verification report for: 4404-1916 · the verification strategy relied on both control and...

Cap-Op Energy Emission Reductions From Pneumatic Devices (Pool B) 4404-1916 December 2018

Verification Report for:

Cap-Op Energy Emission Reductions From Pneumatic Devices (Pool B) 4404-1916

Proponent:

Cap-Op Energy Inc.

Prepared by: Brightspot Climate Inc.

Prepared for:

Alberta Climate Change Office

Version:

Final

Date:

December 14, 2018


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Table of Contents 1.0 Summary – Offset Project ..................................................................................... 4 1.1 Summary – Facility ........................................................................................................ 7 2.0 Introduction ........................................................................................................ 8

2.1 Objective ............................................................................................................ 8 2.2 Scope ................................................................................................................. 9 2.3 Level of Assurance ............................................................................................. 10 2.4 Criteria ............................................................................................................. 10 2.5 Materiality ......................................................................................................... 10

3.0 Methodology ..................................................................................................... 10 3.1 Procedures ........................................................................................................ 11 3.2 Team ............................................................................................................... 25 3.3 Schedule .......................................................................................................... 26

4.0 Results ............................................................................................................. 27 4.1 Assessment of Internal Data Management and Controls .......................................... 27 4.2 Assessment of GHG Data and Information ............................................................. 28 4.3 Assessment against Criteria ................................................................................. 34 4.4 Evaluation of the GHG Assertion .......................................................................... 40 4.5 Summary of Findings .......................................................................................... 40 4.6 Opportunity for Improvement .............................................................................. 42

5.0 Closure ............................................................................................................. 43 5.1 Verification Statement ........................................................................................ 43 5.2 Limitation of Liability .......................................................................................... 43 5.3 Confirmations .................................................................................................... 43

6.0 References ........................................................................................................ 44 Appendix A: Final Verification Plan and Sampling Plan ............................................................ 45 Appendix B: Statement of Qualifications .............................................................................. 73 Appendix C: Findings and Issues ......................................................................................... 76 Appendix D: Statement of Verification ................................................................................. 78 Appendix E: Conflict of Interest Checklist ............................................................................. 81 Appendix F: Supplemental Diagrams/Tables/Figures .............................................................. 84

List of Tables Table 1: Risk Assessment .................................................................................................. 15 Table 2: Findings of Data Integrity Verification Procedures ..................................................... 28 Table 3: Findings of GHG Data and Information Verification Procedures .................................... 29 Table 4: Findings of Criteria Verification Procedures ............................................................... 35 Table 5: Offset Criteria Assessment ..................................................................................... 39 Table 6: Summary of Findings ............................................................................................ 41 Table 7: Confirmation Findings ........................................................................................... 43 Table 8: Detailed Findings and Issues Log ............................................................................ 77 Table 9: Supporting Documentation Reviewed ...................................................................... 85


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Instructions are in italics throughout and should not be deleted when report is complete. Some instructions are specific to the verification of facilities and for offset projects. The document is not restricted but do not alter the format, the layout, the headings or the overall ‘look and feel’ of the document. If is more useful to paste information outside of the text box, use the empty line just below the text box to drop text or tables int. This should not change the headings or the formats. There are several dropdown boxes in the document that must be completed.

• Complete report in Verdana 10pt font (no italics). • After the report is complete, right click the table of contents and ‘update field’ which will

update page numbers in Table of Contents. • If an instruction only applies to facilities or only applies to offsets indicate ‘not applicable’. • Appendix F is available for additional tables, diagrams etc.


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1.0 Summary – Offset Project

Item Description

Project Title

Enter project title (must match the registry project title)

Cap-Op Energy Emission Reductions from Pneumatic Devices (Pool B)

Project Description

Provide a brief description of the project and baseline conditions.

This Project endeavours to reduce emissions of greenhouse gases at a variety of oil and gas production and processing sites by reducing or eliminating vented gas emitted from pneumatic devices. The Project is an aggregation of installations at multiple project sites. These installations are typically pneumatic controller or pump conversions from high bleed to low bleed devices or electrification of chemical injection pumps.

Project Location

Include the latitude and longitude for each unique location or installation. Include legal land location if applicable and other information identifying the unique location.

The project is located at various locations throughout Alberta. All emission reduction activities related to this project will occur within Alberta. Please refer to the Aggregated Project Planning sheet for the location of specific subprojects.

Project Start Date

Enter the project start date.

There are multiple project start dates depending on when the Project Participant implemented the pneumatic device vent gas reduction project; however, all projects were implemented after January 1, 2002. Please refer to the SDD for the exact start date for each subproject.

Offset Start Date

Enter the start date for offset credit generation.

The start date for offset credit generation was January 1, 2016.

Offset Crediting Period

Enter the offset crediting period, including the offset start date. Include day, month year.

The credit duration period for each project will be 7 years, from January 1, 2016 until December 31, 2022.

Reporting Period

Enter the reporting period being verified.

January 1, 2017 to December 31, 2017.

GHG Assertion (Actual Emission Reductions/Sequestration Achieved)

73,661 tonnes CO2e


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Enter the actual emissions reductions / sequestration for the reporting period. Enter serial numbers if available.

Protocol

Indicate the relevant protocol (if applicable)

Quantification Protocol for Greenhouse Gas Emission Reductions from Pneumatic Devices, Version 2.0, January 2017.

Ownership

Enter offset project owner.

The aggregator, Cap-Op Energy Inc., is not the owner of the pneumatic device vent gas reduction projects and is not the owner of the offset credits generated by this project. The Proponent is an aggregator of carbon credits and acts as the agent of the originator and other originators to facilitate project development, credit verification and serialization.

Project Activity

State how the project activity meets the eligibility requirements

The project must meet the eligibility criteria stated in Part 3, Section 16 of the Carbon Competitiveness Incentive Regulation (CCIR). In order to qualify, emission reductions must:

• Occur in Alberta; • Result from an action taken that is not otherwise

required by law at the time the action is taken; • Result from actions taken on or after January 1,

2002; • Occur on or after January 1, 2002; • Be real, demonstrable, quantifiable and verifiable; • Be quantifiable and measurable, directly or by

accurate estimation using replicable techniques.

The verification included an evaluation of these criteria as well as the specific applicability criteria described in the Protocol. The results of this analysis are described in Section 4.3 of this report.

Project Contact

Enter contact name, company name, mailing address, phone number and email address.

Andria Panidisz Sustainability Engineer Cap-Op Energy Inc. 610, 600 – 6th Ave SW Calgary, AB T2P 0S5 +1 (403) 457-1029 ext 2002

[email protected]

Verifier

Verifier name, verifier’s company name, address, phone number email etc.

Aaron Schroeder, P.Eng. Brightspot Climate 225 West 8th Avenue, Suite 300 Vancouver BC V5Y 1N3 +1 (604) 353-0264 [email protected]


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Verification Team Members

Include verification team members, roles, training, training dates and qualifications.

Aaron Schroeder, P.Eng. Roles: Lead Verifier and Designated Signing Authority Training: Greenhouse Gas Verification – ISO 14064- 3, Canadian Standards Association, 2012; Instructor – Greenhouse Gas Verification – ISO 14064-3, University of Toronto, 2015 – 2018

Jeanna Brown, P.Eng. Role: Associate Verifier Training: GHG Validation and Verification, ISO 14064-3, University of Toronto, October 2017

Rodrigo Cubedo, EIT Role: Associate Verifier

Chris Caners, P.Eng. Role: Peer Reviewer

Training: Greenhouse Gas Verification, ISO 14064-3, Canadian Standards Association, 2008

Designated Signing Authority

Enter the designated signing authority for this verification.

Aaron Schroeder, P.Eng. Brightspot Climate 225 West 8th Avenue, Suite 300 Vancouver BC V5Y 1N3 +1 (604) 353-0264 [email protected]

Verification Strategy

Describe the verification strategy used for the verification, including rationale for the approach. Note, if a controls reliance is used, provide justification for how the project is able to support this approach.

The verification strategy relied on both control and substantive approaches. The verification procedures, which are detailed later in this section and in the verification plan, were designed to test the activity data directly, wherever practical.

The Aggregator has controls in place to address inherent risks from any subproject. Therefore our controls approach was largely testing the controls of the aggregator, rather than the individual subprojects. Please refer to the Verification and Sampling Plan for more specific details on the specific Verification Procedures that were applied.


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1.1 Summary – Facility

Item Description

Facility Name and Company Name

List company name and facility name.

Not applicable for offset verification reports

Facility Description

Provide a brief description of the facility.


Baseline Emissions Intensity Description

List the approved BEIA and the baseline years.


Reporter Contact

Enter contact name, company name, mailing address, phone number and email address.


GHG Assertion

Enter the actual emissions, production, emissions intensity and the reduction target being verified.


Verifier

Verifier name, verifier’s company name, address, phone number email etc.


Verification Team Members

Include verification team members, roles, training, training dates and qualifications.


Designated Signing Authority

Enter the designated signing authority for this verification.



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2.0 Introduction Provide an introduction to the facility or project, the verification, and the background.

For Offset Project: summary of offset project baseline, changes to the baseline since project start date and summary of changes at the project since the offset project start date or baseline period.

For Facilities: Description of compliance or baseline report, facility/project boundary, facility identification information, GHG historical performance, summary of changes since the baseline or since the last compliance report.

Summary of Offset Project Baseline

The Project endeavours to reduce emissions of greenhouse gases at a variety of oil and gas production and processing sites by reducing or eliminating vented gas emitted from pneumatic devices. The Project is an aggregation of installations at multiple project sites. These installations are typically pneumatic controller conversions from high bleed to low bleed devices or electrification of chemical injection pumps.

The baseline condition is quantified as the emissions from the high-venting pneumatic devices under original or theoretical configurations prior to the conversion. This project has a dynamic baseline as the baseline emissions are determined by quantifying the activity level in the project and multiplying by the change in vent rates between baseline and project.

Summary of Changes

The Responsible Party’s Offset Project Report (OPR) indicates that there have been no changes to the project boundaries and no equipment changes during the reporting period.

The OPR states that the project’s boundaries, operations and major sources of greenhouse gas emissions have not changed from those previously reported.

2.1 Objective Describe the objective of the verification (should include expressing an opinion).

The objective of the verification is as follows:

• to issue an verification statement on whether the GHG assertion is without material discrepancy;

• to issue an verification report that provides details of the verification activities; and • to complete the “confirmations” activities defined in the Alberta Climate Change Office

Standard for Validation, Verification and Audit, Section 5.1.3.


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2.2 Scope Define the scope in terms of: geographical, organizational, activities and processes, sources, sinks, categories and greenhouse gases included (considering the completeness of the inventory), GHG assertion time period.

For offset verifications: include the serial range (i.e. XXXX-XXXX-XXX-XXX-XXX-XXX to XXXX-XXXX-XXX-XXX-XXX-XXX) if assigned (i.e. in the case of government verification a serial range will be available, otherwise not applicable).

For Facilities: ensure all specified gases and source categories are evaluated. Include list of negligible emission sources and justification for Emission Performance Credits (EPCs). Include listing of end products.

Project Name: Cap-Op Energy Emission Reductions from Pneumatic Devices (Pool B)

Serial Range: To be assigned at registration.

Geographic Boundary: Various sites across Alberta. Please refer to the Aggregated Project Planning Sheet for the location of specific subprojects.

Physical Operations: Natural gas processing and compression:

§ Pneumatic devices and controllers § Chemical injection pumps

Emission Sources: High-to-low Bleed Pneumatic Controller Conversions

§ B7: Vented Fuel Gas § P7: Project Vented Gas § P9: Fuel Extraction and Processing

Gas to Electric Chemical Injection Pump and Controller Conversions

§ B7: Vented Fuel Gas § P7: Projected Vented Gas § P9: Fuel Extraction and Processing

IPCC GHGs Emitted/Removed: Carbon Dioxide (CO2)

Methane (CH4)

Nitrous Oxide (N2O);

Remaining IPCC GHGs were not emitted in the baseline or project condition.

