alberta remvue engine fuel management and vent gas capture aggregation project - 1090-6410 february...

Alberta REMVue Engine Fuel Management and Vent Gas Capture Aggregation Project - 1090-6410

February 2019

Verification Report for: Alberta REMVue Engine Fuel Management and Vent Gas Capture

Aggregation Project - 1090-6410

Proponent:

Blue Source Canada ULC

Prepared by: Stantec Consulting Ltd.

845 Prospect Street, Fredericton NB E3B 2T7

Prepared for:

Blue Source Canada ULC Suite 1605 840 7th Avenue SW, Calgary AB T2P 3G2

Version:

Final

Date:

February 27, 2019


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Table of Contents 1.0 Summary – Offset Project ...................................................................................... 4 1.1 Summary – Facility ......................................................................................................... 8 2.0 Introduction ....................................................................................................... 10

2.1 Objective ........................................................................................................... 11 2.2 Scope ................................................................................................................ 11 2.3 Level of Assurance .............................................................................................. 12 2.4 Criteria .............................................................................................................. 12 2.5 Materiality .......................................................................................................... 13

3.0 Methodology ....................................................................................................... 13 3.1 Procedures ......................................................................................................... 13 3.2 Team ................................................................................................................. 17 3.3 Schedule ............................................................................................................ 18

4.0 Results .............................................................................................................. 18 4.1 Assessment of Internal Data Management and Controls ........................................... 18 4.2 Assessment of GHG Data and Information .............................................................. 19 4.3 Assessment against Criteria .................................................................................. 20 4.4 Evaluation of the GHG Assertion ............................................................................ 22 4.5 Summary of Findings ........................................................................................... 24 4.6 Opportunity for Improvement ............................................................................... 26

5.0 Closure .............................................................................................................. 26 5.1 Verification Statement ......................................................................................... 26 5.2 Limitation of Liability ........................................................................................... 26 5.3 Confirmations ..................................................................................................... 27

6.0 References ......................................................................................................... 27 Appendix A: Final Verification Plan and Sampling Plan ............................................................ 28 Appendix B: Statement of Qualifications................................................................................ 30 Appendix C: Findings and Issues .......................................................................................... 33 Appendix D: Statement of Verification .................................................................................. 35 Appendix E: Conflict of Interest Checklist .............................................................................. 39 Appendix F: Supplemental Diagrams/Tables/Figures ............................................................... 42

List of Tables Table 1: Offset Criteria Assessment ...................................................................................... 20 Table 2: Summary of Findings ............................................................................................. 25 Table 3: Detailed Findings and Issues Log ............................................................................. 34


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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 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)

Alberta REMVue Engine Fuel Management and Vent Gas Capture Aggregation Project

Project Description

Provide a brief description of the project and baseline conditions.

The Project achieves emission reductions through the retrofit and installation of various engine management technologies on existing or new engine units in Alberta.

The baseline condition is the emissions that would have occurred in the normal operation without the project technology.

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.

Multiple locations throughout Alberta as provided in the Aggregated Project Report Form.

Project Start Date

Enter the project start date.

The earliest subproject began on August 8, 2003, and is a result of actions taken on, or after, January 1, 2002.

Offset Start Date

Enter the start date for offset credit generation.

January 1, 2013

Offset Crediting Period

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

January 1, 2013 – December 31, 2020

Reporting Period

Enter the reporting period being verified.

October 1, 2017 – September 30, 2018

GHG Assertion (Actual Emission Reductions/Sequestration Achieved)

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

October 1 – December 31, 2017: 6,015 t CO2e January 1 – September 30, 2018: 19,700 t CO2e Total: 25,715 t CO2e

Protocol

Indicate the relevant protocol (if applicable)

Quantification Protocol for Engine Fuel Management and Vent Gas Capture Projects (version 1.0, October 2009)


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Ownership

Enter offset project owner.

Blue Source Canada ULC (“Bluesource”) is the project developer and project proponent for this Project. Through agreements with each participating company (i.e. the owners of the technologies that have been installed), Bluesource is given authority to aggregate and register the Project's offset credits. The ownership model varies with each participating company depending on the respective agreements. In some cases, ownership is defined by the direct purchase agreement with transfer of title occurring at time of registration, while other agreements follow the Agency model, with title remaining with the subproject owner until time of sale.

Project Activity

State how the project activity meets the eligibility requirements

For the verification period, the Project activities are eligible under the Alberta Carbon Competitiveness Incentive Regulation (CCIR) to generate offsets as they meet the following conditions:

• Result from actions taken on or after January 1, 2002 – the Project began after this date.

• Be real, demonstrable, and quantifiable – the Project has been verified according to the following verification criteria: - Climate Change and Emissions

Management Act, S.A. 2003, c. C-16.7

- The Carbon Competitiveness Incentive Regulation, Alberta Regulation 255/2017, with amendments up to and including Alberta Regulation 199/2018 (Regulation or CCIR)

- Standard for Greenhouse Gas Emission Offset Project Developers, Carbon Competitiveness Incentive Regulation (July 2018, V2.0)

- Quantification Protocol for Engine Fuel Management and Vent Gas Capture (October 2009, V1.0), referred to as the Protocol

- The Emission Factors Handbook (March 2015, V1.0)

• Not be required by law – the Project is not required by any current or proposed law.


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• Have clearly established ownership – the Project Developer has provided sufficient and appropriate evidence that Torxen Resources Ltd. (Torxen), International Petroleum Corp. (IPC), Canadian Natural Resources Ltd. (CNRL), and Repsol Oil & Gas Canada Inc. (Repsol) own the offset credits generated by the respective subprojects and that Bluesource is authorized to quantify and report on the emission reductions.

• Be counted once for compliance purposes – the Project offset credits are serialized on the Alberta Emission Offset Registry (AEOR).

• Be verified by a qualified third party – Stantec is a qualified third-party verifier, as defined by Section 24 of the CCIR. Stantec is accredited with the American National Standards Institute (ANSI), a member of the International Accreditation Forum (IAF), in accordance with ISO 14065 (Accreditation ID #0805 issued to Stantec Consulting Ltd. for greenhouse gas (GHG) verification and validation).

• Have occurred in Alberta – the Project engines are physically located in Alberta.

Project Contact

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

Blue Source Canada ULC Amy Zell 1605 – 840 7 Ave SW Calgary, AB T2P 3G2 (403) 262-3026 ext 260 [email protected]

Verifier

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

Christina Varner, P.Eng. Stantec Consulting Ltd. 845 Prospect Street Fredericton, NB E3B 2T7 Phone: (506) 457-3237 Email: [email protected]

Verification Team Members

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

Lead Verifier: Christina Varner, P.Eng. Completed ISO 14064-3 training on January 29, February 5, February 11, 2010

Christina Varner is a professional engineer registered by the Association of Professional Engineers and Geoscientists of New Brunswick (APEGNB), which satisfies

mailto:[email protected]



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Section 24(1)(a)(ii)(A) of the CCIR. She has the required technical knowledge of GHG emission quantification methodologies and has 9 years of experience in completing third party GHG verifications which satisfies Section 24(1)(b)( i-iii) of the CCIR.

Verifier: Daniel Hegg, M.Sc., CEM Completed ISO 14064-3 training on February 18-20, 2009

Daniel has the required technical knowledge of GHG emission quantification methodologies and has 10 years of experience in completing third party GHG verifications.

Verifier: Rengarajan Vaiyapuri, M.Eng., EIT Completed ISO 14064-3 training on November 17 -18, 2015.

Rengarajan Vaiyapuri graduated with a M.Eng. from the University of Alberta and is also an EIT. He has the required technical knowledge of GHG emission quantification methodologies and has 5 years of experience in completing third party GHG verifications.

Verifier: Catherine MacFarlane, M.A.Sc. Completed ISO 14064-3 training in September 2012.

Catherine MacFarlane graduated with an M.A.Sc. in Environmental Science and Resource Management from Ryerson University. She has the required technical knowledge of GHG emission quantification methodologies and has over 6 years of experience in completing third party GHG verifications.

Independent Peer Reviewer: Nicole Flanagan, M.A.Sc., P.Eng.

Completed ISO 14064-3 training in the fall of 2005.

Nicole Flanagan is a professional engineer registered by Professional Engineers Ontario, which satisfies Section 24(1)(a)(ii)(A) of the CCIR. She has the required technical knowledge of GHG emission quantification methodologies and has 13 years of experience in completing


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third party GHG verifications, which satisfies Section 24(1)(b)( i-iii) of the CCIR.

Quality Reviewer: Vicki Corning, P.Eng.

Completed ISO 14064-3 training in January 2008

Vicki Corning is a professional engineer registered by the Association of Professional Engineers and Geoscientists of New Brunswick (APEGNB) which satisfies Section 24(1)(a)(ii)(A) of the CCIR. She has the required technical knowledge of GHG emission quantification methodologies and has 13 years of experience in completing third party GHG verifications, which satisfies Section 24(1)(b)( i-iii) of the CCIR.

Designated Signing Authority

Enter the designated signing authority for this verification.

Christina Varner, P.Eng, is a professional engineer registered by the Association of Professional Engineers and Geoscientists of New Brunswick (APEGNB), which satisfies Section 24(1)(a)(ii)(A) of the CCIR and Section 3(e)(iii) of the Standard for Validation, Verification, and Audit (version 3.0, December 2019). Furthermore, Christina Varner has signing authority on behalf of Stantec for the purpose of verification reports.

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 strategy used in the verification is included in the Verification Plan, which is provided in Appendix A.

1.1 Summary – Facility

Item Description

Facility Name and Company Name

List company name and facility name.

Not Applicable

Facility Description

Provide a brief description of the facility.

Not Applicable


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Baseline Emissions Intensity Description

List the approved BEIA and the baseline years.

Not Applicable

Reporter Contact

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

Not Applicable

GHG Assertion

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

Not Applicable

Verifier

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

Not Applicable

Verification Team Members

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

Not Applicable

Designated Signing Authority

Enter the designated signing authority for this verification.

