The Biobased and Renewable Products Advocacy Group (BRAG) helps members develop and bring to market their innovative biobased and renewable chemical products through insightful policy and regulatory advocacy. BRAG is managed by B&C® Consortia Management, L.L.C., an affiliate of Bergeson & Campbell, P.C.

By Lynn L. Bergeson

On October 2, 2019, the government of Quebec, Canada, published in its Official Gazette a notice of a draft regulation setting standards for the integration of renewable fuels into gasoline and diesel fuel.  Under the draft regulation, the standards will apply on July 1, 2021, and will then increase. As of July 1, 2025, the integration of a minimum volume of ethanol of 15 percent into gasoline and a minimum volume of biobased diesel fuel of 4 percent into diesel fuel will be required. Given the evaluation by the Canadian government of this matter, the notice states that the proposed regulation would have no particular impact on small and medium-sized businesses because the petroleum products distribution sector is made up of large businesses.  Also on July 1, 2025, enterprises subject to the regulation will invest a total of 110 million Canadian dollars in infrastructure to comply with the set standards for the integration of renewable fuels into gasoline and diesel fuel.


 

By Lynn L. Bergeson and Ligia Duarte Botelho, M.A.

On October 2, 2019, the Green Party of Canada commented, via a press release, on its Green Climate Action Plan called “Mission:  Possible.” Aiming to exceed the U.S. Green New Deal, under this plan, the Green Party outlines a 20-step action plan to achieve the goal of zero emissions by 2050.  Part of the strategy outlined emphasizes the idea that heavy-duty industrial machinery will need to rely on biofuels.  Although the plan is to ban internal combustion engines and ensure that cars, buses, and trains are powered by electricity by 2030, biofuels will still be needed for fishing, mining, and forestry equipment.  According to the plan, these biofuel needs will be addressed through the creation of biofuels using waste plant matter from forests and agriculture -- and only plant-based biofuels.  Claiming that food that would otherwise be used to feed Canadians, the Green Party highly opposes food-based biofuels.  Its plan, therefore, promotes development of local, small-scale biodiesel production that would rely primarily on used vegetable fat from restaurants across Canada, along with wood and agricultural waste.  Fuel switching to biodiesel would be required for agricultural, fishing, and forestry equipment.


 

By Lynn L. Bergeson

On June 27, 2019, the Government of Canada’s Natural Resources Canada (NRCan) opened the application process for a grant to develop next generation biobased foam insulation products. Called the Plastics Challenge, this funding opportunity seeks solutions that result in foam insulation products (either spray foam or rigid foam board) that:

  • Are predominantly derived from Canadian forest residue;
     
  • Have similar insulation values (within 20 percent) as currently available petroleum-based versions;
     
  • Would have similar cost (within 20 percent) as currently available versions;
     
  • Are less flammable;
     
  • Are fully recyclable at end of life; and
     
  • Would generate less GHG emissions during manufacturing.
Applications must be submitted prior to 2:00 p.m. (EDT), August 27, 2019.

 

By Lynn L. Bergeson

In April 2019, Navius Research Inc. (Navius Research) published a report titled “Biofuels in Canada 2019: Tracking biofuel consumption, feedstocks and avoided greenhouse gas emissions.” Using public data, the report analyzes the volume of transportation biofuels consumed in each Canadian province and estimates the impact of this consumption on greenhouse gas (GHG) emissions and transportation energy costs. An increase in both ethanol and renewable fuel consumption is noted in the report, which has led to reduced fuel expenditures in Canada by 0.42 percent from 2010 through 2017. This decreased expenditure is relative to a counterfactual scenario without biofuel consumption. Relative to this counterfactual scenario, differences in fuel energy density and fuel costs, Canada has ended up paying more taxes due to biofuel blending and consumption.


 

By Lynn L. Bergeson

On December 5, 2018, the Government of British Columbia, Canada, released CleanBC, a climate plan outlining the province’s path to a cleaner, more sustainable future. The plan includes implementation activities on how to make energy use more efficiently and prevent waste through cleaner technologies. Highlighting increases in funds for renovations and energy retrofits, the plan also states that by 2032, every new building constructed in the province will be “net-zero energy ready.” By 2040, the goal is to make zero-emissions vehicles more affordable as well as make all new cars zero-emission. With a large focus on waste reduction, the plan also focuses on turning waste into clean resources, and launching training programs for clean jobs. These actions will be implemented in the hopes of achieving 75 percent of the way to the 2030 target of 40 percent less emissions below the 2007 levels. In addition to these activities, several initiatives will remain in place. Among them are the Carbon Tax, the Climate Action Charter, the Carbon Neutral Government, and the Clean Energy Act.


