5. Questions for Stakeholders

Environment Canada is now moving ahead to develop regulations to restrict the level of sulphur in on-road diesel fuel to a maximum of 15 ppm commencing in June 2006. Parties are invited to provide their views on how the regulations should be designed. In particular, Environment Canada is soliciting views on the following issues:

1. Should the Canadian regulations permit companies to produce or import a small amount of on-road diesel fuel that does not meet the 15-ppm requirement between for a short period of time after June 2006, recognizing that to so would require complex regulations to address downstream issues? Working within the legal constraints of CEPA, 1999, which, if any, of the U.S.-style flexibilities for refiners and importers should be considered? What would be the costs and benefits of this relative to regulations without such flexibilities?
   
2. If two grades of on-road diesel were allowed for some short period of time:
   1. How could the availability of 15-ppm diesel throughout Canada be assured? What specific regulatory provisions would be required?
   2. What safeguards would need to be put into place to minimize misfuelling and contamination of low-sulphur diesel fuel?
   3. How could contamination of low-sulphur diesel batches be handled?
   4. Should a temporary sulphur credit trading program be included? How would trading regions be defined? Should generation of early credits be allowed?
3. Is extra time required for the Arctic's diesel distribution system to prepare for the 15-ppm requirement (in addition to the three months likely to be allowed elsewhere in Canada)?
   
4. Working within the legal constraints of CEPA, 1999, how should Canadian regulations handle imports of on-road diesel from Alaska during the U.S. transition period?
   
5. What is the appropriate test method for measuring sulphur in on-road diesel at concentrations of less than 15 ppm? Should alternative methods for the purposes of record keeping and reporting be allowed? What alternative methods should be allowed? Should performance-based methods be considered?
   
6. Should any of the other instruments that are being used by other countries also be considered?