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

This report synthesizes over 125 written submissions from stakeholders regarding the Government of Canada's proposed Clean Fuel Standard (CFS). The CFS aims to reduce annual greenhouse gas (GHG) emissions by 30 megatonnes (Mt) by 2030 by increasing the use of lower-carbon fuels and alternative technologies across the transportation, industry, and building sectors.

• Stakeholders expressed divergent views on the 30 Mt annual GHG emission reduction target for 2030. Some viewed the target as achievable through cost-effective pathways, while others considered it ambitious or challenging to achieve within a 10-year window. Conversely, some stakeholders argued the target was insufficient and called for longer-term signals, including deep decarbonization by 2050.
• There is a general preference for an emission intensity-based approach for the CFS, though some stakeholders support a volumetric approach for renewable fuels. Proponents of sector-specific targets argue they maximize emission-reduction opportunities based on technical feasibility, while opponents argue they increase reporting complexity and risk competitiveness.
• Stakeholders recommended several compliance and cost-containment mechanisms to maintain market stability and limit costs. These include credit trading, a price floor to provide certainty for alternative fuel providers, and a price ceiling to limit compliance costs, with some suggesting a ceiling of CAD 200–250 per tonne CO2e.
• The inclusion of indirect land use changes (iLUC) in life-cycle analysis (LCA) is a point of significant contention. Environmental organizations and next-generation fuel producers support iLUC to prevent the displacement of GHG gains and the destruction of tropical forests. In contrast, first-generation producers and agricultural stakeholders oppose it, citing complex and uncertain modelling.
• Industry stakeholders raised concerns that the CFS could increase costs for suppliers and consumers, potentially leading to 'carbon leakage' where industry relocates to jurisdictions with less stringent regulations. Some estimated costs for ethanol and biodiesel policies could range from CAD 130 to 185 per tonne of avoided GHG, significantly higher than the planned CAD 50 per tonne carbon price by 2022.
• Infrastructure is identified as both a barrier and an enabler for the transition to lower-carbon fuels. Specific gaps include the need for modified refining terminals and retail outlets for higher ethanol blends (above 15%) and a lack of natural gas refuelling infrastructure for heavy-duty trucking, which is estimated to cost CAD 200 million over five years.
• Stakeholders emphasized the need for the CFS to be complementary to, rather than duplicative of, existing carbon pricing and renewable fuel regulations. While some see the CFS as a necessary tool to drive innovation where carbon pricing is insufficient (particularly in transportation), others argue it adds unnecessary regulatory layering and costs.
• For the aviation and marine sectors, stakeholders stressed the importance of aligning the CFS with international standards to avoid competitive disadvantages. Specifically, they referenced the International Maritime Organization (IMO) and the International Civil Aviation Organization (ICAO) CORSIA agreement.

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} }