Need to Move Quickly •…

Need to Move Quickly
• Ontario is behind the curve in terms of developing the legal and economic framework that would accelerate the expansion of carbon storage projects in the province.
• Due to the recently passed Carbon Capture, Utilization, and Storage tax credits, potential projects are becoming economically viable, and Linde is evaluating with business partners on how to investment across Canada in this decarbonization technology.
• We encourage the Ministry to move quickly and finalize the required legislation and regulations to support carbon storage in Ontario.
• The federal government tax credits are set to expire, and proponents must make final investment in the near term in order to access the full value of the incentives to support carbon capture and storage projects.

Long Term Liability
• Currently in Ontario, potential participants in a carbon storage project run the risk of taking on the perpetual liability for a carbon storage site. To facilitate the development of this industry, we encourage the Ministry to take on the approach where following the issuance of a closure certificate, the Crown assumes long-term liability for the CO2, the site, and the well that make up the carbon storage.
• We encourage the Crown to take on long term liability after any geologic carbon storage project is completed and closed in a satisfactory manner that meets the stringent safety and security requirements of the government.
• As carbon storge industry is just getting started, the risk is too high and it is not economically viable for proponents to provide financial assurance and assume long-term liability for commercial scale storage projects following their regulated closure.
• Without long-term support from the government, geologic carbon storage could be untenable.

Pore Space
• Due to the extent that underground geologic formations don’t follow the boundaries of land ownership, the operator must be able to control the entire formation in order to develop a successful carbon storage project. There could be dozens, even hundreds of surface owners involved in any project, depending on the proposed location.
• It is fundamental to the success of carbon storage in Ontario that the Crown assume responsibility for both the vesting and the allocation of pore space under both private and Crown lands to support viable carbon storage projects.
• This is an imperative step in protecting the viability of projects and ensuring that carbon storage proceeds in Ontario.
• This approach also eliminates the risk of land speculators and/or landowners from effectively blocking viable projects so that project proponents are able to secure the necessary rights for a commercial scale project in a timely manner.