Thank you for the…

Thank you for the opportunity to review and provide feedback on the development of Ontario’s regulatory framework for Commercial Scale Geologic Carbon Storage Projects. Please find attached TC Energy’s submission, summarizing feedback in alignment with the questions raised in your Discussion Paper: Regulating Commercial Scale Geologic Carbon Storage Projects in Ontario.

To highlight a few of our comments, TC Energy is supportive of the phased approach to expanding carbon storage projects in Ontario that the MNRF has proposed for the development of a regulatory framework.

In addition, TC Energy supports a staged approach to development, as staged authorizations enable project developers to de-risk the project in stages and minimize capital exposure.

We agree with best practices that early and ongoing engagement is necessary to build long-term, constructive relationships between project proponents and Indigenous groups and other parties who may be affected by a proposed project. Commercial-scale geological carbon storage projects should be no different. Notification and engagement requirements must be flexible to allow for project-specific engagement to be developed and adapted commensurate with the nature, location, scale, scope, potential effects and phase of the project, and to the identified interests, information needs, and degree of concern expressed.

Regarding operational controls such as Monitoring, Measurement and Verification (MMV), post-closure plans and funding, and understanding ownership of liability during and post-injection, we believe these should all be put in place to ensure safe and responsible development, operation and decommissioning of commercial scale carbon storage.

In conclusion, TC Energy looks forward to opportunities to provide further feedback on the development of Ontario’s regulatory framework regarding sequestration. We will continue to work closely with our neighbors, customers, Indigenous peoples and governments to build relationships, create mutually beneficial opportunities and build the energy systems of the future.