Alberta’s review of its Renewable Fuels Standard presents an opportunity to consider how provincial fuel policy can better support the development and deployment of low-carbon fuels.
In response to Alberta Environment and Protected Areas’ Renewable Fuels Standard Discussion Paper, the Edmonton Region Hydrogen Hub (ERH2) submitted recommendations informed by its market-development work and ongoing engagement with industry, government and regional partners.
ERH2’s submission supports moving beyond a renewable fuel blending requirement toward a broader, performance-based framework that rewards verified emissions reductions while enabling the infrastructure, investment and market demand required to deploy low-carbon fuels at scale.
The executive summary below outlines ERH2’s recommendations for developing a framework that supports Alberta-produced fuels and strengthens their ability to compete in domestic and international markets.
Executive Summary
The Edmonton Region Hydrogen Hub (ERH2) welcomes the Government of Alberta’s review of the Renewable Fuels Standard (RFS). The review is an important opportunity to ensure Alberta’s fuel policy reflects current market realities, emerging technologies, investment opportunities and the province’s broader economic and environmental objectives.
ERH2 supports modernizing the RFS from a renewable fuel blending requirement into a broader deployment-focused, performance-based low-carbon fuels framework. The future framework should reward verified lifecycle emissions reductions while also recognizing operational performance, commercial scalability, infrastructure readiness, market demand and long-term supply resilience.
ERH2’s recommendations are informed by practical market-development work, including the Western Canada Hydrogen Corridors Initiative, which has developed Levelized Cost of Hydrogen and Commercial Business Model tools that are being shared with Alberta Government departments for policy and program design purposes. The recommendations are also informed by ERH2 and partner's Sustainable Aviation Fuel (SAF) work, which assessed advanced bio-based and synthetic SAF opportunities in the Edmonton Region, as well as ongoing local, national and international industry and policy engagement.
ERH2 recommends that Alberta:
- Modernize the RFS into a deployment-focused, performance-based compliance framework.
- Adopt a technology-, pathway- and feedstock-neutral approach.
- Build integrated low-carbon fuel value chains.
- Support both production and utilization.
- Develop an Alberta Lifecycle Accounting Framework that Maximizes Market Access and Interoperability.
ERH2 thanks Alberta Environment and Protected Areas for the opportunity to contribute to this important policy discussion, and looks forward to continuing to support the province's development of a modernized, performance-based low-carbon fuels framework.
