Policy Positions

Canadian Fuels members seek a public policy/regulatory environment that supports a competitive and reliable petroleum refining and marketing industry in Canada. Key attributes of this environment are regulatory certainty, regulatory simplicity, jurisdictional consistency, flexible compliance, underpinned by sound science and market principles.

Climate Change and GHGs
Air Emissions
Brownfield Remediation
Fuel Policies
Water Use and Effluent
Management and Reduction of Toxic Substances

Climate Change / GHG Emission Reduction

To address the risks of climate change, reducing GHG emissions has become an important global issue. Under the auspices of the Paris Agreement, virtually every country has committed to reduce their GHG emissions.  

For Canada, our collective efforts to achieve a sustainable, lower carbon future must be founded on three key actions:
  • Explore, define and evaluate GHG emission-reduction pathways in collaboration with all stakeholders before targets are set.
  • Recognize Canada’s productivity and competitiveness as core considerations in the development and implementation of a national GHG-reduction strategy.
  • Ensure that sound evidence and cost-benefit analyses drive decision-making and are transparently shared with citizens.
Climate policy has far reaching implications for citizens, business and society in general.  Canadian Fuels Association and its members support policy approaches that minimize the overall cost to society of reducing climate risks.  Broad-based carbon pricing mechanisms that are transparent, uniform and predictable are useful tools to send clear price signals across the economy that can effectively and efficiently reduce Canada’s carbon footprint.  

Industrial Facility Emissions - Refineries

Refining is an energy intensive and trade exposed sector.  Maintaining Canadian refining industry competitiveness is a key principle to underpin any GHG emissions reduction policy.  Policies must maintain a level playing field between jurisdictions, between sectors and within sectors.  This is best accomplished with a national approach, rather than the current federal/provincial patchwork, and one that is aligned with approaches implemented by our major trading partners.  Emission expectations for Canadian refineries should be determined with reference to an established global benchmark.

Transportation Emissions

Transportation is a significant component of GHG emissions globally and in Canada.  Transportation is also vital to a strong economy and a progressive quality of life.  Successfully reducing transport emissions is a complex and challenging task.  The goal must be a sustainable transportation system that balances Canadians’ environmental, economic and social aspirations.  Carbon pricing mechanisms can play an important role. Beyond that, achieving the aspirations of the Paris Agreement will require Canadians and our governments to make smart decisions about where we live and work, and how we get around. 

Air Emissions 

Refiners care about air quality.  They have a solid track record of reducing air emissions.  The Canadian Council of Ministers of Environment (CCME) approved National Framework for Petroleum Refinery Emission Reductions (NFPRER) provides effective principles and methods contributing to improved air quality, supporting protecting human health and the environment via real, quantifiable and verifiable emission reductions. 

This is achieved through benchmarking performance to the best in the world and over time continuing to reduce facility emissions for key air pollutants and air toxins from petroleum refineries.  This initiative is a pragmatic approach to improving air quality and helping reduce negative health impacts such as respiratory and chronic illnesses linked to criteria air contaminants and air toxins. 

Emissions reduction requirements should be outcomes focused, and based on sound science and effective risk management principles.

Emissions Quantification and Reporting

Regulators, the communities in which refineries operate, and the general public should have confidence in the accuracy and validity of refinery emissions reporting. Canadian Fuels members follow a strict Code of Practice in reporting refinery emissions.  The Code improves consistency and inter-company comparability of the emissions inventory data by reducing non-performance related variability of the estimated releases.  The Code assures that relevant significant sources are considered and that appropriate assumptions and methodologies are used in developing a refinery's emissions inventory.

Canadian Fuels members support initiatives to seek improved approaches to emissions' monitoring and, ultimately, emissions management.  New quantification or reporting requirements should be supported by a demonstrated need, based on sound science and credible cost-benefit analysis.

Canadian Fuels members expect that relevant government jurisdictions should coordinate requirements through a single window reporting system in order to avoid duplication and unnecessary administrative costs.

