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Ember Resources Instrument Air Conversion at Strathmore (1665-4576) August 2018
Verification Report for: Ember Resources Instrument Air Conversion at Strathmore (1665-4576)
Proponent:
Ember Resources Inc.
Prepared by:
Brightspot Climate Inc.
Prepared for:
Alberta Climate Change Office
Version: Final
Date:
August 22, 2018
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Table of Contents 1.0 Summary – Offset Project ...................................................................................... 4 1.1 Summary – Facility ......................................................................................................... 7 2.0 Introduction .......................................................................................................... 8
2.1 Objective .............................................................................................................. 8 2.2 Scope .................................................................................................................. 9 2.3 Level of Assurance ................................................................................................. 9 2.4 Criteria .............................................................................................................. 10 2.5 Materiality .......................................................................................................... 10
3.0 Methodology ....................................................................................................... 10 3.1 Procedures ......................................................................................................... 11 3.2 Team ................................................................................................................. 23 3.3 Schedule ............................................................................................................ 25
4.0 Results ............................................................................................................... 25 4.1 Assessment of Internal Data Management and Controls ........................................... 25 4.2 Assessment of GHG Data and Information .............................................................. 26 4.3 Assessment against Criteria .................................................................................. 29 4.4 Evaluation of the GHG Assertion ............................................................................ 34 4.5 Summary of Findings ........................................................................................... 34 4.6 Opportunity for Improvement ............................................................................... 36
5.0 Closure .............................................................................................................. 36 5.1 Verification Statement ......................................................................................... 36 5.2 Limitation of Liability............................................................................................ 36 5.3 Confirmations ..................................................................................................... 37
6.0 References ......................................................................................................... 37 Appendix A: Final Verification Plan and Sampling Plan ............................................................. 38 Appendix B: Statement of Qualifications ................................................................................ 64 Appendix C: Findings and Issues .......................................................................................... 66 Appendix D: Statement of Verification ................................................................................... 68 Appendix E: Conflict of Interest Checklist .............................................................................. 71 Appendix F: Supplemental Diagrams/Tables/Figures ............................................................... 74
List of Tables Table 1: Risk Assessment .................................................................................................... 15 Table 2: Findings of Data Integrity Verification Procedures ...................................................... 26 Table 3: Findings of GHG Data and Information Verification Procedures..................................... 27 Table 4: Findings of Criteria Verification Procedures ................................................................ 30 Table 5: Offset Criteria Assessment ...................................................................................... 33 Table 6: Summary of Findings.............................................................................................. 35 Table 7: Confirmation Findings ............................................................................................. 37 Table 8: Detailed Findings and Issues Log ............................................................................. 67 Table 9: Supporting Documentation Reviewed ....................................................................... 75
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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 usefule 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)
Ember Resources Instrument Air Conversion at Strathmore Phase 1
Project Description
Provide a brief description of the project and baseline conditions.
The Responsible Party has installed an instrument air system at its Strathmore 09-27-024-25W4 compressor facility, located in Alberta. The Project reduces emissions of greenhouse gases by retrofitting natural gas-driven instrumentation with air-driven instrumentation. The new air compression system (air compressors, air driers, air receivers, piping and associated infrastructure) is electric-driven and is connected to the Alberta Interconnected Electricity System.
Metered air flow data is collected from the project site using a centralized SCADA system. Natural gas composition is analyzed annually in a third-party laboratory.
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.
Site Name Location (LSD) Coordinates
Strathmore 09-27-024-25W4 51.076, -113.403
Project Start Date
Enter the project start date.
January 1, 2010
Offset Start Date
Enter the start date for offset credit generation.
January 1, 2010
Offset Crediting Period
Enter the offset crediting period, including the offset start date. Include day, month year.
January 1, 2010 - December 31, 2017
Reporting Period
Enter the reporting period being verified.
August 1, 2016 – December 31, 2017
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GHG Assertion (Actual Emission Reductions/Sequestration Achieved)
Enter the actual emissions reductions / sequestration for the reporting period. Enter serial numbers if available.
355 tonnes CO2e
Protocol
Indicate the relevant protocol (if applicable)
Quantification Protocol for Instrument Gas to Instrument Air Conversion in Process Control Systems, Version 1.0, October 2009
Ownership
Enter offset project owner.
Ember Resources owns 100% of the Strathmore 09-27-024-25W4 facility and is the sole owner of the emission offsets from the instrument gas to air conversion project.
Project Activity
State how the project activity meets the eligibility requirements
The project must meet the eligibility criteria stated in Part 3, Section 16 of the Carbon Competitiveness Incentive Regulation (CCIR). In order to qualify, emission reductions must:
• Occur in Alberta; • Result from an action taken that is not otherwise
required by law at the time the action is taken; • Result from actions taken on or after January 1,
2002; • Occur on or after January 1, 2002; • Be real, demonstrable, quantifiable and verifiable; • Be quantifiable and measurable, directly or by
accurate estimation using replicable techniques.
The verification included an evaluation of these criteria as well as the specific applicability criteria described in the Protocol. The results of this analysis are described in Section 4.3 of this report.
Project Contact
Enter contact name, company name, mailing address, phone number and email address.
Steve Gell, P. Eng. Ember Resources Inc. The Devon Tower, 800-400 3rd Ave SW Calgary, AB T2P 4H2 +1 (403) 698-8983 [email protected]
Verifier
Verifier name, verifier’s company name, address, phone number email etc.
Aaron Schroeder, P.Eng. Brightspot Climate 225 West 8th Avenue, Suite 300 Vancouver BC V5Y 1N3 +1 (604) 353-0264 [email protected]
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Verification Team Members
Include verification team members, roles, training, training dates and qualifications.
Aaron Schroeder, P.Eng. Roles: Lead Verifier and Designated Signing Authority Training: Greenhouse Gas Verification – ISO 14064- 3, Canadian Standards Association, 2012; Instructor – Greenhouse Gas Verification – ISO 14064-3, University of Toronto, 2015 – 2018
Jeanna Brown, P.Eng. Role: Associate Verifier Training: GHG Validation and Verification, ISO 14064-3, University of Toronto, October 2017
Chris Caners, P.Eng. Role: Peer Reviewer Training: Greenhouse Gas Verification – ISO 14064-3, Canadian Standards Association
Designated Signing Authority
Enter the designated signing authority for this verification.
Aaron Schroeder, P.Eng. Brightspot Climate 225 West 8th Avenue, Suite 300 Vancouver BC V5Y 1N3 +1 (604) 353-0264 [email protected]
Verification Strategy
Describe the verification strategy used for the verification, including rationale for the approach. Note, if a controls reliance is used, provide justification for how the project is able to support this approach.
The verification strategy applied a largely substantive approach. The verification procedures, which are detailed later in this section, were designed to test the activity data directly, wherever practical. By applying this approach, the verification did not rely heavily on the Responsible Party’s controls, but rather relied on the substantive evidence collected from verification procedures that reviewed metered data, data directly from invoices and independent laboratory reports, for example.
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1.1 Summary – Facility
Item Description
Facility Name and Company Name
List company name and facility name.
Not applicable for offset verification reports
Facility Description
Provide a brief description of the facility.
Not applicable for offset verification reports
Baseline Emissions Intensity Description
List the approved BEIA and the baseline years.
Not applicable for offset verification reports
Reporter Contact
Enter contact name, company name, mailing address, phone number and email address.
Not applicable for offset verification reports
GHG Assertion
Enter the actual emissions, production, emissions intensity and the reduction target being verified.
Not applicable for offset verification reports
Verifier
Verifier name, verifier’s company name, address, phone number email etc.
Not applicable for offset verification reports
Verification Team Members
Include verification team members, roles, training, training dates and qualifications.
Not applicable for offset verification reports
Designated Signing Authority
Enter the designated signing authority for this verification.
Not applicable for offset verification reports
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2.0 Introduction Provide an introduction to the facility or project, the verification, and the background.
For Offset Project: summary of offset project baseline, changes to the baseline since project start date and summary of changes at the project since the offset project start date or baseline period.
For Facilities: Description of compliance or baseline report, facility/project boundary, facility identification information, GHG historical performance, summary of changes since the baseline or since the last compliance report.
Summary of Offset Project Baseline
This Instrument Air Conversion Project reduces greenhouse gas emissions from a natural gas compression facility through the installation of instrument air compressors and related infrastructure to retrofit the existing natural gas-driven pneumatic instrumentation system for process control. The use of compressed air to operate the pneumatic system eliminates the venting of natural gas (primarily methane) that occurred in the baseline scenario from the use of pressurized natural gas to operate the pneumatic instrumentation system.
Summary of Changes
The Responsible Party’s Offset Project Report (OPR) indicates that there have been no changes to the project boundaries and no equipment changes during the reporting period.
