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ARCHIVED - Renewable Fuels Regulation - Elements of Regulatory Flexibility
Meeting of Industry Technical Advisory Group
June 23, 2009
This presentation is also available in PDF (112 Kb)
Flexibilities currently in the Working Document
- Limits are annual, not per-litre.
- Limits are company-wide.
- Compliance units may be traded.
- A broad suite of liquid renewable fuels may be used.
- Compliance units may be created from use of renewable fuel in any liquid petroleum fuel.
- Distillate compliance units may be used to meet the 5% gasoline requirement.
- Small volume (< 400 m³) producers and importers are not subject to requirements.
- Fuel for special uses may be excluded from the regulated pool.
- Gasoline and distillate for use in the territories may be excluded from the regulated pool.
- Gasoline for use in Newfoundland and Labrador may be excluded from the regulated pool.
- The first compliance period is extended to 16 months.
- Definition of "renewable fuel" encompasses small amounts of non-renewable components.
- Compliance units may be created from use of bio-crude feedstock.
- There is a 45-day trading period following the end of a compliance period for "truing-up".
- Some excess compliance units may be carried forward to the next compliance period.
Additional flexibilities that have been suggested
- Extend the "true-up" trading period (e.g., from 45 to 90 days).
- Provide for exclusion from the regulated pool of gasoline and distillate for use north of 60°N (adds northernmost part of Quebec).
- Allow for creation of compliance units upon use or sale for use of B100.
- Allow creation of compliance units from the time the regulations are passed (c. June 2010), rather than from the start of the first compliance period (September 1, 2010).
- Allow all distillate compliance units created before the distillate requirement comes into effect to be carried over into the first distillate compliance period.
- Extend the first gasoline compliance period by an additional 12 months (from 16 to 28 months).
- Allow a deficit carry-forward (e.g., a primary supplier that does not meet the limit for a compliance period is not in contravention if it makes up the deficit in the following compliance period).
- EPA allows a deficit carry forward with restrictions that a regulatee cannot use it in back-to-back compliance periods.
- Allow for compliance units created during a "true-up" period to be used for compliance during the previous compliance period.
- Effect is quite similar to allowing a deficit carry-forward
- Date Modified: