Since the initial announcement of the Clean Fuel Standard (CFS) Regulatory Framework in 2017, the Canadian government has prepared to implement a Clean Fuel Standard to reduce annual greenhouse gas emissions and lower the full lifecycle carbon intensity of fuels used in industry, transportation and buildings.
With a Clean Fuel Standard in place, fuel producers and suppliers can help meet reduced carbon obligations and earn compliance credits by lowering the Lifecycle Carbon Intensity of fuels. One example of how they may do this is by supplying low carbon-intense fuels such as ethanol in gasoline or biodiesel in fuel.
The Ontario Federation of Agriculture (OFA) believes the implementation of CFS regulations can result in better pricing opportunities for Ontario farmers by creating significant growth in the Ontario crop markets while working towards a healthier, more sustainable climate.
The CFS will play a large role in the production of farm-grown feedstock. A carbon lifecycle assessment is used to analyze the greenhouse gas impact of fuels through the entire production lifecycle. For farmers, this includes the cultivation and harvest of feedstock used to produce low carbon intensity fuels. Land Use and Biodiversity (LUB) criteria mentioned in Section 38 of the proposed regulations will ensure the cultivation and harvest of feedstock do not reduce biodiversity or pose risks to any vulnerable species, ecosystems and habitats. The LUB criteria will also help reduce indirect land-use changes that risk increasing carbon emissions by the displacement of forests, wetlands and grasslands.
Increased markets for crops and crop residues in Ontario can provide opportunities for farmers to contribute to the production of lower carbon-emitting fuels. However, there is still work that needs to be done to ensure regulations are attainable for Ontario farmers. Having the ability to produce and grow quality crops is just as important as protecting the environment.
Many farmers are concerned the proposed regulations will hinder their ability to produce and grow feedstocks, impact the expansion and growth of farmland in northern Ontario, increase excluded zones near riparian zones and wetlands, and create red tape.
To address these concerns, Section 39 of the proposed regulations recognizes that the criteria set out for crop feedstocks by the US EPA for their renewable fuel standard are stringent enough to comply with the LUB criteria. This means all Canadian Agricultural feedstock is eligible for CFS compliance credit creation.
Livestock farmers have also voiced concerns on the treatment of pastureland as restricted grassland that cannot be used to produce feedstock for CFS compliance credits. Although pasturelands left unseeded for 10 years could be deemed as restricted grassland under the proposed regulations, intermittent seeding of pasturelands allows these fields to remain unrestricted for cultivating and harvesting CFS compliant feedstocks.
As a united industry, we need to work with the federal government to find a balance between addressing setbacks and supporting the betterment of the environment where we live, work and play. If there are proper measures to help create attainable regulations, these initiatives will help support a healthy environment on farms and are a step in the right direction.
The agriculture community needs investments in programs that advance positive environmental initiatives across the country. This can be done through cost-share incentives and by increasing market opportunities like a Clean Fuel Standard. Ultimately, if the objective is to improve the environment by collecting a carbon tax, why not invest those funds back into the environment we’re trying to protect and preserve?
As farmers, we don’t want more paperwork or red tape when following regulations. We want to work collectively towards a better environment while minimizing any burden required to meet this new standard.
It’s important to recognize that it’s difficult to create a one-size-fits-all approach for all of Canada to follow. OFA will continue to advocate for the federal government to accommodate different regional jurisdictions and crop management practices across the country. Any Clean Fuel Standard that is implemented will need to recognize these differences, with reasonable compliance burden, helping farmers follow best farm management practices while improving the environment.
For more information, contact:
Ontario Federation of Agriculture