A change of ownership occurred prior to the reporting period. The Instrument Air Conversion at Strathmore Phase 1 is now 100% owned and operated by Ember Resources.
Operational changes at the Strathmore Phase 1 facility have significantly reduced the consumption of instrument air since April 2016, and therefore the GHG emission reductions generated from the Project have decreased.
A change in gas composition occurred at the Strathmore Phase 1 facility during the reporting period. In August 2017, the Facility began received a richer gas supply from a third party. The gas composition used in the quantification was therefore updated to reflect the new gas analysis from August 1, 2017 forward.
Through the course of the verification, the changes described above were confirmed. No additional changes to the project boundary, emission sources, measurement and monitoring or quantification methodologies were found.
2.1 Objective Describe the objective of the verification (should include expressing an opinion).
The objective of the verification is as follows:
• to issue a verification statement on whether the GHG assertion is without material discrepancy;
• to issue a verification report that provides details of the verification activities; and • to complete the “confirmations” activities defined in the Alberta Climate Change Office
Standard for Validation, Verification and Audit, Section 5.1.3.
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2.2 Scope Define the scope in terms of: geographical, organizational, activities and processes, sources, sinks, categories and greenhouse gases included (considering the completeness of the inventory), GHG assertion time period.
For offset verifications: include the serial range (i.e. XXXX-XXXX-XXX-XXX-XXX-XXX to XXXX-XXXX-XXX-XXX-XXX-XXX) if assigned (i.e. in the case of government verification a serial range will be available, otherwise not applicable).
For Facilities: ensure all specified gases and source categories are evaluated. Include list of negligible emission sources and justification for Emission Performance Credits (EPCs). Include listing of end products.
Project Name: Ember Resources Instrument Air Conversion at
Strathmore Phase 1
Serial Range: To be assigned at registration.
Geographic Boundary: The Strathmore Phase 1 compressor station is located at 09-27-024-25 W4M. The instrument air conversion project is entirely located within the compressor station lease site.
Physical Operations: Natural gas processing and compression Pneumatic devices and controllers
Emission Sources: Instrument Air Conversion
§ B7: Vented Fuel Gas § B10: Fuel Extraction and Processing § P6: Air Compression
IPCC GHGs Emitted/Removed: Carbon Dioxide (CO2)
Methane (CH4)
Nitrous Oxide (N2O);
remaining IPCC GHGs were not emitted in the baseline or project condition.
Reporting Period: August 1, 2016 – December 31, 2017
2.3 Level of Assurance The verification was conducted to a reasonable level of assurance.
Choose type of verification from the dropdown box above.
Provide explanation on level of assurance.
The Standard for Validation, Verification and Audit, Version 2.0, June 2018 requires that verifications must be designed and completed to a reasonable level of assurance.
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2.4 Criteria Outline the program criteria used and relevant supporting documentation (acts, regulations, protocols, standards, guidance documents, project documentation etc).
The program criteria used and relevant supporting documentation is as follows:
• Climate Change and Emissions Management Act • Carbon Competitiveness Incentive Regulation (255/2017) • Standard for Greenhouse Gas Emission Offset Project Developers, Version 2.0, July 2018 • Standard for Validation, Verification and Audit, Version 2.0, June 2018 • Quantification Protocol for Instrument Gas to Instrument Air Conversion in Process
Control Systems, Version 1.0, October 2009
2.5 Materiality Define the materiality of the verification.
The materiality threshold is defined in the Standard for Validation, Verification and Audit, Version 2.0, June 2018. For this verification, the materiality threshold is 5%.
3.0 Methodology Statement that the verification is performed according to ISO 14064-3.
Summary of the assessments/tests/reviews/evaluations that were conducted during the verification.
This verification was designed and completed according to the requirements of the ISO 14064-3 Standard.
The following verification activities (assessments/tests/reviews/evaluations) were conducted through the course of this verification. The specific verification activities that were conducted are detailed in the Verification Plan, which is appended to this report. They are also listed with the verification findings throughout section 4 of this report.
• Observations: the site visit included a tour of the project site to observe emission sources, metering, and data systems used for recording metered quantities;
• Review of documentation: documentation supporting the activity data was reviewed, including review of any manual transcription that was applied between documents and the emission quantification software, meter calibration reports were reviewed for completeness and to identify any metering issues;
• Recalculation: the emissions reduction was recalculated using metered data and original data sources and by applying the quantification methodologies stated in the Responsible Party’s Offset Project Report; the methods for calculating any averages used in the emission quantification were recalculated and evaluated for accuracy and appropriateness;
• Inquiry: the site visit included an interview of operations and instrumentation personnel; • Analytical procedures: a year-over-year comparison of overall emissions offsets was
performed.
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3.1 Procedures Description of how the verification was conducted including: description of the nature, scale and complexity of the verification activity, confidence and completeness of the responsible party’s GHG information and assertion, assessment of GHG information system and its controls, assessment of GHG data and information, assessment of GHG information system and controls, assessment against criteria, evaluation of the GHG assertion.
The verification strategy applied a largely substantive approach. The verification procedures, which are detailed later in this section, were designed to test the activity data directly, wherever practical. By applying this approach, the verification did not rely heavily on the Responsible Party’s controls, but rather relied on the substantive evidence collected from verification procedures that reviewed metered data, data directly from invoices and independent laboratory reports, for example.
Regarding the scale and complexity of the verification procedures, the verification risk assessment was leveraged to design verification activities appropriate to address the inherent, controls and detection risk evaluated in relation to each activity data and boundary condition. In most cases, these verifications involved review of documentation, recalculation or analytical procedures designed to produce verification evidence to support the accuracy, completeness and consistency of the information. All activity data and boundary conditions were evaluated through the verification risk assessment and verification activities were designed and completed commensurate with the verification risk assessed.
In a similar way, the data integrity, quantification methodologies and quantification itself were assessed through the verification risk assessment. Verification procedures were designed and completed to address each of these key areas.
Verification evidence was developed from each of these verification activities, which was used to establish a verification conclusion regarding the GHG information systems, the Responsible Party’s controls and ultimately, the GHG Assertion.
Describe steps of the verification including planning, assessment, site visit, off-site verification, and report preparation.
The verification was conducted according to the ISO 14064-3 standard, which establishes four primary phases of a greenhouse gas verification as described in this section. The relevant sections from the ISO standard are noted below.
Agreement (ISO Section 4.3)
The verification level of assurance, objectives, criteria, scope and materiality was affirmed in the contract for services and re-affirmed during a verification kickoff meeting.
A conflict of interest review was conducted prior to beginning work and monitored throughout the verification. A conflict of interest statement is appended to this report.
Internally, Brightspot Climate began documenting the verification upon contract signing. All documentation related to the verification will be maintained for a period of seven years following the date of the verification statement.
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Approach (ISO Section 4.4)
Brightspot Climate conducted an initial review of the Project’s greenhouse gas information, primarily by reviewing the reports and the Offset Project Plan. Brightspot Climate prepared a verification risk assessment based on this information, evaluating:
a) the inherent risks of discrepancies for each variable used to calculate each emission source and the general greenhouse gas reporting system;
b) the risk that the Responsible Party’s controls are insufficient to detect and prevent each inherent risk from causing a discrepancy in the GHG assertion; and
c) the potential magnitude of each inherent and control risk described above resulting from the contribution of the associated emission source.
This information was used to develop an appropriate verification procedure for each identified risk. Each procedure was designed to reduce the probability that the verification would not detect a discrepancy that has not been corrected by the Responsible Party’s controls. The tolerable error for each emission source is stated in the verification risk assessment.
Generally, a substantive approach was applied to the verification. Therefore, the verification procedures relied more heavily on data analysis than on controls testing.
Verification Plan
Brightspot Climate developed a Verification Plan that documents the level of assurance, verification objective, verification criteria, verification scope, and materiality. Additionally, the Verification Plan provides general description of the Project, documents operational and organizational changes that have occurred since the previous verification, explains the Project’s control environment, and describes the safety requirements of the site visit.
The results of the verification risk assessment and the verification procedures (including the sampling plan) has been included in the Verification Plan, but will not be disclosed to the Responsible Party until the final Verification Statement is issued.
Assessment (ISO Sections 4.5 – 4.7)
The verification procedures consist primarily of tests, analysis and review focused on the following six critical areas:
a) The completeness and relevance of emission sources included in the GHG Assertion;
b) The consistency of the emission sources and quantification methodologies between the Protocol, the Offset Project Plan, Offset Project Report and the tools used to quantify the emission reduction;
c) The accuracy and level of transparency of measured and estimated data sources, data integrity of electronic and manual data transfers and transcription between data systems and the GHG calculation;
d) The accuracy of the GHG emissions reduction calculations;
e) The completeness, accuracy and transparency of information presented in the Offset Project Plan and Offset Project Report documents, including the implementation of stated methodologies and emission factors in the quantification of emissions reductions; and
f) The accuracy of transcription of final calculated values into the GHG Assertion, including the “confirmations” required by ACCO as described in the ACCO Standard for Validation, Verification and Audit document.
