The Pembina Institute submitted comments on Alberta Environment and Protected Areas' draft Quantification Protocol for CO2 Capture and Permanent Geologic Sequestration.
A summary of our comments is as follows:
- The Pembina Institute welcomes the update to the quantification protocol as it will further clarify accounting in hub-and -spoke carbon capture and storage (CCS) models, a key to attracting future investment in Alberta and decarbonizing existing industry. We are also pleased to see the inclusion of a carbon dioxide removal (CDR) credit label for activities that permanently remove CO2 from the atmosphere. While the label does not provide any significance within the Technology Innovation and Emissions Reduction (TIER) system, its inclusion is a significant step towards recognizing the differences between removal and reduction activities.
- We recommend that the quantification methodology be revised for emissions from off-site electricity generation to allow for environmental attributes purchased through market-based mechanisms such as virtual power purchase agreements.
- A higher voluntary discount rate should be considered for projects that carry a higher risk of reversal.
- Re-introducing a minimum allowable storage depth of 1,000 metres below ground would ensure stored CO2 remains in a dense state, reducing the risk of reversal.