Reporting Period: January 1, 2017 – December 31, 2017


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2.3 Level of Assurance The verification was conducted to a reasonable level of assurance.

Choose type of verification from the dropdown box above.

Provide explanation on level of assurance.

The Standard for Validation, Verification and Audit, Version 2.0, June 2018 requires that verifications must be designed and completed to a reasonable level of assurance.

2.4 Criteria Outline the program criteria used and relevant supporting documentation (acts, regulations, protocols, standards, guidance documents, project documentation etc).

The program criteria used and relevant supporting documentation is as follows:

• Climate Change and Emissions Management Act • Carbon Competitiveness Incentive Regulation 255/2017, with amendments up to and

including Alberta Regulation 96/2018 • Standard for Validation, Verification and Audit, Version 2.0, June 2018. Alberta Climate

Change Office • Standard for Greenhouse Gas Emission Offset Project Developers, Version 2.0, July 2018 • Technical Guidance for the Assessment of Additionality, Version 1.0, May 2018 • Quantification Protocol for Greenhouse Gas Emission Reductions from Pneumatic

Devices, Version 2.0, January 2017

2.5 Materiality Define the materiality of the verification.

The materiality threshold is defined in The Standard for Validation, Verification and Audit, Version 2.0, June 2018. For this verification, the materiality threshold is 5%.

3.0 Methodology Statement that the verification is performed according to ISO 14064-3.

Summary of the assessments/tests/reviews/evaluations that were conducted during the verification.

This verification was designed and completed according to the requirements of the ISO 14064-3 Standard.

The following verification activities (assessments/tests/reviews/evaluations) were conducted through the course of this verification. The specific verification activities that were conducted are detailed in the Verification Plan, which is appended to this report. They are also listed with the verification findings throughout section 4 of this report.


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• Observations: the site visit included a tour of a sample of the project sites to observe emission sources, metering, and data systems used for recording metered quantities;

• Review of documentation: documentation supporting the activity data was reviewed, including review of any manual transcription that was applied between documents and the emission quantification software;

• Recalculation: emissions quantities were recalculated using metered data and original data sources and by applying the quantification methodologies stated in the Responsible Party’s Offset Project Report; the methods for calculating any averages used in the emission quantification were recalculated and evaluated for accuracy and appropriateness;

• Inquiry: the site visit included an interview of plant operation and instrumentation personnel;

• Analytical procedures: a year-over-year comparison of overall emissions offsets was performed.

3.1 Procedures Description of how the verification was conducted including: description of the nature, scale and complexity of the verification activity, confidence and completeness of the responsible party’s GHG information and assertion, assessment of GHG information system and its controls, assessment of GHG data and information, assessment of GHG information system and controls, assessment against criteria, evaluation of the GHG assertion.

The verification strategy relied on both a control and a substantive approach. The verification procedures, which are detailed later in this section, were designed to test the activity data directly, wherever practical. The Aggregator has controls in place to address inherent risks from any subproject. Therefore our controls approach was largely testing the controls of the aggregator, rather than the individual subprojects. Please refer to the Verification and Sampling Plan for more specific details on the specific Verification Procedures that were applied.

Regarding the scale and complexity of the verification procedures, the verification risk assessment was leveraged to design verification activities appropriate to address the inherent, controls and detection risk evaluated in relation to each activity data and boundary condition. In most cases, these verifications involved review of documentation, recalculation or analytical procedures designed to produce verification evidence to support the accuracy, completeness and consistency of the information. All activity data and boundary conditions were evaluated through the verification risk assessment and verification activities were designed and completed commensurate with the verification risk assessed.

In a similar way, the data integrity, quantification methodologies and quantification itself were assessed through the verification risk assessment. Verification procedures were designed and completed to address each of these key areas.

Verification evidence was developed from each of these verification activities, which was used to establish a verification conclusion regarding the GHG information systems, the Responsible Party’s controls and ultimately, the GHG Assertion.

Describe steps of the verification including planning, assessment, site visit, off-site verification, and report preparation.


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The verification was conducted according to the ISO 14064-3 standard, which establishes four primary phases of a greenhouse gas verification as described in this section. The relevant sections from the ISO standard are noted below.

Agreement (ISO Section 4.3)

The verification level of assurance, objectives, criteria, scope and materiality was affirmed in the contract for services and re-affirmed during a verification kickoff meeting.

A conflict of interest review was conducted prior to beginning work and monitored throughout the verification. A conflict of interest statement is appended to this report.

Internally, Brightspot Climate began documenting the verification upon contract signing. All documentation related to the verification will be maintained for a period of seven years following the date of the verification statement.

Approach (ISO Section 4.4)

Brightspot Climate conducted an initial review of the Project’s greenhouse gas information, primarily by reviewing the Offset Project Plan and other project documentation. Brightspot Climate prepared a verification risk assessment based on this information, evaluating:

a) the inherent risks of discrepancies for each variable used to calculate each emission source and the general greenhouse gas reporting system;

b) the risk that the Responsible Party’s controls are insufficient to detect and prevent each inherent risk from causing a discrepancy in the GHG assertion; and

c) the potential magnitude of each inherent and control risk described above resulting from the contribution of the associated emission source.

This information was used to develop an appropriate verification procedure for each identified risk. Each procedure was designed to reduce the probability that the verification would not detect a discrepancy that has not been corrected by the Responsible Party’s controls. The tolerable error for each emission source is stated in the verification risk assessment.

Verification Plan

Brightspot Climate developed a Verification Plan that documents the level of assurance, verification objective, verification criteria, verification scope, and materiality. Additionally, the Verification Plan provides general description of the Project, documents operational and organizational changes that have occurred since the previous verification, explains the Project’s control environment, and describes the safety requirements of the site visit.

The results of the verification risk assessment and the verification procedures (including the sampling plan) has been included in the Verification Plan, but will not be disclosed to the Responsible Party until the final Verification Statement is issued.

Assessment (ISO Sections 4.5 – 4.7)

The verification procedures consist primarily of tests, analysis and review focused on the following six critical areas:

a) The completeness and relevance of emission sources included in the GHG Assertion;

b) The consistency of the emission sources and quantification methodologies between the Protocol, the Offset Project Plan, Offset Project Report and the tools used to quantify the emission reduction;

c) The accuracy and level of transparency of measured and estimated data sources, data integrity of electronic and manual data transfers and transcription between data systems and the GHG calculation;


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d) The accuracy of the GHG emissions reduction calculations;

e) The completeness, accuracy and transparency of information presented in the Offset Project Plan and Offset Project Report documents, including the implementation of stated methodologies and emission factors in the quantification of emissions reductions; and

f) The accuracy of transcription of final calculated values into the GHG Assertion, including the “confirmations” required by ACCO as described in the ACCO Standard for Validation, Verification and Audit document.

The principles defined in the preceding six areas are defined in ISO 14064-1 (accuracy, completeness, consistency, relevance and transparency).

Site Visit

Site visits were conducted over three full days by Jeanna Brown and Rodrigo Cubedo of Brightspot Climate, for a sample of the subproject sites within the aggregated project. The selection of sites to be visited was made during the verification risk assessment process. The selection considered site ownership and subproject types, and the magnitude of the emission reduction for each site within the aggregated assertion. During the site visits, completeness of data sources, accuracy of measurement and data system integrity were tested through observation and interviews with site operations and instrumentation personnel.

Further details of the verification activities that were conducted on site, including observations and inquiries, are provided in Section 4 of this report.

Verification Procedures

The remainder of the verification procedures were conducted through a desk review following receipt of the draft GHG Assertion.

Through the course of the assessment phase of the verification, Brightspot Climate issued questions and requests for additional documentation and data. These requests were consolidated in a simple electronic tracking document to maintain a common record of communication.

The Responsible Party had the opportunity to address any issues that were raised through the course of the verification before they were documented as discrepancies in the Verification Report.

Evaluation and Statement (ISO Sections 4.8 – 4.9)

Following the completion of all verification procedures and consideration of all information received from the Responsible Party, the verifier was tasked with concluding whether the GHG assertion is without material discrepancy and whether the verification reviewed sufficient and appropriate evidence to support a reasonable level of assurance.

If any outstanding discrepancies remained, their materiality would have been calculated according to ACCO guidance such that both the aggregate net quantitative error and the absolute quantitative error could be reported. In such circumstances, qualitative discrepancies would be evaluated based on the potential impact on the GHG assertion and the potential impact on the Intended User’s ability to use the reported information.

Peer Review

The independent Peer Reviewer conducted a complete review of the verification. The peer review process examined:

a) The completeness of the verification risk assessment; b) The appropriateness of the verification procedures considering the inherent and control

risks identified in the verification risk assessment;


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c) The appropriateness of any sampling conducted in each of the verification procedures; d) The completeness of each verification procedure, including the verifier’s documentation

of work completed; e) Closure of any issues raised by the verifier through the course of the verification; f) The sufficiency and appropriateness of all evidence reviewed through the verification to

support a reasonable level of assurance; and g) A review of the final Verification Statement and Conflict of Interest Statement.

Verification Report

The Verification Report includes a Verification Statement, Statement of Qualifications, Conflict of Interest Statement and a report on the findings of the verification. The final Verification and Sampling Plan has been appended to the Verification Report, including the results of the verification risk assessment.

Describe how the risk based approach was implemented in the sampling plan. Identify categories of risk including inherent risk, and detection risk (organization and verifier). Include the Verification Plan with the Sampling Plan in Appendix A. Paste the risk assessment table in this section.

Verification risk is defined as the risk of an incorrect verification conclusion. It can be calculated as the product of

• The Project’s inherent risks; • The Responsible Party’s control risks; and • The detection risks associated with the verifier’s verification procedures.

Inherent Risk × Control Risk × Detection Risk = Verification Risk

The verifier cannot affect the inherent risk or the control risk. Therefore, to reduce the overall verification risk and reach the agreed level of assurance (defined in the verification scope), the verifier must design verification procedures that reduce the detection risk.

Each inherent and control risk was provided with the risk score (high/medium/low). The risk analysis of inherent and control risks considers both the magnitude of the activity data or inventory component on the overall GHG assertion as well as the probability that the risk will result in a discrepancy, as assessed by the verifier.

The Verification Risk Assessment Summary on the following pages describes the following information: • Activity Data / Inventory Component: The boundary, eligibility requirement, data

component or reporting activity being evaluated. • Inherent Risk: The verifier’s evaluation of inherent risk. Inherent risks have been

categorized according to the ISO 14064-1 principles (accuracy, completeness, consistency, relevance, transparency).

• Control Risk: A description of the Responsible Party’s controls (if any controls are applicable) and the verifier’s evaluation of control risks.

• Max Detection Risk: The maximum detection risk that can be applied and still result in an overall verification risk that meets the agreed level of assurance.


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• Designed Detection Risk: The detection risk of the verification procedure that the verifier intends to complete. Note that the designed detection risk must always be equal to or lower than the maximum detection risk.

• Verification risk: the product of the inherent, control and (designed) detection risk, as defined in the equation above.

Important note: The verification strategy for this verification applies both substantive tests and control tests. Substantive tests are designed to focus on directly testing activity data or inventory components and their associated inherent risks. Control tests are designed to focus on testing the Responsible Party’s controls and if the test is successful, relying on the Responsible Party’s control. Therefore, control tests indirectly test activity data or inventory components.

Each verification procedure listed in the following table denotes if the procedure is a substantive or control test.

Table 1: Risk Assessment

Activity Data/ Inventory Component

Inherent Risk Control Risk Max Detection Risk

Detection Risk Design

Description of Verification Procedure

Verification Risk

Protocol Applicability Requirements

Functional equivalence must be demonstrated

Relevance (high)

Level of service may have changed between the baseline and project conditions.

Control: The Responsible Party’s Offset Project Plan describes how functional equivalence is maintained.

Control Risk: The Offset Project Plan may be inaccurate or out of date (low).

Low Low Substantive test: Observe operations and interview operations staff during site visit to determine level of service provided by project implementation.

Low

Protocol is applicable to methane vent reductions; not applicable to reduction of propane or conversion from propane to methane

Relevance (low)

Propane devices may have been included in the inventory

The Responsible Party does not have a control specifically designed to address this inherent risk.

High Low Substantive test: Observe operations and interview operations staff to determine if any propane devices are, or have been, installed.

Low


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Verification Risk

Project must be a conversion (brownfield) or an acceptable install (greenfield)

Relevance (high)

Project may have been implemented at greenfield sites that do not meet protocol requirements.

Control: The Responsible Party’s Offset Project Plan describes how eligibility is established.


Low Low Substantive test: Review documentation for a sample of sites that establishes eligibility according to Table 1 of the protocol.

Low

Pneumatic devices must be properly maintained and inspected

Consistency (low)

Pneumatic devices may vent excessively if not properly maintained.

Control: The Responsible Party has ensured that the Subproject Proponents have implemented a management system for leak detection and repair, and for visual inspection of pumps.

Control Risk: This system may not have been implemented or maintained at all project sites (low).

High Medium Control Test: Review the Responsible Party’s management system for maintenance and inspection to determine if system is complete for all sites and has been maintained through the reporting period.

Low


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Verification Risk

An inventory of devices must be maintained

Completeness (medium)

The inventory of devices may be incomplete.

Control: The Responsible Party has generated an inventory list with data confirmation via field visits.

Control Risk: This inventory may be incomplete or contain inaccurate data (low).

Low Low Control test: Observe devices during site visit and compare against project inventory to evaluate completeness.

Low

Substantive test: Review documentation supporting the record of conversion (installation/conversion date) and device specifications.

Low

The project must meet the requirements of the Alberta Offset System

Relevance (high)

The project may not have met the requirements of the Alberta Offset System.

Control: The Responsible Party’s Offset Project Plan describes how the requirements of the Alberta Offset System are met.


Low Low Substantive test: Evaluate the Responsible Party’s evidence regarding the general requirements of the Alberta Offset System.

Low


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Verification Risk

Protocol Flexibility

Implementation of multiple pneumatic device conversions

Completeness (medium)

The project aggregates installations at multiple project sites. The data and documentation may not be complete for all sites.

Control: The Responsible Party has implemented a centralized data management system.

Control Risk: The inputted data may be incorrect or incomplete (low).

Low Low Substantive test: Evaluate the completeness of the required data and documentation for all project sites included in the aggregated project.

Low

Statistically relevant comparisons or emission factors may be used

N/A N/A N/A N/A Not applicable for this project.

N/A

Site-specific and make and model-specific emission factors may be applied

N/A N/A N/A N/A Not applicable for this project.

N/A


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Verification Risk

Preferential order of methods for baseline and project activity quantification for certain project types

Accuracy (low)

An inappropriate quantification methodology may be used.

Control: The preferential quantification methods have been implemented in the Responsible Party’s data management system.

Control Risk: The system may not function correctly (low).

High Low Substantive Test: Recalculate the emission reduction.

Low

Quantification Data

Protocol specified vent rates

Accuracy (low)

An incorrect value may be used in the calculation.

Control: Vent rate values are taken from the Protocol and are input into the Responsible Party’s data management system.

Control Risk: An incorrect value may have been selected or input (low).

High Low Substantive test: Review and confirm selected specified vent rate values.

Low


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Verification Risk

Manufacturer specified Emissions Factors for chemical injection pumps

Accuracy (low)

An incorrect value may be used in the calculation

Control: Manufacturer’s specified values are input into the Responsible Party’s data management system.

Control Risk: An incorrect value may have been selected or input (low).

High Low Substantive test: Review and confirm selected specified values.

Low

Gas analysis

(%CH4 and %CO2)

Accuracy (low)

Reported gas compositions may not accurately represent the gas composition or may be incorrectly transcribed into the emission reduction calculation.

Control: Independent lab conducts gas analysis. An internal process is used to validate results.

Control Risk: The validation of lab results may not have been completed (low).

High Medium Substantive test: Analyze gas compositions for significant fluctuations or abnormal gas concentrations.

Control test: Confirm the accurate transcription of the gas analysis into the emission reduction calculation.

Low

Completeness (low)

The gas compositions may not include a valid gas composition for each period at the required frequency.


High Medium Substantive test: Review completeness of gas composition data.

Low


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Verification Risk

Reference density of methane at STP conditions

Accuracy (low)

The density of methane applied in the calculation may not represent the density at STP conditions.


High Low Substantive test: Compare the density of methane applied in the calculations to the reference value provided in the relevant reference documents.

Low

Alberta electricity grid factor

Accuracy (low)

The Alberta electricity grid factor applied in the calculation may not represent the correct grid factor.


High Low Substantive test: Compare the Alberta electricity grid factor applied in the calculations to the reference value provided in the relevant reference documents.

Low

Pump stroke count

Accuracy (medium)

The pump stroke count used to assess pump conversions may be incorrect if total strokes, operating hours or proration calculation is incorrect.


Low Low Substantive test: Recalculate prorated pump strokes.

Low


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Verification Risk

Operating hours

Accuracy (low)

Inaccurate or incomplete operating hours.


High Medium Substantive test: Compare operating hours used in calculations with values government reported hours.

Low

Chemical Injection Volume

Accuracy (low)

Volume of chemical injected may not be measured or recorded accurately.


High Medium Substantive test: Review tank fill reports and compare to values used in calculations.

Low

Emission Quantification and Reporting

Application of the approved quantification protocol

Accuracy (high)

The project developer may not have implemented approved quantification methodologies or applied additional methodologies.

Control: Responsible Party has developed an Offset Project Plan that is intended to conform to the requirements of the approved quantification protocol.

Control Risk: The protocol requirements may not have been implemented correctly (medium).

Low Low Controls test: Compare the methodologies described in the Responsible Party’s Offset Project Plan to the methodologies described in the approved quantification protocol.

Low


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Verification Risk

Substantive test: Recalculate the emission reduction using original metered data and methods described in the approved quantification protocol.

Low

Quantification of emission reduction

Accuracy (high)

Emission reduction calculation may contain arithmetic errors.


Low Low Substantive test: Recalculate the emission reduction using original metered data.

Low

Data Integrity

Activity data and emission factor data integrity

Accuracy (medium)

Data may not have been accurately transferred between electronic systems and calculation sheets.

Control: The Responsible Party uses electronic data transfers whenever possible to maintain data integrity.

Control Risk: Electronic data transfers may result in errors or may not be available for all data (medium).

Low Low Controls test: Analyze activity data for abnormal data (zeros, missing data, values outside range).

Low


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Verification Risk

Substantive test: Recalculate the complete emission reduction using original data.

Low

Transcription of final emission reduction into Offset Project Report

Accuracy (low)

Final emission reduction may not have been transcribed accurately from calculation spreadsheets into the Offset Project Report.


High Low Substantive test: Compare the final emission reduction quantity reported by the Responsible Party to the quantity reported in the Offset Project Report. Also, compare these quantities to the recalculated quantity in previous verification procedures.

Low


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3.2 Team List verification team members including peer reviewer(s).

Describe the qualifications and training of the team members and peer reviewer(s) including dates of training and certifications.

For Offsets: fill in the sample Statement of Qualification provided and included in Appendix B.

For Facilities: include the Statement of Qualifications from the facility compliance form in Appendix B.

ISO 14064-3 defines sixteen subject matter areas in which the verifier should demonstrate familiarity (see ISO 14064-3, Section A.2.2.3). The verification team has competencies in each of these sixteen subject matter areas.

Lead Verifier: Aaron Schroeder, P.Eng.

Aaron Schroeder will be the Lead Validator and Designated Signing Authority. His extensive experience quantifying and verifying greenhouse gas emissions satisfies all sixteen subject matter areas defined in the standard.

Biography: Aaron Schroeder has eleven years of professional experience analyzing, quantifying and verifying greenhouse gas emissions in North America. Prior to forming Brightspot Climate Inc. in 2015, Aaron worked for several years leading a team of fifteen greenhouse gas verification and policy analysts across Canada with ICF International. He provided leadership for this team and led the development of ICF’s standardized verification process, conformant with ISO 14064-3. In 2012, ICF’s verification process was accredited by the American National Standards Institute (ANSI).

Mr. Schroeder’s hands on experience conducting greenhouse gas verifications includes numerous engagements for oil and gas extraction and processing, refining, pipeline, electricity generation and petrochemical facilities. Additionally, he has conducted verifications of emission reduction projects in industrial facilities, renewable energy, waste management and agriculture. He is sought after for his expertise devising strategies to bridge the gap between theoretical and practical implementation of methodologies for quantifying, reporting and verifying.

In 2014, the University of Toronto engaged Mr. Schroeder to instruct professional development courses on greenhouse gas inventory and project quantification, reporting and verification. Since 2014, Mr. Schroeder has instructed several of these courses in live, two-day sessions and on-line instruction as a sessional lecturer through the university’s School of Environment. Additionally, Mr. Schroeder has worked with the School of Environment to re-write and update the courses.

Training: Greenhouse Gas Verification – ISO 14064-3, Canadian Standards Association, 2012; Instructor – Greenhouse Gas Verification – ISO 14064-3, University of Toronto, 2015 - 2017

Associate Verifier: Jeanna Brown, P.Eng.

Biography: Jeanna Brown is a Professional Engineer with thirteen years of experience in the oil and gas industry. During her previous employment, she focused on drilling engineering and well planning for wells of varying complexity. She has experience with field based drilling engineering/operations, wellsite supervision and exploration projects. More recently, Jeanna’s technical focus concentrated on in-situ oil sands projects and thermal/steam well design. Since joining Brightspot, Jeanna has gained experience working on GHG verifications for a variety of projects related to oil and gas production and processing, agriculture and electricity generation.

Training: Jeanna received GHG Validation and Verification, ISO 14064-3, training through the University of Toronto in September 2017.


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Associate Verifier: Rodrigo Cubedo, B.Eng.

Biography: Rodrigo Cubedo has a background in mechanical engineering, specializing in aerospace projects. Rodrigo has leveraged his engineering experience to understand and systematically improve the processes used to work with international clients. He is fluent in Spanish, English, French and basic Mandarin. His experience working with a large accounting firm through an in-house deployment of analytical software exposed him to a systematic research framework, which he has recently used to complete GHG verifications.

Training: Rodrigo Cubedo graduated as a mechanical engineer from McGill University in June of 2016.

Peer Reviewer: Chris Caners, P.Eng.

Biography: Chris Caners has more than a decade of practice in the energy and environment industry. He has extensive knowledge of energy efficiency, greenhouse gas quantification, assessment and verification; energy and emissions modeling and policy analysis. He has experience leading conservation potential assessments, energy audits, and conservation program planning and design efforts. He recently directed an assessment of energy efficiency potential for a unique electrical distribution system in Canada; he also led a detailed natural gas conservation potential study in Ontario.

Chris has audited dozens of facilities and facility level emission reports (conventional and unconventional oil and gas extraction, processing and transmission, cogeneration, power generation and mining) and energy efficiency and emission reductions projects across Canada, including anaerobic wastewater treatment, commercial building efficiency, acid gas injection, enhanced oil recovery, wind energy, aerobic composting and landfill gas.

Training: Greenhouse Gas Verification – ISO 14064-3, Canadian Standards Association, 2008

3.3 Schedule Provide a list or table of verification activities and dates. Indicate when the verification was completed.

Verification Kickoff Meeting August 1, 2018

Draft Verification Plan August 3, 2018

Site Visit August 13-15, 2018

Supplementary Information Request November 27, 2018

Draft Verification Report December 13, 2018

Final Verification Report December 14, 2018


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4.0 Results Add introduction to results section here, if desired.

The verification results are presented in the following five subsections. Subsections 4.1 – 4.3 present the results of the verification procedures for the data integrity (4.1), Quantification Methodologies and Quantification (4.2), and Boundary Conditions and Activity Data (4.3).

4.1 Assessment of Internal Data Management and Controls Provide a summary the information system(s) and its controls for sources of potential errors. Include information on the selection and management of data, process for collecting and consolidating data, data accuracy systems, design and maintenance of the GHG system, the systems and processes that support the GHG information system and results from previous assessments if applicable.

The Responsible Party’s GHG quantification is primarily performed in a proprietary software program, known as “Distributed Energy Efficiency Project Platform (DEEPP)”. All data required to quantify emissions reductions for the Project are input into DEEPP via spreadsheets, which are either manually transcribed into these spreadsheets or electronically transferred from other spreadsheets. The final calculated quantities are exported from DEEPP into spreadsheets and then manually transferred into the Offset Project Report. Data validation is completed before information is transferred into the report; therefore, there are no active data controls in the document. The functionality of the DEEPP software was not directly tested or investigated through the course of this verification. However the input data required for the quantification were reviewed and validated, and outputs from the DEEPP software were found to reasonably match the results of the recalculation.

Activity data required for the emissions reduction quantification are referenced from government reported datasets and third party laboratory reports.

The Responsible Party maintains an Offset Project Plan (OPP) and produces an Offset Project Report (OPR), which document the emission sources, processes for collecting GHG activity data, equations applied to quantify emissions reduction, calculation assumptions, meter calibration procedure and schedule, the averaging method applied to quantification, and a discussion of GHG data management.

Findings from Previous Verification

The following findings were noted in the previous verification report:

• The Responsible Party included B10 emissions (Fuel Extraction & Processing) in the quantification but later removed this SSR, in accordance with the Protocol.

• Transcription errors were identified for some gas composition data, for some C2+ components. As this only applied to C2+ components it did not affect the outcome of the emission reduction calculation. This was identified as a qualitative immaterial discrepancy.

• A discrepancy was identified between operating hours used in the quantification and government reported values for a very small number of subprojects. This was identified as a qualitative immaterial discrepancy.


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Results of Verification Procedures

There were three verification procedures completed to test data integrity. The results of these procedures are provided in the following table.

Table 2: Findings of Data Integrity Verification Procedures

GHG Report Element

Detection Risk

Verification Procedures Verification Findings

Activity data and emission factor data integrity

Low Controls test: Analyze activity data for abnormal data (zeros, missing data, values outside range).

Activity data was reviewed and evaluated for anomalies such as zeros, missing data points, values outside range, etc.

No discrepancies were detected in the metered activity data.

Low Substantive test: Recalculate the emission reduction using original metered data.

The recalculated emission reductions matched the quantities asserted by the Responsible Party. It is therefore a reasonable conclusion that data integrity has been maintained from points of metering through reporting.

No discrepancies were detected in the accuracy of the emission reduction quantification.

Transcription of final emission reduction into Offset Project Report

Low Substantive test: Compare the final emission reduction quantity reported by the Responsible Party to the quantity reported in the Offset Project Report. Also, compare these quantities to the recalculated quantity in previous verification procedures.

Values reported in the Offset Project Report match the values quantified by the Responsible Party.

No discrepancies were detected in the transcription of values in the Offset Project Report.

4.2 Assessment of GHG Data and Information Provide a summary of the information found during the verification of the GHG data and a summary of the GHG Assertion that was assessed.

For Facilities: Confirm that the quantification methodologies that were used in the compliance report are the same as those reported in the BEIA.

For Offset Projects: Confirm that the quantification methodologies that were used by the project proponent are the same as those described in the project plan. Indicate which quantification methodologies were used by the project proponent.


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The GHG information consists of the activity data applied to quantify emissions reductions, the source documentation for the activity data, the information in the Offset Project Plan, as described in the previous section of this report, and the documentation supporting the boundary, methodologies, meter calibration, and emission factors.

Table 3: Findings of GHG Data and Information Verification Procedures

GHG Report Element

Detection Risk


Verification Findings

Quantification Data

Protocol specified vent rates

Low Substantive test: Review and confirm selected specified vent rate values.

The vent rate values used in the quantification match the Protocol values.

For devices where the supply pressure was between the two supply pressures listed in Appendix C of the Protocol, the Responsible Party applied an appropriate method to select a conservative emission factor. Their approach is conservative in the baseline condition, and ensures consistency between the baseline and project assumptions.

For certain controller conversions in a specific supply pressure range, the Responsible Party applied a calculation method to estimate an appropriate emission factor. This was done based on input from the controller supplier, and is a reasonable approach in this limited pressure range, for these specific devices.

No discrepancies were detected in the vent rate values used in the quantification.


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GHG Report Element

Detection Risk



Manufacturer specified Emissions Factors for chemical injection pumps

Low Substantive test: Review and confirm selected specified values.

The manufacturer supplied emissions factors are available for injection pressures ranging from 100 psi to 6000 psi. However, many of the pumps in this aggregated project operate at injection pressures below 100 psi. The Responsible Party therefore applied a calculation method to estimate the emission factor for injection pressures below 100 psi. This approach was found to be an appropriate means of using the manufacturer’s specifications, and adds further conservatism to the quantification.

For pumps where the injection pressure was between two injection pressure values in the manufacturer supplied data, the Responsible Party applied an appropriate method to select a conservative gas consumption value. This approach is conservative in the baseline condition, and ensures consistency between the baseline and project assumptions.

No discrepancies were detected in the chemical injection pump emission factor values used in the quantification.

Gas analysis

(%CH4 and %CO2)

Medium Substantive test: Analyze gas compositions for significant fluctuations or abnormal gas concentrations.

Review of the gas compositions did not reveal significant fluctuations or abnormal concentrations.

No discrepancies were detected in the gas composition analyses used in the quantification.


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GHG Report Element

Detection Risk



Control test: Confirm the accurate transcription of the gas analysis into the emission reduction calculation.

For several subproject participants, gas analysis data was provided as an export from a third party laboratory database. A portion of gas composition data was manually transcribed into a spreadsheet and then inputted into the Responsible Party’s calculation software. A sample of gas analyses were selected and transcription was checked. No discrepancies were identified in the transcription of the gas analysis data to the emission reduction calculation.

No discrepancies were detected in the gas composition analyses used in the quantification.

Medium Substantive test: Review completeness of gas composition data.

Gas composition data was complete for all subprojects.

No discrepancies were detected in the completeness of gas composition data.

Reference density of methane at STP conditions

Low Substantive test: Compare the density of methane applied in the calculations to the reference value provided in the relevant reference documents.

The Responsible Party used a value of 0.678 kg/m3 for the density of methane at STP conditions (source: WCI – Final Essential Requirements for Mandatory Reporting)

No discrepancies were detected in the reference density of methane at STP conditions used in the quantification.


Low Substantive test: Compare the Alberta electricity grid factor applied in the calculations to the reference value provided in the relevant reference documents.

All pump conversions included in this aggregated project are conversions to solar pumps. Therefore SSR P8 (Process Control Electricity) is zero in accordance with the Protocol, and an electricity grid factor is not required.

No discrepancies were detected in the electricity grid factor.


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GHG Report Element

Detection Risk



Pump stroke count

Low Substantive test: Recalculate prorated pump strokes.

The data collection period for some of the pump stroke data extended outside (before/after) the reporting period. Since it is impractical to measure stroke count precisely at the beginning and ending of the reporting period, the Responsible Party applied the following methodology: The Responsible Party performed a proration calculation that determined the number of pump strokes associated with the reporting period for each device. Actual recorded operating hours were applied for the duration of the reporting period, and the average of 2016 and 2017 operating hours were assumed for the time period after the reporting period.

The independent recalculation of prorated pump strokes used in the quantification resulted in the same pump strokes calculated by the Responsible Party.

No discrepancies were detected in the recalculation of prorated pump strokes.

Operating hours Medium Substantive test: Compare operating hours used in calculations with values government reported hours.

Operating hours were extracted from Petrinex and applied in the recalculation of the emissions reduction. As the independent recalculation of the emissions reduction reasonably matched the emissions reduction asserted by the Responsible Party, the verification team concluded that operating hours matched the government reported hours.

No discrepancies were detected in the operating hours used in the emissions reduction calculation.

Chemical Injection Volume

Medium Substantive test: Review tank fill reports and compare to values used in calculations.

Chemical injection volumes were used only when pump stroke counts were not available. Injection volumes were reviewed and compared to tank fill reports.

No discrepancies were found in the chemical injection volumes used in the quantification.


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GHG Report Element

Detection Risk



Emission Quantification and Reporting

Application of the approved quantification protocol

Low Controls test: Compare the methodologies described in the Responsible Party’s Offset Project Plan to the methodologies described in the approved quantification protocol.

The verification team compared the methods described in the Offset Project Plan to the methods described in the approved Quantification Protocol.

The quantification methods described in the Responsible Party’s Offset Project Plan adhere to the methods described in the approved Quantification Protocol. The preferential quantification methods have been implemented in the Responsible Party’s data management system appropriately, as per Table 2.0 of the Protocol.

No discrepancies were detected in the methodologies described in the Offset Project Plan.

Substantive test: Recalculate the emission reduction using original metered data and methods described in the approved quantification protocol.

The independent recalculation of the emission reduction resulted in the same emission reduction quantity asserted by the Responsible Party. Therefore, the approved Protocol quantification methods were applied in the Responsible Party’s emission reduction quantification.

No discrepancies were detected in the methodology used in the calculation of the emission reduction.


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GHG Report Element

Detection Risk



Quantification of emission reduction

Low Substantive test: Recalculate the emission reduction using original metered data.

The functionality of the DEEPP calculation software was not directly tested or investigated through the course of this verification. However the input data required for the quantification were reviewed and validated, and outputs from the DEEPP software were found to reasonably match the results of the recalculation.

The independent recalculation of the emission reduction resulted in the same emission reduction quantity asserted by the Responsible Party. Therefore, the Verification Team concluded that no arithmetic or calculation errors were made by the Responsible Party in the emission reduction quantification.

No discrepancies were detected in the recalculation of the emission reduction.

4.3 Assessment against Criteria Provide a description of how eligibility criteria is met or not met.

For Offset Project: Complete Table 1 to indicate if the GHG Assertion conforms to the Regulation and Standard for Greenhouse Gas Emission Offset Project Developers eligibility criteria.

For Facilities: Delete Table 1 and Indicate if verification criteria are met or not met and explain.


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Table 4: Findings of Criteria Verification Procedures

GHG Report Element

Detection Risk



Protocol Applicability Requirements

Functional equivalence must be demonstrated

Low Substantive test: Observe operations and interview operations staff during site visit to determine level of service provided by project implementation.

During the site visits, the verification team observed the pneumatic valves, controllers and chemical injection pumps, and found that an equivalent level of service is provided by all installations.

Site staff indicated that the systems work well and reliably. Ongoing maintenance is performed during regular maintenance of the full facility.

No discrepancies were detected in the functional equivalence of the converted devices.

Protocol is applicable to methane vent reductions; not applicable to reduction of propane or conversion from propane to methane

Low Substantive test: Observe operations and interview operations staff to determine if any propane devices are, or have been, installed.

During the site visits and interviews with site personnel no propane devices were observed, and there were no indications of the use of propane.

No discrepancies were detected in the application of the Protocol to methane vent reductions only.

Project must be a conversion (brownfield) or an acceptable install (greenfield)

Low Substantive test: Review documentation for a sample of sites that establishes eligibility according to Table 1 of the protocol.

During the site visits, the verification team confirmed that all sites that were visited were implemented as brownfield conversions or acceptable greenfield installs, as per Table 1 of the Protocol.

No discrepancies were detected in the eligibility of subprojects.


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GHG Report Element

Detection Risk



Pneumatic devices must be properly maintained and inspected

Medium Control Test: Review the Responsible Party’s management system for maintenance and inspection to determine if system is complete for all sites and has been maintained through the reporting period.

Interviews with operations personnel indicated that ongoing maintenance and inspection programs are performed as part of regular maintenance of the full facility.

No discrepancies were detected in the maintenance and inspection of the pneumatic devices in this aggregated project.

An inventory of devices must be maintained

Low Control test: Observe devices during site visit and compare against project inventory to evaluate completeness.