The principles defined in the preceding six areas are defined in ISO 14064-1 (accuracy, completeness, consistency, relevance and transparency).
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Site Visit
A site visit was conducted on December 5, 2017 by Jeanna Brown of Brightspot Climate. The site visit included observation of the emission sources, metering and data systems used for recording metered quantities. The following Responsible Party staff were interviewed regarding various aspects of the project:
• Jamie Callendar, Consultant • Jim Weleschuck, Instrument Technician, Ember Resources
Further details of the verification activities that were conducted on site, including observations and inquiries, are provided in Section 4 of this report.
Verification Procedures
The remainder of the verification procedures was conducted through a desk review following receipt of the draft GHG Assertion.
Through the course of the assessment phase of the verification, Brightspot Climate issued questions and requests for additional documentation and data. These requests were consolidated in a simple electronic tracking document to maintain a common record of communication.
The Responsible Party had the opportunity to address any issues that were raised through the course of the verification before they were documented as discrepancies in the Verification Report.
Evaluation and Statement (ISO Sections 4.8 – 4.9)
Following the completion of all verification procedures and consideration of all information received from the Responsible Party, the verifier was tasked with concluding whether the GHG assertion is without material discrepancy and whether the verification reviewed sufficient and appropriate evidence to support a reasonable level of assurance.
If any outstanding discrepancies remained, their materiality would have been calculated according to ACCO guidance such that both the aggregate net quantitative error and the absolute quantitative error could be reported. In such circumstances, qualitative discrepancies would be evaluated based on the potential impact on the GHG assertion and the potential impact on the Intended User’s ability to use the reported information.
Peer Review
The independent Peer Reviewer conducted a complete review of the verification. The peer review process examined:
a) The completeness of the verification risk assessment; b) The appropriateness of the verification procedures considering the inherent and control
risks identified in the verification risk assessment; c) The appropriateness of any sampling conducted in each of the verification procedures; d) The completeness of each verification procedure, including the verifiers documentation
of work completed; e) Closure of any issues raised by the verifier through the course of the verification; f) The sufficiency and appropriateness of all evidence reviewed through the verification to
support a reasonable level of assurance; and g) A review of the final Verification Statement and Conflict of Interest Statement.
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Verification Report
The Verification Report includes a Verification Statement, Statement of Qualifications, Conflict of Interest Statement and a report on the findings of the verification. The final Verification and Sampling Plan has been appended to the Verification Report, including the results of the verification risk assessment.
Describe how the risk based approach was implemented in the sampling plan. Identify categories of risk including inherent risk, and detection risk (organization and verifier). Include the Verification Plan with the Sampling Plan in Appendix A. Paste the risk assessment table in this section.
Verification risk is defined as the risk of an incorrect verification conclusion. It can be calculated as the product of
• The Project’s inherent risks; • The Responsible Party’s control risks; and • The detection risks associated with the verifier’s verification procedures.
Inherent Risk × Control Risk × Detection Risk = Verification Risk
The verifier cannot affect the inherent risk or the control risk. Therefore, to reduce the overall verification risk and reach the agreed level of assurance (defined in the verification scope), the verifier must design verification procedures that reduce the detection risk.
Each inherent and control risk was provided with the risk score (high/medium/low). The risk analysis of inherent and control risks considers both the magnitude of the activity data or inventory component on the overall GHG assertion as well as the probability that the risk will result in a discrepancy, as assessed by the verifier.
Important note: The verification strategy for this verification is to use substantive tests instead of control tests wherever possible. Substantive tests are designed to focus on directly testing activity data or inventory components and their associated inherent risks. Control tests are designed to focus on testing the Responsible Party’s controls and if the test is successful, relying on the Responsible Party’s control. Therefore, control tests indirectly test activity data or inventory components.
Each verification procedure listed in the following table denotes if the procedure is a substantive or control test.
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Table 1: Risk Assessment
Activity Data/ Inventory Component
Inherent Risk Control Risk Max Detection Risk
Designed Detection Risk
Description of Verification Procedure
Verification Risk
Protocol Applicability Requirements
Functional equivalence must be demonstrated
Relevance (high)
Level of service may have changed between the baseline and project conditions.
The Responsible Party does not have a control specifically designed to address this inherent risk.
Low Low Substantive test: Observe operations and interview operations staff during site visit to determine level of service provided by project implementation.
Low
Project must be a conversion (not a greenfield or end-of-life replacement)
Relevance (high)
Project may have been implemented at greenfield sites or as end-of-life replacement.
The Responsible Party does not have a control specifically designed to address this inherent risk.
Low Low Substantive test: Observe operations during site visit to determine if project was implemented as a retrofit and not as an end-of-life replacement.
Low
An inventory of devices must be maintained
Completeness (medium)
The inventory of devices may be incomplete.
The Responsible Party does not have a control specifically designed to address this inherent risk.
Medium Medium Substantive test: Observe devices during site visit and compare against project inventory to evaluate completeness.
Medium
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Activity Data/ Inventory Component
Inherent Risk Control Risk Max Detection Risk
Designed Detection Risk
Description of Verification Procedure
Verification Risk
Demonstrate compliance with Section 8.7 of Directive 60 related to fugitive emissions management prior to project implementation
Completeness (medium)
A leak detection and repair program may not have been implemented at all project sites.
Control: The project developer has implemented a management system for leak detection and repair.
Control Risk: This system may not have been implemented or maintained at all project sites (low).
Medium Medium Control test: Review the project developer’s management system for leak detection and repair to determine if system is complete for all sites and has been maintained through the reporting period.
Low
Protocol may be applied to chemical injection pumps.
N/A N/A N/A N/A Not applicable for this project.
N/A
The project must meet the requirements of the Alberta Offset System
Relevance (high)
The project may not have met the requirements of the Alberta Offset System.
The Responsible Party does not have a control specifically designed to address this inherent risk.
Low Low Substantive test: Evaluate the project developer’s evidence regarding the general requirements of the Alberta Offset System.
Low
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Activity Data/ Inventory Component
Inherent Risk Control Risk Max Detection Risk
Designed Detection Risk
Description of Verification Procedure
Verification Risk
Project developer must establish the ownership of the emission reduction for each site within the aggregated project
Completeness (high)
Ownership may not be established with documentation for all sites within the aggregated project.
The Responsible Party does not have a control specifically designed to address this inherent risk.
Low Low Substantive test: Review ownership documents for each project site within the aggregated project.
Low
Protocol Flexibility
Site specific emission factors may be applied
N/A N/A N/A N/A Not applicable for this project.
N/A
Baseline and project metering may be extended beyond one year.
Accuracy (medium)
Project metering is continuous through the reporting period. Undetected leaks may overstate the emission reduction.
Control: Project developer has implemented a leak detection and repair program at the project sites, as required by the Protocol.
Control Risk: This system may not have been implemented or maintained at all project sites (low).
Medium Low See verification procedure regarding leak detection and repair in the “Protocol Applicability Requirements” section, above.
Low
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Activity Data/ Inventory Component
Inherent Risk Control Risk Max Detection Risk
Designed Detection Risk
Description of Verification Procedure
Verification Risk
Use of instrument counts and vent rates may be used to estimate baseline emissions.
N/A N/A N/A N/A Not applicable for this project.
N/A
Flaring may be used to destroy captured vent gas
N/A N/A N/A N/A Not applicable for this project.
N/A
Implementation of instrument air conversion at multiple facilities.
Completeness (medium)
The project aggregates installations at multiple project sites. The data and documentation may not be complete for all sites.
The Responsible Party does not have a control specifically designed to address this inherent risk.
Medium Low Substantive test: Evaluate the completeness of the required data and documentation for all project sites included in the aggregated project.
Low
Quantification Data
Air compressor equipment nameplate capacity
Accuracy (low)
The recorded air compressor nameplate capacity may be inaccurate.
The Responsible Party does not have a control specifically designed to address this inherent risk.
High Medium Substantive test: Observe the nameplate information for the air compressors during the site visit and review supporting documentation.
Low
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Activity Data/ Inventory Component
Inherent Risk Control Risk Max Detection Risk
Designed Detection Risk
Description of Verification Procedure
Verification Risk
Metered compressed air volume
Accuracy (high)
The metered compressed air volume may be incorrect if meters are not properly maintained.
Control: The Responsible Party has implemented a meter maintenance program that includes periodic meter calibration.
Control Risk: The maintenance program may not be operating effectively (low).
Low Low Controls test: Review meter calibration reports to determine if the meter maintenance program is operating effectively.