Not Applicable


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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.

Stantec Consulting Ltd. (Stantec) was contracted by Blue Source Canada ULC (Bluesource) to conduct an independent third-party verification of the greenhouse gas (GHG) Assertion provided in the Alberta REMvue Engine Fuel Management and Vent Gas Capture Aggregation Project Report, dated February 12, 2019. The Alberta REMvue Engine Fuel Management and Vent Gas Capture Aggregation Project (the Project) consists of the retrofit and installation of various engine management technologies on 56 engines operated by four different companies. The four Project Participants (Participants) are Canadian Natural Resources Ltd. (CNRL), Repsol Oil and Gas Canada Inc. (Repsol), Torxen Resources Ltd. (Torxen) and International Petroleum Corporation (IPC).

In this work, CNRL, Repsol, Torxen and IPC own and operate the natural gas engines and thus are responsible for the collection of activity data used in the calculations and data management for engine-specific data. Bluesource was responsible for the completion of the calculations, presentation of the information within the Project Report, and for the supporting technical documents.

Bluesource is the aggregator and project proponent for this project. Via the agreements with each Participant, Bluesource is given authority to aggregate and register the project's Offset Credits. The ownership model varies with each Participants depending on the respective agreements. In some cases, ownership is defined by the Direct Purchase agreement with transfer of title occurring at time of registration, while other agreements follow the Agency model, with title remaining with the subproject owner until time of sale.

Stantec was responsible for planning and executing the verification to deliver an opinion to a reasonable level of assurance as to whether the Project Report and the GHG Assertion are presented fairly and in accordance with the verification criteria. Stantec is a qualified third-party verifier, as defined by Section 24 of the CCIR. Stantec is accredited with the American National Standards Institute (ANSI), a member of the International Accreditation Forum (IAF), in accordance with ISO 14065 (Accreditation ID #0805 issued to Stantec Consulting Ltd. for greenhouse gas (GHG) verification and validation).

The Project technologies include:

• REMVue 500 Air:Fuel Ratio Controller System (EFM) which controls and monitors the air to fuel ratio in each engine to improve brake specific fuel consumption (BSFC), thus reducing fuel use and GHG emissions.

• REMVue SlipStream (VGC) which captures hydrocarbons otherwise vented to atmosphere and redirects them as a supplementary fuel source thus reducing fuel use and GHG emissions.


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The engine types included during this reporting period are: Caterpillar 3512, 3516, 3608; Waukesha 3521, L5108, L7042, P9390; and White Superior 8GTL-825. Each of the included engines are using either EFM or VGC or combination of both.

The baseline condition is the emissions that would have occurred in the normal operation without the above technologies. The offset credits are generated by reducing the fuel use through the retrofit and installation of engine management technologies on existing or new engines.

For this reporting year, there are 38 new subprojects added. Of the newly added subprojects, 20 belong to Torxen and 18 belong to IPC. As of October 1, 2017, the 38 subprojects were transferred into this Project from the projects titled:

• Cap-Op Energy Engine Fuel Management and Vent Gas Capture Program (ID # 8237-6623) • Cap-Op Energy Engine Fuel Management and Vent Gas Capture Aggregated Project (Pool B)

(ID# 4471-2239) • Cap-Op Energy Engine Fuel Management and Vent Gas Capture Aggregated Project (Pool C)

(ID# 4984-6118)

The subprojects were quantified by Cap-Op Energy until September 30, 2017. Bluesource will quantify the transferred subprojects on a go-forward basis from October 1, 2017. The original offset crediting period for each subproject will not be exceeded. The Alberta Climate Change Office approved the transfer of these 38 subprojects in an email dated October 16, 2018.

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

The objective of the verification was to assess whether the Project Report and GHG Assertion, dated February 12, 2019, satisfy the verification criteria identified in Section 2.4 below.

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.

The verification is for the Project Report and GHG Assertion for the period of October 1, 2017 until September 30, 2018. The Project has 56 engines in total, of which 20 belong to Torxen, 18 belong to IPC, 13 belong to CNRL, and 5 belong to Repsol. All engines are located within Alberta.

The verification covers the specified gases required by the CCIR. These include:

• carbon dioxide (CO2);


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• methane (CH4);

• nitrous oxide (N2O);

• hydrofluorocarbons (HFCs);

• perfluorocarbons (PFCs);

• sulphur hexafluoride (SF6); and

• nitrogen trifluoride (NF3).

The total GHG emissions and reductions are reported as equivalent tonnes of carbon dioxide (t CO2e) emissions.

Sources of Project GHG emissions included:

• Emissions from Fuel Extraction and Processing, P1 (CO2, CH4, and N2O): Emissions that occurred due to the use of fossil fuel in the Project engines.

• Emissions from Unit Operation, P4 (CO2, CH4, and N2O): Emissions that occurred from fuel combustion in the engine with the Project technologies.

• Emissions from Captured Vent Gas, P5b (CO2, CH4, and N2O): Emissions that occurred from combustion of captured vent gas.

Sources of baseline GHG emissions included:

• Emissions from Fuel Extraction and Processing, B1 (CO2, CH4, and N2O): Emissions that would have occurred from the extraction and processing of the baseline quantity of fuel combusted.

• Emissions from Unit Operation, B4 (CO2, CH4, and N2O): Emissions that would have occurred from fuel combustion in the normal operation of the unit without the Project technologies.

• Emissions from Venting of Emissions Captured in Project, B5b (CH4): Emissions that would have occurred from vented fuel in the normal operation of the unit without the capture of vent gas.

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 CCIR requires the verifier to conduct sufficient procedures to deliver a reasonable level of assurance. The verification was planned and executed accordingly.

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

Stantec has conducted sufficient and appropriate procedures to express a reasonable level of assurance opinion as to whether the Project Report and GHG Assertion, dated February 12, 2019, satisfies the following criteria:


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• Climate Change and Emissions Management Act, S.A. 2003, c. C-16.7; • The Carbon Competitiveness Incentive Regulation, Alberta Regulation 255/2017, with

amendments up to and including Alberta Regulation 199/2018 (Regulation or CCIR); • Standard for Greenhouse Gas Emission Offset Project Developers, Carbon Competitiveness

Incentive Regulation (July 2018, V2.0); • Quantification Protocol for Engine Fuel Management and Vent Gas Capture (October 2009,

V1.0), referred to as the Protocol; and • The Emission Factors Handbook (March 2015, V1.0).

Further, Stantec has conducted sufficient and appropriate procedures to express an opinion as to whether the GHG assertion is free from material discrepancies, is fairly presented, and is substantiated by sufficient and appropriate evidence

2.5 Materiality Define the materiality of the verification.

The Standard for Validation, Verification, and Audit has set the quantitative materiality threshold at 5% of the total reported GHG emission reductions or removals asserted for Projects that generate less than 500,000 t CO2e per year. Materiality of qualitative misstatements are at the discretion of the verification body.

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.

The verification was conducted in accordance with ISO 14064:3, Stantec’s Standard Operating Procedures designed for accreditation to ISO 14065, and the Standard for Validation, Verification, and Audit (version 3.0, December 2019).

For more information on the verification procedures, see Section 3.1 of this report and the Verification Plan provided in Appendix A.

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.

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

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 Procedures:


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The verification team developed initial verification procedures and sampling plan during the initial desktop review, based on a review of the Project Report, Offset Plan, and available documentation and in consideration of the verification risk. Over the course of the verification, the verification team considered whether additional verification procedures or samples were required to achieve a reasonable level of assurance.

Stantec’s final sampling plan included reviewing and sampling all data for fuel consumption, operating hours, engine load, engine speed, gas analysis, all emission factors, as well as recalculating baseline and Project emissions. This included recalculating the GHG Assertion, independently obtaining emission factors and assessing consistency with the Project Plan, Protocol, and ACCO guidance.

For more information, see the Verification Plan provided in Appendix A.

Site Visit:

Stantec Verifier, Rengarajan Vaiyapuri, conducted a site visit to the following sites on November 22, 29 and 30, 2018:

Panel Number Geographical Location Company RP-26908-AA 16-17-081-04 W6 CNRL RP-26909-AA 8-36-080-04 W6 CNRL PN-14538AA 12-33-022-18 W4 Torxen PN-14538AB 12-33-022-18 W4 Torxen PN-19188AA 12-33-022-18 W4 Torxen PN-19188AB 12-33-022-18 W4 Torxen PN-16777 8-21-021-15 W4 Torxen PN-19562 8-21-021-15 W4 Torxen

PN-19819AA 1-04-015-06 W4 IPC PN-18566AA 1-04-015-06 W4 IPC PN-20181AA 1-04-015-06 W4 IPC PN-19116AB 1-04-015-08 W4 IPC PN-27449AA 1-17-014-08 W4 IPC PN-27503 9-21-014-09 W4 IPC PN-27451 1-04-015-07 W4 IPC PN-27452 4-13-014-07 W4 IPC

During the site visits, the following personnel were interviewed:

• Ms. Amy Zell (Manager, Bluesource) • Mr. Cam Lizee (Plant Foreman, CNRL) • Mr. Lloyd Ehmann (Lead Operator, IPC) • Mr. Matt Gagnon (Instrumentation Technician, Tarpon (third party consultant to engine

operators)) • Mr. Wade Kraus (Operator, Torxen) • Mr. Scott Green (Instrumentation Technician, Torxen) • Mr. Lorne Lappin (Operator, Torxen) • Mr. Shawn Forsynth (Operator, CNRL) • Mr. Gavin Roen (Operator, Torxen)


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The site visits involved a review of data collection, data tracking, and retention and transfer procedures. Activities associated with operations, record keeping, data management and emissions sources were also reviewed to better understand the quantification calculations, data treatment and data management. Through interviews, and by attending the site visit, the site boundaries were evaluated by the verifier to confirm their veracity. The verification team performed procedures to identify Project boundaries, confirm GHG sources, look for additional sources, visually confirm the presence of engines, make and model, fuel gas meter, fuel gas sampling points and installation dates of the technology. Stantec confirmed emission sources, sinks and reservoirs and evaluated the potential for additional sources that were excluded.

Verification Strategy and Risk:

Details of the verification activities undertaken as part of the verification strategy are set out in the Verification Plan in Appendix A and summarized in Section 4.0 of this report.

The Verification and Sampling Plan for the Project was developed considering our initial assessment of the verification risk for the engagement. The initial and final risk assessment are shown below.

Risk Area Preliminary Assessment

Final Assessment

Inherent Risk Medium Medium Control Risk Medium Medium

Detection Risk Low Low Overall Risk Medium Medium

Inherent Risk

Inherent risk is the risk of error that occurs as a result of the lack of capacity by staff, the size/complexity of the organization or GHG project, the industrial sector, or the technologies or processes being applied in the organization or GHG project. The final inherent risk was deemed to be Medium because of the following:

• The Project includes numerous project participant, subprojects, sites, and engines which increases the challenge of the logistics of data collection (medium risk).

• Fuel consumption, engine running speed, operating horsepower, and operating hours are logged either automatically using a data logger (low risk) or manually by an operator (medium risk).

• Bluesource prepared an engine fuel performance map to deploy the advanced measurement approach identified in the protocol. The engine fuel performance map required the standardization of assumptions which may or may not reflect the actual scenarios. Those engines that do not fall within the engine fuel performance map’s requirements use the protocol’s flexibility mechanism and conservative assumptions with respect to fuel savings. As with any model, there is residual inherent risk that the performance map may be incorrectly modelled thus resulting in an incorrect assertion for each Project activity (low risk).

• Fuel consumption is metered by the owners of the compressor engines; the meters were manufacturer calibrated prior to installation. Stantec determined that periodic calibration of the meters is not required during reporting period due to the type of meter (Coriolis) used (low risk).


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• This is the fifth verification for the Project and the quantification methodologies are same as previous reporting period (low risk).

Control Risk

Control risk is the risk that the proponent’s control system will not detect and rectify a discrepancy. The final control risk was deemed to be Medium because of the following:

• Data are obtained from CNRL, Repsol, Torxen, and IPC and transferred to the Bluesource offset quantification spreadsheets, and thus there is a potential for erroneous data transposition within the calculation tool (medium risk);

• Bluesource has a QA/QC program in place for their offset quantification spreadsheets (low risk);

• Bluesource has continuously corrected their GHG calculators from the previous reporting years in accordance with verification findings. As such, there is a low risk for quantification errors (low risk).

Detection Risk

Detection risk is the risk that Stantec will not identify a material misstatement. We initially regarded this risk as Low due to:

• Our Quality Management Procedures. We are committed to providing exceptional service to our clients in accordance with our ISO 9001 and ISO 14065 accreditations. We believe that quality is a basic principle and that quality management is an integral part of our work. We take a systematic approach to quality management to comply with requirements and to strive for continual improvement. The cornerstone of our quality management system is an entrenched process of quality and independent review where by our deliverables are vetted by senior and expert people in our firm (low risk).

• Level of Assurance. The reasonable level of assurance applied in this verification (as required by the CCIR) mandates that Stantec perform increased sampling to meet the assurance requirements, however, the level of assurance still increases the risk to Stantec as the risk-based verification approach means that not all information can be reviewed. Stantec has designed the sampling plan to target potentially material items in the GHG information to minimize detection risk (low risk). The verification team assessed that the Project resulted in emission reductions in a manner consistent with the project offset plan. During the verification, the verification team took into account the level of audit risk assessed and incorporated necessary tasks to reduce the audit risk.

The verification team assessed whether the Project resulted in emission reductions in a manner consistent with the Project Plan. During the verification, the verification team considered the level of audit risk noted above and incorporated necessary procedures to mitigate the audit risk. These procedures included:

• assessing conformance with applicable verification criteria, including the principles and requirements of relevant standards or GHG programs within the scope of verification

• evaluating the establishment, justification, and documentation of the Project Report • assessing the GHG Project's quality assurance and controls • assessing the information for consistency with our knowledge of the operation of the

engines.


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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.

Name Role ISO 14064-3

Training Completion

Responsibilities

Daniel Hegg Verifier / Project Manager

February 18-20, 2009

Conduct desktop review of the Project. Manage the verification financials.

Nicole Flanagan Independent Peer Reviewer

January 21-23, 2008

Review verification deliverables technical soundness and compliance with Stantec’s internal processes and ACCO criteria.

Vicki Corning Quality Reviewer

Fall 2005 Independent review of verification activities and concludes on the outcome of the verification. The independent reviewer confirms the verification activities have been completed and that the activities provide the required level of assurance.

Christina Varner Lead Verifier / Designated Signing Authority

January 29, February 5, February 11, 2010

Lead desktop review, sampling plan execution and working paper completion, and prepare verification documentation. Designated Signing Authority on verification documents.

Rengarajan Vaiyapuri

Verifier November 17 -18, 2015

Conduct desktop review of the Project and Lead the site visit.

Catherine MacFarlane

Verifier September 2012 Conduct desktop review of the

Project.

Christina Varner is a professional engineer registered by the Association of Professional Engineers and Geoscientists of New Brunswick (APEGNB), which satisfies Section 24(1)(a)(ii)(A) of the CCIR. She has the required technical knowledge of GHG emission quantification methodologies and has 9 years of experience in completing third party GHG verifications, which satisfies Section 24(1)(b)( i-iii) of the CCIR and Section 3(e)(iii) of the Standard for Validation, Verification, and Audit.


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Nicole Flanagan is a professional engineer registered by Professional Engineers Ontario (PEO), which satisfies Section 24(1)(a)(ii)(A) of the CCIR. She has the required technical knowledge of GHG emission quantification methodologies and has 9 years of experience in completing third party GHG verifications, which satisfies Section 24(1)(b)( i-iii) of the CCIR and Section 3(f)(iii) of the Standard for Validation, Verification, and Audit (version 3.0, December 2019).

With respect to the technical knowledge required by the CCIR, each member of the team has the required technical knowledge of GHG emission quantification methodologies and all have experience in completing third party GHG verifications. Please refer to the team profiles included in the verification plan in Appendix A.

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

Stantec’s Verification Schedule is provided in the following table.

Verification Activity Responsible Party Date of Completion

Kick-Off Meeting with Bluesource

Stantec / Bluesource November 5, 2018

Provide Verification Plan to Bluesource

Stantec November 20, 2018

Site Visit Stantec / Bluesource November 22, 29 and 30, 2018

Receive Bluesource Documentation

Bluesource January 18, 2019

Initial Desktop Review Stantec January 18 – February 6, 2019

Draft Verification Report Stantec February 11, 2019

Address Follow-Up Items Stantec / Bluesource February 12, 2019

Finalize Verification Report and Statement of Verification

Stantec February 14, 2019

Issue revised Verification Report

Stantec February 27, 2019

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

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.


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Engine data are monitored in one of two ways, either through operating logs and records in Detechtion (third party data collection system) or through the installation of a data logger (called GHGDL). The data loggers provide one data point per day. For CNRL, when both Detechtion and data loggers are available, the latter is used as it limits errors introduced through human-machine interface interactions. One of Torxen’s engines, PN-27448, used a data logger that provided multiple data points per day. This data was averaged by Bluesource to yield a daily value before being entered into the quantification calculator.

Stantec’s assessment of the Project’s GHG data management and controls is provided in the table below.

Parameter Procedures Sampling Plan Result

Quality Assurance / Control and Data Management

Assessed whether GHG data management system and quality control for the Project is adequate.

Overall system for completeness, accuracy, validity, and restricted access, through interviews, Project documentation, and site visit.

Satisfactory

Data Retention and Security

Assessed whether there is sufficient document storage and retention.

Not applicable. Satisfactory

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.

The GHG Assertion that was assessed is as follows:

Facility

Emission Reduction

(tCO2e) in 2017

(October 1, 2017 to December 31,

2017)

Emission Reduction (tCO2e) in 2018

(January 1, 2018 to September 30,

2018)

Total Emission Reductions

(tCO2e)

Total 6,015 19,700 25,715


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Facility

Emission Reduction

(tCO2e) in 2017

(October 1, 2017 to December 31,

2017)

Emission Reduction (tCO2e) in 2018

(January 1, 2018 to September 30,

2018)

Total Emission Reductions

(tCO2e)

Notes: Emission reduction are rounded down

The GHG emission reductions were quantified per “Quantification Protocol for Engine Fuel Management and Vent Gas Capture Projects (version 1.0, October 2009)”. The quantification methodologies that were used by the Bluesource for this reporting period are the same as the methodologies described in the Project Report and Project Plan. The Project Updates (variances from the Project Plan) are appropriately described in Section 2 of the Project Report.

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.

Table 1: Offset Criteria Assessment

Offset Eligibility Criteria

Assessment

Reduction or sequestration occurs in Alberta

Satisfactory – the Project is physically located in Alberta.

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

Satisfactory – the Project is not required by any current or proposed law.

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

Satisfactory – the Project began operation after this date.

Reduction or sequestrations is real and demonstrable

Satisfactory - the Project has been verified according to the Verification Criteria listed in Section 2.4 of this report.


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Quantifiable and measureable

Satisfactory – the Project has an Offset Project Plan which indicates quantification and measurement per an ACCO approved Protocol.

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

Satisfactory – Stantec is a qualified third-party verifier, as defined by Section 24 of the CCIR. Stantec is accredited with the American National Standards Institute (ANSI), a member of the International Accreditation Forum (IAF), in accordance with ISO 14065 (Accreditation ID #0805 issued to Stantec Consulting Ltd. for greenhouse gas (GHG) verification and validation).

Alberta REMVue Engine Fuel Management and Vent Gas Capture Aggregation Project - 1090-6410 February 2019

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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.


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A summary of the key findings from this verification is provided below.


