I wish to provide some…

I wish to provide some insight into the issue pertaining to this amendment given my background, experience, and current research activities. My knowledge of southwestern Ontario’s sub-surface geology has been gathered over my professional career as a geoscientist. I am currently a Professor at a large university in Ontario. My research activities include working with an institutional research center related to sustainable energy innovation and policy. My work in this space has been published in several prominent peer-reviewed journals. A current project involving a multiple institutional team is exploring CO2 capture and sequestration (CCS) technologies. As part of that research, my responsibility is principally related to innovation commercialization and, given my geoscience background, includes the evaluation of southwestern Ontario’s existing subsurface reservoirs for CCS. In discussion with various members of the Ontario Petroleum Institute, this amendment was brought to my attention. Accordingly, I would like to share some of my research related to the use of existing oil and gas reservoirs for CCS.

There is debate regarding the use of enhanced oil recovery (EOR) for CCS purposes. On one side are those who argue that CCS as part of any CO2 -EOR project is simply encouraging the production of carbon-emitting fossil fuels. The contrary argument is that the combination of CO2-EOR and CCS is required to encourage CCS at scale because it is currently economic to do so and that growth in this area will contribute to reduced CCS costs and eventual development of additional non-fossil fuel related CCS activities in reservoirs above and below the initial EOR operation. I wish to submit my professional and academic opinion to this argument.

Firstly, I am a product of the Canadian oil and gas industry having profited from my involvement in it for over 25 years. However, I wish to point out that, like a reformed-smoker, I have become a more critical appraiser of the activities of oil and gas on our environment. I remain pragmatic in recognizing that our society continues to use oil and gas as significant energy sources for transport and heating in Canada. My research into consumer knowledge, attitudes, and behaviour when it comes to environmental sustainability continues to identify a disconnect between pro-environmental consumer attitudes and their actual behaviours. To think that Canadians will rapidly move away from fossil fuel use is misguided. Pro-environmental attitudes do not translate to pro-environmental behaviour on a large scale when there is a cost to do so. Relatively low natural gas prices and oil price stability, controlled by OPEC’s supply elasticity, will continue to make fossil fuel use economically attractive for the near and medium term. While increasing carbon taxes could expedite a consumer movement away from fossil fuels, past anecdotal evidence has shown that political resistance to higher energy costs can be a barrier to policies that would increase energy cost to the consumer.

Secondly, Canadian carbon tax policy could continue to increase annually the value of carbon but, at present, that policy includes carbon rebates to households. Very current research (Mildenberger et al. 2022; Benjamin et al. 2022) suggests that it is likely that the Canadian carbon tax escalation will receive increased resistance from the public. Therefore, relying on future carbon pricing policy to support the economic value of non-EOR investment in CCS remains very risky.

Thirdly, absent the certainty of an economic return on investment in non-EOR CCS, the only economically attractive option for CCS is that associated with EOR. However, while that supports the economic sustainability of that approach, what is the impact on environmental sustainability? That question was recently addressed in a peer-reviewed study (Núñez-López et al., 2019) where an environmental and operational performance of CO2-EOR as a CCS technology was undertaken considering an environmental life cycle assessment approach. Their study confirmed that CO2-EOR can be operationally designed to both enhance oil production and reduce greenhouse gas emissions into the atmosphere. Furthermore, the argument that CO2-EOR is required to stimulate the development of large-scale saline acquifer CCS projects has been supported by the Clean Air Task Force, an environmental charity.

Fourthly, simple logic would suggest that if there remains growing consumer demand for oil in this country (barring the 2020-21 pandemic anomaly) and an Ontario depleted oil field has more space for CO2 than the CO2 that could be produced from the remaining producible oil reserves, then the net impact would be more CO2 sequestered than produced, thus providing a net environmental benefit.

Finally, I wish to commend the authors of the discussion paper in recognizing the importance of the role that proper engineering design and implementation will take with CCS. As with my experience in the underground gas storage field, storage operations can be safely conducted when sound engineering and planning has been applied. Industry experience with CO2-EOR operations has existed for several decades and proper engineering and operating protocol exists to ensure safe operations. With appropriate planning and design there is no rational reason that CCS cannot be combined with existing oil and gas operations, in much the same way as natural gas storage operations did in Ontario decades ago (e.g. Consumers Tecumseh [Enbridge] and Imperial Oil’s Kimball Collinville storage pool and Union Gas and Imperial Dawn 156 storage pool).

References
Benjamin, E. O., Hall, D., Sauer, J., & Buchenrieder, G. (2022). Are carbon pricing policies on a path to failure in resource-dependent economies? A willingness-to-pay case study of Canada. Energy Policy, 162, 112805.
Clean Air Task Force (2019) https://www.catf.us/2019/06/leveraging-enhanced-oil-recovery-for-large-…
Mildenberger, M., Lachapelle, E., Harrison, K., & Stadelmann-Steffen, I. (2022). Limited impacts of carbon tax rebate programmes on public support for carbon pricing. Nature Climate Change, 1-7.
Núñez-López, V., Gil-Egui, R., & Hosseini, S. A. (2019). Environmental and operational performance of CO2-EOR as a CCUS technology: a Cranfield example with dynamic LCA considerations. Energies, 12(3), 448.