Clean Energy Canada and the Pembina Institute comment on the federal government’s Clean Fuel Standard Proposed Regulatory Approach, which outlines many key policy design decisions taken in light of stakeholder consultations held over the past several years. In our jointly held view, many of the policy design choices in the regulatory approach chart the right course for the Clean Fuel Standard—a critical part of the Pan-Canadian Framework for Clean Growth and Climate Change.
The comments in this submission apply to the June 2019 paper on the proposed regulatory approach for the liquid class regulations. We begin with a set of general comments presenting our key reflections on the PRA. Following this, we concentrate selectively on what we view as the most promising aspects of the policy directions outlined by ECCC. In addition to specifying the regultatory design choices we support, we also identify areas of concern, and offer comments and recommendations organized according to the format of the PRA.