GHG Assertion Conducted site tours to compare emissions inventory to on-site sources.

16 sites Satisfactory

Reviewed the Project Report for a statement regarding credit ownership.

Not applicable Satisfactory

Reviewed the Engine Fuel Management and Vent Gas Capture (EFM/VGC) quantification calculators.


Project Additionality Reviewed if the project developer is meeting the additionality criteria


Consistency with Project Plan

Reviewed the Project Report against the Project Plan for the following criteria: • deviation of the Project from the Project

Plan • same baseline and Project boundaries for

the Project and the Project Plan


Quantification and Monitoring

Traced engine records to the quantification spreadsheet.

Sample data for the following 21 engines: CNRL: 3622, 3590, 2888, 6008, 5046, 2891 Repsol: K163, WR_K2010 IPC: PN-18566-AA, PN-20183-AA, PN-27437-AA, PN-17116-AB, PN-26007, PN-11243 Torxen: PN-29005, PN-16777, PN-19562, PN-19188-AA, PN-27446, PN-31585

Satisfactory

Assessed the Project for missing engine data and confirmed records were within the crediting period.

Satisfactory

Assessed the Project for inconsistent quantification methodologies.

All methodologies (including baseline emissions, Project emissions, and emission reductions).

Satisfactory

Traced pre- and post-BSFC from Master Map to quantification spreadsheet.

The 21 engines listed above. Satisfactory


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Inspected evidence of data collection systems.

Review data collection procedures and evidence of meters (GHGDL and Detechtion).

Satisfactory

Assessed whether the calculated and default emission factors were appropriate and agree with the source data.

Emission factors for natural gas extraction and processing, CH4 and N2O emission factors from natural gas combustion, site-specific CO2 emission factors calculated by Bluesource (sampled Torxen 32638; Torxen PN-31160; Repsol K160; IPC PN-11243 IPC PN-25179-AA; CNRL 3549 P1B)

Satisfactory

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 2: 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 CO2 eq % net

Tonnes CO2 eq % absolute

None

Total Error


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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.

There is an opportunity for improvement in ensuring consistent data collection methods are used for engines using Detechtion data.

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.

Stantec has undertaken all assignments in its role as an environmental engineering consulting firm using professional effort consistent with the Standard for Validation, Verification, and Audit (version 3.0, December 2019). Stantec has assessed the Project Report submitted by Bluesource for the Alberta REMvue Engine Fuel Management and Vent Gas Capture Aggregation Project (for October 1, 2017 until September 30, 2018) using reasonably ascertainable information, as defined by ISO 14064-3, obtained from a review of operational records and available literature and documents. The assessment represents the conditions in the subject area at the time of the assessment. Stantec did not conduct direct monitoring or measurement or other physical sampling and analysis in conjunction with this verification report. Stantec disclaims liability for use by any other party and for any other purpose.

Stantec will retain all Project documents for a minimum of seven (7) years.


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

For this Project, Stantec confirmed that the:

• Project information contained in the Project Plan was consistent with the Project Report and GHG Assertion

• Project location is as indicated in the Project Report (i.e., in Alberta) • Project Plan contains the monitoring and quantification procedures applied to this Project for

the period verified • Project proponent, report date, emission reduction numbers and other related information

are accurate for the verification period verified • Project’s information systems are consistent with the descriptions contained in the Project

Plan.

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

Alberta Environment and Parks. 2003. Climate Change and Emissions Management Act, S.A. 2003, c. C-16.7.

Alberta Environment and Parks. 2009. Quantification Protocol for Engine Fuel Management and Vent Gas Capture (October 2009, V1.0).

Alberta Environment and Parks. 2015. The Emission Factors Handbook (March 2015, V1.0).

Alberta Environment and Parks. 2018. The Carbon Competitiveness Incentive Regulation, Alberta Regulation 255/2017, with amendments up to and including Alberta Regulation 199/2018.

Alberta Environment and Parks. 2018. Standard for Greenhouse Gas Emission Offset Project Developers, Carbon Competitiveness Incentive Regulation (July 2018, V2.0).

Blue Source Canada ULC. 2013. Alberta REMvue Engine Fuel Management and Vent Gas Capture Aggregation Project – Offset Project Plan (V2.3, dated December 20, 2013).

Blue Source Canada ULC. 2019. Alberta REMvue Engine Fuel Management and Vent Gas Capture Aggregation Project Project Report (dated February 12, 2019).


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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

Stantec Consulting Ltd. 845 Prospect Street Fredericton, NB E3B 2T7 Tel: (506) 457-3237 Fax: (506) 452-0112

Template version 3.0 August 2018

VIA EMAIL <[email protected]> February 14, 2019 File: 123220684

Attention: Amy Zell Blue Source Canada ULC 700, 717-7th Ave. SW Calgary, AB T2P 0Z3

Dear Ms. Zell,

RE: INITIAL VERIFICATION PLAN – CARBON COMPETTITIVENESS INCENTIVE REGULATION VERIFICATION OF THE BLUE SOURCE ALBERTA REMVUE ENGINE FUEL MANAGEMENT AND VENT GAS CAPTURE AGGREGATION PROJECT

INTRODUCTION

Stantec Consulting Ltd. (Stantec) provides this initial verification plan for the Blue Source Canada ULC Alberta REMVue Engine Fuel Management and Vent Gas Capture Aggregation Project (the Project), for the period of October 1, 2017 to September 30, 2018. Project consists of (based on initial information) 56 engines and they are operated by four different companies. The four Project Participants (Participants) are Canadian Natural Resources Ltd. (CNRL), Repsol Oil and Gas Canada Inc. (Repsol), Torxen Resources Ltd. (Torxen) and International Petroleum Corporation (IPC)

The verification is being completed under the Alberta Climate Change Office (ACCO) Carbon Competitiveness Incentive Regulation (CCIR). The verification plan outlines the terms of the engagement and the planned verification procedures. The verification plan also contains a list of data and documentation required to complete the planned procedures.

Blue Source Canada ULC (Bluesource) is the aggregator and project proponent for this project. Via the agreements with each Participants (i.e. the owners of the engines that have been installed technologies), Bluesource is given authority to aggregate and register the project's Offset Credits. The ownership model varies with each Participants depending on the respective agreements. In some cases, ownership is defined by the Direct Purchase agreement with transfer of title occurring at time of registration, while other agreements follow the Agency model, with title remaining with the subproject owner until time of sale.

Bluesource was responsible for the collection of activity data used in the calculations and data management for facility specific data. For the Project, Bluesource was responsible for the completion of the calculations, presentation of the information within the GHG Assertion, Project Report, and for the supporting technical documents.

This is Stantec’s fifth verification of the Project.

February 14, 2019 Blue Source Canada ULC Page 2 of 20

RE: INITIAL VERIFICATION PLAN - CARBON COMPETITIVENESS INCENTIVE REGULATION VERIFICATION OF BLUE SOURCE ALBERTA REMVUE ENGINE FUEL MANAGEMENT AND VENT GAS CAPTURE AGGREGATION PROJECT

OFFSET PROJECT SUMMARY AND VERIFICATION FUNDAMENTALS

The summary of the Project, verification objectives, criteria, standards, level of assurance, and materiality threshold are presented in Table 1.

Table 1 Offset Project Summary and Verification Fundamentals

Item Description

Project Title Alberta REMvue Engine Fuel Management and Vent Gas Capture Aggregation Project (Project)

Project Description

The Project achieves emission reductions through the retrofit and installation of various engine management technologies on existing or new engine units in Alberta. The baseline condition is the emissions that would have occurred in the normal operation without the project technology.

Project Location

All the engines are located within Alberta’s provincial boundary. The Project are developed using the aggregated offset project structure. Individual subproject installations’ legal land location are provided in the Aggregated Project Planning sheet submitted separately to the Registry.

Project Start Date July 16, 2003 (activity start date according to the Project Plan)

Offset Start Date January 1, 2013

Offset Crediting Period January 1, 2013 until December 31, 2020

Reporting Period October 1, 2017 until September 30, 2018

GHG Assertion (Actual Emission Reductions/Sequestration Achieved)

The GHG Assertion (i.e., reductions being claimed for the Project) is not available at issuance of the initial verification plan. This initial verification plan will be updated once the GHG Assertion is provided by Bluesource.

Ownership

Bluesource is the aggregator and project proponent for this project. Via the agreements with each Participants (i.e. the owners of the technologies that have been installed), Bluesource is given authority to aggregate and register the project's Offset Credits. The ownership model varies with each Participants depending on the respective agreements. In some cases, ownership is defined by the Direct Purchase agreement with transfer of title occurring at time of registration, while other agreements follow the Agency model, with title remaining with the subproject owner until time of sale. Participants of this Project are: CNRL, Repsol, Torxen, and IPC.

Project Activity Stantec will be conducting sufficient and appropriate procedures to assess the Project activities for the verification period, as part of the Project are eligible under the Carbon Competitiveness Incentive Regulation (CCIR) to generate offsets,



Table 1 Offset Project Summary and Verification Fundamentals

Item Description whether they meet the following conditions. Note that this Project will be developed using the aggregated offset project structure. These subprojects are collectively referred to as the Project herein. • Result from actions taken on or after January 1, 2002 • Be real, demonstrable, and quantifiable • Not be required by law • Have clearly established ownership • Be counted once for compliance purposes • Be verified by a qualified third party • Have occurred in Alberta

Project Contact

Company Name: Blue Source Canada ULC Main Contact Name: Yvan Champagne Address: Suite 1506, 840 7th avenue SW, Calgary, Alberta, T2P 3G2 Telephone: (403) 262-3026 x226 Website: www.bluesourcecan.com Email: [email protected]

Verification Objective and Criteria

Stantec will be conducting sufficient and appropriate procedures to express an opinion as to whether the Project Report (once provided) is materially in accordance with the requirements of:

• Climate Change and Emissions Management Act, S.A. 2003, c. C-16.7; • The Carbon Competitiveness Incentive Regulation, Alberta Regulation 255/2017,

with amendments up to and including Alberta Regulation 96/2018 (Regulation or CCIR);

• Standard for Greenhouse Gas Emission Offset Project Developers, Carbon Competitiveness Incentive Regulation (July 2018, V2.0);

• Quantification Protocol for Engine Fuel Management and Vent Gas Capture (October 2009, V1.0); and

• The Emission Factors Handbook (March 2015, V1.0). Further, Stantec will be conducting sufficient and appropriate procedures to express an opinion as to whether the GHG assertion is free from material discrepancies, is fairly presented and is substantiated by sufficient and appropriate evidence

Verification Standards

The verification will be performed in accordance with the following standards:

• ISO 14064 Part 3 – Greenhouse Gases: Specification with guidance for the validation and verification of greenhouse gas assertions (ISO 14064-3);

• ISO 14065 - Requirements for greenhouse gas validation and verification bodies for use in accreditation or other forms of recognition (ISO 14065); and

• Standard for Validation, Verification and Audit, Carbon Competitiveness Incentive Regulation (December 2018, V3.0).

