Clean Fuel Standard: Summary of stakeholder written comments on the Discussion Paper

The document summarizes over 125 written submissions and workshop contributions regarding the proposed Canadian Clean Fuel Standard (CFS). Stakeholders generally support the CFS's goal of reducing GHG emissions by 30 Mt annually by 2030, though they diverge on the feasibility of the timeline and the specific regulatory design. Key areas of discussion include the preference for an emission intensity-based approach over volumetric mandates, the need for flexible compliance pathways such as credit trading, and the importance of harmonizing the CFS with existing carbon pricing and international aviation and marine standards. Industrial sectors expressed significant concerns regarding competitiveness, carbon leakage, and the technical feasibility of fuel switching, while environmental groups advocated for broad sustainability criteria and the inclusion of indirect land use changes (iLUC) in life-cycle analyses.

• There is broad agreement on the objective of reducing greenhouse gas emissions by 30 megatonnes (Mt) annually by 2030, although stakeholders differ on whether this target is too ambitious or insufficient. Some suggest the target is achievable through cost-effective pathways, while others argue it requires "substantial changes to the economy."
• Stakeholders generally support an emission intensity-based approach for the CFS, though some advocate for a hybrid model that includes volumetric requirements for biofuels to drive demand and eliminate provincial policy fragmentation.
• Compliance mechanisms should prioritize flexibility and market-based tools. Stakeholders support credit trading and the implementation of price floors to provide market certainty for alternative fuel providers, and price ceilings to limit compliance costs, with some suggesting a ceiling of CAD 200–250 per tonne CO2e.
• There is significant disagreement regarding the inclusion of indirect land use changes (iLUC) in life-cycle analysis (LCA). Environmental organizations argue iLUC is necessary to prevent the displacement of GHG gains, while agricultural producers claim the modelling is "complex, uncertain and contentious"
• Industrial sectors, including oil and gas, mining, and cement, expressed concerns that the CFS could lead to "carbon leakage" and a loss of global competitiveness if Canadian regulations are more stringent than those in other jurisdictions, particularly the United States.
• Infrastructure is identified as both a barrier and an enabler for the transition to lower-carbon fuels. Specific gaps include the need for modified fuel refining, terminal and retail outlets, and a projected cost of CAD 200 million over five years to develop extensive natural gas refuelling infrastructure for heavy trucking.
• Stakeholders emphasize the need to avoid policy duplication and ensure the CFS is complementary to carbon pricing. While some see the CFS as a necessary tool to drive innovation where carbon pricing is insufficient, others argue it could create a "double hit" for consumers and industry.
• For the aviation and marine sectors, stakeholders stress the importance of aligning the CFS with international standards, such as those from the International Maritime Organization (IMO) and the International Civil Aviation Organization (ICAO), to avoid competitive disadvantages and regulatory conflict.

APA

International Institute for Sustainable Development (2017). Clean Fuel Standard: Summary of stakeholder written comments on the Discussion Paper. https://www.iisd.org/system/files/publications/clean-fuel-standard-summary-comments-en.pdf

Chicago

International Institute for Sustainable Development. Clean Fuel Standard: Summary of stakeholder written comments on the Discussion Paper. 2017. https://www.iisd.org/system/files/publications/clean-fuel-standard-summary-comments-en.pdf.

Wikipedia

{{cite report |author=International Institute for Sustainable Development |title=Clean Fuel Standard: Summary of stakeholder written comments on the Discussion Paper |date=September 2017 |url=https://www.iisd.org/system/files/publications/clean-fuel-standard-summary-comments-en.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{internationalinstituteforsustainabledevelopment2017clean, author = {{International Institute for Sustainable Development}}, title = {{Clean Fuel Standard: Summary of stakeholder written comments on the Discussion Paper}}, institution = {International Institute for Sustainable Development}, year = {2017}, month = sep, url = {https://www.iisd.org/system/files/publications/clean-fuel-standard-summary-comments-en.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }