Carbon Capture, Utilization and Storage (CCUS)

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Overview

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Carbon capture, utilization and storage, commonly referred to as CCUS, involves capturing carbon dioxide and injecting it into deep subsurface formations for long-term storage. In Alberta, carbon sequestration tenure is used to grant rights to pore space for the permanent storage of captured CO₂.

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Alberta has developed two main pathways for carbon sequestration tenure: large-scale carbon storage hubs and small-scale or remote carbon sequestration projects. Carbon storage hubs are intended to allow multiple emitters to access shared pore space, while small-scale and remote applications are intended for projects that may not be practical or viable through an existing or forthcoming hub.

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A major focus of these applications is plume migration. The regulator needs to understand where the CO₂ fluid plume and pressure plume are expected to move over time because plume behavior affects the size of the requested tenure area, overlap with other subsurface rights, resource conservation, containment, monitoring, legacy well risk, and long-term project liability.

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​Approval Types

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There are several CCUS-related pathways that may apply depending on the project.

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• Carbon Storage Hubs

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A carbon storage hub is an area of pore space managed by a hub proponent that can plan, enable, and undertake sequestration of captured CO₂ from multiple emissions sources. Alberta uses the hub model to avoid numerous overlapping sequestration proposals and to support coordinated development of pore space.

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• Small-Scale and Remote Carbon Sequestration

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Small-scale and remote carbon sequestration tenure is intended for projects where an existing or forthcoming hub does not address the proponent’s sequestration needs. Applicants must provide a business case explaining why hub access is not viable.

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• CO₂ Enhanced Oil Recovery

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Carbon sequestration tenure is generally not required for projects that inject CO₂ as part of enhanced oil recovery. CO₂ EOR continues to operate under the existing mineral rights tenure system.

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• Acid Gas Disposal and Captured CO₂

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Existing acid gas disposal operations do not generally need carbon sequestration tenure for ongoing disposal operations. However, where an acid gas operator proposes to supplement volumes with captured CO₂ and that additional volume requires a new or amended Directive 065 scheme approval, the proponent may need to apply for a grant of pore space. All new acid gas disposal operations are required to apply for a grant of pore space from Alberta Energy and Minerals.

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Important note on CCUS tenure vs. AER approval:

Carbon sequestration tenure applications are submitted to Alberta Energy and Minerals and are intended to secure the right to evaluate or use pore space for CO₂ sequestration. This tenure process is separate from the AER Directive 065 regulatory approval process. Securing carbon sequestration tenure does not authorize injection on its own. A proponent must still obtain the required Alberta Energy Regulator (AER) approvals, including the applicable Directive 065 scheme approval, before CO₂ injection or sequestration operations can proceed. Alberta’s CCUS tenure guidance states that operators must still obtain AER approvals to ensure the activity is safe and environmentally responsible

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Application Process

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The CCUS application process depends on whether the project is being advanced as a hub or as a small-scale and remote project.

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For carbon storage hubs, Alberta uses a competitive tenure process. Successful proponents may be offered a CSEA to evaluate the suitability of the proposed location. After evaluation, a proponent may apply for a CSA if the project demonstrates safe and permanent storage potential. Regulatory approvals are still required and are not granted automatically through the tenure process.

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For small-scale and remote sequestration projects, the applicant must submit an application through Alberta’s Electronic Transfer System, or ETS. The application must identify the requested lands, sequestration formation, project business case, technical evidence, overlapping interests, and the authorized party for the pore space and unit agreements. Incomplete applications may be rejected without further consideration.

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A practical process is:

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1. Confirm whether the project should proceed through a hub, small-scale and remote tenure, EOR, acid gas disposal, or another pathway.

2. Define the CO₂ source, volume, project life, and injection timeline.

3. Identify the proposed sequestration formation and requested lands.

4. Evaluate the storage capacity, injectivity, containment, and plume behaviour.

5. Identify overlapping subsurface rights, mineral interests, active disposal wells, existing wells, and other resource activity.

6. Prepare geological, reservoir engineering, and plume migration support.

7. Prepare the business case and tenure application.

8. Submit through ETS, where applicable.

9. Complete further evaluation, regulatory applications, monitoring, measurement and verification planning, and AER approvals.

 

Data Requirements

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A CCUS tenure application should include enough information to demonstrate that the proposed location is technically suitable, appropriately sized, and consistent with the expected CO₂ storage requirements.

Common data requirements include:

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• CO₂ source or sources

• Estimated annual CO₂ volumes

• Estimated lifetime CO₂ volumes

• Project timeline

• Requested lands

• Legal land descriptions

• Sequestration formation description

• Storage capacity estimate

• Pore volume estimate

• CO₂ available pore volume isopach

• Net reservoir isopach

• Cross-sections

• Logs with marked formation tops

• Core analysis

• Brine analysis

• Directional surveys

• Injectivity tests

• Injection forecasts

• Pressure transient analysis

• Fluid compatibility testing

• Seismic interpretation with suitable well tie, where available

• Existing wells and legacy wells

• Existing disposal wells

• Mineral ownership and overlapping rights

• Areas of resource interest or activity overlap

• Projected CO₂ fluid plume area

• Projected pressure plume area

• Dynamic reservoir simulation of the pressure plume area of influence

 

For small-scale and remote applications, Alberta’s application guide specifically identifies the projected area of influence of CO₂ fluid and pressure plumes, including a dynamic reservoir simulation model of the pressure influence of the plume AOI.