Level of Assurance Reasonable level of assurance




VERIFICATION SCOPE

Stantec understands the Project is described in the following manner. The reasonableness of this project description is subject to verification by Stantec.

The Projects, as defined above, achieve greenhouse gas (GHG) reductions through the retrofit of engine management technologies on existing, or new engine units in Alberta. The Project technologies include:

• REMVue 500 Air:Fuel Ratio Controller System (EFM) which controls and monitors the air to fuel ratio in each engine to improve brake specific fuel consumption (BSFC), thus reducing fuel use and GHG emissions.

• REMVue SlipStream (VGC) which captures hydrocarbons otherwise vented to atmosphere and redirect this stream as a supplementary fuel source thus reduces fuel use and GHG emissions.

The baseline condition is the emissions that would have occurred in the normal operation without the above technologies. The offset credits are generated by reducing the emission through the retrofit and installation of various engine management technologies on existing or new engines. The legal land location of each engine is tracked within the Project inventory and the Aggregated Project Planning sheet. All subprojects are located within Alberta’s provincial boundary. The Project includes the list of engines shown in Table 2.

Table 2 Bluesource Alberta REMVue Engine Fuel Management and Vent Gas Capture Aggregation Project Engines

Item Number Panel Number Existing or

New Project Type Geographical Location Company

1. PN-31160 New EFM + VGC 4-22-017-14 W4 Torxen


3. PN-29005 New VGC 5-17-027-19 W4 Torxen




7. PN-16777 New EFM 8-21-021-15 W4 Torxen






13. PN-14538AA New EFM 12-33-022-18 W4 Torxen

14. PN-14538AB New EFM + VGC 12-33-022-18 W4 Torxen

15. PN-19188AA New EFM 12-33-022-18 W4 Torxen

16. PN-19188AB New TBD 12-33-022-18 W4 Torxen






18. PN-28131AA New VGC 13-24-019-15 W4 Torxen



21. PN-19819AA New EFM 1-04-015-06 W4 IPC

22. PN-18566AA New EFM + VGC 1-04-015-06 W4 IPC

23. PN-20181AA New EFM 1-04-015-06 W4 IPC

24. PN-19820AA New EFM 1-04-015-08 W4 IPC


26. PN-19116AB New EFM 1-04-015-08 W4 IPC




30. PN-22057AA New EFM 4-03-019-09 W4 IPC

31. PN-27503 New EFM + VGC 9-21-014-09 W4 IPC

32. PN-17116-B New EFM 14-15-020-04 W4 IPC

33. PN-17116-C New EFM + VGC 14-15-020-04 W4 IPC

34. PN-26129 New EFM 04-04-017-04 W4 IPC


36. PN-27451 New EFM 1-04-015-07 W4 IPC

37. PN-27452 New EFM 4-13-014-07 W4 IPC


39. 35354-B Existing EFM 8-05-053-21 W5 CNRL

40. RM-13638-AA Existing EFM 1-24-052-20 W5 CNRL




44. RP-20135-AA Existing EFM 1-24-096-05 W6 CNRL












52. RM-11231-AA Existing EFM 14-28-059-22 W5 Repsol




56. RP-11229-AA Existing EFM 14-28-059-22 W5 Repsol NOTES: TBD – To be determined

The engine types are Waukesha P9390GSI, L7044GSI, 7042GSI, L5794GSI, F3521GSI, F3524GSI, F3514GSI, L5790GSI, L5108GSI, and F2895GSI (according to Project Plan). Each of the included engines are using either EFM or VGC or combination of both. The engines are located across Alberta at existing CNRL, Torxen, IPC and Repsol sites. The engines are monitored in one of two ways, either through operating logs and records in Detechtion (third party data collection system) or through the installation of a GHG data logger. Where both systems are available, data from the GHG Data Logger (GHGDL) is preferred as it limits errors introduced through human-machine interface (HMI) interactions.

The following GHGs were included within the scope of the verification as required by the CCIR:

• carbon dioxide (CO2); • methane (CH4); • nitrous oxide (N2O); • hydrofluorocarbons (HFCs); • perfluorocarbons (PFCs); • sulphur hexafluoride (SF6); and • nitrogen trifluoride (NF3). The total equivalent GHG emissions are reported as tonnes of carbon dioxide equivalents (t CO2e).

High to Low or No Bleed Controller Conversions:

Sources of Project GHG emissions included:

• Emissions from Fuel Extraction and Processing, P1 (CO2, CH4, and N2O): Emissions that occurred due to the use of fossil fuel in the Project engines.

• Emissions from Unit Operation, P4 (CO2, CH4, and N2O): Emissions that occurred from fuel combustion in the engine with the Project technologies.

• Emissions from Captured Vent Gas, P5b (CO2, CH4, and N2O): Emissions that occurred from combustion of captured vent gas.



Sources of baseline GHG emissions included:

• Emissions from Fuel Extraction and Processing, B1 (CO2, CH4, and N2O): Emissions that would have occurred from the extraction and processing of the baseline quantity of fuel combusted.

• Emissions from Unit Operation, B4 (CO2, CH4, and N2O): Emissions that would have occurred from fuel combustion in the normal operation of the unit without the Project technologies.

• Emissions from Venting of Emissions Captured in Project, B5b (CH4): Emissions that would have occurred from vented fuel in the normal operation of the unit without the capture of vent gas.

MATERIALITY

ACCO has set the quantitative materiality threshold to 5% of the asserted emission reductions and removals for offset Projects. The materiality will be assessed on the net and absolute values of discrepancies. The identification of material qualitative discrepancies is at the discretion of the verification body. Stantec will execute the verification accordingly.

VERIFICATION SCHEDULE

Table 3 presents the verification schedule.

Table 3 Planned Verification Schedule

Verification Activity Responsible Party Date of Completion

Kick-Off Meeting with Bluesource Stantec / Bluesource November 5, 2018

Provide Verification Plan to Bluesource Stantec November 20, 2018

Site Visit Stantec / Bluesource November 22, 29 and 30 2018

Receive Blue Source Documentation Bluesource Week of December 3, 2018

Initial Desktop Review Stantec Week of December 10 and 17, 2018

Receive Additional Information Bluesource Week of January 7, 2018

Draft Verification Report Stantec Week of January 21, 2018

Address Follow-Up Items Stantec / Bluesource Week of January 28, 2018

Finalize Verification Report and Statement of Verification

Stantec Week of January 28, 2018

* Dates in italics are proposed.

VERIFICATION TEAM: QUALIFICATIONS, ROLES AND RESPONSIBILITIES

As part of Stantec’s GHG Standard Operating Procedures (SOP), the competence and selection of the team is completed following ISO 14066 - Greenhouse Gases – Competence requirements for greenhouse gas validation teams and verification teams.



Table 4 presents the verification team.

Table 4 Verification Team

Name Role Responsibilities

Daniel Hegg Lead Verifier Lead desktop review, sampling plan execution and working paper completion, and prepare verification documentation.


Independent review of verification activities and conclusions. The independent reviewer confirms the verification activities have been completed and that the activities provide the required level of assurance.

Vicki Corning Quality Reviewer / Designated Signing Authority

Review verification deliverables technical soundness and compliance with Stantec’s internal processes and ACCO criteria. Designated Signing Authority on verification documents. Carry out project management duties.

Christina Varner Verifier Assist with the completion of the desktop review.

Rengarajan Vaiyapuri Verifier Assist with the completion of the desktop review and conduct site visits.

TEAM PROFILE

Lead Verifier – Daniel Hegg, M.Sc., CEM, ENV-SP Verifier

Daniel Hegg is a Carbon Mitigation and Climate Resilience Specialist for Stantec Consulting Ltd.

Living on Canada’s west coast has deepened Dan’s passion for the development and implementation of sustainable practices. His unique perspectives and insights cross many important areas such as sustainable asset management, strategic energy and water management, sustainable ROI business case development, full value accounting, climate change infrastructure risk assessment for the private and public sectors.

In addition to providing strategy and policy advice, Daniel has specialized expertise in climate change adaptation planning. Daniel utilizes a modified risk assessment framework designed to align with ISO 31010 Risk Management Standard and the PIEVC Engineering Protocol to assess various assets and their exposure to climate change risks and hazards, determine priority areas, and develop short/medium/long term strategies to build natural and engineering resilience. Dan has prepared multiple climate-resilience strategies across a variety of sectors including buildings/real-estate, forestry, oil & gas, renewable energy, and mining. Much of his work has directly helped guide various private and public-sector organizations in sustainability and climate action decision-making. Having worked on over 175 organizational and facility GHG inventories and offset projects across a wide range of industry sectors, and on numerous GHG mitigation and energy reduction plans, Daniel has proven expertise in GHG offset verifications.

Independent Peer Reviewer – Nicole Flanagan, M.A.Sc., P.Eng

Nicole Flanagan, M.A.Sc., P.Eng. has 18 years of environmental engineering experience, twelve of which are with Stantec. Nicole’s experience is specialized in air emissions under a variety of industrial, government and corporate settings. She is currently a senior practitioner and technical reviewer for



greenhouse emission quantification, reporting and verification. Nicole was the lead verifier of some of the first regulatory greenhouse gas offsets sold in North America, has completed Environmental Compliance Approvals (ECAs), and National Pollutant Release Inventory reporting for several clients facilitating regulatory compliance. In addition, she has completed projects for various facilities developing voluntary greenhouse gas inventories, emission/energy performance key metrics, and identification of reduction opportunities. Her clients include major electric utilities, energy companies, petrochemical production facilities as well as oil & gas companies.

She also spent four years with Environment Canada working on program development and program delivery of greenhouse gas inventory and reduction programs, which included meeting with stakeholders and administering procedural processes. During this time, she developed a strong understanding of the workings of government from program administration (Greenhouse Gas, NPRI Reporting Division and Canada’s Offset System) as well as regulatory and instrument development (development of regulations and Pollution Prevention Planning requirements).

Quality Reviewer / Designated Signing Authority – Vicki Corning, P.Eng.

Vicki has a degree in chemical engineering and over 13 years of technical and management expertise in the field of atmospheric emissions and environmental permitting. She has been involved in over 175 verifications for organizational inventories and GHG offset projects in western Canada, Ontario, Quebec, Atlantic Canada and the United States. Vicki developed Stantec’s internal GHG program competency training process and has delivered course material on GHG verification, inventory, and data management through a contract with the Canadian Standards Association.

Vicki also regularly leads air, noise, and climate components of environmental assessments for a range of industrial clients. These environmental assessments involve monitoring existing conditions using analytical techniques, establishing emissions inventories for new facilities, and evaluating expected environmental effects using modeling. Vicki has worked with clients in a variety of different industries in Canada and the United States, including: upstream and downstream oil and gas (gas processing plants, oil refineries, steam assisted gravity drainage facilities, pipeline operations), electrical generating stations (coal, gas, co-generation, biomass), manufacturing plants, chemical processing facilities, mining, construction projects, and pulp and paper. She has managed the preparation of several policy reports on renewable energy for the New Brunswick Department of Energy and authored technical content on carbon capture systems for coal facilities as part of an environmental report for Carbon Capture Nova Scotia.

Verifier – Christina Varner, P.Eng.

Christina has practiced environmental engineering, specializing in atmospheric environment, for seven years. She is a lead GHG verifier at Stantec, having been a verifier of lead verifier in over 100 GHG validation and verification projects for clients in oil and gas, chemical manufacture, electricity generation, commercial operations, and municipal governments. In particular, she has participated as a verifier or lead verifier in 16 offset verifications where Bluesource was the aggregator or quantifier. Further, Christina has led eight verifications under the AB SGER, including one as an Alberta Environment and Sustainable Resource Development (AESRD) audit. She has completed desktop reviews, reporting, and site visits for facility and project GHG inventories under Alberta’s SGER, British Columbia’s Emissions Offset Regulation and Reporting Regulation, The Climate Registry, Verified Carbon Standard, Ontario’s Environmental Protection Act 452/09, and Massachusetts’ Mandatory Greenhouse Gas Reporting Regulation.



Christina has been involved in air quality studies such as dispersion modelling, noise monitoring, source emissions testing, and ambient air quality monitoring. Her clients include pulp and paper mills, petroleum refineries, electricity generating stations, and asphalt plants. She has performed data collection and analysis for environmental assessments. Christina has created emissions inventories to address regulatory requirements and permitting, including National Pollutant Release Inventory (NPRI) and Environment Canada Greenhouse Gas program reporting.

Verifier – Rengarajan Vaiyapuri, M.Eng. EIT

Rengarajan obtained a Master’s in Environmental Engineering from the University of Alberta and working with Stantec as an air quality scientist for over six years. He has completed the ISO 14064-3 GHG verification training course in November 2015 and has been identified as a verifier at Stantec. He has conducted over 50 greenhouse gas verification by completing desktop reviews, reporting, and conducted site visits for facilities under Alberta Specified Gas Emitters Regulation (SGER), Carbon Competitiveness Incentive Regulation (CCIR), Alberta’s Offset Credit System, British Columbia GHG reporting regulation, British Columbia offset regulation, Ontario Environmental Protection Act 452/09 and Nova Scotia Regulation 29/2018. The GHG verification projects have included the following sectors: organizations, manufacturing, oil and gas, power generation, chemical production, natural gas distribution, mining and mineral production.

During this time at Stantec, Rengarajan has also been involved in air quality studies including dispersion modelling, emission estimation, odour monitoring, National Pollutant Release Inventory (NPRI) reporting and other assigned duties. His dispersion modeling experience includes working with the U.S. Environmental Protection Agency’s AERMOD and CALPUFF dispersion modeling systems, assessing the effect of air emissions on local air quality. He has worked on projects for various industrial clients including power generation, oil and gas, wood, pulp and paper mills, chemical manufacturing and mining.

RISK ASSESSMENT

Stantec has done a preliminary assessment of the potential risk associated with this verification assignment. The risk assessment is an internal procedure used to assess inherent, control, and detection risk which uses the following equation:

Audit Risk = Inherent Risk x Control Risk x Detection Risk

Detection risk is the risk that Stantec will not uncover a material discrepancy (e.g., the misstatement was present in the assertion and was not identified during the verification). The assessment of detection risk impacts the nature, timing and extent of the verification procedures that are to be performed by Stantec. Inherent Risk is the risk of a material misstatement that arises due to error or omission as a result of factors that are outside of the failure of controls. Inherent risk is generally considered to be higher where a high degree of judgment and estimation is involved or where GHG emissions data collection and processing are highly complex and involved processes. Organizations must have adequate internal controls in place to prevent and detect instances of error, misstatements, and omissions. Control Risk is the risk of a material misstatement arising due to absence or failure in the operation of relevant GHG system controls. Control risk is considered to be high where the Project does not have adequate internal controls to prevent and detect misstatements in the assertion.



There is an inverse relationship between the inherent and control risks, and the detection risk. If the inherent and control risks are high, Stantec will perform verification and sampling procedures that reduce detection risk so that the final verification risk is maintained at a low level. Higher control and inherent risk equates to more rigorous investigation and sampling. It typically results in additional detailed on and off-site sampling, additional information requests and staff interviews. Detection risk is lowered by more rigorous sampling; however, sampling is always done as per the verification criteria and standards.

Based on the risk assessment in each of these categories, the Stantec team assigns an overall risk to the verification. The preliminary overall risk for this verification has been assessed as Medium. A summary of the risk assessment is provided in Table 5.

Table 5 Risk Summary

Risk Area Preliminary Assessment Final Assessment Inherent Risk Medium To be determined

Control Risk Medium To be determined

Detection Risk Low To be determined

Overall Risk Medium To be determined

We consider the initial inherent risk to be Medium based on the following:

• The Project includes numerous project participant, subprojects, sites, and engines and there would be a challenge to data collection (medium risk);

• Fuel consumption, engine running speed, operating horsepower, and operating hours are logged either automatically using a data logger (low risk) or manually by an operator (medium risk);

• There is a risk that engines may be inappropriately included in the GHG Assertion as they do not meet the eligibility criteria (i.e. they do not exist) (medium risk);

• Bluesource prepared an engine fuel performance map to deploy the advanced measurement approach identified in the protocol. The engine fuel performance map required the standardization of assumptions which may or may not reflect the actual scenarios. Those engines that do not fall within the engine fuel performance map’s requirements use flexible mechanism and conservative assumptions with respect to fuel savings. As with any model, there is residual inherent risk that the performance map may be incorrectly modelled thus resulting in an incorrect assertion for each Project activity (low risk);

• Fuel consumption is metered by the owners of the compressor engines; the meters were manufacturer calibrated prior to installation and based on supporting data provided during previous verifications; Stantec determined that periodic calibration of the meters is not required during reporting period due to the type of meter (Coriolis) used (low risk);

• There is a risk that the ownership over engine emission reductions has changed (due to sale or otherwise) and has not been captured by Bluesource’s systems (low risk); and




We consider the initial control risk to be Medium based on the following:

• Data is obtained from CNRL, Repsol, Torxen, and IPC and transferred to the Bluesource offset quantification system, and thus there is a potential for erroneous data transposition within the calculation tool (medium risk);

• The flexible mechanism is quantified from the average of the difference BSFC between pre and post AFR installation for all Project engines in a certain reporting year. Therefore, the correct flexible mechanism is available once the engine list and engine data are finalized. There is a risk of quantification errors as calculators are a work in progress and all calculators will require updating (medium risk); and

• Bluesource has continuously corrected their GHG calculators for this reporting period, from the previous reporting years in accordance with verification findings. As such, there is a low risk for quantification errors (low risk).

Detection risk is the risk that Stantec will not identify a material discrepancy. We regard this risk as Low due to:

• Our Quality Management Procedures. We are committed to providing exceptional service to our clients in accordance with our ISO 9001 and ISO 14065 accreditations. We believe that quality is a basic principle and that quality management is an integral part of our work. We take a systematic approach to quality management to comply with requirements and to strive for continual improvement. The cornerstone of our quality management system is an entrenched process of quality and independent review where by our deliverables are vetted by senior and expert people in our firm (low risk).

• Level of Assurance. The reasonable level of assurance applied in this verification (as required by the Regulation) mandates that Stantec perform increased sampling to meet the assurance requirements, however, the level of assurance still increases the risk to Stantec as the risk-based verification approach means that not all information can be reviewed. Stantec has designed the sampling plan to target potentially material items in the GHG information to minimize detection risk (low risk).

VERIFICATION PLAN

The verification and sampling plan is intended to facilitate the assessment of completeness, conservativeness, consistency, accuracy, and transparency of the responsible party’s GHG information and confirm the GHG Assertion as identified in the Project Report. The verification team has established and will modify the sampling plan to verify that sufficient and appropriate evidence is available to support the Project Report and GHG Assertion presented. Further, any discrepancies that contribute to the GHG Assertion will be assessed and documented in the verification report.

