THIS COMMENT SECTION ONLY…

THIS COMMENT SECTION ONLY INCLUDES THE EXECUTIVE SUMMARY. PLEASE SEE THE DOCUMENT ATTACHED FOR ENBRIDGE'S FULL SUBMISSION.

Executive Summary
Enbridge is uniquely positioned to build, transform and maintain the low-carbon energy system Ontario needs. Climate change requires serious attention, and Enbridge is well equipped to be a part of the solution. Across our business, we’ve committed to achieve net-zero greenhouse (“GHG”) emissions by 2050 and to reduce our emissions intensity 35% by 2030.
We are pleased to provide this submission in response to the Ministry of Northern Development, Mines, Natural Resources and Forestry’s (the “Ministry’s”) Discussion Paper on Geologic Carbon Storage in Ontario (the “Discussion Paper”). We are encouraged that the Government of Ontario (the “government”) is seriously exploring ways to enable and support the safe and permanent sequestration of carbon dioxide (“CO2”) in the province, which we see as critical to ensuring the long-term competitiveness of many hard-to-abate, emission intense, trade exposed (“EITE”) sectors of Ontario’s economy, including steel and cement production, oil and gas refining, petrochemicals, and gas-fired power generation. Carbon sequestration will also be critical to unlocking low-cost low carbon hydrogen production in southwestern Ontario.

In developing a regulatory framework for carbon capture and sequestration (“CCS”) in Ontario, we encourage the government to be guided by five key principles:
1. Positioning Ontario as a CCS leader;
2. Removing the regulatory barriers to CCS in Ontario;
3. Creating a streamlined approval regime for new CCS projects;
4. Encouraging commercial-scale CCS projects; and
5. Facilitating cost-effective and scalable carbon capture, utilization and sequestration (“CCUS”) infrastructure across the province.

Enbridge fully supports and encourages the government to move quickly to make needed legislative and regulatory changes that would enable and support geologic sequestration of CO2.
Summary of recommendations

Building on the five key principles above, Enbridge offers the following recommendations in response to the Discussion Paper. We recommend the Ministry:
1. Expedite the consultation and amendments necessary to fully enable and support CCS in Ontario to take advantage of Ontario’s unique geology, the environmental imperative and business case for CCS and the growing regulatory momentum in this space.
a. Provide a clear signal to industry by Q3 2022 with a timeline for legislative changes to help ensure CCS investment continues to focus on potential opportunities in Ontario.

2. Amend the relevant legislation and regulations to remove the barriers to CCS in Ontario:
a. Amend Oil, Gas and Salt Resources Act (“OGSRA”) to revoke section 11(1.1) in its entirety, thereby removing the prohibition on the use of wells for CO2 injection in underground formations generally or for enhanced oil and gas recovery; and
b. Amend the Mining Act to allow for storage leases that authorize the permanent storage of CO2 on Crown lands, while ensuring that such leases can cover broad geographic areas and be applicable to specific stratigraphic zones.

3. Establish a streamlined approvals regime for new CCS projects to provide certainty to investors and emitters:
a. Enact a permitting regime for CO2 wells, injection activities and related surface facilities such as CO2 pipelines, which is modelled after the existing regime for compressed air energy storage (“CAES”) projects under the OGSRA;
b. Ensure this regime is flexible and avoids any limits on the types of storage applications that proponents might submit;
c. Ensure the application review process is expedited and subject to regulatory review timelines;
d. Adopt the relevant aspects of CSA Z-741 and Z-341 Codes, as appropriate for CO2 in Ontario; and
e. Enact a process for land rights acquisitions that ensures sufficiently large blocks of pore space can be efficiently acquired by a potential project developer and the Ontario Lands Tribunal can resolve disputes over pore space acquisition.

4. Create regulatory framework to encourage commercial CCS projects:
a. Amend the EPS to allow CO2 that is captured from a covered facility and appropriately sequestered to be deducted from a covered facility’s verified emissions;
b. Create a carbon offset system in connection with the EPS and develop a project methodology for CO2 sequestration that would allow offset credits to be issued to voluntary CCS projects that take place outside the covered sectors; and
c. Ensure there is an appropriate transfer of long-term responsibilities for stored CO2, following the model established in Alberta.

5. Ensure scalable and cost-effective CCS infrastructure development:
a. Ensure that any regulatory amendments designed to facilitate an initial set of CCS projects can be leveraged in the future to approve more extensive CCS infrastructure, as Alberta is doing under the MMA; and
b. Design the regulatory regime for CCS projects to minimize costs, while still ensuring public safety, in part by adopting open access policies to third parties and non-discriminatory rates where appropriate.

The following submission describes these recommendations in detail, after first providing some background on Enbridge’s extensive experience and involvement with CCS across the country.

Enbridge and CCS
Enbridge is deeply engaged in the energy transition underway today. We have taken deliberate steps to diversify our business to include lower-emission energy sources and we have made early, strategic investments in low-carbon solutions, including hydrogen, renewable natural gas, and compressed natural gas. Through our gas distribution business’s leading energy efficiency programming, we are helping residential, commercial, and industrial customers lower both energy costs and emissions. Enbridge’s leading position in the global energy transition positions us well to assist in the development of CCS infrastructure in Ontario and the delivery of CCS and low carbon services for our customers, including in EITE sectors.

Enbridge has long been involved in the CCS space. For example:
• Project Pioneer – In 2011, Enbridge partnered with TransAlta Corporation and Capital Power Corporation on Project Pioneer which aimed to capture 1 Mtpa of CO2 from TransAltas Keephills 3 power plants west of Edmonton, Alberta. Project Pioneer assessed CO2 storage in the Nisku formation through a drilling program that included an extensive characterization plan.
• Wabamun Area Sequestration Project (WASP) – The Wabamun Area Sequestration Project (WASP) was a University of Calgary-led project with industry partners that included Project Pioneer partners Enbridge and TransAlta. The project involved a comprehensive characterization study of large-scale CO2 sequestration opportunities in the Wabamun area, west of Edmonton, Alberta. It examined the feasibility of storing 20 Mtpa of CO2 per year within a 60 km by 90 km area extending south of the Wabamun Lake area. The Nisku formation was selected as the primary target for CO2 sequestration.
• Alberta Saline Aquifer Project – Enbridge and Capital Power (then EPCOR) co-launched the Alberta Saline Aquifer Project (ASAP) in 2007. Led by Enbridge, this project was a broad-based initiative to advance carbon sequestration technology and capacity in Alberta. Initially comprising a group of 19 private sector companies, the number of ASAP participants eventually grew to 36 industry participants, one academic institute, and one research institute. This project was aimed at gaining a better understanding of the potential costs, procurement constraints, and technological considerations of the various components required for successful carbon sequestration projects.
• Fort Nelson Carbon Storage Project – In 2012, Spectra Energy (which combined with Enbridge in 2017) explored the technical and economic feasibility of sequestering carbon from a commercial natural gas processing facility in Fort Nelson in a deep carbonate saline formation in northeast British Columbia.

Ultimately, these CCS projects did not proceed because the policy landscape at the time did not support the projects’ economics. We are very encouraged to see this changing in Canada and, specifically, Ontario.

Today, we’re actively pursuing CCS opportunities across North America, including the development of the Open Access Wabamun Carbon Hub in Alberta, west of Edmonton. This hub is being developed with local Indigenous partners to support near-term carbon capture projects announced by Lehigh Cement and Capital Power.

Finally, it’s worth highlighting that Enbridge has significant, transferrable experience operating natural gas storage facilities. Enbridge manages approximately 440 billion cubic feet (“Bcf”) of natural gas storage capacity across North America, including 280 Bcf of networking storage through our storage operations at the Dawn Hub and other Enbridge Gas locations in southwest Ontario.