Low
Methane concentration in gas
Accuracy (low)
Reported gas compositions may not accurately represent the gas composition or may be incorrectly transcribed into the emission reduction calculation.
Control: Gas analysis is conducted by an independent lab. An internal process is used to validate results.
Control Risk: Validation process may not be properly implemented or transcription errors may be introduced (low).
High Low Substantive test: Analyze gas compositions for significant fluctuations or abnormal gas concentrations. Confirm the accurate transcription of the gas analysis into the emission reduction calculation.
Low
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Activity Data/ Inventory Component
Inherent Risk Control Risk Max Detection Risk
Designed Detection Risk
Description of Verification Procedure
Verification Risk
Completeness (low)
The gas compositions may not include a valid gas composition for each period at the required frequency.
The Responsible Party does not have a control specifically designed to address this inherent risk.
High Medium Substantive test: Review completeness of gas composition data.
Low
Reference density of methane at STP conditions
Accuracy (low)
The density of methane applied in the calculation may not represent the density at STP conditions.
The Responsible Party does not have a control specifically designed to address this inherent risk.
High Low Substantive test: Compare the density of methane applied in the calculations to the reference value provided in the relevant reference documents.
Low
Alberta electricity grid factor
Accuracy (low)
The Alberta electricity grid factor applied in the calculation may be incorrect.
The Responsible Party does not have a control specifically designed to address this inherent risk.
High Low Substantive test: Compare the Alberta electricity grid factor applied in the calculations to the reference value provided in the relevant reference documents.
Low
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Activity Data/ Inventory Component
Inherent Risk Control Risk Max Detection Risk
Designed Detection Risk
Description of Verification Procedure
Verification Risk
Emission Quantification and Reporting
Application of the approved quantification protocol
Accuracy (high)
The project developer may not have implemented approved quantification methodologies or applied additional methodologies.
Control: Responsible Party has developed an Offset Project Plan that is intended to conform to the requirements of the approved quantification protocol.
Control Risk: The protocol requirements may not have been implemented correctly (medium).
Medium Low Controls test: Compare the methodologies described in the Responsible Party’s Offset Project Plan to the methodologies described in the approved quantification protocol.
Low
Substantive test: Recalculate the emission reduction using original metered data and methods described in the approved quantification protocol.
Low
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Activity Data/ Inventory Component
Inherent Risk Control Risk Max Detection Risk
Designed Detection Risk
Description of Verification Procedure
Verification Risk
Quantification of emission reduction
Accuracy (high)
Emission reduction calculation may contain arithmetic errors.
The Responsible Party does not have a control specifically designed to address this inherent risk.
Low Low Substantive test: Recalculate the emission reduction using original metered data.
Low
Data Integrity
Activity data and emission factor data integrity
Accuracy (high)
Data may not have been accurately transferred between electronic systems and calculation sheets.
Control: The Responsible Party uses electronic data transfers whenever possible to maintain data integrity.
Control Risk: Electronic data transfers may result in errors or may not be available for all data (medium).
Low Low Controls test: Analyze all metered data for abnormal data (zeros, missing data, values outside range).
Low
Substantive test: Recalculate the complete emission reduction using original data.
Low
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Activity Data/ Inventory Component
Inherent Risk Control Risk Max Detection Risk
Designed Detection Risk
Description of Verification Procedure
Verification Risk
Transcription of final emission reduction into Offset Project Report
Accuracy (high)
Final emission reduction may not have been transcribed accurately from calculation spreadsheets into the Offset Project Report.
The Responsible Party does not have a control specifically designed to address this inherent risk.
Low Low Substantive test: Compare the final emission reduction quantity reported by the Responsible Party to the quantity reported in the Offset Project Report. Also, compare these quantities to the recalculated quantity in previous verification procedures.
Low
3.2 Team List verification team members including peer reviewer(s).
Describe the qualifications and training of the team members and peer reviewer(s) including dates of training and certifications.
For Offsets: fill in the sample Statement of Qualification provided and included in Appendix B.
For Facilities: include the Statement of Qualifications from the facility compliance form in Appendix B.
ISO 14064-3 defines sixteen subject matter areas in which the verifier should demonstrate familiarity (see ISO 14064-3, Section A.2.2.3). The verification team has competencies in each of these sixteen subject matter areas.
Lead Verifier: Aaron Schroeder, P.Eng.
Aaron Schroeder will be the Lead Validator and Designated Signing Authority. His extensive experience quantifying and verifying greenhouse gas emissions satisfies all sixteen subject matter areas defined in the standard.
Biography: Aaron Schroeder has eleven years of professional experience analyzing, quantifying and verifying greenhouse gas emissions in North America. Prior to forming Brightspot Climate Inc. in 2015, Aaron worked for several years leading a team of fifteen greenhouse gas verification and policy analysts across Canada with ICF International. He provided leadership for this team and led the development of ICF’s standardized verification
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process, conformant with ISO 14064-3. In 2012, ICF’s verification process was accredited by the American National Standards Institute (ANSI).
Mr. Schroeder’s hands on experience conducting greenhouse gas verifications includes numerous engagements for oil and gas extraction and processing, refining, pipeline, electricity generation and petrochemical facilities. Additionally, he has conducted verifications of emission reduction projects in industrial facilities, renewable energy, waste management and agriculture. He is sought after for his expertise devising strategies to bridge the gap between theoretical and practical implementation of methodologies for quantifying, reporting and verifying.
In 2014, the University of Toronto engaged Mr. Schroeder to instruct professional development courses on greenhouse gas inventory and project quantification, reporting and verification. Since 2014, Mr. Schroeder has instructed several of these courses in live, two-day sessions and on-line instruction as a sessional lecturer through the university’s School of Environment. Additionally, Mr. Schroeder has worked with the School of Environment to re-write and update the courses.
Training: Greenhouse Gas Verification – ISO 14064-3, Canadian Standards Association, 2012; Instructor – Greenhouse Gas Verification – ISO 14064-3, University of Toronto, 2015 - 2017
Associate Verifier: Jeanna Brown, P.Eng.
Biography: Jeanna Brown is a Professional Engineer with thirteen years of experience in the oil and gas industry. During her previous employment, she focused on drilling engineering and well planning for wells of varying complexity. She has experience with field based drilling engineering/operations, wellsite supervision and exploration projects. More recently, Jeanna’s technical focus concentrated on in-situ oil sands projects and thermal/steam well design. Since joining Brightspot, Jeanna has gained experience working on greenhouse gas verifications for a variety of projects related to oil and gas production and processing, pulp and paper, agriculture and electricity generation. This has included both emission reduction (offset) projects and annual industrial facility reports under the Alberta Specified Gas Emitters Regulation (SGER). Jeanna’s other work in greenhouse gas quantification includes scenario modelling for regulatory compliance, quantification of corporate inventories and consulting on offset project development.
Training: Jeanna received GHG Validation and Verification, ISO 14064-3, training through the University of Toronto in September 2017.
Peer Reviewer: Chris Caners, P.Eng.
Biography: Chris Caners has more than a decade of practice in the energy and environment industry. He has extensive knowledge of energy efficiency, greenhouse gas quantification, assessment and verification; energy and emissions modeling and policy analysis. He has experience leading conservation potential assessments, energy audits, and conservation program planning and design efforts. He recently directed an assessment of energy efficiency potential for a unique electrical distribution system in Canada; he also led a detailed natural gas conservation potential study in Ontario.
Chris has audited dozens of facilities and facility level emission reports (conventional and unconventional oil and gas extraction, processing and transmission, cogeneration, power generation and mining) and energy efficiency and emission reductions projects across Canada, including anaerobic wastewater treatment, commercial building efficiency, acid gas injection, enhanced oil recovery, wind energy, aerobic composting and landfill gas.
Training: Greenhouse Gas Verification – ISO 14064-3, Canadian Standards Association
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3.3 Schedule Provide a list or table of verification activities and dates. Indicate when the verification was completed.
Verification Kickoff Meeting November 28, 2017
Draft Verification Plan December 4, 2017
Site Visit December 4-5, 2017
Supplementary Information Request July 16, 2018
Draft Verification Report July 17, 2018
Final Verification Report August 22, 2018
4.0 Results Add introduction to results section here, if desired.
The verification results are presented in the following five subsections. Subsections 4.1 – 4.3 present the results of the verification procedures for the data integrity (4.1), Quantification Methodologies and Quantification (4.2), and Boundary Conditions and Activity Data (4.3).
4.1 Assessment of Internal Data Management and Controls Provide a summary the information system(s) and its controls for sources of potential errors. Include information on the selection and management of data, process for collecting and consolidating data, data accuracy systems, design and maintenance of the GHG system, the systems and processes that support the GHG information system and results from previous assessments if applicable.
