Recommendations from BC Clean Technology Roundtable

Office of the Minister of Natural Resources Canada
Cabinet du ministre des Ressources naturelles Canada
580 Booth Street / 580 rue Booth
Ottawa, ON K1A 0E4

Attn: The Honourable Jonathan Wilkinson, Minister of Natural Resources

Honourable Minister Wilkinson:

Thank you for inviting Hydra Energy to join the ministerial roundtable with leaders from British Columbia’s clean technology sector held in Vancouver, British Columbia on November 12th, 2021

Hydra Energy (Hydra) is a British Columbia-based clean technology company that employs an innovative business model to provide heavy-duty fleets with a market-ready solution [1] to reduce emissions and costs with limited risk and no up-front investment. We source low-carbon by-product hydrogen from chemical plants and provide clean fuel to Hydra-retrofitted fleets at diesel-equivalent (or lower) prices. enabling an immediate and affordable transition to cleaner trucking.

As kindly requested, we are writing to request your consideration for the following two recommendations which were discussed at the roundtable :

1. For Canada to utilize technology neutral language in policies that regulate greenhouse gas emissions, specially in transportation.
   Rationale:

   Emission reduction policies written with technology-neutral language offer regulated entities with long-term regulatory certainty and flexibility to adopt the technologies deemed best to achieve the desired regulatory outcomes. They provide potential efficiency gains, as industries are incentivized to innovatively comply with regulatory requirements without compromising health, safety, security, or environmental protections. Technology neutrality in policies also makes it easier for businesses to adopt novel technologies with high potential.

   For example, the federal government definition of Zero Emissions Vehicles (ZEVs) includes: battery-electric, plug-in hybrid electric and hydrogen fuel cell vehicles.

   This definition excludes hydrogen internal combustion engine vehicles which also have the potential to produce no tailpipe emissions.

   By utilizing a non-technology neutral language in the definition of ZEVs, tax payers can’t access incentives such as the (iZEV) Program or current tax write-off for businesses). By adopting technology neutral language, Canada can support the adoption of market-ready domestic solutions, like Hydra’s, which can immediately reduce heavy-duty vehicle (HDV) emissions as the sector awaits the widespread commercialization of zero-emission technologies.

2. Forthefederalgovernmenttosupportlowemissionstransitional technologies that can immediately decarbonize hard-to-abate sectors (e.g. commercial transportation) and help bridge the zero-emission technology availability gap.
   Rationale:
   Transitional technologies provide Canada with the opportunity to immediately reduce emissions in sectors that currently await the commercialization of zero emission technologies. For example, British Columbia’s updated CleanBC Roadmap introduces a zero-emission vehicle (ZEV) mandate for medium and heavy-duty vehicles [2]. Modelled after California’s proposed policy, the province will likely require that 5% of HDVs sold in 2024 be zero emission, increasing to 30% by 2030 [3].

   With the current readiness level of heavy-duty zero emission technologies, as they are currently defined, it will be difficult for BC and the rest of Canada to meet established GHGreduction targets. Expanding the ZEV definition to include other low emission technologies, like HICE, or making commercially available low emission technologies like hydrogen-diesel co-combustion or other dual-fuel and co-combustion technologies eligible for regulatory compliance, will enable the province to reduce its emissions more rapidly with transitional technologies in the short to medium term.

Minister Wilkinson, we appreciate your consideration of our request to expand the government’s support for decarbonization technologies to include all available technologies. Please do not hesitate to contact me if we can provide additional information to you or your staff.

Thank you for your time and consideration,

Jessica Verhagen
CEO