tonne CO 2 e. Switching from heating oil to wood pellets has a fuel cost of -$7 to -$49 per tonne CO 2 e. But pellet boiler penetration of Canada’s heat market is low. A CFS with a provision for end-use fuel switching in liquid class stationary applications would drive adoption of pellet boilers, thereby lowering fuel and delivered heat costs. • Despite large investments in lignocellu-losic liquid transportation biofuels, all technologies are still pre-commercial. Co-processing pyrolysis oil or biocrude at a meaningful volume will not occur before 2030. Canada’s forest sector rep-resents over 75 per cent of annually avail-able biomass resources and its exclusion from participation in the liquids class, which ECCC seeks to account for over 75 per cent of GHG reductions under the CFS, will increase the cost of compliance. Domestic lipid and starch supplies are limited, so excluding forest feedstocks will lead to more renewable fuel imports to Canada, contradicting ECCC’s goal of attracting investment. • ECCC’s proposed regulatory approach is in apparent conflict with the govern-ment’s objective of phasing out diesel and heating oil in rural and remote com-munities. Under Clean Energy for Rural Remote Communites, $55 million is al-located to bioheat. It is contradictory for the government to support bioheat dis-placement of heating oil with one policy, only to exclude it from another policy. • Since the government has made elimi-nating diesel and heating oil consump-tion in remote communities a priority, it is difficult to understand why ECCC would decide to exclude these fuels from CFS compliance. The exclusion misses two important points. 1. In most remote communities, electric-ity generated by diesel is already sub-sidized by grid-connected electricity rate payers in the province, the provin-cial/territorial government, and/or the federal government. Excluding remote community diesel under the CFS rein-forces the status-quo of energy insecu-rity. Many remote communities have opportunities for bioheat or biomass combined heat-and-power. The CFS is a chance to encourage local distri-bution companies to engage with res-idents to pursue these opportunities. 2. Remote communities are already pur-suing bioheat development because of potential cost savings. The CFS could accelerate this switch to renewable, low-carbon wood fuel resources. The Northwest Territories is a major bio-heat hub. It is not logical to exclude regions that are ideal for switching to low-carbon fuels under the CFS. RECOGNIZING WOOD PELLETS’ VALUE ECCC has made a significant effort to de-sign a compliance credit creation mech-anism for electric and hydrogen fuel cell vehicles. Companies such as U.S.-based Tesla will generate and sell credits, which will allow them to offer their vehicles for less. This will completely change Canada’s energy market dynamics. It is only fair for the Canadian wood pellet industry to expect the same policy development effort. Permitting end-use fuel switching in stationary liquid class ap-plications under the CFS is not asking for special treatment – it is asking for the same treatment afforded foreign electric vehicle manufacturers. • FUEL | AIR | GAS | ASH www.processbarron.com | 205-663-5330 | 2770 Welborn Street Pelham, AL 35124 CBM_ProcessBaron_Summer19_CSA.indd 1 Canadian BIOMASS 2019-07-02 11:26 AM 9
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