The Responsible Party maintains a comprehensive inventory list of subprojects included in the aggregated project. Installed equipment observed during site visits were compared against the Responsible Party’s inventory.

No discrepancies were detected in the project device inventory.

Substantive test: Review documentation supporting the record of conversion (installation/conversion date) and device specifications.

Installation records were reviewed for a sample of subprojects (86 records, as per the sampling plan). Device specifications and installation dates were compared between the installation records and the input sheets for the emissions reduction calculation.

No discrepancies were detected in the transcription of device specifications.


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GHG Report Element

Detection Risk



The project must meet the requirements of the Alberta Offset System

Low Substantive test: Evaluate the Responsible Party’s evidence regarding the general requirements of the Alberta Offset System.

Occurs in Alberta – All sites in the aggregated project are located within Alberta, as confirmed by project documentation.

Actions not otherwise required by law – No regulatory requirements were found to apply to the project activity for the sites in the aggregated project.

Actions taken on or after January 1, 2002 – Installation and commissioning of all devices occurred after this date, as confirmed by project documents and inquiries of site operations staff.

Real, demonstrable, quantifiable – The verification procedures confirmed that the emission reductions in the aggregated assertion meet these requirements. The specific verification procedures supporting this conclusion include observation during the site visits, review of supporting meter calibration reports and documentation and the recalculation of the emission reduction.

Clearly established ownership – This project involves a number of Project Participants. The Responsible Party has clearly established ownership through contractual agreements.

Counted once for compliance purposes – The project credits will be registered with the Alberta Emissions Offset Registry (AEOR). Brightspot Climate is not aware of any other systems or registries where the Project has been registered. The Responsible Party has not disclosed registration of the Project on any other system or registry.


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GHG Report Element

Detection Risk



Protocol Flexibility

Implementation of multiple pneumatic device conversions

Low Substantive test: Evaluate the completeness of the required data and documentation for all project sites included in the aggregated project.

Data and documentation for all sites has been included in the aggregated project.

No discrepancies were detected in the completeness of the data and documentation for the device conversions included in this aggregated project.

Statistically relevant comparisons or emission factors may be used

N/A Not applicable for this project.

Not applicable. Statistically relevant comparisons or emission factors were not used in the quantification.

Site-specific and make and model-specific emission factors may be applied

N/A Not applicable for this project.

Not applicable. Site-specific and make and model-specific emission factors were not used in the quantification.

Preferential order of methods for baseline and project activity quantification for certain project types

Low Substantive Test: Recalculate the emission reduction.

The independent recalculation of the emission reduction resulted in the same emission reduction quantity asserted by the Responsible Party. Therefore, the approved Protocol quantification methods and preferential order of methods were applied in the Responsible Party’s emission reduction quantification.

No discrepancies were detected in the recalculation of the emission reduction.


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Table 5: Offset Criteria Assessment

Offset Eligibility Criteria

Assessment

Reduction or sequestration occurs in Alberta

The aggregated project includes sub-projects in locations throughout Alberta. The Aggregated Project Reporting Sheet was reviewed to confirm all locations are within the Province of Alberta.

Result from actions not required by Law at the time the action is taken

The project activity is not required by municipal, provincial or federal regulations or directives.

Federal and provincial regulations and directives requiring this activity are expected to take effect on January 1, 2023.

Result from Actions taken on or after January 1, 2002 and occur on or after January 1, 2002

Installation and commissioning of all devices occurred after this date, as confirmed by project documents and inquiries of site operations staff.

Reduction or sequestrations is real and demonstrable

The emission reduction was demonstrated through measurement and estimation of data required for the quantification. The GHG information presented to the verification team included sufficient and appropriate evidence to substantiate conformance with the Protocol Applicability Requirements and to substantiate the quantification data.

Quantifiable and measurable

The emission reduction was demonstrated through measurement and estimation of data required for the quantification. This data was substantiated by sufficient and appropriate evidence. Table 3 of this report presents the findings of the evaluation of each variable required for the emission reduction quantification.

Verified by a third party verifier that meets the requirements in Part 1 for the Standard for Verification.

Brightspot Climate Inc. is an independent third-party verifier that meets the requirements outlined in Section 1 of the Standard for Verification. The Lead Verifier and Designated Signing Authority, Aaron Schroeder, is a Professional Engineer and has extensive experience quantifying and verifying greenhouse gas emissions, satisfying all sixteen subject matter areas defined in the ISO 14064-3 Standard.


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4.4 Evaluation of the GHG Assertion The verification assessment is that the GHG Assertion meets the requirements of the Carbon Competitiveness Incentive Regulation

Provide an assessment of the evidence collected during the verification. Determine if the data and information available support the GHG assertion. Provide a conclusion on whether the assertion meets the materiality requirements and the level of assurance agreed to at the beginning of the verification process.

The results of each verification procedure are provided in the preceding three subsections (4.1 – 4.3). Sufficient and appropriate evidence was collected through the verification procedures to reach the verification conclusion at a reasonable level of assurance, which is provided in the Verification Statement.

The data and GHG information provided by the Responsible Party is sufficient to support the GHG assertion.

There were no material or immaterial discrepancies detected in the final GHG assertion.

4.5 Summary of Findings Provide a summary of material and immaterial discrepancies expressed in tonnes and as net and absolute error in Table 2. Include whether the discrepancy was an understatement or an overstatement.

Include a more detailed description and log of results in Appendix C the “Issues Log”. This log will include both resolved and unresolved issues from the verification. Unresolved issues should be brought forward to Table 2.


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Table 6: Summary of Findings

Number the finding with the year and provide a unique # for each finding. Note: A detailed description of all material and immaterial findings should be provided in Table 3 of Appendix C. Provide only a summary statement (1-4 sentences) for each unresolved immaterial finding and each material finding (resolved or unresolved). If the finding is a resolved material finding, then put the tonnes net and absolute in the summary description column and indicate n/a in the net and absolute columns. Do not include the tonnes in the total error calculation. Indicate the type of error (qualitative or quantitative). Indicate the Source Category (for facilities) or the Source/Sink (for offsets). Indicate if the finding is an understatement or overstatement. Provide both net and absolute error in tonnes of CO2 eq and as a % of the assertion. Provide the total net error and the total absolute error in tonnes of CO2 eq and as a % of the assertion.

Result Type Summary Description of Finding Source Category or Source/Sink

Understatement / Overstatement

Tonnes CO2e % net

Tonnes CO2e % absolute

17-01 Quantitative One transcription error was detected in the sample of pump stroke count reading dates.

The error rate determined through this verification procedure was extrapolated from the sample to the full population of data. The error that was detected was corrected, which was considered in the estimation of the discrepancy.

Transcription errors in this data point could result in an overstatement or understatement.

Overstatement or Understatement

0.4% 0.4%

17-02 Qualitative The Responsible Party transcribed some high to low bleed device conversion dates incorrectly.

All of the incorrectly transcribed dates fall before the project crediting period and therefore do not affect the asserted emission reduction for this reporting period (or the previous reporting period).

This error was evaluated as a qualitative discrepancy.

Qualitative N/A N/A

Total Error 0.4% 0.4%


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4.6 Opportunity for Improvement Provide feedback on the data management system and controls, transparency, completeness of the inventory, additions to the quantification methodology document or diagrams, etc. Include positive considerations and observations also.

Identify strengths and weaknesses that may help to improve the report/s for the current facility, sector, and compliance program. Identify ways in which the project/facility could be more easily verified.

Overall, the GHG information was orderly and thoroughly presented.

The quantification spreadsheets were satisfactorily organized and sufficiently transparent to conduct the verification procedures.

Sufficient and appropriate evidence was provided by the Responsible Party to conduct each of the verification procedures.

The Offset Project Plan and Offset Project Report thoroughly document the emission sources, quantification approach, equations, data collection and information controls.

A number of Opportunities for Improvement were identified through the course of this verification:

• As noted in Table 3, a calculation method was applied to estimate the emission factor associated with certain controller conversions within a specific supply pressure range. An explanation of this interpolation calculation and how it was applied should be documented.

• As noted in Table 3, a calculation method was applied to estimate gas consumption rates for pump conversions where the injection pressure was less than 100 psi (and therefore below the range provided in the manufacturer’s specification). An explanation of this calculation method and how it was applied should be documented.

• Further to the previous recommendation, the Responsible Party should endeavor to obtain gas consumption rate data from the pump manufacturer for injection pressure ranges less than 100 psi. This would provide stronger evidence and increase the accuracy of the emission reduction quantification for pump conversions with injection pressures below 100 psi.

• As noted in Table 3, pump stroke data collected by the Responsible Party was for a period of time that extended outside of the reporting period. The Responsible Party therefore performed a proration calculation that determined the number of pump strokes associated with the reporting period for each device. An explanation of this proration calculation and how it was applied should be documented.

• Through the course of the verification, it was observed that data collection and management vary between Subproject Proponents. It would be beneficial to provide a more detailed explanation of data management for each Subproject Proponent.

• In some cases, gas analyses were used across multiple sites. Additional clarity on the source of the gas analysis and illustration of how a particular gas analysis is applied to multiple sites could expedite and improve accuracy of the review process.

• Through the course of the verification, some of the supporting documents were not loaded or unavailable in their system, DEEPP. These documents were on file with the Responsible Party. If all documents were loaded in DEEPP, this would improve verification efficiency.


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5.0 Closure 5.1 Verification Statement Include the signed verification statement in Appendix D.

Instructions to insert a pdf: 1. Click Insert>Object 2. In the Object dialog box click Create from File and then click Browse. 3. Find the pdf you want to insert then click Insert. 4.Click OK.

For Offset Projects: fill in the sample Verification Statement provided, sign, scan and paste.

For Facilities: paste a signed version of the Verification Statement from the facility compliance form. Include the conclusion on the GHG assertion and any qualification or limitations and the level of assurance.

Provide the verification conclusion in the drop down box below.

The verification conclusion is:

Positive

5.2 Limitation of Liability Include signed Conflict of Interest Checklist in Appendix E.

For Offset Projects: fill in the sample Conflict of Interest Checklist provided, sign, scan and paste.

For Facilities: paste the signed Conflict of Interest Checklist from the facility compliance form.

Insert limitation of liability statement and include information in an Appendix F if applicable.

5.3 Confirmations Document information confirmed, including any discrepancies or inconsistencies, as per the Confirmations section in the Standard for Greenhouse Gas Verification.

Section 5.1.3 of the Standard for Verification document lists seven activities that are beyond the scope of a typical greenhouse gas verification.

Table 7: Confirmation Findings

Confirmation Confirmation Finding

Correct entry of administrative fields such as facility codes and legal locations

The Offset Project Report was reviewed for completeness and accuracy. All facility and legal location information is complete and accurate.

Quantification Methodology document is provided and consists of the required components

The Responsible Party has documented all relevant methodologies, procedures and controls in the Offset Project Plan and the Offset Project Report.

Simplified process flow diagrams and energy diagrams

The Responsible Party’s Offset Project Plan and Offset Project report provide process flow


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diagrams, which were reviewed and found to accurately represent the Project.

Fuel usage This requirement is not applicable to Offset Projects.

Additional request items/forms are complete and reasonable justification provided where needed

The Statutory Declaration was reviewed and found to be complete.

The Aggregated Project Reporting Sheet was reviewed. Sub-projects listed on this sheet were included in the Aggregated Project Planning Sheet and accurately describe the sub-projects included in the Project.

N/A is checked on pages in the reporting form that do not apply

This requirement is not applicable to Offset Projects.

Project report information details as required The Responsible Party has prepared an Offset Project Report that meets all the requirements specified in the Standard for Greenhouse Gas Emission Offset Project Developers, Version 2.0, July 2018.

