Executive Summary and Top 5…

Executive Summary and Top 5 Recommendations are pasted below while the full document is attached here in .pdf format.

Executive Summary and Top 5 Recommendations
Enbridge supports the Government of Ontario’s intent to enable CCS in Ontario and we remain committed to continue working with government, local communities, and our partners to help inform next steps. At this time, we believe there are significant considerations that must first be resolved and clarified in order to ensure that CCS is developed safely and efficiently before any actions are taken to unlock the potential for ad-hoc drilling into the Cambrian saline reservoir as is contemplated by the current proposed draft for special projects regulations. The proposed regulations have aimed for speed and flexibility; however, from the lens of large emitters and project proponents, these require greater clarity and alignment toward an overall vision for a safe, efficient, and robust CCS industry in Ontario.

Enbridge and our industry partners recommend that the Government of Ontario first address the larger, more strategic issues related to CCS that have not yet been resolved (e.g. pore space vesting, which Alberta and B.C. have provided best practices to learn from). Not addressing these issues up front adds greater uncertainty and delays for significant investment and job creation in the province while opening the door for potential legal complications and jeopardizing public acceptance.

It is imperative that Ontario gets this right and starts with a strong policy foundation informed by best practices from other jurisdictions like Alberta and British Columbia. Enbridge supports the Ministry of Natural Resources and Forestry (MNRF) and other key ministries in taking a leadership role to support and enable the CCS industry in Ontario. Government’s stewardship and strategic control of all Cambrian saline reservoirs suitable for CO₂ storage is needed immediately to ensure the optimal development of this resource.

Enbridge recommends the Government of Ontario swiftly implement the following 5 actions as listed here before advancing the provisions in the ERO proposal:

1. The Government of Ontario must leverage best practices (e.g. those from Alberta and British Columbia) and assume control and stewardship over the Cambrian saline reservoir in Southwestern Ontario – under both private and public lands, together. Vesting the Cambrian saline reservoir pore space, like Alberta did in 2010, would send a strong signal that Ontario is serious about being actively involved in managing this precious resource for the benefit of all Ontarians. This action should be taken upfront and before moving ahead with any regulations as proposed in this ERO. This would also signal that Ontario would only review and approve any CCS project after a thorough technical and safety review. This was recommended in the joint policy memo released in summer 2023 by the C.D. Howe Institute and the International CCS Knowledge Centre available online here.

2. Release the draft framework for commercial-scale geologic carbon storage projects before allowing any incremental well penetrations into the Cambrian reservoir (via special projects designation or otherwise). The framework should ideally include signals that Ontario intends to:
a. Initiate a Request for Proposal (RFP) type of process to receive competitive proposals for evaluation of the Cambrian reservoir for CCS. Approve RFP’s based on a scoring system across all eligibility requirements (see Eligibility Requirements for Special Projects below), evaluation rights (similar to the Alberta process) and,
b. Subsequently regulate and approve large scale commercial CCS projects to facilitate cost effective open access regional hubs under both private and public land and,
c. Provide a potential path or process for the CCS Hub operator to transfer the long-term liability from the CCS Hub operator back to the crown after a successful implementation of an approved closure plan.
d. Ensure that participants in each part of the CCS value chain (capturing, transporting, and storing of CO2) can monetize the value of the emission reduction benefits so as to adequately incentivize commercial-scale projects.

3. Signal other legislative amendments to set up CCS success, including amending the Mining Act to allow for permanent CO₂ storage on Crown land and regulatory amendments including for the Emissions Performance Standards (EPS) to provide non-registered emitters the ability to create credits and offsets through CCS. These are outlined below and in previous submissions.

4. Merge the currently bifurcated “private” then “public” land processes. Over two-thirds of the potential Cambrian reservoir is under Crown land and any CO₂ injections near the shoreline boundary will result in a CO2 pressure rise under both the nearby private and public land. This bifurcated approach is not required and does not reflect the hydraulic reality of CO₂ plumes and pressures.

5. Work with the Government of Canada to ensure that Ontario becomes eligible for incentives, including the CCS Investment Tax Credit as soon as possible.

Drilling CCS evaluation wells is costly but necessary in order to gather further data on Ontario’s pore space potential, and the province has one chance to get the development of a legal and regulatory framework right. Without setting the stage for the strategic vision of how CCS will work in Ontario, there are significant uncertainties, and it is difficult to attract the serious investment with the requisite safety, financial, and technical expertise needed to drill and evaluate while these larger issues remain unclear. Without clarifying the above issues, any projects that do move ahead to drill and conduct injection tests with these uncertainties will likely be involved in litigation if they were ever to propose converting those wells into commercial operation, while also undermining public acceptance of CCS.