To: Ontario Ministry of…

To: Ontario Ministry of Northern Development, Mines, Natural Resources and Forestry (NDMNRF)
From: Scott Rennie, President & CEO, Vault 44.01
Date: March 14th, 2022
Re: Geologic Carbon Storage in Ontario – ERO Number 019-4770

Vault 44.01 is a Canadian company specializing in the permanent geologic sequestration of carbon dioxide. In partnership with industrial facility operators, Vault provides carbon sequestration expertise spanning the project lifecycle from concept through development to operations with the objective of enabling safe and robust development of commercial carbon capture and sequestration (CCS) projects. Vault’s core skill set around carbon sequestration includes site selection and characterization, regulatory permitting, pore space acquisition, site development and operations and is underpinned by a technical and execution team with decades of CCS experience across North America. Members of Vault’s team have been involved in over 20 carbon sequestration projects across the continent, including the three currently operating projects injecting CO2 into saline formations (Shell Quest in Alberta, Aquistore in Saskatchewan and ADM Decatur Industrial CCS in Illinois). Vault’s team members have engaged in CCS permitting in regulatory environments including Alberta and the USA and have permitted injection wells across western Canada and the USA. We are currently developing carbon sequestration projects in western Canada, the US Midwest and the US Southeast.

Vault is encouraged that NDMNRF is seeking to take steps that would lay the groundwork for the emergence of CCS in Ontario. We have been exploring CCS opportunities in Ontario for over a year and believe that with a supportive policy and regulatory environment, substantial decarbonization of southwestern Ontario’s industrial sector can be achieved through CCS. We see multiple opportunities for deployment of CCS in southwestern Ontario:

• Existing industrial facilities with process CO2 emissions that cannot be removed without CCS
• Existing industrial facilities with hard-to-decarbonize combustion CO2 emissions
• Fuel-switching from natural gas to blue and green hydrogen with blue hydrogen employing CCS to achieve a low carbon intensity
• Deployment of bioenergy with CCS to provide low to negative emissions heat and power

Providing an opportunity to deploy CCS as a decarbonization pathway complementary to other opportunities available to industry to reduce their greenhouse gas emissions will likely enable improved economics, sustainability and longevity of southwestern Ontario industrial participants.

Considering geologic sequestration, Vault believes that certain limited onshore areas of southwestern Ontario possess the required combination of reservoir depth, thickness, quality, salinity and bounding sealing formations to enable deployment of demonstration and early commercial CCS projects.
Ultimately, most carbon sequestration in southwestern Ontario is likely to occur offshore in Lake Erie. On the one hand, this will reduce impact to onshore landowners and other stakeholders. On the other hand, the increased costs of offshore pipelines and wells will likely require collaboration between multiple industrial participants, pipeline and sequestration operators along with supportive and stable government policy and regulations to facilitate the large investments that will be required.

Vault is currently working with an industrial facility that we believe represents among the best opportunities in Ontario for a demonstration-scale CCS project. We fully support the Ontario government’s actions envisioned by this consultation that will enable such a project to explore its potential and provide industry, government and the public an opportunity to better understand and gain confidence in the potential for deployment of CCS in Ontario.

We see NDMNRF’s proposed approach – facilitating agreements between demonstration project proponents and government – as a prudent approach to enabling near-term progression of certain qualified projects, while allowing time for development of a more comprehensive and stable regulatory framework for carbon sequestration in Ontario that will support larger-scale deployment of CCS.

Vault is committed to supporting the emergence of CCS as a material pathway for decarbonization in Canada. We fully support NDMNRF’s proposed initiative and stand ready to support your efforts as you proceed.

With Best Regards,

Scott Rennie