6.0 References Author. Year. Title. (no hyperlinks)

None

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Appendix A: Final Verification Plan and Sampling Plan


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Information to be included in the Verification Plan and Sampling Plan:

Revisions to the sampling plan

Date originally sent to Facility/project

Level of assurance agreed with the facility/project developer

Verification scope

Verification criteria

Amount and type of evidence (qualitative and quantitative) necessary to achieve the agreed level of assurance

Methodologies for determining representative samples

Sampling Plan and Procedures

Risk Assessment: Risks of potential errors, omissions or misrepresentations that are identified throughout the verification process including:

- Details of site visit

-offset/facility boundaries

- Methodologies, emissions factors and conversions used

- Comparability with the approved baseline

- Conformance to the program criteria

- Integrity for the responsible party’s data management system and control (organization chart, GHGH management plan, personnel/consultant training, protocols used, control system documentation, software/program documentation/certifications)

- Greenhouse gas data and information, including the type of evidence collected, verification testing and crosschecking, inventory of emission sources

- Discussion of data management, (measurement, fuel sampling, calibration, consistent use of standard conditions, data storage, procedures to fill missing data; procedures to repair inconsistent data, adjustment of variables and factors)

- Other relevant information

+1 (604) 353-0264 • www.brightspot.co • [email protected]

Cap-Op Energy Inc.

Cap-Op Energy Emission Reductions From Pneumatic Devices (Pool B)

Verification Plan

August 3, 2018

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Brightspot Climate Inc. – Verification Plan Cap-Op Energy Inc. – Emission Reductions from Pneumatic Devices (Pool B)

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Terminology

ISO 14064-2 defines the following terms used in the context of a GHG verification:

GHG Assertion: a declaration or factual and objective statement made by the Responsible

Party.

The Alberta Climate Change Office Standard for Validation, Verification and Audit1 extends this

definition to include the document that identifies the greenhouse gas emission reduction and/or

removals and emissions offsets being claimed by the offset project over a defined period of

time.

Project: activity or activities that alter the conditions identified in the baseline scenario which

cause greenhouse gas emission reductions or greenhouse gas removal enhancements.

The GHG Assertion subject of this verification is for the Cap-Op Energy Emission Reductions

from Pneumatic Devices (Pool B) project which will be referred to throughout this document as

“the Project”.

ISO 14064-2 defines the following parties associated with the verification:

Responsible Party: person or persons responsible for the provision of the greenhouse gas

assertion and supporting GHG information.

The Responsible Party for this verification is Cap-Op Energy Inc. (Cap-Op).

Intended User: individual or organization identified by those reporting GHG-related information

as being the one who relies on that information to make decisions.

The Intended User for this verification is the Alberta Climate Change Office (ACCO).

Verifier: competent and independent person, or persons, with the responsibility of performing

and reporting on the verification process.

The Verifier for this verification is Brightspot Climate Inc. (Brightspot Climate). The members of

the verification team are provided in section 2 of this document.

1 Standard for Validation, Verification and Audit, Version 2.0, June 2018, Alberta Climate Change Office.


1

Introduction

This document serves to communicate information between the parties associated with the

independent verification of the Offset Project Report for the Cap-Op Energy Emission Reductions from

Pneumatic Devices (Pool B) project.

This document contains six sections:

1. The Introduction, which defines the principles by which this verification will be conducted;

2. The Verification, which defines the verification parameters and the GHG inventory principles that

will be tested by the verification. This section also provides information regarding the verification

team and site visit;

3. The Responsible Party Data Management and Controls, which describes the data management

system and control environment implemented by the Responsible Party;

4. Previous GHG Assertions, which describes any modifications to the original project that have

been made since the original Offset Project Plan was developed and any findings from previous

verifications for this Project;

5. The Verification Risk Assessment and Verification Procedures, which describes the risks of

potential errors, omissions or misrepresentations to the overall GHG assertion and the

verification procedures that have been developed to reduce the overall verification risk; and

6. The Sampling Plan, which lists the verification procedures that could apply sampling of the

project data, along with the sampling size, the sampling methodology and justification.

The Responsible Party developed the Project in accordance with the requirements of the Quantification

Protocol for Greenhouse Gas Emission Reductions from Pneumatic Devices, Version 2.0, January 2017

(the Protocol).

GHG Quantification Principles

ISO 14064-2 defines six principles that are fundamental to the fair accounting and reporting of GHG

information. The verification procedures will test that these principles have been upheld through the

Responsible Party’s inventory, accounting and reporting processes.

Section 3.2 – 3.6 of ISO 14064-1 defines these principles as follows:

Accuracy: reduce bias and uncertainty as far as practical

Completeness: include all relevant emission sources

Conservativeness: use conservative assumptions, values and procedures to ensure that GHG

emission reductions or removal enhancements are not over-estimated

Consistency: enable meaningful comparisons of reported emissions (from year to year or

between facilities or between companies)

Relevance: select GHG sources, sinks and reservoirs, data and quantification methodologies

appropriate to the needs of the intended user


2

Transparency: disclose sufficient and appropriate GHG information to facilitate verification and

to allow intended users to make decisions with relative confidence


3

Verification

Verification Principles

ISO 14064-3 defines four fundamental principles to conducting a greenhouse gas verification, namely

independence, ethical conduct, fair presentation and due professional care.

Brightspot Climate has implemented processes, including mandatory training for all verification team

members, to ensure the application of these principles for this verification.

Regarding the principle of independence, Brightspot Climate conducted an assessment of threats to

independence prior to initiating this verification. No real or perceived threats to independence were

identified. Brightspot Climate will continue to monitor for threats to independence throughout the

course of this verification. A final “Conflict of Interests Checklist” will be appended to the Verification

Statement.

Verification Parameters

The verification will be conducted according to the parameters defined in the following table:

Table 1: Verification Parameters

Level of Assurance Reasonable assurance

Objectives

• issue a verification statement on whether the GHG assertion is

without material discrepancy;

• issue a verification report that provides details of the verification

activities; and

• complete the “confirmations” activities defined in the Standard for

Validation, Verification and Audit2, Section 5.1.3.

Criteria

• Climate Change and Emissions Management Act

• Carbon Competitiveness Incentive Regulation (255/2017)

• Standard for Greenhouse Gas Emission Offset Project Developers,

Version 2.0, July 2018

• Standard for Validation, Verification and Audit, Version 2.0, June

2018

• Quantification Protocol for Greenhouse Gas Emission Reductions

from Pneumatic Devices, Version 2.0, January 2017

2 Standard for Validation, Verification and Audit, Version 2.0, June 2018, Alberta Climate Change Office.


4

Scope

Project Name: Emission Reductions from Pneumatic Devices

(Pool B)

Geographic Boundary: All subprojects are located within Alberta’s

provincial boundary.

Physical Operations: Natural gas processing and compression:

• Pneumatic devices and controllers

• Chemical injection pumps

Emission Sources: Gas to Electric Chemical Injection Pump and

Controller Conversions

• B7: Vented Fuel Gas

• P7: Project Vented Gas

• P8: Process Control Electricity

• P9: Fuel Extraction and Processing

High-to-Low Bleed Pneumatic Controller

Conversions

• B7: Vented Fuel Gas

• P7: Project Vented Gas

• P8: Process Control Electricity

• P9: Fuel Extraction and Processing IPCC GHGs Emitted: Carbon Dioxide (CO2)

Methane (CH4)

Nitrous Oxide (N2O)

Reporting Period: January 1, 2017 – December 31, 2017

Materiality Quantitative materiality threshold is 5% of asserted greenhouse gas

emission reduction.

Preliminary Verification

Schedule

Verification Kickoff Meeting August 1, 2018

Draft Verification Plan August 3, 2018

Site Visit August 13-15, 2018

Draft Verification Report September 15, 2018

Final Verification Report September 30, 2018

Verification Team

Aaron Schroeder, P.Eng., will be the Lead Verifier and Designated Signing Authority for this verification.

His extensive experience quantifying and verifying greenhouse gas emissions satisfies all sixteen subject

matter areas defined in the ISO 14064-3.

Jeanna Brown, P.Eng., will provide analytical support to the verification team through the completion of

the verification procedures and the development of the Verification Report.


5

Rodrigo Cubedo, EIT will provide analytical support to the verification team through the completion of

the verification procedures and the development of the Verification Report.

Chris Caners, P.Eng., will conduct an independent peer review of the verification.

Additional information regarding the qualifications of the verification team will be provided in a

Statement of Qualifications, which will be appended to the Statement of Verification.

Site Visit Safety Requirements

Personnel conducting site visits are required to wear personal protective equipment including steel-toed

boots, Nomex coveralls, hard hat, safety glasses with side shields and gloves. A site orientation must

be completed before entering the site.

Some of the operators participating in this aggregated project require visitors to have a valid H2S Alive

certificate, in addition to operator-specific online orientations.


6

Responsible Party Data Management and Controls

Data Management Systems

The Sustainability Engineer from Cap-Op Energy Inc, as the project aggregator, has the primary

responsibility for collecting GHG information, quantifying the emission reduction and completing

required documentation.

The Responsible Party has developed a fit for purpose electronic data management and calculation

software system that is used to manage GHG information and quantify the emission reduction. Table 2,

below, describes the data measurement, estimation and data storage locations for all GHG information

used by the Responsible Party to produce the GHG inventory. The final column in this table describes

the data storage location and the path (intermediate data transfer) prior to use in the GHG inventory.

Table 2: GHG Information Data Management

Activity Data Description Measurement Type Data Storage Location / Path

High to Low Pneumatic Controller Conversions

Supply pressure Manual reading,

annual

Client report

> Inventory Template

> Cap-Op GHG calculation (DEEPP)

Gas analysis

(% CH4 and % CO2)

Third party analysis, annual

Default (if annual analysis is

not available)

Third party report or default value



Operating hours Client records,

annual/monthly

Client report



Baseline vent rate Third party reference,

annual

Manufacturer Reference documents


Project vent rate Third party reference,

annual



Pneumatic Pump Electrifications

Pump injection pressure Manual reading,

annual

Client report



Pump piston diameter Manual reading,

annual

Client report




7

Activity Data Description Measurement Type Data Storage Location / Path

Pump stroke length Manual reading,

annual

Client report



Gas analysis

(% CH4 and % CO2)

Third party analysis, annual

Default (if annual analysis is

not available)

Third party report or default value



Pump operating hours Client records,

annual/monthly

Client report



Pump stroke count Manual reading,

annual

Client report

> Sample Template


Chemical volume injected Manual reading,

annual

Client report

> Sample Template


Pump emission factor

(m3/L, m3/stk)

Third party reference,

annual


> DEEPP Library



8

Control Environment

The Responsible Party’s Offset Project Plan (OPP) describes the processes, procedures and systems

that have been designed and implemented within their quality assurance/quality control framework. The

accuracy and completeness of the documentation of the Responsible Party’s controls will be reviewed

through the course of the verification.

The following processes, procedures and systems have been employed by the Responsible Party:

• Quantification is based on direct metering and measurement as required by the Protocol.

• Gas composition is analyzed by third party laboratories.

• A fit for purpose electronic data management and calculation system has been developed by

the Responsible Party, called “Distributed Energy Efficiency Project Platform” (DEEPP). This

system is used to store all of the data parameters and perform the calculations to support the

quantification.

• Data is transferred electronically between systems wherever possible to reduce transcription

errors.

• Meters used to measure parameters required for the quantification are calibrated in accordance

with manufacturer guidelines.

• All quantification data is stored in the Responsible Party’s central database which is hosted on

a third party server with full redundancy in two locations. All information stored in the database

is secured and backed up through database management functions built into the daily

operation of the system.

• The Responsible Party has implemented a record retention system that meets the requirements

of the Regulation.

• The Offset Project Plan (OPP) is reviewed annually for accuracy, completeness, consistency,

relevance and transparency. The OPP documents:

• Project boundary

• Project processes

• Emission sources

• Changes made to the project since the baseline condition was established

• Activity data used to quantify emissions

• Emission quantification equations and other methods for deriving values required for the

quantification of emissions and production

• Emission factors and references

• Meter maintenance processes

• Data management


9

Previous GHG Assertions

Changes to Operations and Boundaries

This is the second year that Brightspot Climate has provided verification services for the Project.

