Re: ERO 019-6752 Proposed changes to the OGSRA
OFA submitted comments to the Ministry of Natural Resources and Forestry (MNRF) on the proposed amendments to the Oil, Gas and Salt Resources Act (OGSRA) to regulate projects to assess, pilot or demonstrate new geological storage activities and technologies.
Under proposed OGSRA amendments, geological carbon storage pilots or demonstrations could use existing wells to access underground geologic formations. Proposed OGSRA amendments are meant to assist Ontario’s transition to a low-emission energy system.
OFA recommends MNRF work to ensure landowners concerns are considered during processes that will increase activities under existing lease arrangements. OFA recommends that the ministry collaborate with landowners to better understand the long-term impacts of ceding personal land rights or Crown property rights to better protect people.
OFA supports stronger oversight towards preventing impacts to public safety and the environment, and the intention to create or amend future regulations to establish a clear framework for special projects to identify, assess and mitigate potential impacts. While regulating geologic carbon storage pilot projects will provide clarity for business and investment planning, OFA supports including measures to enhance the protection of public safety and the environment, such as court and inspector’s orders for carbon storage.