Comments on the Clean Fuel Standard Regulatory Design Paper

Published by: David Suzuki Foundation and partners
Authored by: Ian Bruce, Warren Mabee
Partners: Queen's University

Climate solutions decarbonization, sustainable transportation, Trottier Energy Futures Project, energy, greenhouse gas emissions, industry, policy, fossil fuels

The Trottier Energy Futures Project scenarios suggest the most significant change required in order to reduce carbon emissions in Canada by 80 per cent by 2050 is to progressively reduce reliance on fossil fuels to meet energy-based end uses. The supply of biofuels will need to increase significantly. A robust clean fuel standard can help drive this transition. This submission by the David Suzuki Foundation and Queen’s University to Environment and Climate Change Canada includes eight recommendations to strengthen the standard:

1. Include sustainability criteria to avoid potential and unintended ecological impacts from direct and indirect land-use change;
2. Integrate expanded renewable fuel regulations (i.e., volumetric requirements);
3. Establish facility-based and crude-specific carbon intensity values, instead of national averages;
4. Ensure that competitiveness considerations are evidence-based, targeted and time-limited;
5. Implement a robust credit trading system that supports decarbonization objectives;
6. Develop an approach and timelines for the inclusion of aviation fuels;
7. Ensure a robust approach to governance and policy oversight;
8. Signal intention to align CFS emission reduction targets with decarbonization objectives.