The following modifications to the original project have been made since the original Offset Project Plan

was developed:

• The original Offset Project Plan (OPP) was registered in December 2016 to meet the

requirements of the Quantification Protocol for Instrument Gas to Instrument Air Conversion in

Process Control Systems, October 2009. That protocol was subsequently revised and replaced

with the Quantification Protocol for Greenhouse Gas Reductions from Pneumatic Devices,

Version 2.0, January 2017. The OPP was updated throughout to meet the requirements of the

revised protocol, and an updated OPP was registered in December 2017.

Further details of each of these items are provided in the Offset Project Report.

Findings from Previous Verifications

This is the second verification for the Project. The previous verification report noted the following

findings:

• The Responsible Party included B10 emissions (Fuel Extraction & Processing) in the

quantification but later removed this SSR, in accordance with the Protocol.

• Transcription errors were identified for some gas composition data, for some C2+ components.

As this only applied to C2+ components it did not affect the outcome of the emission reduction

calculation. This was identified as a qualitative immaterial discrepancy.

• A discrepancy was identified between operating hours used in the quantification and

government reported values for a very small number of subprojects. This was identified as a

qualitative immaterial discrepancy.

These previous discrepancies will be reviewed through the course of this verification to determine if the

underlying issues have been addressed.


10

Verification Risk Assessment and Verification Procedures

Verification risk is defined as the risk of an incorrect verification conclusion. It can be calculated as the

product of

• The Project’s inherent risks;

• The Responsible Party’s control risks; and

• The detection risks associated with the verifier’s verification procedures.

Inherent Risk × Control Risk × Detection Risk = Verification Risk

The verifier cannot affect the inherent risk or the control risk. Therefore, to reduce the overall verification

risk and reach the agreed level of assurance (defined in the verification scope), the verifier must design

verification procedures that reduce the detection risk.

Each inherent and control risk was provided with the risk score (high/medium/low). The risk analysis of

inherent and control risks considers both the magnitude of the activity data or inventory component on

the overall GHG assertion as well as the probability that the risk will result in a discrepancy, as assessed

by the verifier.

The Verification Risk Assessment Summary on the following pages describes the following information:

• Activity Data / Inventory Component: The boundary, eligibility requirement, data component or

reporting activity being evaluated.

• Inherent Risk: The verifier’s evaluation of inherent risk. Inherent risks have been categorized

according to the ISO 14064-1 principles (accuracy, completeness, consistency, relevance,

transparency).

• Control Risk: A description of the Responsible Party’s controls (if any controls are applicable)

and the verifier’s evaluation of control risks.

• Max Detection Risk: The maximum detection risk that can be applied and still result in an overall

verification risk that meets the agreed level of assurance.

• Designed Detection Risk: The detection risk of the verification procedure that the verifier intends

to complete. Note that the designed detection risk must always be equal to or lower than the

maximum detection risk.

• Verification risk: the product of the inherent, control and (designed) detection risk, as defined in

the equation above.

Important note: The verification strategy for this verification is to use substantive tests instead of control

tests wherever possible. Substantive tests are designed to focus on directly testing activity data or

inventory components and their associated inherent risks. Control tests are designed to focus on

testing the Responsible Party’s controls and if the test is successful, relying on the Responsible Party’s

control. Therefore, control tests indirectly test activity data or inventory components.

Each verification procedure listed in the following table denotes if the procedure is a substantive or

control test.


11

Table 3: Verification Risk Assessment Summary

Activity Data /

Inventory

Component

Inherent Risk Control Risk Max

Detection

Risk

Detection

Risk

Design

Description of Verification

Procedure

Verification

Risk

PROTOCOL APPLICABILITY REQUIREMENTS

Functional

equivalence must be

demonstrated

Relevance (high)

Level of service may

have changed between

the baseline and

project conditions.

Control: The

Responsible Party’s

Offset Project Plan

describes how

functional equivalence

is maintained.

Control Risk: The

Offset Project Plan

may be inaccurate or

out of date (low).

Low Low Substantive test: Observe

operations and interview

operations staff during site visit

to determine level of service

provided by project

implementation.

Low

Protocol is

applicable to

methane vent

reductions; not

applicable to

reduction of

propane or

conversion from

propane to methane

Relevance (low)

Propane devices may

have been included in

the inventory

The Responsible

Party does not have a

control specifically

designed to address

this inherent risk.

High Low Substantive test: Observe

operations and interview

operations staff to determine if

any propane devices are, or

have been, installed.

Low


12

Activity Data /

Inventory

Component


Detection

Risk

Detection

Risk

Design


Procedure

Verification

Risk

Project must be a

conversion

(brownfield) or an

acceptable install

(greenfield)

Relevance (high)

Project may have been

implemented at

greenfield sites that do

not meet protocol

requirements.

Control: The


Offset Project Plan

describes how

eligibility is

established.

Control Risk: The

Offset Project Plan


out of date (low).

Low Low Substantive test: Review

documentation for a sample of

sites that establishes eligibility

according to Table 1 of the

protocol.

Low

Pneumatic devices

must be properly

maintained and

inspected

Consistency (low)

Pneumatic devices may

vent excessively if not

properly maintained.

Control: The

Responsible Party

has ensured that the

Subproject

Proponents have

implemented a

management system

for leak detection and

repair, and for visual

inspection of pumps.

Control Risk: This

system may not have

been implemented or

maintained at all

project sites (low).

High Medium Control Test: Review the


management system for

maintenance and inspection to

determine if system is complete

for all sites and has been

maintained through the

reporting period.

Low


13

Activity Data /

Inventory

Component


Detection

Risk

Detection

Risk

Design


Procedure

Verification

Risk

An inventory of

devices must be

maintained

Completeness

(medium)

The inventory of

devices may be

incomplete.

Control: The

Responsible Party

has generated an

inventory list with data

confirmation via field

visits.

Control Risk: This

inventory may be

incomplete or contain

inaccurate data (low).

Low Low Control test: Observe devices

during site visit and compare

against project inventory to

evaluate completeness.

Low

Substantive test: Review

documentation supporting the

record of conversion

(installation/conversion date)

and device specifications.

Low


14

Activity Data /

Inventory

Component


Detection

Risk

Detection

Risk

Design


Procedure

Verification

Risk

The project must

meet the

requirements of the

Alberta Offset

System

Relevance (high)

The project may not

have met the

requirements of the

Alberta Offset System.

Control: The


Offset Project Plan

describes how the

requirements of the

Alberta Offset System

are met.

Control Risk: The

Offset Project Plan


out of date (low).

Low Low Substantive test: Evaluate the

Responsible Party’s evidence

regarding the general

requirements of the Alberta

Offset System.

Low

PROTOCOL FLEXIBLITY

Implementation of

multiple pneumatic

device conversions

Completeness

(medium)

The project aggregates

installations at multiple

project sites. The data

and documentation

may not be complete

for all sites.

Control: The

Responsible Party

has implemented a

centralized data

management system.

Control Risk: The

inputted data may be

incorrect or

incomplete (low).

Low Low Substantive test: Evaluate the

completeness of the required

data and documentation for all

project sites included in the

aggregated project.

Low


15

Activity Data /

Inventory

Component


Detection

Risk

Detection

Risk

Design


Procedure

Verification

Risk

Statistically relevant

comparisons or

emission factors

may be used

N/A N/A N/A N/A Not applicable for this project. N/A

Site-specific and

make and model-

specific emission

factors may be

applied

N/A N/A N/A N/A Not applicable for this project. N/A

Preferential order of

methods for

baseline and project

activity quantification

for certain project

types

Accuracy (low)

An inappropriate

quantification

methodology may be

used.

Control: The

preferential

quantification

methods have been

implemented in the


data management

system.

Control Risk: The

system may not

function correctly

(low).

High Low Substantive Test: Recalculate

the emission reduction.

Low


16

Activity Data /

Inventory

Component


Detection

Risk

Detection

Risk

Design


Procedure

Verification

Risk

QUANTIFICATION DATA

Protocol specified

vent rates

Accuracy (low)

An incorrect value may

be used in the

calculation.

Control: Vent rate

values are taken from

the Protocol and are

input into the


data management

system.

Control Risk: An

incorrect value may

have been selected or

input (low).

High Low Substantive test: Review and

confirm selected specified vent

rate values.

Low

Manufacturer

specified Emissions

Factors for chemical

injection pumps

Accuracy (low)

An incorrect value may

be used in the

calculation

Control:

Manufacturer’s

specified values are

input into the


data management

system.

Control Risk: An

incorrect value may

have been selected or

input (low).

High Low Substantive test: Review and

confirm selected specified

values.

Low


17

Activity Data /

Inventory

Component


Detection

Risk

Detection

Risk

Design


Procedure

Verification

Risk

Gas analysis

(%CH4 and %CO2)

Accuracy (low)

Reported gas

compositions may not

accurately represent

the gas composition or

may be incorrectly

transcribed into the

emission reduction

calculation.

Control: Independent

lab conducts gas

analysis. An internal

process is used to

validate results.

Control Risk: The

validation of lab

results may not have

been completed (low).

High Medium Substantive test: Analyze gas

compositions for significant

fluctuations or abnormal gas

concentrations.

Control test: Confirm the

accurate transcription of the

gas analysis into the emission

reduction calculation.

Low

Completeness (low)

The gas compositions

may not include a valid

gas composition for

each period at the

required frequency.

The Responsible



designed to address

this inherent risk.

High Medium Substantive test: Review

completeness of gas

composition data.

Low

Reference density of

methane at STP

conditions

Accuracy (low)

The density of methane

applied in the

calculation may not

represent the density at

STP conditions.

The Responsible



designed to address

this inherent risk.

High Low Substantive test: Compare the

density of methane applied in

the calculations to the

reference value provided in the

relevant reference documents.

Low


18

Activity Data /

Inventory

Component


Detection

Risk

Detection

Risk

Design


Procedure

Verification

Risk

Alberta electricity

grid factor

Accuracy (low)

The Alberta electricity

grid factor applied in

the calculation may not

represent the correct

grid factor.

The Responsible



designed to address

this inherent risk.



applied in the calculations to

the reference value provided in

the relevant reference

documents.

Low

Pump stroke count Accuracy (medium)

The pump stroke count

used to assess pump

conversions may be

incorrect if total

strokes, operating

hours or proration

calculation is incorrect.

The Responsible



designed to address

this inherent risk.

Low Low Substantive test: Recalculate

prorated pump strokes.

Low

Operating hours Accuracy (low)

Inaccurate or

incomplete operating

hours.

The Responsible



designed to address

this inherent risk.

High Medium Substantive test: Compare

operating hours used in

calculations with values

government reported hours.

Low


19

Activity Data /

Inventory

Component


Detection

Risk

Detection

Risk

Design


Procedure

Verification

Risk

Chemical Injection

Volume

Accuracy (low)

Volume of chemical

injected may not be

measured or recorded

accurately.

The Responsible



designed to address

this inherent risk.

High Medium Substantive test: Review tank

fill reports and compare to

values used in calculations.

Low

EMISSION REDUCTION QUANTIFICATION

Application of the

approved

quantification

protocol

Accuracy (high)

The project developer

may not have

implemented approved

quantification

methodologies or

applied additional

methodologies.

Control: Responsible

Party has developed

an Offset Project Plan

that is intended to

conform to the

requirements of the

approved

quantification

protocol.

Control Risk: The

protocol requirements

may not have been

implemented correctly

(medium)

Low Low Controls test: Compare the

methodologies described in the

Responsible Party’s Offset

Project Plan to the

methodologies described in the

approved quantification

protocol.

Low


20

Activity Data /

Inventory

Component


Detection

Risk

Detection

Risk

Design


Procedure

Verification

Risk

Substantive test: Recalculate

the emission reduction using

original metered data and

methods described in the

approved quantification

protocol.

Low

Quantification of

emission reduction

Accuracy (high)

Emission reduction

calculation may contain

arithmetic errors.

The Responsible



designed to address

this inherent risk.

Low Low Substantive test: Recalculate

the emission reduction using

original metered data.

Low

DATA INTEGRITY

Activity data and

emission factor data

integrity

Accuracy (medium)

Data may not have

been accurately

transferred between

electronic systems and

calculation sheets.

