ERO number


Comment ID


Commenting on behalf of


Comment status

Comment approved More about comment statuses



MARCH 14, 2022

The Geologic Carbon Storage in Ontario Discussion Paper (January 2022) provides a cursory proposal for carbon storage in the province. It generally follows the Natural Resources Canada carbon capture, utilization and storage plan. The province states that they anticipate neutral to positive environmental, social, and economic consequences of the carbon capture proposal. However, the impacts to Métis Nation of Ontario citizens may range between negative to positive, dependent on the scale and type of project. A general overview of the geological, engineering, and technical aspects of carbon capture are presented below to provide the current understanding of carbon capture and how it may impact Métis Nation of Ontario citizens.
Anthropogenic climate change is an immediate- to long-term global threat (IPCC, 2022). One major contributor to climate change is the release of carbon into the global environment, such as through the burning of fossil fuels, power generation, industrial extraction, and other sources. One tool to mitigate climate change is through carbon capture and storage which is the subject of this Discussion Paper. The Ontario government currently does not have existing laws and regulations in place to address carbon storage and this is the first proposal to remedy this issue. The Discussion Paper addresses the need to update the Mining Act and Oil, Gas and Salt Resources Act under the Ministry of Northern Development, Mining, Natural Resources and Forestry (NDMNRF) to address carbon storage. This response to the Geologic Carbon Storage in Ontario Discussion Paper (January 2022) addresses the technical, economic and policy dimensions and how they may impact Ontario and Métis Nation of Ontario citizens. The Métis Nation of Ontario encourages ongoing engagement and consultation as the carbon capture policies are developed.

Carbon storage has been at the forefront of geoengineering and climate change policy since the start of the 21st century. It involves capturing carbon dioxide (CO2) and other carbon-rich gases that are released by fuel combustion and industrial processes, then transportation of the carbon, and then lastly storing (or “capturing”) it indefinitely (e.g., on a geological timescale). Canada has been a global leader in carbon capture and was a case study in the IPCC Third Assessment Report (2001 a, b). In fact, the first IPCC workshop was held in 2002 in Regina, Saskatchewan, Canada, the homelands of the Métis Nation of Saskatchewan.
The Ontario government has provided their first Discussion Paper on carbon capture strategies for the province in the “Geologic Carbon Storage in Ontario Discussion Paper (2022)”. The Discussion Paper broadly follows the current Federal Natural Resources Canada carbon capture, utilization and storage plan at a high level. It touches on a few topics put forth by the IPCC (2001-2022) however it does not significantly address them, particularly the topics related to capture, transportation, engineering, and sciences. The IPCC has produced numerous reports since 2001 to address carbon capture and storage and is the standard to which most countries strive towards. Both the federal and IPCC frameworks should be used as a reference guide in the next iteration of the Ontario’s policies on carbon capture.
Many other countries have also adopted carbon storage as an economic and environmental tool to combat climate change and provide socio-economic opportunities. Of particular relevance to the Métis Nation of Ontario are the countries with successful carbon capture policies and large and diverse Indigenous populations including: Brazil, Finland, and the U.S.A. among others. Extensive literature has previously been conducted globally as well as throughout Canada concerning Indigenous carbon rights, offset regimes, and accounting and should also be referenced in upcoming carbon capture policies (Dohan, and Voora, 2010 and references therein).

All Earth systems, including the atmosphere, ocean, cryosphere, and biosphere are unequivocally changed by anthropogenic influence (IPCC, 2021, 2022). Global atmospheric annual averages for carbon dioxide (CO2) are 410 parts per million (ppm) and 1866 parts per billion (ppb) for methane (CH4), both up since the last IPCC report in 2011 (IPCC, 2021). Current projections include rising global mean temperatures, rising sea levels, and increased frequency of heat waves.
Carbon storage is one of many interventions that can be utilized to reduce anthropogenic impact to the global climate. Carbon storage requires a chemical reaction to occur between dissolved CO2 and minerals to form ionic species so that some of the injected CO2 will be converted to solid carbonate minerals over geological time. To develop carbon storage there must be a source of CO2, capture, transport, and storage. Currently there are numerous sources of CO2 globally, nationally, provincially, regionally, and locally which are available for carbon capture. Carbon capture and storage consists of the separation of CO2 from source materials that require advanced geotechnical and engineering processes to be successful. Transportation requires significant infrastructure, typically by pipeline, rail, or water and also require substantial engineering and monitoring. Storage and isolation from the global ecosystem may include underground geological storage, ocean storage, and mineral carbonation and industrial uses.