With regards to the magnitude of potential errors, omissions and misrepresentations, the various vent rates and gas compositions represent the greatest risk of material error to the GHG Assertion (e.g., tracking of



device conversions, vent rates and gas compositions). Thus, verification procedures focused on the evidence and controls related to these parameters.

Table 6 shows the planned verification procedures.


RE: INITIAL VERIFICATION PLAN - CARBON COMPETTITIVENESS INCENTIVE REGULATION VERIFICATION OF THE BLUE SOURCE ALBERTA REMVUE ENGINE FUEL MANAGEMENT AND VENT GAS CAPTURE AGGREGATION PROJECT

Table 6 Verification Procedures

Line Item Verification Objective Risk Identified Type of Procedure Description of Procedure

Greenhouse Gas Assertion

Completeness Incompleteness of inventory.

Test of detail – inspection.

Conduct a site tour of the Facilities to determine sources and compare with inventory.


Accuracy Classification

Information not appropriately disclosed.


Inspect Project Report for correct reporting of emissions and related information.


Completeness Incompleteness of Project Report.


Inspect Project Report for missing information.


Accuracy Conservativeness

GHG Assertion is incorrect

Test of detail – inspection and reconciliation.

Check emission factors, quantification methodology and recalculate GHG Assertion.


Occurrence Document storage and retention practices may not be sufficient.

Test of detail – inquiry. Inquire of Proponent the location and retention period of data used for GHG Assertion.

Flexibility Mechanism

Accuracy Inconsistency of Flexibility Mechanism from the Protocol


Inspect Flexibility Mechanism used and assess consistency with the Protocol.

Ownership Completeness Offsets have multiple owners.

Test of detail – inspection

Outside of the site visit sample, test a representative sample of the population for demonstration of ownership.

Occurrence / Existence

Completeness Conversions have not occurred

Test of detail – inspection

Outside of the site visit sample test a representative sample of the population for evidence that the conversions have occurred.

Fuel Gas Combustion

Completeness Missing load, engine speed, operating hours and fuel consumption data.

Test of detail – tracing. Trace load, speed, engine consumption, captured vent gas and operating hours from records to emission reduction calculations.

Fuel Gas Combustion

Consistency Inconsistent quantification methodologies.


Assess whether quantification methodologies (including emission factors) are consistent between the Reports, the Offset Plans, and the Protocol.

Fuel Gas Combustion

Accuracy Anomaly in emissions trend.

Analytical test – profile.

Run profile tests for monthly data for sampled engines with data logger.



Table 6 Verification Procedures

Line Item Verification Objective Risk Identified Type of Procedure Description of Procedure

Test of detail – inquiry. Inquire with operators on anomalies in natural gas use.

Fuel Gas Combustion

Accuracy Inaccurate aggregation of fuel receipts.

Test of control – inquiry. Inquire on data aggregation and quality assurance and control procedures.

Fuel Gas Combustion

Accuracy Inaccurate measurement of fuel gas used.

Test of control –inquiry. Inquire on data aggregation and quality assurance and control procedures.

Fuel Gas Combustion

Accuracy Inaccurate calculation of emissions.

Test of detail – tracing, recalculation, inspection.

Trace fractional change from Master Map to Project Reports. Recalculate site specific emission factors. Review calculators for errors.

Fuel Gas Combustion

Cut-off Improper dates on engine records.


Inspect the engine data records.

Fuel Extraction and Processing

Accuracy Inaccurate calculation of emissions.

Test of details – inspection.

Review calculators for errors.


RE: INITIAL VERIFICATION PLAN - CARBON COMPETTITIVENESS INCENTIVE REGULATION VERIFICATION OF THE BLUE SOURCE ALBERTA REMVUE ENGINE FUEL MANAGEMENT AND VENT GAS CAPTURE AGGREGATION PROJECT

SITE VISIT

Stantec Verifier, Rengarajan Vaiyapuri, will be conducting a site visit to the following sites on November 22, 29 and 30, 2018:

Table 7 Site Visit Locations Panel Number Geographical Location Company

RP-26908-AA 16-17-081-04 W6 CNRL RP-26909-AA 8-36-080-04 W6 CNRL PN-14538AA 12-33-022-18 W4 Torxen PN-14538AB 12-33-022-18 W4 Torxen PN-19188AA 12-33-022-18 W4 Torxen PN-19188AB 12-33-022-18 W4 Torxen

PN-16777 8-21-021-15 W4 Torxen PN-19562 8-21-021-15 W4 Torxen

PN-19819AA 1-04-015-06 W4 IPC PN-18566AA 1-04-015-06 W4 IPC PN-20181AA 1-04-015-06 W4 IPC PN-19116AB 1-04-015-08 W4 IPC PN-27449AA 1-17-014-08 W4 IPC

PN-27503 9-21-014-09 W4 IPC PN-27451 1-04-015-07 W4 IPC PN-27452 4-13-014-07 W4 IPC

The proposed site visit agenda is provided in Table 8. The agenda was structured to include a general site tour where the verification team will look at engine, make and model, fuel gas meter, fuel gas sampling points and installation dates of the technology. Each day will start with introduction, overview of verification process and site visit objectives. During the site visits, the verifier will check for reporting boundaries, conduct data sampling, as well as investigate data management and storage procedures for GHG data on site.

Table 8 Site Visit Agenda

Date LSD Responsible Party Time

November 22, 2018 RP-26908-AA - 16-17-081-04 W6 RP-26909-AA - 8-36-080-04 W6

Stantec / Bluesource

To be confirmed by Bluesource



Table 8 Site Visit Agenda

Date LSD Responsible Party Time

November 29-30, 2018

PN-14538AA - 12-33-022-18 W4 PN-14538AB - 12-33-022-18 W4 PN-19188AA - 12-33-022-18 W4 PN-19188AB - 12-33-022-18 W4 PN-16777 - 8-21-021-15 W4 PN-19562 - 8-21-021-15 W4 PN-19819AA - 1-04-015-06 W4 PN-18566AA - 1-04-015-06 W4 PN-20181AA - 1-04-015-06 W4 PN-19116AB - 1-04-015-08 W4 PN-27449AA - 1-17-014-08 W4 PN-27503 - 9-21-014-09 W4 PN-27451 - 1-04-015-07 W4 PN-27452 - 4-13-014-07 W4

Stantec / Bluesource

To be confirmed by Bluesource

INFORMATION REQUEST

Table 9 contains a list of documentation and data requested by Stantec to complete the proposed procedures and the outcome of the requests. This table will be updated as needed through the verification process to track requests.

Table 9 Information Requested

Information Requested Request Date Obtained On

1 Offset Project Plan 20-Nov-18 Downloaded from Registry

2 Offset Project Report (draft and final, signed version) 20-Nov-18 Draft: January 24,

2019 Final: February 12, 2019

3 GHG Calculator including supporting data (e.g. gas compositions, vent rates)

20-Nov-18 23-Jan-18

4 Ownership evidence including subproject ownership records 20-Nov-18 18-Jan-19

5 Fuel Gas analysis data 20-Nov-18 18-Jan-19

6 Explain whether any missing data has been substituted in the reporting period. If any provide a justification.

20-Nov-18 31-Jan-19

7 What QA/QC methods are being applied to ensure that the data used to calculate the GHG Assertions are accurate and conservative?

20-Nov-18 31-Jan-19

8 Current agreement between CNRL and Bluesource for all current subprojects.

28-Jan-19 31-Jan-19



Table 9 Information Requested

Information Requested Request Date Obtained On

9 Current agreement between IPC and Bluesource for all current subprojects.

28-Jan-19 31-Jan-19

10 Current agreement between IPC and Bluesource for all current subprojects.

28-Jan-19 31-Jan-19

11 Current agreement between Torxen and Bluesource for all current subprojects.

28-Jan-19 31-Jan-19

12 Current agreement between Repsol and Bluesource for all current subprojects.

28-Jan-19 31-Jan-19

13 Are any of the subprojects affected by Directive 084? 28-Jan-19 31-Jan-19

14 We notice that the Torxen and IPC contracts with Bluesource are signed in 2018; however, Bluesource is aggregating credits for Torxen and IPC starting in October 1, 2017. Do you have evidence that shows Bluesource may aggregate for Torxen and IPC starting in October 2017?

1-Feb-19 5-Feb-19

15 The termination date of the Talisman (Repsol)-Bluesource contract appears to be located on Appendix C, which was not provided to Stantec. Please provide Appendix C (or other evidence that shows the termination date).

1-Feb-19 5-Feb-19

FINALIZING THE VERIFICATION PLAN

TEAM CHANGE

The verification team changed during the verification. Christina Varner (originally identified as a verifier) became the lead verifier and designated signing authority and Daniel Hegg (originally identified as lead verifier) became a verifier. The final verification team is shown in Table 10. Table 10 Verification Team


Christina Varner Lead Verifier / Designated Signing Authority

Lead desktop review, sampling plan execution and working paper completion, and prepare verification documentation.


Independent review of verification activities and conclusions. The independent reviewer confirms the verification activities have been completed and that the activities provide the required level of assurance.

Vicki Corning Quality Reviewer

Review verification deliverables technical soundness and compliance with Stantec’s internal processes and ACCO criteria. Designated Signing Authority on verification documents. Carry out project management duties.



Table 10 Verification Team


Daniel Hegg Verifier / Project Manager

Assist with the completion of the desktop review. Manage verification financials.

Rengarajan Vaiyapuri Verifier Assist with the completion of the desktop review and conduct site visits.

FINAL RISK

The final assessment of verification risk is Medium. The verification risk was updated throughout the verification as information was reviewed. The final inherent risk was deemed to be Medium because of the following:

• The Project includes numerous project participant, subprojects, sites, and engines which increases the challenge of the logistics of data collection (medium risk).