 

By Lynn L. Bergeson

On October 31, 2018, the Canadian National Energy Board released its 2018 report on energy supply and demand projections to 2040: “Canada’s Energy Future 2018: An Energy Market Assessment.” Based on a set of assumptions about technology, energy, climate, human behaviors, and the structure of the economy, the assessment identifies five key findings as follows:

  1. Canada’s energy demand growth is slowing, while the sources to meet these demands are becoming less carbon intensive;
  2. With greater adoption of new energy technologies, Canadians use over 15 percent less total energy and 30 percent less fossil fuels by 2040;
  3. Energy use and economic growth continue to decouple;
  4. Canada’s energy mix continues to become more diverse, adding more renewables; and
  5. Canadian oil and natural gas production increases, with price and technology changes influencing production in the future.

The report predicts that energy generation from renewable sources will increase in 2040 to represent 12 percent of all electricity generation. It concludes, that given the higher demand in reducing carbon emissions and the increase in biofuel blending rates, the costs of renewables will likely drop.


 

 

By Lauren M. Graham, Ph.D.

Renewable Industries Canada (RICanada), a principal stakeholder representing Canadian producers of clean-burning renewable fuels, announced that the Quebec Government’s 2017-2020 Action Plan under the 2030 Energy Policy included, for the first time, renewable fuel volume requirements for fuels such as ethanol and biodiesel.  The renewable fuel blending requirement was set at 5% for gasoline and 2% diesel and is expected to increase after 2020.  RICanada stated that the “announcement on renewable transportation fuels further entrenches Quebec’s position as a leader in the production of renewable energy and in the broader battle against climate change” and that its “members look forward to helping the Government of Quebec ensure that the province’s GHG targets in the transportation sector are achieved.”  More information on the Action Plan for Energy Policy 2030 is available on the Minister of Energy and Natural Resources website.


 

On February 4, 2017, the Canadian Department of the Environment and the Department of Health published in the Canada Gazette the draft screening assessment of the commercially relevant fungus, Trichoderma reesei, stating that the organism is nontoxic and does not require regulatory action under Section 77 of the Canadian Environmental Protection Act (CEPA). Following a screening assessment, Trichoderma reesei , which is used to convert biomass to biofuels and sugars and to produce food and health products, was found to not meet the criteria set out in CEPA Section 64 since the amount entering the environment does not pose a risk to human health.  Options are being considered, however, for follow-up activities to track changes in the commercial use of and exposure to Trichoderma reesei . Comments on the draft assessment and the related scientific considerations are due by April 5, 2017.


 

On October 4, 2016, Canada’s Ecofiscal Commission (EFC) published a report,  Course Correction: It’s Time to Rethink Canadian Biofuel Policies, arguing for the termination of biofuel subsidies.  The report claims that Canadian biofuel policies have reduced greenhouse gas (GHG) emissions an average of three million tonnes annually, accounting for less than 0.5 percent of Canada’s total GHG emissions.  Annual costs of the biofuel policies were estimated to be C$640 million, resulting in an estimated average per-tonne cost of GHG emission reduction ranging between C$128 and C$185.  The report then argues for increased carbon pricing policies over the production subsidies and biofuel mandates that are currently in place as a more cost effective strategy for reducing GHG emissions.
 
Renewable Industries Canada (RIC) has spoken out against the report, calling the study “skewed, flawed, and unacceptable,” as it ignores independent biofuel cost benefit analyses as well as current government data (data used in the study was from a report published in 2010).  RIC claims that biofuel mandates have returned over C$5 billion to the Canadian economy, created 14,000 jobs since 2007, and provided a C$3.7 billion net return on government investments.  RIC does support carbon pricing policies, but argues that the best approach to reducing GHG emissions is a holistic approach that includes a variety of policies, incorporating carbon pricing as well as biofuel mandates.


 
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