Point sources of industrial activities of worldwide, large, stationary CO2 sources with significant emissions include those by fossil fuels (i.e. power generation, oil and gas processing, petrochemical industry, mines, refineries, cement, and steel industry) and biomass (i.e. bioenergy). These point sources are located throughout Ontario, including those in the traditional territories of the Métis Nation of Ontario.

The capture of CO2 from a point source is dependent on producing a concentrated stream that can be safely used in house or transported offsite. The three main types of capture for industrial or power plant applications include:
1) Post-combustion
2) Pre-combustion
3) Industrial process streams
Pre-combustion processes the fuel in a reactor to produce streams of both CO2 and hydrogen (H2) to be used as fuels. Post-combustion capture separates CO2 from flue gases after combustion of a fuel (i.e. natural gas, oil, biomass). Industrial process streams also capture CO2, however most of the CO2 is vented to the atmosphere as there may be no economic advantages to doing so. Other processes are at various stages of development.
Post-combustion, is economically feasible in most settings and captures CO2 from gases in power plants or gas processing industries. Pre-combustion is also possible and is used in fertilizer manufacturing and hydrogen production, although costlier. However, pre-combustion has higher concentrations of CO2 in the gas steam and make separation easier. Industrial process streams are numerous including cement, steel, and food processing.

When transportation is required it is currently transported as gas, liquid and solid through tanks, above ground and underwater pipelines, and ships. One land CO2 pipeline in Canada is the Weyburn Pipeline between North Dakota, U.S.A. and Weyburn, Saskatchewan. The type of transportation required is dependent on the distance to compressors, infrastructure, safety and the market. Rail and road transportation is also possible but unlikely due to options requiring large-scale transportation needs. Safety is a consistent concern in Canada and particularly in the transportation via pipeline, rail, and ship. Failure and accident rates in pipeline and ship have a general strong safety record and subject to regulatory approval and standards. International standards of CO2 transport are governed by the American Society of Mechanical Engineers Pipeline Transportation Systems for Liquid Hydrocarbons and Other Liquids (ASME B31.4).

1) Geological Storage
2) Ocean Storage
3) Mineral Carbonation
The first option, geological storage, include methods utilizing geological formations such as sedimentary oil, gas, and coal formations. The second option is ocean storage through direct release into the water column. As Ontario has no direct access to ocean or sea this option will not be discussed here. There may be future potential for lake storage but that has not yet been developed. The third option is fixation of CO2 into inorganic minerals, including carbonates. Currently the most common and economical option is geological storage. Geological storage captures CO2 from a source, transported via pipeline or other methods, and then injected into rock formations. This process mimics and speeds up the natural rock cycle that already occurs in the crust and mantle. Carbon dioxide storage has been utilized since the 1990s in the Alberta and Saskatchewan petroleum industries.
For CO2 storage to occur there must be the source, capture and transportation steps listed above. There must also be an economical market for carbon capture, community support and political will. The process for geological storage requires the CO2 to be compressed into a supercritical fluid (a dense, gas-liquid state) typically at depths greater than 800 meters. Once these parameters are reached the geological storage can be undertaken in many types of geological settings. The settings with the greatest potential include sedimentary basins, oil and gas fields, coal seams and saline formations both onshore and offshore (ocean storage). All geological storage requires specific rock types, mineralogy, textures, permeability, porosity, hydrology, seismicity, pressure gradients, diffusion rates, absorption rates, structures and other chemical, mineralogical, and geological characteristics. It cannot be understated that effective, safe and economic carbon storage requires a very specific set of geological requirements to be met. Long-term storage security and stewardship monitoring is critical in the carbon storage process and all of the above components must be assessed and monitored for safe and effective carbon storage.
Mineral carbonation requires different rock formations, including mafic to ultramafic volcanic and plutonic igneous rocks and metamorphic rocks of those same protoliths. Alternatively, these processes may also be produced in an industrial or lab setting. Mineral carbonation is based on the reaction of CO2 with metal oxides or silicates to form carbonate minerals, particularly those with calcium, iron and magnesium. Materials can include naturally formed minerals, including silicate rocks or high-magnesium minerals including olivine and serpentine or industrial residues such as waste or slag materials left over from industrial processes. The process may take place in a processing plant after mining or by injecting CO2 into the geological formations. The later requires additional processing steps and a greater energy input.
The most common and cost effective reactions required for carbon storage by mineral carbonation are listed below:
1. Mg2SiO4 + 2CO2→ 2MgCO3 + SiO2+ 89 kJ mol–1CO2 (olivine)
2. Mg3Si2O5(OH)4 + 3 CO2→ 3MgCO3 + 2SiO2 + 2H2O+ 64 kJ mol–1CO2 (serpentine)
3. CaSiO3 + CO2→ CaCO3 + SiO2 + 90 kJ mol–1CO2 (wollastonite)
Mineral carbonation carbon capture requires less monitoring is a more permanent option than the previously mentioned type of geological storage. Limiting factors for mineral carbonation carbon capture are typically the lack of mining infrastructure, proper mineralogy and rock types. However, Ontario has both extensive mining districts with these correct mineralogy and rock types. Mineral carbonation is also a newer technology than standard geological storage in sedimentary rock formations which has been the greatest limiting factor to date.

