TAF comments on the Federal Clean Fuel Standard Framework

January 2018. Government of Canada. TAF responded to the Federal Clean Fuel Standard Framework consultation, an initiative under the Pan-Canadian Climate Framework. A main concern highlighted in our feedback was the lack of consideration for indirect land use change when calculating carbon intensity values for different fuels. Given the indirect effects biofuel production can have on the environment – in particular through the expansion of crop fields- it is essential that the government take action to ensure that established carbon intensities reflect the full lifecycle impact of the fuel production.