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Geological Requirements

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The geological work must demonstrate that the proposed sequestration formation is suitable for permanent CO₂ storage. Typical geological requirements include:

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• Formation description

• Reservoir thickness and quality

• Net reservoir isopach

• CO₂ available pore volume isopach

• Formation tops

• Cross-sections

• Caprock description

• Under-burden description

• Structural mapping

• Stratigraphic interpretation

• Fault and fracture assessment

• Seismic interpretation, where available

• Containment assessment

• Identification of legacy wells

• Existing disposal wells

• Resource conflicts

• Mineral reserves or recoverable resource assessment

• Pore volume calculations

 

The small-scale and remote application guide requires the applicant to confirm that the intended formation has no recoverable resources, or that recoverable resources have been addressed in a unit application, and that the formation does not have active disposal wells unless they are addressed within the unit application.

For carbon storage hubs, the proposal guidance asks proponents to describe the proposed reservoir, caprock, and under-burden, and to support the proposal with available data such as cores, logs, pressure transient analyses, minifracs, and regional or local analogues.

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Why Plume Migration Matters

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Plume migration is one of the most important topics in a CCUS application.

There are two related plume concepts:

• The CO₂ fluid plume, which is the area where injected CO₂ is expected to physically move within the storage formation.

• The pressure plume, which is the larger area where reservoir pressure may be affected by injection.

 

These plumes matter because they define the area of influence of the project. The projected plume area helps determine whether the requested lands are large enough, whether other mineral or pore space users could be affected, whether existing disposal wells or legacy wells create risk, and what monitoring will be required.

Plume migration is also directly tied to containment. If the plume or pressure front intersects faults, legacy wells, depleted pools, active disposal wells, or other subsurface activity, the project may require additional technical support, mitigation, monitoring, or a different project configuration.

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For this reason, Alberta’s small-scale and remote application guide specifically identifies the projected area of influence of CO₂ fluid and pressure plumes, dynamic reservoir simulation of the pressure plume AOI, areas of resource interest or activity overlap, and existing disposal wells within the current and projected area of influence.

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Engineering Requirements

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The engineering evaluation should demonstrate that the proposed project can inject the planned CO₂ volumes safely and that the storage formation can accept those volumes without unacceptable pressure increase, containment risk, or interference with other subsurface users. Typical engineering requirements include:

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• Injection forecast

• Annual injection volumes

• Lifetime injection volumes

• Injectivity assessment

• Pressure transient analysis

• Reservoir simulation

• Pressure plume forecast

• CO₂ plume forecast

• Storage capacity calculation

• Pore volume calculation

• Fluid compatibility review

• Well design concept

• Injection pressure assessment

• Induced seismicity risk review

• MMV concept

• Legacy well risk assessment

• Containment risk assessment

 

For hub proposals, Alberta asks proponents to identify key project and sequestration risks, including containment, capacity, injection pressure, injectivity, induced seismicity, and impacts to other subsurface users and resources within the zone of pressure influence.

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The same guidance asks for an overview of monitoring, measurement and verification planning, including expected requirements for monitoring plume containment and conformance, legacy wells, and other features of interest to containment.

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Regulatory Requirements

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Carbon sequestration tenure is not the same as final regulatory approval.

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A Carbon Sequestration Evaluation Agreement (CSEA) allows the proponent to evaluate the suitability of a location. A CSA grants rights related to pore space and sequestration within defined zones, but the operator must still obtain required regulatory approvals. Alberta’s hub proposal guidance states that all required regulatory approvals are the responsibility of the proponent and that the tenure process does not guarantee or certify the location’s suitability for sequestration.

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The AER is responsible for regulatory approvals related to CCUS activity, including safety and environmental responsibility. Alberta has also delegated oversight of MMV plans, closure plans, and closure certificates for CCUS activities to the AER.

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For small-scale and remote sequestration, the application may require:

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• Pore Space Lease

• Pore Space Unit Agreement

• Completed application through ETS

• Business case

• Requested lands and formation description

• Technical support for the proposed location

• Identification of overlapping rights and activities

• APEGA Responsible Member authentication

• Additional information where project size, requested area, or proximity to a hub warrants further review

 

The small-scale and remote guide notes that additional information may be requested where the proposal seeks to sequester more than 200,000 tonnes of CO₂ per year, requests more than one quarter township, or is within or near a current or forthcoming carbon sequestration hub.

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Stakeholder Engagement

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Stakeholder engagement is a major part of CCUS project development because these projects can affect large subsurface areas over long periods of time.

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For hub proposals, Alberta asks proponents to provide a plan for robust, non-standard, ongoing public engagement, including how the proponent will safeguard public confidence in carbon capture and storage.

