OFA submitted comments on the provincial government’s proposed regulatory framework to enable geologic carbon storage. The key points outlined in the document include:

• OFA is a strong advocate for the protection of Ontario’s agricultural lands for the long-term use in farming. OFA recommends that all proponents be required to conduct Agricultural Impact Assessments, to the acceptance of all impacted municipalities, to ensure surface activity, traffic volumes, construction and operation of geologic carbon storage sites avoid adverse impacts to the surrounding agricultural communities.
• Considering the cost of establishing, operating and policing a geologic carbon storage framework, OFA recommends the provincial government determine whether redirecting efforts towards reducing emissions of carbon intense industries, including fuel switching, is more feasible.
• OFA recommends Responsible Operators be required to illustrate that any and all wells above a pore space are properly sealed and capped.
• Considering the stability of atmospheric CO2, OFA recommends the provincial government conduct analysis to ensure that not only will Stewardship Fund requirements be sufficient to offset the costs of a failure, but that they be sufficient to ensure resources are available for several hundred years.
• Obtaining the rights to of pore space owners for geologic carbon storage is new to Ontario. OFA recommends further engagement with Indigenous and private land owners to confirm what is an appropriate level of majority consent needed for a project to proceed.
• OFA represents the interests of thousands of landowners in areas identified as areas where geologic carbon storage activities may occur. OFA recommends further engagement with private landowners to establish a fair and equitable settlement for leasing rights for surface activities and rights for pore space injection.