The Project’s GHG quantification is primarily performed in an Excel spreadsheet: “IA Projects Master Calculator_2016-2017_Final For Verifier_June 13, 2018.xlsx”. All data required to quantify emissions reductions for the Project is either manually transcribed into these spreadsheets or electronically transferred from other spreadsheets. The final calculated quantities from this spreadsheet are transferred into the Offset Project Report. Data validation is completed before information is transferred; therefore, there are no active data controls in this document.
All activity data are either metered or referenced from third party data. Meters are maintained on a preventative maintenance program, including periodic calibration. Calibration records are filed on-site.
The Responsible Party maintains an Offset Project Plan (OPP) and produces an Offset Project Report (OPR), which document the emission sources, processes for collecting GHG activity data, equations applied to quantify emissions reduction, calculation assumptions, meter calibration procedure and schedule, the averaging method applied to quantification, and a discussion of GHG data management.
Findings from Previous Verification
There were no unresolved discrepancies identified in the previous verification.
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Results of Verification Procedures
There were three verification procedures completed to test data integrity. The results of these procedures are provided in the following table.
Table 2: Findings of Data Integrity Verification Procedures
GHG Report Element
Verification Procedures Verification Findings
Activity data and emission factor data integrity
Controls test: Analyze all metered data for abnormal data (zeros, missing data, values outside range).
Metered data was reviewed and evaluated for anomalies such as zeros, missing data points, values outside range, etc.
No discrepancies were detected in the activity data.
Substantive test: Recalculate the complete emission reduction using original data.
The recalculated emission reduction matched the quantity asserted by the Responsible Party. It is therefore a reasonable conclusion that data integrity has been maintained from points of metering through reporting.
No discrepancies were detected in the accuracy of the emission reduction quantification.
Transcription of final emission reduction into Offset Project Report
Substantive test: Compare the final emission reduction quantity reported by the Responsible Party to the quantity reported in the Offset Project Report. Also, compare these quantities to the recalculated quantity in previous verification procedures.
Values reported in the Offset Project Report matches the values quantified by the Responsible Party.
No discrepancies were detected in the transcription of values in the Offset Project Report.
4.2 Assessment of GHG Data and Information Provide a summary of the information found during the verification of the GHG data and a summary of the GHG Assertion that was assessed.
For Facilities: Confirm that the quantification methodologies that were used in the compliance report are the same as those reported in the BEIA.
For Offset Projects: Confirm that the quantification methodologies that were used by the project proponent are the same as those described in the project plan. Indicate which quantification methodologies were used by the project proponent.
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The GHG information consists of the activity data applied to quantify emissions reductions, the source documentation for the activity data, the information in the Offset Project Plan, as described in the previous section of this report, and the documentation supporting the boundary, methodologies, meter calibration, and emission factors.
Table 3: Findings of GHG Data and Information Verification Procedures
GHG Report Element
Verification Procedures
Verification Findings
Quantification Data
Air compressor equipment nameplate capacity
Substantive test: Observe the nameplate information for the air compressors during the site visit.
The air compressor nameplate specifications were noted during the site visit. The nameplate specifications were found to match the capacities used in the quantification.
No discrepancies were detected in the air compressor nameplate capacities used in the quantification.
Metered compressed air volume
Controls test: Review meter calibration reports to determine if the meter maintenance program is operating effectively.
The meter calibration reports were reviewed and were found to be complete.
No discrepancies were detected in the meter calibration reports.
Methane concentration in gas
Substantive test: Analyze gas compositions for significant fluctuations or abnormal gas concentrations. Confirm the accurate transcription of the gas analysis into the emission reduction calculation.
A change in gas composition occurred at the Strathmore Phase 1 facility during the reporting period. In August 2017, the Facility began received a richer gas supply from a third party which significantly changed the methane concentration in the gas stream, from 0.9759 (November 7, 2016 gas analysis) to 0.7981 (October 13, 2017 gas analysis). The gas composition used in the quantification was updated to reflect the new gas analysis from August 1, 2017 forward.
Transcription of the gas analysis to the emission reduction calculation was completed accurately.
No discrepancies were detected in the gas composition analyses used in the quantification.
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GHG Report Element
Verification Procedures
Verification Findings
Substantive test: Review completeness of gas composition data.
Gas composition data was reviewed and found to be complete.
No discrepancies were detected in the completeness of gas composition data.
Reference density of methane at STP conditions
Substantive test: Compare the density of methane applied in the calculations to the reference value provided in the relevant reference documents.
The Responsible Party used a value of 0.6797 kg/m3 for the density of methane at STP conditions (referenced from http://encyclopedia.airliquide.com)
No discrepancies were detected in the reference density of methane at STP conditions used in the quantification.
Alberta electricity grid factor
Substantive test: Compare the Alberta electricity grid factor applied in the calculations to the reference value provided in the relevant reference documents.
The Alberta electricity grid factor applied in the calculations was taken from the Carbon Offset Emission Factors Handbook and was confirmed to match the reference value.
No discrepancies were detected in the electricity grid factor used in the quantification.
Emission Quantification and Reporting
Application of the approved quantification protocol
Controls test: Compare the methodologies described in the Responsible Party’s Offset Project Plan to the methodologies described in the approved quantification protocol.
The verification team compared the methods described in the Offset Project Plan to the methods described in the approved Quantification Protocol.
The quantification methods described in the Responsible Party’s Offset Project Plan adhere to the methods described in the approved Quantification Protocol.
No discrepancies were detected in the methodologies described in the Offset Project Plan.
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GHG Report Element
Verification Procedures
Verification Findings
Substantive test: Recalculate the emission reduction using original metered data and methods described in the approved quantification protocol.
The independent recalculation of the emission reduction resulted in the same emission reduction quantity asserted by the Responsible Party. Therefore, the approved Protocol quantification methods were applied in the Responsible Party’s emission reduction quantification.
No discrepancies were detected in the application of the approved quantification protocol.
Quantification of emission reduction
Substantive test: Recalculate the emission reduction using original metered data.
The independent recalculation of the emission reduction resulted in the same emission reduction quantity asserted by the Responsible Party. Therefore, the Verification Team concluded that no arithmetic or calculation errors were made by the Responsible Party in the emission reduction quantification.
No discrepancies were detected in the recalculation of the emission reduction quantification.
4.3 Assessment against Criteria Provide a description of how eligibility criteria is met or not met.
For Offset Project: Complete Table 1 to indicate if the GHG Assertion conforms to the Regulation and Standard for Greenhouse Gas Emission Offset Project Developers eligibility criteria.
For Facilities: Delete Table 1 and Indicate if verification criteria are met or not met and explain.
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Table 4: Findings of Criteria Verification Procedures
GHG Report Element
Verification Procedures Verification Findings
Protocol Applicability Requirements
Functional equivalence must be demonstrated
Substantive test: Observe operations and interview operations staff during site visit to determine level of service provided by project implementation.
During the site visit, the verification team observed the instrument air system and found that an equivalent level of service is provided.
Site staff indicated that following the commissioning stage, the system has worked well. Ongoing maintenance is performed during regular maintenance of the full facility. They reported that the instrument air system requires less maintenance than the instrument gas system that was replaced as part of the project.
No discrepancies detected.
Project must be a conversion (not a greenfield or end-of-life replacement)
Substantive test: Observe operations during site visit to determine if project was implemented as a retrofit and not as an end-of-life replacement.
During the site visit, the verification team confirmed that the project was implemented as a retrofit and not as an end-of-life replacement.
No discrepancies detected.
An inventory of devices must be maintained
Substantive test: Observe devices during site visit and compare against project inventory to evaluate completeness.
The installed equipment was confirmed against the Responsible Party’s inventory during the site visit.
No discrepancies detected.
Demonstrate compliance with Section 8.7 of Directive 60 related to fugitive emissions management prior to project implementation
Control test: Review the project developer’s management system for leak detection and repair to determine if system is complete for all sites and has been maintained through the reporting period.
The Responsible Party maintains documentation of the ongoing leak detection and repair that is conducted for the instrument air site. Leaks are systematically identified and scheduled for repair.
The leak detection and repair report was reviewed; no leaks were detected.
No discrepancies detected.
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GHG Report Element
Verification Procedures Verification Findings
Protocol may be applied to chemical injection pumps.
Not applicable for this project.
Not applicable.
The project must meet the requirements of the Alberta Offset System
Substantive test: Evaluate the project developer’s evidence regarding the general requirements of the Alberta Offset System.
Occurs in Alberta – The project site is located within Alberta, as confirmed by the site visit and project documentation.
Actions not otherwise required by law – confirmed that the site is not defined as a “regulated facility” under the Specified Gas Emitters Regulation. No other regulatory requirements were found to apply to the project activity for this site.
Actions taken on or after January 1, 2002 – commissioning of the instrument air system occurred after this date, as confirmed by project documents and inquiries of site operations staff.
