for energy used in cells AQ236–AQ239 in the ‘Input’ sheet of GHGenius 4.03).
   • Feedstock transportation: the yellow grease feedstock is transported from the feedstock production facility to the renewable diesel production facility (enter average distance shipped in cells Z78–Z82, as applicable by type of conveyance, in the 'Input' sheet of GHGenius 4.03).
   • Fuel production: just as energy is used to produce renewable diesel from yellow grease, energy is required to produce renewable diesel from non-rendered used cooking oil (enter energy used in cells BH236–BH239, as applicable by energy type, in the ‘Input’ sheet of GHGenius 4.03).
   • Note: where a zero value needs to be inputted in GHGenius 4.03 and the default value is not zero, enter a value of 0.001 instead (model loses calculation functions when a zero value is entered in some cells).



4. Model for renewable diesel from biodiesel distillation bottoms

   The proponent’s proposal is to use the existing GHGenius4.03 model for renewable diesel from yellow grease (i.e. no changes to the equations in that model) as the model for renewable diesel from biodiesel distillation bottoms (BDBs). The key lifecycle stages of the model (and the proponent’s proposed directions for entering any values in GHGenius 4.03) can be characterized as follows:

   • If BDBs are to be considered a waste with zero GHG emissions attributable to their creation (like used cooking oil is in the model for renewable diesel from yellow grease), the owner of the renewable diesel plant that produced the BDBs shall have attributed zero GHG emissions to the BDBs (i.e. the owner cannot take any credit for those BDBs as a co-product).
   • Unlike used cooking oil, BDBs are not collected (enter zeroes for average distance shipped in cells Y78–Y82 in the ‘Input’ sheet of GHGenius 4.03 to remove the collection stage from the lifecycle GHG emissions intensity calculation).
   • Unlike used cooking oil, which usually needs to be processed into a usable feedstock (i.e. yellow grease), BDBs can be used directly as a feedstock in some renewable diesel production facilities. If that is the case, GHG emissions start at the feedstock transportation stage (and enter zeroes for energy used in cells AQ236–AQ239 in the ‘Input’ sheet of GHGenius 4.03 to remove the feedstock production stage from the lifecycle GHG emissions intensity calculation).
   • Fuel production: just as energy is used to produce renewable diesel from yellow grease, energy is required to produce renewable diesel from BDBs (enter energy used in cells BH236–BH239, as applicable by energy type, in the ‘Input’ sheet of GHGenius 4.03).
   • Note: where a zero value needs to be inputted in GHGenius 4.03 and the default value is not zero, enter a value of 0.001 instead (model loses calculation functions when a zero value is entered in some cells).