All components of carbon capture listed above have the potential to be economically viable in Ontario. Site-specific considerations must be taken into account to assess market viability, community support, technology, environmental assessment, political support and safety. Cost estimates and market value range significantly between sites. Currently there are no approximations for the value in Ontario, however some comparison can be made between other North American and European sites. The global value of increased carbon storage in relation to climate change is marketed as invaluable and estimates of thousands of gigatonnes of CO2 have the potential to be captured. Financial estimates of market value by energy and economic modelling suggest prices range approximately from 25–30 US$/tCO2 (IEA, 2004; Johnson and Keith, 2004; Wise and Dooley, 2004; McFarland et al., 2004) to 45-60 US$/tCO2 (Hepburn et al., 2019).

The Discussion Paper provides the first cursory proposal on the potential of carbon storage in the province of Ontario. The entirety of the proposal is based solely on carbon capture via geological storage in one type of rock formation located in southwestern Ontario. The tone of the entire Discussion Paper is limited by the lens of economic recovery due to the COVID-19 pandemic and support for businesses and not environmental recovery, stewardship, and improving global climate.
The new proposal with the inclusion of carbon storage into the Mining Act and Oil, Gas and Salt Resources Act would allow for:
1. Reduce prohibitions on injection of carbon dioxide for the purpose of carbon storage to enhance the recovery of oil or gas.
2. Allow the MNDMNRF to grant use of Crown land for carbon storage.
3. Expand the Oil, Gas and Salt Resources Act to allow for the MNDMNRF to enter into agreements with companies to use wells to explore, test, pilot or demonstrate new technologies, including carbon storage.
4. Enhance corporate accountability and protections to prevent risks to the public or environment.

The Discussion Paper proposes that the pilot projects would occur in southwestern Ontario in the regions with petroleum and salt production and underground storage. Detailed investigation, site selection and data collection would be required to progress beyond a pilot trial. Currently there is a prohibition on the injection of CO2 for storage in Ontario under the Oil, Gas and Salt Resources Act. The proposed changes would allow for carbon storage in wells regulated under this Act. Changes to the Mining Act are also required as there is also a prohibition on the permanent storage of any substance. The proposal states that changes would accommodate permanent storage and would be limited to carbon storage only involving Crown land.
The proposal is limited in that it only includes sedimentary rock formations in the southwest and lacks detailed scientific or engineering reasoning as to why other geological formations throughout Ontario would be less acceptable. It also states that, “… as our knowledge of the geology of Ontario and technology for carbon storage advances” they will be more willing to expand. The current scientific, technological, and engineering fields are sufficiently advanced to fully support both the geological and technological potential throughout Ontario. However, the political and socio-economic potential and support must be in place first and may be the real limiting factors.

Changes to the Oil, Gas and Salt Resources Act would allow for the MNDMNRF to create the authority to enter into agreements with proponents to test, pilot, or demonstrate new technologies in petroleum or salt resources. Agreements between the ministry and proponent are described as “nimble” to support the needs of the project while also protecting public and environmental safety. Proponents would be required to address all phases of the project including long-term management, monitoring, and ongoing management post-closure.
The appeals process or hearing by the Ontario Land Tribunal or Ontario Energy Board under the Oil, Gas and Salt Resources Act will not occur during the pilot or demonstration stage of projects. The lack of democratic and legal oversight is problematic as any stage of mining and mining-related projects have the potential to impact the environment, society, Indigenous rights, and other down-stream effects. Preventative orders could be made under the Act to avoid or reduce risks, however these are not described other than provisions to hold directors of corporations accountable. How oversight will be conducted and enforced is not provided.

The proposed changes in the Discussion Paper provide an initial step towards carbon storage regulation and management in Ontario. The ministry is confident that they will learn the needs of proponents during the pilot and demonstration projects and these will dictate a more standardized regulatory framework. MNDMNRF does not state how the needs of Ontario Métis Nation of Ontario citizen’s needs will be met by these projects. This framework will accommodate commercial projects and provide standards for public and environmental safety. Future framework for commercial projects will address how long-term carbon storage and management will fall on the responsibility of the proponent and not Ontario citizens.

The Geologic Carbon Storage in Ontario Discussion Paper (January 2022) put forth by the MNDMNRF provides a cursory overview of carbon storage in the province. The preliminary Discussion Paper highlights and addresses potential economic issues and impacts for potential proponents. It does not address the increased workload to ministry staff which will in fact increase administrative costs to the public, contrary to their statement.
The Discussion Paper superficially addresses, or does not address, many equally important issues, including scientific, technological, engineering, transportation, processing, socio-economic, environmental, and impacts to Indigenous rights. These must be properly addressed in the next stage of developing carbon storage policies in Ontario.
Of particular concern is the lack of information on how the source, capture, transportation, storage, and market will be included in the carbon storage framework. Carbon storage includes many components and the Discussion Paper reads as if the entire process is always conducted at the point source. While all stages of carbon storage have the potential to affect Métis rights it is the stage of transportation that may be one of the most significant as it can cover broad geographical areas, including Crown land. Cumulative effects of loss of Crown land to Métis Nation of Ontario citizens is of great concern. The framework for monitoring is not described but stewardship monitoring of pipelines and point sources would provide an excellent opportunity for the Ontario government to ensure community participation and oversight. Further details on how Indigenous consultation would be developed is also required and hidden in the technical section.
The Discussion Paper incorrectly states that carbon storage is a new technology with many unknowns. While it is important to start with pilot and demonstration projects for safety reasons it is important to note that carbon storage has been conducted safety and economically for decades in Canada and globally. It is therefore not in fact a new technology with many unknowns. Scientific, engineering, and technological advancement in the field is far more advanced than stated and described. Particularly, the advancement of carbonation in mafic and ultramafic rocks are already past the stage of pilot studies elsewhere. This type of storage is of particular importance to the MNO as these rock types are also located throughout their traditional territories. This includes the MNO Region 3 which hosts world-class mining districts (point sources), transportation corridors (pipeline, rail, road), and mafic to ultramafic lithologies including serpentine. The Third Assessment Report (TAR) by ICPP (ICPP, 2001 a, b) has clearly stated that no single technology will be able to effectively combat successful stabilization of carbon dioxide but a group of mitigation measures. Therefore, it is preferred to use both geologic storage and mineral carbonation technologies. Other foreword thinking measures could also include hydrogen (H+) and helium (He) as other provinces and nations have been successful at, including Saskatchewan. Hydrogen is of particular importance as it is already being utilized in pre-combustion processes. Further research and collaboration with scientific, engineering, and technological experts in the field could greatly improve the next stage in the carbon storage framework in Ontario.
Other similar issues with the Discussion Paper include the lack of geological understanding of how carbon storage sites are chosen. It is stated that the obvious choice is the southwestern Ontario region, which is one excellent choice of many. However, many important factors must also be addressed, including: rock type, stratigraphy, mineralogy, textures, permeability, porosity, hydrology, seismicity, pressure gradients, diffusion rates, absorption rates, structures and other geological characteristics. The other factors beyond point source must always be addressed. Important factors in choosing the site must include knowledge of Indigenous, archeological and paleontological importance - all of which are present in many areas in southwestern Ontario. Incorrect word usage is also noted in the Discussion Paper, including the term “resource” in the context of mining. Review from advanced scientific and technical experts is highly recommended during the next phase of implementing carbon storage in Ontario.
Finally, the statement at the start of the Discussion Paper reads, “The anticipated environmental, social, and economic consequences of the proposal are expected to be neutral to positive.” While this statement may hold true on a provincial-scale it does not mention how impacts could be negative on the local-scale or to Métis Nation of Ontario citizens. Most importantly, the province must consult with Indigenous groups in Ontario to verify this claim. This is particularly relevant as loss of Crown land may negatively impact Aboriginal and/or Treaty rights. All stages of carbon capture may also negatively impact Aboriginal and/or Treaty rights and only through consultation can these impacts be assessed. Engagement and consultation with the Métis Nation of Ontario is required at each step of the process to develop successful carbon storage in Ontario.

Carbon capture is one of many tools to reduce and mitigate climate change. The first proposal from the Ontario government follows the Federal Natural Resources Canada carbon capture, utilization and storage plan. Canada and other nations have been utilizing carbon capture for decades, including nations with involvement from Indigenous peoples. The potential for global- to regional- positive impacts are significant but local- to regional-scale impacts may range from negative to positive, dependent on the project. The Métis Nation of Ontario must be involved at every stage of the process in developing, implementing, and monitoring the carbon capture framework in Ontario as it has the potential to directly impact Aboriginal and/or Treaty rights. The next stage of developing a carbon capture framework must include the most recent research and development in the sector of carbon capture. The framework could model the carbon capture conducted in the Weyburn deposit in Saskatchewan. Incorporation of mineral carbonation is also important as it is well past the research and development stage and is being utilized in other regions.

Dohan, R. and Voora, V., 2011 (compliers): First Nations carbon collaborative Indigenous – Indigenous Peoples and Carbon Markets: An annotated bibliography, International Institute for Sustainable Development, Winnipeg, Canada, 40 pp.
Hepburn, C., Adlen, E., Beddington, J. et al., 2019: The technological and economic prospects for CO2 utilization and removal, Nature, 575, p. 87–97 https://doi.org/10.1038/s41586-019-1681-6
IPCC, 2001a: Climate Change 2001a: Synthesis Report. A Contribution of Working Groups I, II, and III to the Third Assessment Report of the Intergovernmental Panel on Climate Change [Watson, R.T. and the Core Writing Team (eds.)]. Cambridge University Press, Cambridge, United Kingdom, and New York, NY, USA, 398 pp.
IPCC, 2001b: Climate Change 2001b: Mitigation. Contribution of Working Group III to the Third Assessment Report of the Intergovernmental Panel on Climate Change. Metz, B., O.R. Davidson, R. Swart, J. Pan (eds.). Cambridge University Press, Cambridge, UK.
IEA, 2004: Energy Balances of Non-OECD Countries, 2001–2002. OECD/IEA, Paris.
IPCC, 2005: Bertz Metz, Ogunlade Davidson, Heleen de Coninck, Manuela Loos and Leo Meyer (Eds.), Cambridge University Press, UK, pp. 431.
IPCC, 2021: Summary for Policymakers. In: Climate Change 2021: The Physical Science Basis. Contribution of Working Group I to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change [Masson-Delmotte, V., P. Zhai, A. Pirani, S.L. Connors, C. Péan, S. Berger, N. Caud, Y. Chen, L. Goldfarb, M.I. Gomis, M. Huang, K. Leitzell, E. Lonnoy, J.B.R. Matthews, T.K. Maycock, T. Waterfield, O. Yelekçi, R. Yu, and B. Zhou (eds.)]. Cambridge University Press.
IPCC, 2022: Climate Change 2022: Impacts, Adaptation, and Vulnerability. Contribution of Working Group II to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change [H.-O. Pörtner, D.C. Roberts, M. Tignor, E.S. Poloczanska, K. Mintenbeck, A. Alegría, M. Craig, S. Langsdorf, S. Löschke, V. Möller, A. Okem, B. Rama (eds.)]. Cambridge University Press. In Press.
Johnson, T.L. and D.W. Keith, 2004: Fossil Electricity and CO2 sequestration: How Natural Gas Prices, Initial Conditions and Retrofits Determine the Cost of Controlling CO2 Emissions. Energy Policy, 32, p. 367–382.
McFarland, J.R., J.M. Reilly, and H.J. Herzog, 2004: Representing energy technologies in top-down economic models using bottom-up information, Energy Economics, 26,685–707.
Wise, M.A. and J.J. Dooley: Baseload and Peaking Economics and the Resulting Adoption of a Carbon Dioxide Capture and Storage System for Electric Power Plants. In, E.S. Rubin, D.W. Keith and C.F. Gilboy (eds.), Proceedings of 7th International Conference on Greenhouse Gas Control Technologies. Volume 1: Peer-Reviewed Papers and Plenary Presentations, IEA Greenhouse Gas Programme, Cheltenham, UK, 2004."