Canada’s Clean Fuel Regulations - Submission to the Senate of Canada’s Standing Committee on Energy, the Environment and Natural Resources

The objective of my remarks today are twofold: first, to communicate our support of the regulations; and second, to provide recommendations on how the federal government may clarify the intent and scope of any eligible fund under the regulations. [...] The CFR has proven to be a cost-effective means to incentivizing oil and gas producers and suppliers to reduce the life cycle emissions of fuel production and to attract new investment in the clean fuel technologies needed in Canada’s future lower-carbon energy system. [...] For these reasons, the federal government should provide greater clarity to ensure that the potential for multiple compliance fund mechanisms do not undermine the environmental integrity of the regulation. [...] This is all the more reason for the federal compliance fund to establish criteria for eligibility to prevent over-compensating some projects at the expense of others and to ensure the most cost-effective means of disbursement. [...] Additionally, Canada’s fuel refiners and importers have extensive knowledge of the low-carbon fuel requirements in other jurisdictions, as well as full knowledge of the three primary compliance pathways to meet the compliance requirements in the CFR.