Real, demonstrable, quantifiable – the verification procedures confirmed that the emission reduction in the assertion meet these requirements. The specific verification procedures supporting this conclusion include observation during the site visit, review of supporting meter calibration reports and documentation, and the recalculation of the emission reduction.
No discrepancies detected.
Project developer must establish the ownership of the emission reduction for each site within the aggregated project
Substantive test: Review ownership documents for each project site within the aggregated project.
Ember Resources owns 100% of the Strathmore 09-27-024-25W5 facility and is the sole owner of the emission offsets from this project.
Ownership documentation was reviewed by the verification team.
No discrepancies detected.
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GHG Report Element
Verification Procedures Verification Findings
Protocol Flexibility
Site specific emission factors may be applied
Not applicable for this project.
Baseline and project metering may be extended beyond one year.
Not applicable for this project.
Use of instrument counts and vent rates may be used to estimate baseline emissions.
Not applicable for this project.
Flaring may be used to destroy captured vent gas
Not applicable for this project.
Implementation of instrument air conversion at multiple facilities.
Not applicable for this project.
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Table 5: Offset Criteria Assessment
Offset Eligibility Criteria
Assessment
Reduction or sequestration occurs in Alberta
The project site is located within Alberta, as confirmed by the site visit and project documentation.
Result from actions not required by Law at the time the action is taken
The project activity is not required by municipal, provincial or federal regulations or directives.
Result from Actions taken on or after January 1, 2002 and occur on or after January 1, 2002
Commissioning of the instrument air system occurred after this date, as confirmed by project documents and inquiries of site operations staff.
Reduction or sequestrations is real and demonstrable
The emission reduction was demonstrated through measurement and estimation of data required for the quantification. The GHG information presented to the verification team included sufficient and appropriate evidence to substantiate conformance with the Protocol Applicability Requirements and to substantiate the quantification data.
Quantifiable and measurable
The emission reduction was demonstrated through measurement and estimation of data required for the quantification. This data was substantiated by sufficient and appropriate evidence. Table 3 of this report presents the findings of the evaluation of each variable required for the emission reduction quantification.
Verified by a third party verifier that meets the requirements in Part 1 for the Standard for Validation, Verification and Audit.
Brightspot Climate Inc. is an independent third-party verifier that meets the requirements outlined in Section 1 of the Standard for Validation, Verification and Audit. The Lead Verifier and Designated Signing Authority, Aaron Schroeder, is a Professional Engineer and has extensive experience quantifying and verifying greenhouse gas emissions, satisfying all sixteen subject matter areas defined in the ISO 14064-3 Standard.
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4.4 Evaluation of the GHG Assertion The verification assessment is that the GHG Assertion meets the requirements of the Carbon Competitiveness Incentive Regulation
Provide an assessment of the evidence collected during the verification. Determine if the data and information available support the GHG assertion. Provide a conclusion on whether the assertion meets the materiality requirements and the level of assurance agreed to at the beginning of the verification process.
The results of each verification procedure are provided in the preceding three subsections (4.1 – 4.3). Sufficient and appropriate evidence was collected through the verification procedures to reach the verification conclusion at a reasonable level of assurance, which is provided in the Verification Statement.
The data and GHG information provided by the Responsible Party is sufficient to support the GHG assertion.
There were no material or immaterial discrepancies detected in the final GHG assertion.
4.5 Summary of Findings Provide a summary of material and immaterial discrepancies expressed in tonnes and as net and absolute error in Table 2. Include whether the discrepancy was an understatement or an overstatement.
Include a more detailed description and log of results in Appendix C the “Issues Log”. This log will include both resolved and unresolved issues from the verification. Unresolved issues should be brought forward to Table 2.
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Table 6: Summary of Findings
Number the finding with the year and provide a unique # for each finding. Note: A detailed description of all material and immaterial findings should be provided in Table 3 of Appendix C. Provide only a summary statement (1-4 sentences) for each unresolved immaterial finding and each material finding (resolved or unresolved). If the finding is a resolved material finding, then put the tonnes net and absolute in the summary description column and indicate n/a in the net and absolute columns. Do not include the tonnes in the total error calculation. Indicate the type of error (qualitative or quantitative). Indicate the Source Category (for facilities) or the Source/Sink (for offsets). Indicate if the finding is an understatement or overstatement. Provide both net and absolute error in tonnes of CO2 eq and as a % of the assertion. Provide the total net error and the total absolute error in tonnes of CO2 eq and as a % of the assertion.
Result Type Summary Description of Finding Source Category or Source/Sink
Understatement / Overstatement
Tonnes CO2e % net
Tonnes CO2e % absolute
There were no material or immaterial discrepancies detected in the final GHG assertion.
Total Error 0 0
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4.6 Opportunity for Improvement Provide feedback on the data management system and controls, transparency, completeness of the inventory, additions to the quantification methodology document or diagrams, etc. Include positive considerations and observations also.
Identify strengths and weaknesses that may help to improve the report/s for the current facility, sector, and compliance program. Identify ways in which the project/facility could be more easily verified.
Overall, the GHG information was orderly and thoroughly presented.
The quantification spreadsheets were satisfactorily organized and sufficiently transparent to conduct the verification procedures.
Sufficient and appropriate evidence was provided by the Responsible Party to conduct each of the verification procedures.
The Offset Project Plan and Offset Project Report thoroughly document the emission sources, quantification approach, equations, data collection and information controls.
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.
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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.
Section 5.1.3 of the Standard for Validation, Verification and Audit document lists seven activities that are beyond the scope of a typical greenhouse gas verification.
Table 7: Confirmation Findings
Confirmation Confirmation Finding
Correct entry of administrative fields such as facility codes and legal locations
The Offset Project Report was reviewed for completeness and accuracy. All facility and legal location information is complete and accurate.
Quantification Methodology document is provided and consists of the required components
The Responsible Party has documented all relevant methodologies, procedures and controls in the Offset Project Plan and the Offset Project Report.
Simplified process flow diagrams and energy diagrams
This requirement is not applicable to this Offset Project.
Fuel usage This requirement is not applicable to Offset Projects.
Additional request items/forms are complete and reasonable justification provided where needed
The Statutory Declaration was reviewed and found to be complete.
N/A is checked on pages in the reporting form that do not apply
This requirement is not applicable to Offset Projects.
Project report information details as required The Responsible Party has prepared an Offset Project Report that meets all the requirements specified in the Standard for Greenhouse Gas Emission Offset Project Developers, Version 2.0, July 2018.
6.0 References Author. Year. Title. (no hyperlinks)
None
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Appendix A: Final Verification Plan and Sampling Plan
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Information to be included in the Verification Plan and Sampling Plan:
Revisions to the sampling plan
Date originally sent to Facility/project
Level of assurance agreed with the facility/project developer
Verification scope
Verification criteria
Amount and type of evidence (qualitative and quantitative) necessary to achieve the agreed level of assurance
Methodologies for determining representative samples
Sampling Plan and Procedures
Risk Assessment: Risks of potential errors, omissions or misrepresentations that are identified throughout the verification process including:
- Details of site visit
-offset/facility boundaries
- Methodologies, emissions factors and conversions used
- Comparability with the approved baseline
- Conformance to the program criteria
- Integrity for the responsible party’s data management system and control (organization chart, GHGH management plan, personnel/consultant training, protocols used, control system documentation, software/program documentation/certifications)
- Greenhouse gas data and information, including the type of evidence collected, verification testing and crosschecking, inventory of emission sources
- Discussion of data management, (measurement, fuel sampling, calibration, consistent use of standard conditions, data storage, procedures to fill missing data; procedures to repair inconsistent data, adjustment of variables and factors)
- Other relevant information
+1 (604) 353-0264 • www.brightspot.co • [email protected]
Ember Resources Inc.
Instrument Air Conversion Aggregation Projects Verification Plan
December 4, 2017
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Terminology
ISO 14064-2 defines the following terms used in the context of a GHG verification:
GHG Assertion: a declaration or factual and objective statement made by the Responsible
Party.
The Alberta Climate Change Office Standard for Verification1 extends this definition to include
the document that identifies the greenhouse gas emission reduction and/or removals and offset
credits being claimed by the offset project over a defined period of time.
Project: activity or activities that alter the conditions identified in the baseline scenario which
cause greenhouse gas emission reductions or greenhouse gas removal enhancements.
The GHG Assertion subject of this verification is Ember Resources’ Instrument Air Conversion
Aggregation Projects, namely:
• Ember Resources Instrument Air Conversation at Strathmore Phase 1
• Ember Resources Instrument Air Conversion Aggregation Project
• Ember Resources Instrument Air Conversion Aggregation Project Phase 2
Collectively, these three emission reduction projects will be referred to throughout this proposal
as “The Projects”.
