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Factors considered to determine the number of projects

An analysis is undertaken and relevant factors are considered to determine whether a submitted project plan is a single CCUS project or multiple CCUS projects.

The analysis and determination are done on a case-by-case basis.

The CRA may consider:

Ownership

One or more of the CCUS segments within a CCUS value chain may have different owners as opposed to a single owner for the entire CCUS value chain.

Different owners of the CCUS segments comprising a CCUS value chain could indicate multiple CCUS projects.

Location

In some situations, the existence of multiple distinct sites of the same nature may suggest that there are multiple CCUS projects.

Such sites include:

  • CO2 storage sites
  • CO2 capture sites
  • CO2 emission source sites
  • CO2 storage hubs

However, where there is physical or functional integration of infrastructure and equipment among multiple sites of the same nature, it may be considered to be a single CCUS project.

Where multiple wells are drilled to facilitate the storage of CO2 from a common CO2 emission source(s), this does not necessarily indicate that each well is a separate CCUS project.

Capacity

Differences in the capacity of different CCUS segments in a CCUS value chain could indicate multiple CCUS projects.

Some CCUS value chains include transportation and storage or use segments that are built with the capacity to transport and store or use the CO2 from a single capture segment.

  • This could indicate that all the CCUS segments in that CCUS value chain are part of a single CCUS project

Some CCUS value chains include CO2 transportation and/or storage or use segments that are specifically overbuilt to accommodate CO2 from multiple CO2 capture segments.

  • This means they have larger CO2 capacity than the aggregate of the initially-connected CO2 capture segments (such as a trunk line or a storage hub)
  • This could indicate that the CO2 transportation and/or storage or use segments are not part of the same CCUS project(s) as the individual CO2 capture segments
Phased construction

If the construction of the facilities and the infrastructure of one or more CCUS segments in a CCUS value chain occurs in phases, the CRA may consider a phase to be a separate CCUS project.

For example, if a phase was not specified in the initial project plan or such phase begins or is under construction after the project start-up date of a different phase of the CCUS segment(s), this could indicate that such phase is a separate CCUS project.

Start of operations of CCUS segments in a CCUS value chain

Where the project start-up date of a particular CCUS segment, such as a storage segment, coincides with the project start-up date of another CCUS segment in the same CCUS value chain, such as a capture segment, this could suggest that the CCUS segments in that particular CCUS value chain are part of the same CCUS project.

Significant expansion of capacity

If an existing CCUS project that has commenced commercial operations undergoes a significant expansion of its capacity, it could be considered to be a new CCUS project.

For example, the addition of a new CO2 trunk line or storage hub.

Written agreements

Written agreements that are in place between the relevant participants in a particular CCUS value chain could be examined to ascertain the degree of interconnection and interdependence between the CCUS segments in order to determine whether there is a single CCUS project or multiple CCUS projects.

Written agreements include:

  • Partnership agreements
  • Joint venture agreements
  • A contract for services or letter of intent between the owners of the CCUS capture and the CCUS transportation and/or storage and use segments
Other Documents

Where applicable, the CRA may consider how you present and describe the project(s):

  • In your financial statements
  • In your other public documents
  • To one or more regulatory and other government agencies, at all relevant levels of government