On March 2, CPA submitted comments on Canada’s proposed Clean Fuel Regulations (CFR). The objective of the CFR is to reduce the carbon intensity (CI) of liquid fossil fuels produced or imported into Canada by mandating annual reductions between 2022 and 2030. The proposed regulations provide flexibility for liquid fossil fuel suppliers to achieve obligations through various market-based credit systems, including:
- Undertaking projects anywhere along the supply chain to reduce the life-cycle carbon intensity of the liquid fossil fuel;
- Supplying low CI fuels (e.g. ethanol, biodiesel); and
- Investing in advanced vehicle technologies, such as electric or hydrogen fuel-cell.
CPA’s comments focused on qualifying the inclusion of “secondary forest residues that are byproducts of industrial wood processing operations” as an eligible feedstock for compliance credit creation under the CFR. Under the current definition, a supplier would receive a financial incentive for converting these feedstocks into a low CI fuel, thereby creating a competitive advantage for fuel producers that could potentially impact composite panel producers’ access to these key raw materials. As previously discussed with CFR staff, CPA included proposed definitions for wood byproduct feedstock eligibility that would deliver a balanced outcome of ensuring that these raw materials remain available to composite wood products manufacturers while retaining low CI fuel credits under the appropriate circumstances. CPA also provided a copy of the comments to senior staff at Natural Resources Canada and key Members of Parliament. See CPA Comments on Proposed Clean Fuel Regulations.