Control: The

Responsible Party

uses electronic data

transfers whenever

possible to maintain

data integrity.

Control Risk:

Electronic data

transfers may result in

errors or may not be

available for all data

(medium).

Low Low Controls test: Analyze activity

data for abnormal data (zeros,

missing data, values outside

range).

Low


21

Activity Data /

Inventory

Component


Detection

Risk

Detection

Risk

Design


Procedure

Verification

Risk

Substantive test: Recalculate

the complete emission

reduction using original data.

Low

Transcription of final

emission reduction

into Offset Project

Report

Accuracy (low)

Final emission

reduction may not have

been transcribed

accurately from

calculation

spreadsheets into the

Offset Project Report.

The Responsible



designed to address

this inherent risk.


final emission reduction

quantity reported by the

Responsible Party to the

quantity reported in the Offset

Project Report. Also, compare

these quantities to the

recalculated quantity in

previous verification

procedures.

Low


22

Sampling Plan

The verification procedures that could apply sampling of the project data are listed in the following table.

The sampling size, the sampling methodology and their respective justifications are also described in the following table.

Table 4: Sampling Plan

Activity Data /

Inventory

Component

Detection

Risk

Design


Procedure

Sample Size Sampling Methodology and

Justification

Protocol specified

vent rates

Low Substantive test: Review and

confirm selected specified vent rate

values.

All values Review of full dataset has lower

detection risk than sampling.

Manufacturer

specified

Emissions Factors

for chemical

injection pumps

Low Substantive test: Review and

confirm selected specified values.



Gas analysis

(%CH4 and %CO2)

Medium Substantive test: Analyze gas

compositions for significant

fluctuations or abnormal gas

concentrations.



Gas analysis

(%CH4 and %CO2)

Medium Control test: Confirm the accurate

transcription of the gas analysis

into the emission reduction

calculation.

86 records in aggregated

assertion (85% confidence level,

92.5% confidence interval;

appropriate for the defined

detection risk)

If error rate is greater than 5%,

sample size will be expanded.

Stratification of subproject

participants; random sampling;

discrepancies are normally

distributed


23

Activity Data /

Inventory

Component

Detection

Risk

Design


Procedure

Sample Size Sampling Methodology and

Justification

Gas analysis

(%CH4 and %CO2)

Low Substantive test: Review

completeness of gas composition

data.

All values There is only one sample per site.

Review of full dataset has lower


Pump stroke count Low Substantive test: Recalculate

prorated pump strokes.



Operating hours

Medium Control test: Review documented

procedures for data flow from the

field to Petrinex, for each

subproject participant and

interview Petrinex experts/analysts

to determine the accuracy and

relevance of the method used for

retrieving operating hours from

Petrinex for use in the

quantification.

Sampling does not apply to

control tests involving retracing.

Sampling does not apply to control

tests involving retracing.

Chemical volume

injected

Medium Substantive test: Review tank fill

reports and compare to values

used in calculations.

All values This verification procedure only

applies to pump electrification

projects, and only to pumps that are

not equipped with stroke counters.

There are only 14 subprojects to

which this applies.

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Appendix B: Statement of Qualifications

of 86

Statement of Qualifications

Offset Report

Project Name Offset Project ID


#4404-1916

Reporting Company Legal Name Report Type Reporting Period

Cap-Op Energy Inc. Offset Report

from

January 1, 2017 - December 31, 2017

to

Signature of Third Party Verifier

I,

Aaron Schroeder (Third Party Verifier), meet or exceed the qualifications of third-party

verifiers described in Section 29 of the Carbon Competitiveness Incentive

Regulation.

Verifying Company Name

Brightspot Climate Inc. Per: Aaron Schroeder

Signature of Third Party Verifier Date:

Training Received Under ISO 14064 Part 3

• Greenhouse Gas Verification – ISO 14064-3, Canadian Standards Association, 2012 • Instructor – Greenhouse Gas Verification – ISO 14064-3, University of Toronto, 2015 – 2018

First Name Last Name

Aaron Schroeder

Professional Designation E-mail Address Phone Number

Professional Engineer [email protected] (604) 353-0264

Lead Verifier

� Same as third party

verifier??




December 14, 2018

of 86

Peer Reviewer


Chris Caners

E-mail Address Phone Number

[email protected] (647) 468-4332


Greenhouse Gas Verification – ISO 14064- 3, Canadian Standards Association, 2008

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Appendix C: Findings and Issues

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Table 8: Detailed Findings and Issues Log

Number the issue with the year and provide a unique # for the issue. If the issue resolved during the verification, indicate that in the resolution column. If the issue is not resolved during the verification, or if the issue was material (whether resolved or not) record it as a finding in Table 2 and provide a cross reference to the finding # in the resolution column. Describe the issues investigated. State the verification criteria that are not met. Provide a description of how it is not met and provide the evidence. Indicate the Source Category (for facilities) or the Source/Sink (for offsets). Indicate if the finding is an understatement or overstatement. Summarize information between verifier and client. Provide a conclusion including % discrepancy, if applicable.

Item (YR-##)

Description of the Issues Investigated During the Verification

Summary of information exchanged between Verifier and Responsible Party

Resolution Conclusion

17-01

One transcription error was detected in the sample of pump stroke count reading dates.

The error rate determined through this verification procedure was extrapolated from the sample to the full population of data. The error that was detected was corrected, which was considered in the estimation of the discrepancy.

Transcription errors in this data point could result in an overstatement or understatement.

The estimated discrepancy represents the maximum expected error, given the available data.

This error was acknowledged and was corrected in the final asserted emission reduction.

Quantitative discrepancy in final assertion

Discrepancy (may be overstatement or understatement) of approximately 22 tonnes CO2e (0.4% of total asserted emission reduction).

17-08

The Responsible Party transcribed high bleed to low bleed device conversion dates incorrectly.

All of the incorrectly transcribed dates fall before the project crediting period and therefore do not affect the asserted emission reduction for this reporting period (or the previous reporting period).

This error was evaluated as a qualitative discrepancy.

The Responsible Party acknowledged the transcription errors in high to low bleed conversion dates.

Qualitative discrepancy

Since the errors in recorded dates occur before the crediting period, there is no quantitative discrepancy; however, this issue does represent a qualitative discrepancy in the project.

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Appendix D: Statement of Verification


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Statement of Verification Associated SGER Submission

Offset Project Protocol Project ID #


Quantification Protocol for Greenhouse Gas Emission Reductions from Pneumatic Devices, Version 2.0, January 2017 4404-1916

Project Developer Serial Range Start Report Period

Cap-Op Energy Inc. TBD

January 1, 2017 – December 31, 2017

Serial Range End

TBD

Statement of Verification

GHG Assertion

Value Units

Total Baseline Emissions 83,650.7 tonnes CO2e

Total Project Emissions 9,989.7 tonnes CO2e

Other 0 tonnes CO2e

Net Reductions 73,661 tonnes CO2e

Statement of Assertion

The Responsible Party’s GHG Assertion is comprised of the Offset Project Plan, Offset Project Report and supporting documentation.

The GHG Assertion covers the reporting period January 1, 2017 to December 31, 2017 and states an emission reduction and removal claim of 73,661 tonnes CO2e over this period.


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The emission reduction and removal claim consists of 2017 vintage credits.

Responsibilities of Project Developer and Third Party Verifier

Our responsibility as the Verifier is to express an opinion as to whether the GHG Assertion is materially correct, in accordance with approved Protocol, the Carbon Competitiveness Incentive Regulation (the “Regulation”), and the Alberta Climate Change Office – Standard for Greenhouse Gas Emission Offset Project Developers, Version 2.0, July 2018.

We completed our review in accordance with the ISO 14064 Part 3: Greenhouse Gases: Specification with Guidance for the Validation and Verification of Greenhouse Gas Assertions (ISO, 2006). As such, we planned and performed our work in order to provide positive, but not absolute assurance with respect to the GHG Assertion.

The verification procedures that were performed through the course of the verification were developed based on the results of a risk assessment that was completed during the verification planning stage. These verification procedures are described in the Verification Plan. Certain verification procedures included data sampling. The sampling type, sample size and the justification for the planned sampling type and size are detailed in a Sampling Plan, which is included in the Verification Plan.

Conclusion

I believe our work provides a reasonable basis for my conclusion.

There were no unresolved misstatements in the final GHG Assertion.

Based on our review, it is my opinion at a reasonable level of assurance that the GHG Assertion is materially correct and presented fairly in accordance with the relevant criteria.





Date:


Aaron S Schroeder


Professional Engineer [email protected] (604) 353-0264

December 14, 2018

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Appendix E: Conflict of Interest Checklist


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Conflict of Interest Checklist

Associated SGER Submission

Offset Project Protocol


Quantification Protocol for Greenhouse Gas Emission Reductions from Pneumatic Devices, Version 2.0, January 2017

Project Developer Report Type Report Period

Cap-Op Energy Inc. Offset Report

January 1, 2016 – December 31, 2016

Checklist Respond either "True" or "False" to each of the following statements:

1. The relationship between my firm and this reporting company poses

unacceptable threat to or compromises the impartiality of my firm.

False

2. The finances and sources of income of my firm compromise the impartiality of

my firm.

False

3. The personnel my firm has scheduled to participate in the verification may have

an actual or potential conflict of interest.

False

4. My firm participated in some manner in the development or completion of the

associated offset submission for this reporting company.

False

5. My firm provided greenhouse gas consultancy services to this reporting

company.

False

6. My firm will use personnel that have, are, or will be engaged or previously

employed by the reporting company.

False

7. My firm will outsource the Statement of Verification for the associated offset

submission.

False

8. My firm offers products or services that pose an unacceptable risk to

impartiality.

False

Important: If you have checked "True" to any of the above, you may not fulfill the "independence" requirement for third party verifiers. Please contact Alberta Environment and Parks for further instruction. If the potential conflict of interest is a sufficient threat to impartiality (perceived or actual), or cannot be effectively managed, you Third Party Verification Report will not be acceptable to Alberta Environment and Parks.


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I , Aaron Schroeder (Third Party Verifier), have personally examined and am familiar

with the information contained in this Conflict-of Interest Checklist, and can demonstrate freedom from any conflict of interest related to the reporting company for which the verification was performed. I hereby warrant that the information submitted in this Conflict-of Interest Checklist is true, accurate and complete to the best of my knowledge, and that all matters affecting the validity of this Conflict-of-Interest Checklist have been fully disclosed. Impartiality shall be monitored over the duration of the verification and any identified actual or potential conflict-of-interest situations will be communicated to AEP directly.



Signature of Third Party Verifier Date:

First Name Last Name Aaron Schroeder Professional Designation E-mail Address Phone Number Professional Engineer [email protected] (604) 353-0264

December 14, 2018

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Appendix F: Supplemental Diagrams/Tables/Figures

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Table 9: Supporting Documentation Reviewed

File Name Description

Cap-Op Energy Inc. 2017. Cap-Op Energy Emission Reductions from Pneumatic Devices (Pool B) – Offset Project Plan.

Offset Project Plan

Cap-Op Energy Inc. 2018. Cap-Op Energy Emission Reductions from Pneumatic Devices (Pool B) – Offset Project Report Form. December 12, 2018

Offset Project Report

XX Inventory_Pool_B_-_17-5.xlsx

XX Inventory_Pool_B_-_17-2.xlsx

Inventory Spreadsheets

Texsteam - Series5100 – worksheet.xlsx

Texsteam - Series5100.pdf

Manufacturer specifications

Gas composition reports

Pump stroke reading logs

Petrinex reports

Supporting documents

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Limitation of Liability

This report is intended for the responsible party and the intended user as defined in the attached verification report. The sole intention of the report is to verify the GHG assertion made by the responsible party named in the report and is not intended to provide assurance of any kind for any purpose other than for reporting under the GHG program as defined in the scope of the attached report.

Brightspot Climate disclaims liability for use by any other party and for any other purpose.

verification report for: 4404-1916 · the verification strategy relied on both control and...

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