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Recent carbon capture and storage applications have sparked an interest in how the AER regulates CCS

Alberta - April 25, 2024

The recent applications for carbon capture and storage (CCS), such as the proposed Shell Atlas project or the Pathways Alliance project, have sparked an interest in how the AER regulates CCS in Alberta. 

The AER regulates the energy-related facilities that capture CO2, the pipelines that transport CO2, and the subsurface injection activities. Several directives provide industry requirements ranging from how to safely transport CO2 in pipelines, to what wells can be used to inject CO2, and where CO2 can be permanently stored in deep subsurface geological formations.

Carbon Capture, Utilization, and Storage Process
Carbon Capture and Storage involves capturing, transporting, and injecting carbon dioxide into deep subsurface geological locations

Under the oil and gas regulatory framework, a CCS project is not a single application. A carbon sequestration agreement from the Government of Alberta is required if a company wants to apply for a CCS project. Different applications are then required for the various component parts, including pipeline applications, facility applications, and well applications. These applications will fall under the Public Lands Act, Pipeline Act, Oil and Gas Conservation Act, Environmental Protection and Enhancement Act, and other acts governing energy resource development in Alberta.

Having different applications for the various components of a CCS project allows more insight into the details of a project and increases regulatory oversight by reviewing the details of each activity. Breaking down a larger project into separate applications enables individuals to pinpoint specific concerns within the development.

Each application undergoes its own review process and is evaluated by technical experts within the AER.  As examples, reviewing potential land impacts from construction in one application, reviewing technical requirements for the safe operation of a well or pipeline in another application, and reviewing subsurface requirements for containment assurance in another application. 

All applications, when received, will be available for viewing on the AER’s Public Notification of Application (PNoA) tool. On each public notice, the deadline for submitting Statements of Concern (SOC) is indicated. This timeframe on the public notice allows stakeholders who think they might be directly or adversely impacted by the proposed project to submit a SOC.

More details about the SOC process can be found on our Statement of Concern page. You can learn more about the requirements for CCS projects, across their life cycle, on our Carbon Capture, Utilization, and Storage page.