Thank you to the chair, vice-chairs and committee members for having us here today to speak on behalf of Renewable Industries Canada, the national representative of Canada's first and foremost renewable fuel producers.
My name is Don O'Connor. I'm a long-time technical adviser to Renewable Industries Canada on carbon policy. As well, I'm the president of S&T2 Consultants, a firm specializing in understanding energy and environmental issues worldwide, including life-cycle assessment, which is a significant and monetized mechanism in the new federal clean fuel regulations, as well as programs such as the low-carbon fuel standard in California.
I work closely with energy companies that produce or are required to blend renewable fuels on both sides of the border. It's this international renewable fuels perspective and how it relates to Canada's ongoing economic competitiveness that I hope to offer to you today.
Canada is an energy-dependent economy. As a country, we're a superpower in energy production, we're an expert in fuel distribution and a very heavy fuel user. This is fundamental to our economy, our climate commitments and the background needed to properly assess the risk and the opportunities for Canada given the U.S. Inflation Reduction Act.
Committee members already know how intensely competitive, trade-exposed and regulated the Canada-U.S. fuel market is. Canadian biofuels are not an exception. The U.S. IRA is proposing to invest $369 billion U.S. in clean fuels. It very well may be a once-a-lifetime investment bonanza for American renewable fuel producers and firms.
To give a few examples in the program, American ethanol producers will be subsidized $115 Canadian per tonne for implementing carbon capture and storage. In Canada, there's a proposed one-time investment tax credit, the details of which are still to be determined. Biomass diesel can get a production tax credit of up to 36¢ Canadian per litre if it's produced in the United States. Sustainable aviation fuel produced in the U.S. can get up to a 63¢-per-litre subsidy. Here in Canada, the credit is zero. Lastly, clean hydrogen production in the U.S. can get up to a $4.05 Canadian-per-kilogram production credit under the IRA. In Canada, there are no production incentives, though the details of a 40% investment tax credit is being considered.
Renewable Industries Canada appreciates that it might not be practical to attempt to match the windfall offerings of the U.S. IRA outright, but it can be a means to level up our thinking and make our policies more effective and more competitive. At the same time, making poor choices can be as much a detriment to economic growth as inaction. Caution must be taken to avoid pitfalls and false assumptions under the guise of competition.
With this in mind, RI Canada has a short list of recommendations, which I'm happy to elaborate on in the committee questions.
First, investment tax incentives are not production incentives. Production incentives, like the ones in the U.S. IRA, pay out, and continue to pay out, based on the amount of fuel produced. An investment tax credit, like what is being considered for some clean fuels in Canada, is essentially a one-time refund of a portion of the investment costs. Both have benefits, but policy-makers should be realistic and properly recognize that these credit mechanisms are different. They are not equal and are not perfectly interchangeable.
Unlike some U.S. incentives, the production credit will only be available to U.S. producers and will apply to products used in the United States and products exported to other countries. Without a targeted and effective Canadian credit mechanism, it becomes likely that future renewable fuel production will be built predominantly in the U.S., and if history repeats, the IRA production credits will continue well beyond the two years that are announced in the bill.
Second, the more that policies recognize the difference between carbon intensity and activity, the more competitive Canada can be.
Canadian programs like the clean fuel regulations and the price on carbon do a better job of recognizing the benefits of low-carbon fuels, but they are not a solution to competitiveness. U.S. producers that export to Canada will get the benefit of both the production credits and any benefits in Canada from having a lower carbon intensity. Canadian producers of low-carbon fuels exporting to the United States will get neither.
Third, we could go a long way by accelerating and deepening the policies Canada already has. The government's clean fuels fund will be helpful for the development of new technologies in Canada. It needs to be rolled out quickly so that it can play a role in producing the fuels that Canada will use to meet our 2030 clean fuel regulations requirements.
Finally, any progress we make can be undone if we inadvertently weaken the market demand signals here at home. Clean fuel regulations will be an important part of reducing the GHG emissions for the transportation sector. The regulations are not the most aggressive in the world, or even in Canada. It's important that there be no backsliding and weakening of the regulations. Any additional credit-generating opportunities that are added to the existing regulations will not produce further emission reductions, but will rather just change where the reductions come from.
In the U.S. renewable fuel program, when they export renewable fuels they do not count toward their domestic renewable fuel targets. Canada—