CPA Public Affairs
August 2018

Environment Canada adjusting time frame for developing CFS

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Environment and Climate Change Canada (ECCC) has informed stakeholders that it is updating the approach for the Clean Fuel Standard (CFS), which it says will “ensure it is developed in a way that supports the transition to lower-carbon fuels throughout our economy, while also supporting Canada’s competitiveness”.
From the perspective of the CPA, if the development of a CFS model is to be of value, it has to be done methodically and with the proper focus. In the CPA’s submission to the CFS Technical Committee on April 12, CPA President & CEO Nathalie St-Pierre wrote, “Reducing carbon intensity / greenhouse gas emissions is a complex endeavour that requires comprehensive policy approaches specific to each fuel. The timeframe allocated – considering the task and the impacts, many unknown at this time – is very short.”
The focus of the submission was to highlight CPA’s position that ECCC postpones including natural gas liquids (NGLs) from phase one, as some jurisdictions in the United States have done. That remains the primary objective for the CPA.
According to ECCC’s notice to stakeholders on July 19, 2018, the new approach for Canada’s CFS will focus on developing standards for the liquid fuel stream first. Standards for the gaseous and solid fuel streams will follow.  The new timelines are:
  • Liquid fuels – Publish proposed regulations in spring/summer 2019 and final regulations in 2020, with requirements coming into force by 2022.
  • Gaseous and solid fuels – Publish proposed regulations in fall 2020 and final regulations in 2021 with requirements coming into force by 2023.  
The Government of Canada noted that it is still committed to developing a CFS that will reduce carbon emissions from all fuels by 30 million tonnes in 2030. In fall 2018, it plans to publish two documents to guide further engagement on the design of the standard:
  1. A regulatory design paper that will provide more information about the design of the policy, including the proposed allocation of the overall 30-million-tonne target among the three fuel streams.
  2. A cost-benefit analysis framework outlining the proposed analytical approach (models, data and key assumptions) for assessing the costs and benefits of implementation of the CFS for the liquid fuel stream.
The CPA’s approach and that of other stakeholders seem to have made an impact. The fact that ECCC is adjusting its timeframe to allow for a more deliberate pace in the development of the CFS provides more time for the CPA to continue to make its case for a full exemption while promoting that propane is an affordable, Canadian alternative fuel that should be used to reduce greenhouse gas emissions.

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