Submission: Comments on the Clean Fuel Standard Proposed Regulatory Approach

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 Proposed Regulatory Approach (PRA). Following this, we concentrate selectively on what we view as the most promising aspects of the policy directions outlined by Environment and Climate Change Canada. In addition to specifying the regulatory design choices we support, we also identify areas of concern, and offer comments and recommendations organized according to the format of the PRA. We look forward to seeing these comments reflected in the publication of the draft regulation on liquid-class fuels in the Canadian Gazette, Part 1, in 2020.