Clean Fuel Standard: Discussion Paper (February 2017) – 2017) –Comments on Design Framework Comments on Design Framework Comments on Design Framework /

The results shared in this submission are preliminary, and we intend to refine this research during the development of the Clean Fuel Standard. [...] In addition, our model is conservative because it does not include electricity in the building and industrial sector as a pathway to meet the standard (this is a limitation of the model, rather than a desired outcome), and there are many other technology and fuel pathways that are not in the model. [...] The examples above show two extremes: one where the Clean Fuel Standard reduces emissions only in the building and industrial sector, and one where reductions occur primarily in the transportation sector. [...] California’s Low-Carbon Fuel Standard’s goal is to reduce the greenhouse gas intensity of fuels by 10% but also to transform and diversify the fuel pool and reduce petroleum dependency.11 Similarly, B. C.’s Renewable and Low Carbon Fuel Requirements Regulation aims to reduce the province’s reliance on non-renewable fuels, help reduce the environmental impact of transportation fuels and contribute [...] While this may be desirable from a cost effectiveness perspective, a non-partitioned policy risks stunting the deployment of low-carbon fuels and technologies in the transportation sector, which in our view is one of the principle objectives of the policy.