ISO 14064-2 defines the following parties associated with the verification:
Responsible Party: person or persons responsible for the provision of the greenhouse gas
assertion and supporting GHG information.
The Responsible Party for this verification is Ember Resources Inc. (Ember Resources).
Intended User: individual or organization identified by those reporting GHG-related information
as being the one who relies on that information to make decisions.
The Intended User for this verification is the Alberta Climate Change Office (ACCO).
Verifier: competent and independent person, or persons, with the responsibility of performing
and reporting on the verification process.
The Verifier for this verification is Brightspot Climate Inc. (Brightspot Climate). The members of
the verification team are provided in section 3 of this document.
1 Standard for Verification, Version 1.0, December 2017. Alberta Climate Change Office.
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Introduction
This document serves to communicate information between the parties associated with the
independent verification of the Offset Project Reports for the Instrument Air Conversion Aggregation
Projects.
This document contains six sections:
1. The Introduction, which defines the principles by which this verification will be conducted;
2. The Verification, which defines the verification parameters and the GHG inventory principles that
will be tested by the verification. This section also provides information regarding the verification
team and site visit;
3. The Responsible Party Data Management and Controls, which describes the data management
system and control environment implemented by the Responsible Party;
4. Previous GHG Assertions, which describes any modifications to the original project that have
been made since the original Offset Project Plan was developed and any findings from previous
verifications for this Project;
5. The Verification Risk Assessment and Verification Procedures, which describes the risks of
potential errors, omissions or misrepresentations to the overall GHG assertion and the
verification procedures that have been developed to reduce the overall verification risk; and
6. The Sampling Plan, which lists the verification procedures that could apply sampling of the
project data, along with the sampling size, the sampling methodology and justification.
The verification procedures, including the sampling plan and the results of the verification risk
assessment, will be appended to this verification plan in the final verification report.
The Responsible Party developed the Project in accordance with the requirements of the Quantification
Protocol for Instrument Gas to Instrument Air Conversion in Process Control Systems, Version 1.0,
October 2009 (the Protocol).
GHG Quantification Principles
ISO 14064-2 defines six principles that are fundamental to the fair accounting and reporting of GHG
information. The verification procedures will test that these principles have been upheld through the
Responsible Party’s inventory, accounting and reporting processes.
Section 3.2 – 3.6 of ISO 14064-1 defines these principles as follows:
Accuracy: reduce bias and uncertainty as far as practical
Completeness: include all relevant emission sources
Conservativeness: use conservative assumptions, values and procedures to ensure that GHG
emission reductions or removal enhancements are not over-estimated
Consistency: enable meaningful comparisons of reported emissions (from year to year or
between facilities or between companies)
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Relevance: select GHG sources, sinks and reservoirs, data and quantification methodologies
appropriate to the needs of the intended user
Transparency: disclose sufficient and appropriate GHG information to facilitate verification and
to allow intended users to make decisions with relative confidence
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Verification
Verification Principles
ISO 14064-3 defines four fundamental principles to conducting a greenhouse gas verification, namely
independence, ethical conduct, fair presentation and due professional care.
Brightspot Climate has implemented processes, including mandatory training for all verification team
members, to ensure the application of these principles for this verification.
Regarding the principle of independence, Brightspot Climate conducted an assessment of threats to
independence prior to initiating this verification. No real or perceived threats to independence were
identified. Brightspot Climate will continue to monitor for threats to independence throughout the
course of this verification. A final “Conflict of Interests Checklist” will be appended to the Verification
Statement.
Verification Parameters
The verification will be conducted according to the parameters defined in the following table:
Table 1: Verification Parameters
Level of Assurance Reasonable assurance
Objectives
• issue a verification statement on whether the GHG assertion is
without material discrepancy;
• issue a verification report that provides details of the verification
activities; and
• complete the “confirmations” activities defined in the Standard for
Verification2, Section 5.1.3.
Criteria
• Climate Change and Emissions Management Act
• Carbon Competiveness Incentive Regulation (255/2017)
• Standard for Greenhouse Gas Emission Offset Project Developers,
Version 1.0, December 2017
• Standard for Verification, Version 1.0, December 2017
• Quantification Protocol for Instrument Gas to Instrument Air
Conversion in Process Control Systems, Version 1.0, October,
2009
2 Standard for Verification, Version 1.0, December 2017, Alberta Climate Change Office.
Brightspot Climate Inc. – Verification Plan Ember Resources Inc. – Instrument Air Conversion Aggregation Projects
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Scope
Project Name: Ember Resources Instrument Air Conversion
Aggregation Project
Ember Resources Instrument Air Conversion
Project Phase 2
Ember Resource Instrument Air Conversion at
Strathmore Phase 1
Geographic Boundary: Natural gas processing and compression
facilities in Ember Resources’ natural gas
network in Central Alberta
Physical Operations: Natural gas processing and compression
Pneumatic devices
Emission Sources: Instrument Air Conversion
• B7: Vented Fuel Gas
• B10: Fuel Extraction and Processing
• P6: Air Compression
IPCC GHGs Emitted: Carbon Dioxide (CO2)
Methane (CH4)
Nitrous Oxide (N2O)
Reporting Period: August 1, 2016 – December 31, 2017
Materiality Quantitative materiality threshold is 5% of asserted greenhouse gas
emission reduction
Preliminary Verification
Schedule
Verification Kickoff Meeting November 28, 2017
Draft Verification Plan December 4, 2017
Site Visit December 4-5, 2017
Draft Verification Report June 15, 2018
Final Verification Report June 30, 2018
Verification Team
Aaron Schroeder, P.Eng., will be the Lead Verifier and Designated Signing Authority for this verification.
His extensive experience quantifying and verifying greenhouse gas emissions satisfies all sixteen subject
matter areas defined in the ISO 14064-3.
Jeanna Brown, P.Eng., will conduct the site visits, complete the verification procedures and prepare the
Verification Report under the supervision of the Lead Verifier.
Chris Caners, P.Eng., will conduct an independent peer review of the verification.
Additional information regarding the qualifications of the verification team will be provided in a
Statement of Qualifications, which will be appended to the Statement of Verification.
Brightspot Climate Inc. – Verification Plan Ember Resources Inc. – Instrument Air Conversion Aggregation Projects
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Site Safety Requirements
Personnel conducting site visits are required to wear personal protective equipment including steel-toed
boots, fire retardant coveralls, hard hat, safety glasses with side shields and gloves. A site orientation
must be completed before entering the site.
Brightspot Climate Inc. – Verification Plan Ember Resources Inc. – Instrument Air Conversion Aggregation Projects
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Responsible Party Data Management and Controls
Data Management Systems
Jamie Callendar, as consultant to the Responsible Party, has the primary responsibility for collecting
GHG information, quantifying the emission reduction and completing required documentation.
The Responsible Party uses an Excel based Emission Reduction Calculator to manage GHG
information and quantify the emission reduction. Table 2, below, describes the data measurement,
estimation and data storage locations for all GHG information used by the Responsible Party to
produce the GHG inventory. The final column in this table describes the data storage location and the
path (intermediate data transfer) prior to use in the GHG inventory.
Table 2: GHG Inventory Data Management
Activity Data Description Measurement Type Data Storage Location / Path
Air compressor nameplate
capacity
Manual reading Calculation spreadsheet
Metered compressed air
volume
Direct metering Metered quantity
>> SCADA system
>> PI system
>> Calculation spreadsheet
Methane concentration in
gas
Third-party analysis Laboratory analysis
>> Calculation spreadsheet
Reference density of
methane at STP conditions
Third-party reference Third party reference value
>> Calculation spreadsheet
Alberta electricity grid
factor
Alberta Environment
and Parks Emission
Factor Handbook
Emission Factor Handbook value
>> Calculation spreadsheet
Control Environment
The Responsible Party’s Offset Project Plan (OPP) describes the processes, procedures and systems
that have been designed and implemented within their quality assurance / quality control framework.
The accuracy and completeness of the documentation of the Responsible Party’s controls will be
reviewed through the course of the verification.
The following processes, procedures and systems have been employed by the Responsible Party:
• Quantification is based on direct metering and measurement.
• The project developer has implemented a management system for leak detection and repair.
• The Responsible Party has implemented a meter maintenance program that includes periodic
meter calibration.
• Gas composition analysis is performed by an independent, third-party laboratory.
Brightspot Climate Inc. – Verification Plan Ember Resources Inc. – Instrument Air Conversion Aggregation Projects
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• Data is transferred electronically between systems where possible to reduce transcription
errors.
• The Responsible Party has implemented a record retention system that meets the requirements
of the Regulation.