Canadian Fuels Position on DIAL (pdf)

Brownfield Remediation

Brownfields are abandoned, idle or underutilized commercial or industrial properties with known or suspected environmental impact but where there is potential for remediation and redevelopment.

In 2003, the National Round Table on the Environment and the Economy (NRTEE) released the report Cleaning up the Past, Building the Future: A National Brownfield Redevelopment Strategy for Canada. Canadian Fuels endorses this report, and urges federal, provincial and municipal governments to implement the strategic directions recommended by NRTEE:

  • Applying Strategic Public Investments to Address Upfront Costs
  • Establishing an Effective Public Policy Regime for Environmental Liability and Risk Management
  • Building Capacity for and Community Awareness of Brownfield Redevelopment

The Association places a priority on the implementation of practical, site specific approaches to remediation based on sound risk management principles, benefit/cost analysis and on achieving regulatory liability certainty for remediated sites. 

Since 2009, Canadian Fuels members have remediated 1,501 surplus sites across Canada, making them available for industrial, recreational, residential or commercial use.

Fuel Policies

A competitive free market, operating on a level playing field within a clear, stable and well-designed legal, fiscal and regulatory framework best serves the broad interests of consumers, suppliers, and the public with respect to economic prosperity, fuel supply security, and environmental sustainability.  

Transportation fuels should be reliable, competitively priced to meet consumer expectations, consistent with vehicle and engine manufacturers’ recommendations (as found in owners’ manuals). Changes in fuel specifications must be compatible with transportation fuel infrastructure.  

Policies should adopt a comprehensive systems approach that addresses fuel, vehicle and infrastructure issues.  They should be underpinned by sound science, credible ‘well to wheels’ environmental impact analysis, and robust cost-benefit analyses that clearly demonstrate a net societal benefit for Canadians. Policies must not compromise fuel suppliers’ ability to meet consumers’ expectations of reliable, high quality and competitively priced fuel choices. 

Regulatory requirements should be clear, and with minimal complexity, provide adequate time and certainty for compliance planning and implementation, provide feasible compliance pathways that allow for optimization in the production and distribution of fuels, and include appropriate structures for compliance and enforcement.  

As part of an integrated North American fuel and vehicle marketplace, the Federal and Provincial governments should strive for harmonized North American fuel standards, with the exception of characteristics unique to Canada’s geography and climate. 

Regulated standards should focus on the environmental performance of fuels.  Fuel specifications that relate to vehicle performance should be developed through the multi-stakeholder process of the Canadian General Standards Board (CGSB). 

Water Use and Effluent

Canadian Fuels members understand the importance of water to Canada and Canadians, and view that all water consumers - from families, to farmers, to industry - share the same responsibility to work to minimize their consumption and to help protect the quality of returned water.  Canadian Fuels members are committed to protecting water quality by managing their operations with the goal of preventing incidents that would be detrimental to water quality, by controlling the release of water streams to meet regulatory quality standards, and by designing, constructing, operating, and maintaining facilities to this end.  Water quality standards should be based on strong science, robust risk management principles, and credible cost-benefit analysis.

Management and Reduction of Toxic Substances

Chemicals are part of everyday life, essential to our economy, our communities and our homes.  While chemicals provide benefits, Canadian Fuels recognizes that some chemicals may also have harmful effects if not properly managed.

In 2006, the Canadian government introduced the Chemical Management Plan (CMP), an initiative aimed at reducing the risks posed by chemicals to Canadians and their environment.  The CMP process assesses chemicals used in Canada and takes actions on chemicals found to be harmful.  The Canadian CMP is well regarded internationally, and has demonstrated success in Canada.

Canadian Fuels supports the CMP, and works with the federal government by providing information in support of properly assessing chemicals and their presence relative to potential harmful effects, and providing input to appropriate manage potential exposures to workers, the public and the environment.

Canadian Fuels supports the CMP as a consistent national approach, based on sound science and risk management principles.