Words and Phrases - "storage"

Regarding the scope of para. (c) of Class 57 (referencing “equipment that is used solely for the storage of captured carbon in a geological formation”) in relation to potentially accessing the carbon capture, utilization and storage (CCUS) investment tax credit, did “storage” in para. (c) include: exploration of the underlying geology to determine if storage was possible; and monitoring activities taking place at the storage site during the storage phase in respect to the captured carbon?

CRA responded that although storage contemplates the injection of carbon dioxide, it does not include exploration, including for determining the adequacy of the geological formation for storage. Therefore, storage would not include such exploration.

However, the monitoring of the captured carbon during the storage phase would appear to be necessary and integral to storage, so that such monitoring activities could be considered part of “storage” for para. (c) purposes.

The casing of a well that was used for both exploration and storage would not qualify under Class 37 or para. (c) of Class 57. Even if the well casing was completed to the specifications required for an injection well, it would not qualify because the well casing would not be exclusively used for the storage of captured carbon.

Para. (e) of Class 57 would include standalone monitoring equipment that was used solely to support equipment that fell within paras. (a) to (d) of Class 57. If this monitoring equipment was not standalone but was instead incorporated into a well casing so that it became part thereof, the well casing could nonetheless fall within para. (c) of Class 57 if the monitoring activity was necessary and integral to storage or was otherwise required for the storage system's safety and integrity.