The Canadian Steel Producers…

The Canadian Steel Producers Association (CSPA) is the national voice of Canada’s $15 billion steel industry. Our members annually produce approximately 13 million tonnes of crude steel as well as over one million tonnes of steel pipe and tube products in facilities located across Canada. Domestic steel operations directly employ some 23,000 Canadians while supporting an additional 100,000 indirect jobs.

We have carefully reviewed the ERO Posting 019-7507 and appreciate the opportunity to provide the following feedback.

While geological carbon sequestration may not be the sole solution to achieving a net-zero economy, it undeniably plays a pivotal role as we jointly strive to innovate and discover new methods to curtail carbon emissions. The proposed regulatory provisions pave the way for both proponents and the government to evaluate the potential of introducing green technology by examining and showcasing the feasibility of carbon sequestration in Ontario.

We acknowledge that a broader regulatory overhaul will be essential to fully commercialize carbon sequestration in Ontario. However, we would like to emphasize a few important elements of the proposed regulatory provisions:

1. Pore Space Rights: The provisions suggest that carbon storage special project applications necessitate applicants to verify the acquisition of all requisite rights pertaining to the lands where the project is to be situated. While securing surface rights on private lands seems feasible for pilot projects, there is a need for explicit guidance on procuring rights for the pore space beneath these lands.

2. Long Term Liability: The provisions mandate a report from a neutral entity proficient in insurance aspects linked to environmental and analogous subsurface operations in Ontario. This report should recommend the necessary insurance types and amounts for the proposed project, encompassing liability and pollution coverage. Given the current absence of geological carbon storage in Ontario, the specifics and expenses of third-party insurance for such projects remain ambiguous. Our apprehension deepens if the Ontario government suggests third-party insurance to manage long-term liabilities for expansive commercial carbon storage endeavors, potentially rendering carbon storage impracticable.

3. Notification and Engagement Requirements: The provisions outline the foundational criteria for notifying and collaborating with stakeholders, including landowners, local and regional municipalities, and Indigenous communities. We stress the importance of continued support from the provincial government throughout all stages of notification and engagement for every carbon storage initiative.

In conclusion, as we navigate the complexities of transitioning to a net-zero economy, it is essential that regulatory provisions are clear, feasible, and supportive of innovative endeavors like carbon sequestration and storage. The Canadian Steel Producers Association remains committed to collaborating with the government and stakeholders to ensure that these provisions not only safeguard our environment but also foster growth and innovation in green technology. We believe that with mutual understanding and proactive engagement, we can collectively pave the way for a sustainable future for Ontario.