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Potential stakeholders and interested parties may include:

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• Landowners

• Municipalities

• Indigenous communities

• Mineral agreement holders

• Mineral owners

• Existing well licensees

• Existing disposal operators

• Geothermal rights holders

• Other carbon sequestration tenure holders

• Other subsurface users

• Emitters seeking hub access

• Public and local community groups

 

For small-scale and remote applications, proponents must address overlapping interests and activities within the proposed location. The Unit Agreement is intended to address varying interests within the location, including Crown mineral agreement and authorization holders and mineral owners.

Because the pressure plume can extend beyond the CO₂ fluid plume, stakeholder review should not be limited only to the area where CO₂ is expected to physically migrate. The pressure area of influence may also affect other users, wells, resources, and future subsurface development.

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Common Deficiencies

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Common issues in CCUS tenure and technical submissions include:

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• Weak explanation of why a hub is not viable for a small-scale or remote project

• Incomplete CO₂ source or volume forecast

• Poorly defined requested lands

• Insufficient formation description

• No clear storage capacity calculation

• No clear pore volume calculation

• Missing CO₂ available pore volume isopach

• Missing cross-sections

• Missing logs with marked formation tops

• Insufficient containment discussion

• Incomplete caprock assessment

• Incomplete legacy well review

• Failure to identify active disposal wells

• Failure to identify overlapping mineral or pore space rights

• Incomplete plume migration assessment

• No dynamic simulation of pressure plume AOI

• Requested lands not aligned with the projected plume and pore volume needs

• Inadequate MMV concept

• Inadequate public or stakeholder engagement plan

• Failure to address induced seismicity risk

• Assuming tenure approval is the same as AER approval

 

The most common technical weakness is likely to be an underdeveloped plume and pressure-area discussion. If the applicant cannot show where the CO₂ and pressure are expected to migrate, it is difficult to justify the requested lands, assess conflicts, design monitoring, or demonstrate long-term containment.

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Frequently Asked Questions

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What is carbon sequestration tenure?

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Carbon sequestration tenure is the right granted by Alberta to use pore space for the permanent storage of captured CO₂. Depending on the pathway, this may involve a Carbon Sequestration Evaluation Agreement, Carbon Sequestration Agreement, Pore Space Lease, or Pore Space Unit Agreement.

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What is the difference between a CSEA and a CSA?

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A CSEA allows a proponent to evaluate whether a location is suitable for carbon sequestration. A CSA may be granted after evaluation and is intended to provide the right to inject captured CO₂ into deep subsurface formations within defined zones.

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Does a CSEA allow injection?

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No. A CSEA is an evaluation agreement. Injection requires further rights and regulatory approvals.

What is a carbon storage hub?

A carbon storage hub is a pore space area managed by a hub proponent to provide sequestration services for multiple CO₂ emitters. Alberta uses hubs to support efficient pore space development and avoid overlapping proposals.

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When is small-scale and remote tenure used?

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Small-scale and remote tenure may be used where a current or forthcoming hub does not address the proponent’s sequestration needs. The applicant must explain why hub access is not viable.

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Does CO₂ EOR require carbon sequestration tenure?

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Generally, no. Alberta’s small-scale and remote guide states that carbon sequestration tenure is not required for projects that inject CO₂ as part of enhanced recovery, such as CO₂ EOR.

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Why is plume migration so important?

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Plume migration determines the expected area affected by injected CO₂ and pressure. It affects tenure size, pore volume, containment, MMV design, overlap with mineral rights, legacy well risk, induced seismicity risk, and potential conflicts with other subsurface users.

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What is the difference between the CO₂ plume and the pressure plume?

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The CO₂ plume is the area where injected CO₂ is expected to physically move. The pressure plume is the area where reservoir pressure is expected to change because of injection. The pressure plume may extend beyond the CO₂ fluid plume.

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What technical evidence is commonly required?

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Common technical evidence includes cross-sections, logs with formation tops, core analysis, brine analysis, injectivity tests, pressure transient analysis, fluid compatibility testing, seismic interpretation, pore volume mapping, plume modelling, and dynamic simulation of pressure influence.

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What happens if an application is incomplete?

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For small-scale and remote tenure, Alberta’s guide states that incomplete applications may be returned as rejected without further consideration, requiring the applicant to re-apply.

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Benoit Technical Tools

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Related Benoit technical tools may include:

• Benoit MWHIP Calculator

• Benoit Reservoir Analysis Toolkit

• Benoit Voidage Replacement Ratio Calculator

• Benoit H2S Release Rate Calculator

 

Need Assistance?

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CCUS applications require careful coordination between tenure, reservoir engineering, geology, plume migration, pore space, overlapping rights, and regulatory approvals. Benoit Regulatory can help operators evaluate the correct pathway, prepare technical support, assess plume and pressure area of influence, identify common deficiencies, and support carbon sequestration tenure and related regulatory applications.

Sources: Alberta Carbon Sequestration Tenure page, Call for Tenure Proposals for Carbon Sequestration Hubs, and Small-Scale and Remote Carbon Sequestration Tenure Application Guidelines.