• Fuel consumption, engine running speed, operating horsepower, and operating hours are logged either automatically using a data logger (low risk) or manually by an operator (medium risk).

• Bluesource prepared an engine fuel performance map to deploy the advanced measurement approach identified in the protocol. The engine fuel performance map required the standardization of assumptions which may or may not reflect the actual scenarios. Those engines that do not fall within the engine fuel performance map’s requirements use the protocol’s flexibility mechanism and conservative assumptions with respect to fuel savings. As with any model, there is residual inherent risk that the performance map may be incorrectly modelled thus resulting in an incorrect assertion for each Project activity (low risk).

• Fuel consumption is metered by the owners of the compressor engines; the meters were manufacturer calibrated prior to installation. Stantec determined that periodic calibration of the meters is not required during reporting period due to the type of meter (Coriolis) used (low risk).


The final control risk was deemed to be Medium because of the following:

• Data are obtained from CNRL, Repsol, Torxen, and IPC and transferred to the Bluesource offset quantification spreadsheets, and thus there is a potential for erroneous data transposition within the calculation tool (medium risk);

• Bluesource has a QA/QC program in place for their offset quantification spreadsheets (low risk);

• Bluesource has continuously corrected their GHG calculators from the previous reporting years in accordance with verification findings. As such, there is a low risk for quantification errors (low risk).



The final detection risk remains Low, for the reasons described in the initial verification plan.

FINAL ASSERTION

Following the issuance of the initial verification plan, Bluesource provided the Offset Project Report with the GHG Assertion. The GHG Assertion is shown in Table 11. Table 10 Final GHG Assertion

Facility Emission Reductions (t CO2e) (Oct. 1, 2017

to Dec. 31, 2017)

Emission Reductions (t CO2e) (Jan. 1, 2018

to Sept. 30, 2018)

Total Emission Reductions (t CO2e)

Total Project 6,015 19,700 25,715

Note: Emission reduction are rounded down.

CLOSURE

Should you have any questions or require additional information, please contact the undersigned directly. Sincerely,

STANTEC CONSULTING LTD.

This report was reviewed and approved for transmittal by:

Christina Varner, P.Eng. Lead Verifier Tel: (506) 457-3237 [email protected]

Nicole Flanagan, M.A.Sc., P.Eng. Independent Peer Reviewer Tel: (613) 738-6086 [email protected]

\\cd1002-f11\ghg\bluesource_remvue_123220684_2018\2_ver_plan\ver_plan\bluesource_ccir_offset_p1_vplan_20190214.docx




February 2019

Page 30 of 43

Appendix B: Statement of Qualifications

Alberta REMVue Engine Fuel Management and Vent Gas Capture Aggregation Project -1090-6410

February 2019

Alberta REMVue Engine FuelManagement and Vent Gas

,l1

Blue Source Canada ULC Offset

October'|',2017 -September 30,2018

Offset P ID

Period

Name

TRe Name

fromto

Christina VarnerThird-party verifiers described in Section 29 of the Carbon Competitiveness lncentive Regulation

Fo6, )-1 ,7.olol

Christina Vamer

[email protected] 506 457-3237

Stantec Consulti Limited

0e* \/^.nISO 14064 Part 3 completed

ature of Third

First Name Last Name

E-mail Address Phone NumberProfessional

Verifier

nation

Trainin Received Under ISO 14064 ParI3

Name

Per:

Date

(Third Party Verifier), meet or exceed the qualifications ofthird party

$tatement of QualificationsOffset Report

Signature of Third Party Verifier

Lead VerifierSame as third partyverifier?

First Name

Professional nation

Last Name

E-mail Address Phone Number

Traini Received Under ISO 14064 ParI3

Page 31 of43


ISO 14064 Part 3 completed

Peer Reviewer

Alberta REMVue Engine Fuel Management and Vent Gas Capture Aggregation Project'1090-541;

February 2019

First Name Last NameNicole Flanaqan

E-mailAddress Phone NumberNicole.fl [email protected] (613) 738-6086

T Received Under ISO 14064 Part 3

Page 32 of 43



February 2019

Page 33 of 43

Appendix C: Findings and Issues


Page 34 of 43

Table 3: 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 client Resolution

Conclusion (including % discrepancy if

applicable)

None


February 2019

Page 35 of 43

Appendix D: Statement of Verification

Alberta REMVue Engine Fuel Management and Vent Gas Capture Aggregation Project'1090-641;

February 2019

GHG Assertion

Value Units

berta REMvue Engine Fuelnagement and Vent Gas Capturegregation Project

Blue Source Canada ULC

Quantification Protocol for Engine:uel Management and Vent Gas3apture Projects (2009, V1.0) 1090-6410

October L,20L7- September30, 2018

Offset Project Protocol Project ID #

Project Developer Start

End

SerialRange

ReportPeriod

SerialRange

Statement of VerificationAssoeiated

Total BaselineEmissions)

Total ProjectEmissions )

Other )

25,7L5

NA

25,715

tonnesCO2eq

tonnesCO2eq

tonnesCO2eq

tonnesCO2eq

0

Net Reductions)

Page 36 of 43

Alberta REMVUe Engine Fuel Management and Vent Gas Capture Aggregation Project1090-641;

February 2019

Statement ofAssertion

l-he fundamental GHG Assertion verified is the quantification of 25,715lCOze in GHG reductions for the period of October 1,2077 to September30, 2018 resulting from the Alberta REMvue Engine Fuel Management and/ent Gas Capture Aggregation Project has been completed in accordancerrrtith the verification criteria.

Responsibilities of Project Developer and Third Party Verifier

Conclusion

Verifying CompanyName

n this work, CNRL, Repsol, Torxen and IPC own and operate the natural gas engines and thus areponsible for the collection of activity data used in the calculations and data management for

ngine-specific data. Bluesource was responsible for the completion of the calculations, presentationf the information within the Project Report, and for the supporting technical documents.

lue Source Canada ULC (Bluesource) is the aggregator and project proponent for this project. Viaagreements with each Participant (i.e. the owners of the engines that have been installed

chnologies), Bluesource is given authority to aggregate and register the project's Offset Credits,ownership model varies with each Participants depending on the respective agreements, In

me cases/ ownership is defined by the Direct Purchase agreement with transfer of title occurringtime of registration, while other agreements follow the Agency model, with title remaining with

ntec was responsible for planning and executing the verification to deliver an opinion to able level of assurance as to whether the Project Report and the GHG Assertion are

fairly and in accordance with the verification criteria. Stantec is a qualified third-partyrifier, as defined by Section 24 of the CCIR. Stantec is accredited with the American Nationalndards Institute (ANSI), a member of the International Accreditation Forum (IAF), in accordance

th ISO 14065 (Accreditation ID #0805 issued to Stantec Consulting Ltd. for greenhouse gas

he subproject owner until time of sale

GHG) verification and validation)

Project Report and GHG Assertion, dated February 72,2019, satisfies the requirements of the

o Climate Change and Emissions Management Act, S.A. 2003, c. C-L6.7o The Carbon Competitiveness Incentive Regulation, Alberta Regulation 255/2OI7, with

amendments up to and including Alberta Regulation 199/20L8 (Regulation or CCIR)o Standard for Greenhouse Gas Emission Offset Project Developers, Carbon Competitiveness

Incentive Regulation (July 2018, V2.0). Quantification Protocol for Engine Fuel Management and Vent Gas Capture (October 2009,

V1.0), referred to as the Protocol. The Emission Factors Handbook (March 2015, V1.O)

e GHG Assertion for the Project is deemed to be fairly presented and substantiated by sufficientnd appropriate evidence. A reasonable level assurance verification statement was issued.

Consulting Ltd. Per

Page 37 of 43

Alberta REMVue Engine Fuel Management and Vent Gas Capture Aggregation Project1090-541;

February 2019

Signature of ThirdParty Verifier

First Name

ProfessionalDesignation

Date

LastName

E-mail Address

F.L,'IJ,z-'otq

PhoneNumber

't ,1,:,11 ;r;lill i, ; i,l.;t rlrtlr,riri, | .ll;,r1 rliilr i'l ,1,

;rli,l

tl.'riti irri

',,t t,',' :., .,',::,,r'

".:. :, ',. t

tr jirtri ii' lijt t:i.,t

Page 38 of 43




February 2019

Page 39 of 43

Appendix E: Conflict of Interest Checklist

Alberta REMvue Engine FuelManagement and Vent Gas

Quantification Protocol for Engine FuelManagement and Vent Gas Capture Projects{2009. v1.0)

)ctober 1,10"t7 -ieptember 30,2018Blue Source ULC Offset

ProtocolOffset

P

ReportPeriod

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

The relationship between my firm and this reporting company poses unacceptablethreat 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 anactual or potential conflict of interest. False

4.My firm participated in some manner in the development or completion of theassociated offset submission for this reporting company. False

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

6.My firm will use personnel that have, are, or will be engaged or previously employed bythe reporting company. False

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

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

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

Conflict of lnterest ChecklistAssociated SGERSubmission

Checklist

Signature of Third PartyVerifier


February 2OL9

Page 40 of 43


February 2019

with the information contained in this Conflict-of lnterest Checklist, and can demonstrate freedom from any conflict ofinterest related to the reporting company for which the verification was performed. I hereby warrant that theinformation submitted in this Conflict-of lnterest Checklist is true, accurate and complete to the best of myknowledge, and that all matters affecting the validity of this Conflict-of-lnterest Checklist have been fully disclosed.lmpartiality 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.

Com Name

S of Third Verifier Date

Christina Varner

Professional nation

(Third Party Verifier), have personally examined and amfamiliar

Per

fra-6. JJ, zorq

First Name Last Name

E-mail Address Number

l#'iffiffiILi.ili:{.tlri,F,€ffi?l

Phone

0e- r./rn*.

Page 41 of43



February 2019

Page 42 of 43

Appendix F: Supplemental Diagrams/Tables/Figures


February 2019

Page 43 of 43

Appendix F is not applicable.

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