The Pembina Institute submitted comments to Environment and Climate Change Canada on their draft federal offset protocol for direct air carbon dioxide capture and geological storage. This protocol is a critical step in developing a vibrant carbon removal industry in Canada, as it would allow these projects to generate offset credits.
A summary of our comments and recommendations is as follows:
- We recommend temporary, initial flexibility in renewable energy requirements with increasing stringency over time. This would acknowledge the current limitations of securing renewable energy in several jurisdictions.
- We recommend that offshore geologic storage be included within the scope of this protocol, as long as the requisite safety criteria are met by a project. Offshore geologic storage has a long history in other jurisdictions.
- We request clarification on the project condition in section 4.1 that requires the capture facility not be registered under any other greenhouse gas offset credit program. Direct air carbon dioxide capture and geological storage (DACCS) projects should be able to sell to different buyers seeking credits that can comply with various programs, and measures can be put in place to ensure credits are not double counted.
- We request clarification on the criteria for determining which jurisdictions have adequate regulations and enforcement mechanisms for the federal DACC protocol to be applicable. Defining what constitutes sufficient regulatory standards will help accelerate progress across other provinces, ensuring clarity in their efforts to move forward.
