Re: ERO 019-6752 – Next…

Re: ERO 019-6752 – Next Steps on Carbon Capture, Utilization and Storage (CCUS)

I am writing to provide feedback on the proposed amendments to the Oil, Gas and Salt Resources Act to create an authorization process for special projects to test or demonstrate new activities, such as carbon storage.

Building on comments provided in our submission dated December 22, 2022, and our remarks at the Standing Committee on Finance and Economic Affairs on February 8, 2023 (see attached), we believe the policy direction signalled by MRNF so far is a step in the right direction but will not allow Ontario to move fast enough to fully capture the opportunity afforded by CCUS technology. What is needed is a comprehensive framework covering both private and crown lands to allow the timely building of utility scale infrastructure for use by industrial customers to abate emissions.

This framework should be informed by the experience of neighboring jurisdictions like Alberta and British Columbia, which have already adopted regulations qualifying investments in those jurisdictions for the federal CCUS tax credit. This includes vesting all saline aquifer pore space for purposes of CO2 storage to ensure the maximum benefit to Ontarians and introducing a streamlined regulatory framework with stringent technical, financial and safety requirements for proponents of new CCS demonstrations, pilots or projects. To promote a consistent approach and regulatory certainty going forward, pore space vesting by the Crown should occur prior to designating special projects.

CME urges the government of Ontario to develop and announce such a comprehensive framework at the earliest convenience.