These comments are in…

These comments are in response to the proposed new Geologic Carbon Storage Act (Environmental Registry of Ontario posting # 019-9299). Comments on behalf of the Municipality of Chatham-Kent are set out below.

Future Risks to Communities

In Chatham-Kent, we have recently experienced a local emergency as a result of a historic gas well, which caused gas leaks and a prolonged evacuation in the community of Wheatley. With that recent experience in mind, there are concerns about the use of underground storage for carbon capture.
There has been a long history of gas well drilling in Southern Ontario, including in Chatham-Kent. There are 219 known wells within Chatham-Kent identified from the OGSR Library information as having penetrated the Precambrian formation in the last 100+ years. Besides these know wells penetrating the Precambrian formation, Southwestern Ontario has significant historic well population, including many wells that are, as yet, undocumented. Historic gas wells may not be reliably capped, resulting in potential paths to surface from deep underground, or potential pathways between geologic zones.
A review of documented wells in Chatham-Kent indicate that wells abandoned prior to the mid 1990’s may not be isolated between the oil producing zones and the Precambrian formation. This leads to several questions and concerns for our community:

• Could this lack of isolation allow cross flow between zones?
• Is the depth of the storage zone, and a single caprock layer, sufficient to ensure there will be no release of CO2, or pressure on historic wells and oil/gas producing layers?
• Can historic well construction methods be relied upon, or may there be risks of well failure?
• Can our community be assured that the abandonment methods for these wells will stand up to an increase in differential pressure across the plugs used in abandonment?
• Have historic wells been constructed with casing or cementing materials to withstand CO2 intrusion?
• May induced seismicity from CO2 disposal result in, or impact, fractures or faults in the earth, leading to inadvertent escape from the storage complex?

If the Province is satisfied that these questions and concerns have been addressed, Chatham-Kent continues to advocate for a more robust approach to long term monitoring, maintenance and mitigation of any uses of the subsurface areas below our community. If these matters are not appropriately dealt with, there are risks that our community may be subject to some other emergency in the future. As a result, detailed engineering work, along with peer study, and a thorough inspections and approval process is required. A Provincial team of experts should be involved in detailed regulation, and approval of design and monitoring this new technology. Provincial staff in this area should be available to municipalities to take the lead on any issues that arise.

Installation of Pipelines and Related Costs and Benefits

Chatham-Kent, along with many other Ontario municipalities, has experienced past issue regarding pipelines being installed within municipal lands, including road allowances. It is important that any regulatory approach properly reflects that there are costs to these installations, including damage to infrastructure through overuse or impacts to soil integrity, inconsistencies between these pipes and other public uses, and issues related to abandonment and decommissioning of pipelines. Without a robust process to ensure that all these costs are borne by the beneficiaries of the program, local citizens are left holding these costs. A process to ensure that Municipal support and approval for any pipeline installation, with adequate plan review, financial compensation and decommissioning plans, is vital.

Community Benefits and Tax Matters

This type of carbon capture technology will act as a benefit to citizens and businesses beyond the communities who are impacted by the project. As a result, a community benefit agreement for jurisdictions that will host the projects, or any parts of the projects, should be included in plans for developing carbon capture initiatives. This is similar to how landfills and other waste disposal projects are handled.

How these facilities will be taxed and a process for tax collection is needed. Current feeder lines for gas exploration often result in uncollected taxes for municipalities, resulting in write offs and costs to local communities.

Economic Development and Sustainability

Commercial-scale geologic carbon storage may provide specific opportunities for the vegetable growing greenhouse industry in Chatham-Kent and area. The feasibility of diverting carbon dioxide for distribution within greenhouses to achieve optimal levels of this input should be studied. The goals of emissions management, production of low-carbon hydrogen, the transition to a low-carbon economy, preserving high-value jobs, attracting investment, and encouraging innovation align with Ontario’s own Agri-food Strategy and the pursuits of the greenhouse industry.