Update to the Lifecycle Assessment (LCA) model listed in the Technical Guideline of the Cleaner Transportation Fuels (CTF) regulation (O. Reg. 663/20)

Ontario is proposing to:

1. Update the lifecycle assessment (LCA) model in the Technical Guideline for the Cleaner Transportation Fuels regulation to GHGenius 5.03, the most current version of the GHGenius model.
2. Modernize compliance requirements for the use of the LCA model in the Technical Guideline to a principle-based approach that will provide fuel suppliers with more latitude to modify LCA model inputs, including the use of secondary data sources except where explicitly prohibited.
3. Provide guidance on how to use the LCA model for reporting:
   1. Coprocessing of biocrude for renewable gasoline and diesel
   2. Use of carbon, capture and storage (CCS) to lower the Carbon Intensity (CI) of renewable fuels
4. Updating standards and the validity period for CI calculations and thresholds for recalculation of carbon intensities.

Transitional Year:

The 2026 compliance period would be designated as a transitional year for the adoption of the proposed model where fuel suppliers are able to use either GHGenius 4.03 (old version) or 5.03 (latest version) to calculate their bio-based content CIs. This means that the existing Technical Guidance will remain valid for the duration of the 2026 compliance year. Fuel suppliers would be required to use GHGenius 5.03 exclusively beginning in 2027.

The current Technical Guideline references an older LCA model (GHGenius 4.03) that no longer reflects current best-in-class LCA science and does not account for the latest innovations in clean fuel production being used by industry.

GHGenius 5.03 is the updated LCA model used in the new proposed Technical Guideline. This version contains an expanded range of feedstock and fuel production pathways, and updated data sets. It also includes pathways for co-processed fuels, carbon capture and storage (CCS), regional electricity emissions, and agricultural feedstock emissions. Updating the LCA model to GHGenius 5.03 will provide added flexibility for fuel suppliers to comply with new domestic content requirements.

The proposed Guideline is principles-based and includes instructions for calculating the CI of co-processed fuels, while clarifying other aspects of the compliance framework, such as the validity period for CI calculations and thresholds for recalculation of carbon intensities.

Key updates include:

• New principles for determining the CI of renewable content using GHGenius 5.03. This includes:
  • principles to be upheld by modeling facilities to ensure data integrity and modelling transparency
  • provisions for alternative electricity data that better represents a facility’s regional electricity grid
  • principles for determining the CI of co-processed fuels
• Updated gasoline and diesel fossil fuel baselines
• Technical instructions for co-processing, including:
  • standards model input data collection
  • principles for measuring CIs within facility operations
  • acceptable methods for determining bio-based content in co-processed fuels
    • NB: The proposed approach will leverage requirements already in place at the federal level and will not impose any additional regulatory burden on fuel suppliers
• Requirements for incorporating CCS data into GHGenius 5.03
• Current fuel quality standards established under the Canadian General Standards Board (CGSB)

To ensure compliance with the principles of the updated Guideline, MECP will reserve the right to audit facility data.

The proposed revisions aim to reduce red tape, reflect the most up-to-date science and industry practices, and provide fuel suppliers with greater flexibility to adopt state-of–the-art technologies to reduce emissions. The proposed update would recognize modern pathways and reduce the need for fuel suppliers and clean fuel producers to engage in the process of approving pathways not found in the current LCA model.