• The Offset Project Plan (OPP) is reviewed annually for accuracy, completeness, consistency,
relevance and transparency. The OPP documents:
o Project boundaries
o Project processes
o Emission sources
o Changes made to the project boundaries, operations or emission sources
o Activity data used to quantify emissions
o Emission quantification equations and other methods for deriving values required for the
quantification of the emission reduction
o Emission factors and references
o Meter maintenance processes
o Data management
o Data quality controls and procedures
Brightspot Climate Inc. – Verification Plan Ember Resources Inc. – Instrument Air Conversion Aggregation Projects
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Previous GHG Assertions
Changes to Operations and Boundaries
This is the second year that Brightspot Climate has provided verification services for the Projects.
A number of changes have been made since the original Offset Project Plans were produced:
• Baseline emissions associated with fossil fuel extraction and processing (SSR B10) were
originally excluded but have been included in the emission reduction quantification since
January 16, 2015 in accordance with the Protocol.
• Project emissions associated with electricity usage to operate the instrument air compressors
(SSR P6) were originally excluded but have been included in the emission reduction
quantification since June 11, 2013 to meet new requirements from Alberta Environment and
Parks (AEP).
• The Global Warming Potential for methane was updated beginning in January 1, 2014, in
accordance with guidance from AEP.
• The data historian for instrument air volume data was changed from “PI” to “SCADAvantage”
beginning in January 2015.
Findings from Previous Verifications
There were no unresolved discrepancies described in the previous verification report (the previous
verification was conducted by Brightspot Climate).
Brightspot Climate Inc. – Verification Plan Ember Resources Inc. – Instrument Air Conversion Aggregation Projects
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Verification Risk Assessment and Verification Procedures
Verification risk is defined as the risk of an incorrect verification conclusion. It can be calculated as the
product of
1) The Facility’s inherent risks;
2) The Responsible Party’s control risks; and
3) The detection risks associated with the auditor’s audit procedures.
!"ℎ$%$"&()*+ × -."&%./()*+ × 0$&$1&)."()*+ = 345)&()*+
The verifier cannot affect the inherent risk or the control risk. Therefore, to reduce the overall verification
risk and reach the agreed level of assurance (defined in the verification scope), the verifier must design
verification procedures that reduce the detection risk.
The Verification Risk Assessment was completed prior to issuing the draft version of this document.
Each inherent and control risk is provided with the risk evaluation (high/medium/low). The risk analysis
of inherent and control risks considers both the magnitude of the activity data or inventory component
on the overall GHG assertion as well as the probability that the risk will result in a discrepancy, as
assessed by the verifier.
The verification procedures define the amount and type of evidence required to achieve a reasonable
level of assurance. All verification procedures must be completed and the associated evidence must be
available to reach an unqualified verification conclusion.
Several verification procedures will be completed during the site visit, as described in the following
table.
Brightspot Climate Inc. – Verification Plan Ember Resources Inc. – Instrument Air Conversion Aggregation Projects
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Table 3: Verification Risk Assessment Summary
Activity Data /
Inventory
Component
Inherent Risk Control Risk Max
Detection
Risk
Designed
Detection
Risk
Description of Verification
Procedure
Verification
Risk
PROTOCOL APPLICABILITY REQUIREMENTS
Functional
equivalence must be
demonstrated
Relevance (high)
Level of service may
have changed
between the baseline
and project
conditions.
The Responsible
Party does not have a
control specifically
designed to address
this inherent risk.
Low Low Substantive test: Observe
operations and interview
operations staff during site visit
to determine level of service
provided by project
implementation.
Low
Project must be a
conversion (not a
greenfield or end-of-
life replacement)
Relevance (high)
Project may have
been implemented at
greenfield sites or as
end-of-life
replacement.
The Responsible
Party does not have a
control specifically
designed to address
this inherent risk.
Low Low Substantive test: Observe
operations during site visit to
determine if projects were
implemented as a retrofit and
not as an end-of-life
replacement.
Low
An inventory of
devices must be
maintained
Completeness
(medium)
The inventory of
devices may be
incomplete.
The Responsible
Party does not have a
control specifically
designed to address
this inherent risk.
Medium Medium Substantive test: Observe
devices during site visit and
compare against project
inventory to evaluate
completeness.
Medium
Brightspot Climate Inc. – Verification Plan Ember Resources Inc. – Instrument Air Conversion Aggregation Projects
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Activity Data /
Inventory
Component
Inherent Risk Control Risk Max
Detection
Risk
Designed
Detection
Risk
Description of Verification
Procedure
Verification
Risk
Demonstrate
compliance with
Section 8.7 of
Directive 60 related to
fugitive emissions
management prior to
project
implementation
Completeness
(medium)
A leak detection and
repair program may
not have been
implemented at all
project sites.
Control: The project
developer has
implemented a
management system
for leak detection and
repair.
Control Risk: This
system may not have
been implemented or
maintained at all
project sites (low).
Medium Medium Control test: Review the project
developer’s management
system for leak detection and
repair to determine if system is
complete for all sites and has
been maintained through the
reporting period.
Low
Protocol may be
applied to chemical
injection pumps.
N/A N/A N/A N/A Not applicable for this project. N/A
The project must
meet the
requirements of the
Alberta Offset System
Relevance (high)
The project may not
have met the
requirements of the
Alberta Offset
System.
The Responsible
Party does not have a
control specifically
designed to address
this inherent risk.
Low Low Substantive test: Evaluate the
project developer’s evidence
regarding the general
requirements of the Alberta
Offset System.
Low
Brightspot Climate Inc. – Verification Plan Ember Resources Inc. – Instrument Air Conversion Aggregation Projects
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Activity Data /
Inventory
Component
Inherent Risk Control Risk Max
Detection
Risk
Designed
Detection
Risk
Description of Verification
Procedure
Verification
Risk
Project developer
must establish the
ownership of the
emission reduction for
each site within the
aggregated project
Completeness (high)
Ownership may not
be established with
documentation for all
sites within the
aggregated project.
The Responsible
Party does not have a
control specifically
designed to address
this inherent risk.
Low Low Substantive test: Review
ownership documents for each
project site within the
aggregated project.
Low
PROTOCOL FLEXIBILITY
Site specific emission
factors may be
applied
N/A N/A N/A N/A Not applicable for this project. N/A
Baseline and project
metering may be
extended beyond one
year.
Accuracy (medium)
Project metering is
continuous through
the reporting period.
Undetected leaks
may overstate the
emission reduction.
Control: Project
developer has
implemented a leak
detection and repair
program at the
project sites, as
required by the
Protocol.
Control Risk: This
system may not have
been implemented or
maintained at all
project sites (low).
Medium Low See verification procedure
regarding leak detection and
repair in the “Protocol
Applicability Requirements”
section, above.
Low
Brightspot Climate Inc. – Verification Plan Ember Resources Inc. – Instrument Air Conversion Aggregation Projects
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Activity Data /
Inventory
Component
Inherent Risk Control Risk Max
Detection
Risk
Designed
Detection
Risk
Description of Verification
Procedure
Verification
Risk
Use of instrument
counts and vent rates
may be used to
estimate baseline
emissions.
N/A N/A N/A N/A Not applicable for this project. N/A
Flaring may be used
to destroy captured
vent gas
N/A N/A N/A N/A Not applicable for this project. N/A
Implementation of
instrument air
conversion at multiple
facilities.
Completeness
(medium)
The project
aggregates
installations at
multiple project sites.
The data and
documentation may
not be complete for
all sites.
The Responsible
Party does not have a
control specifically
designed to address
this inherent risk.
Medium Low Substantive test: Evaluate the
completeness of the required
data and documentation for all
project sites included in the
aggregated project.
Low
Brightspot Climate Inc. – Verification Plan Ember Resources Inc. – Instrument Air Conversion Aggregation Projects
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Activity Data /
Inventory
Component
Inherent Risk Control Risk Max
Detection
Risk
Designed
Detection
Risk
Description of Verification
Procedure
Verification
Risk
QUANTIFICATION DATA
Air compressor
equipment nameplate
capacity
Accuracy (low)
The recorded air
compressor
nameplate capacity
may be inaccurate.
The Responsible
Party does not have a
control specifically
designed to address
this inherent risk.
High Medium Substantive test: Observe the
nameplate information for the
air compressors during the site
visit and review supporting
documentation.
Low
Metered compressed
air volume
Accuracy (high)
The metered
compressed air
volume may be
incorrect if meters are
not properly
maintained.
Control: The
Responsible Party
has implemented a
meter maintenance
program that includes
periodic meter
calibration.
Control Risk: The
maintenance program
may not be operating
effectively (low).
Low Low Controls test: Review meter
calibration reports to determine
if the meter maintenance
program is operating
effectively.
Low
Brightspot Climate Inc. – Verification Plan Ember Resources Inc. – Instrument Air Conversion Aggregation Projects
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Activity Data /
Inventory
Component
Inherent Risk Control Risk Max
Detection
Risk
Designed
Detection
Risk
Description of Verification
Procedure
Verification
Risk
Methane
concentration in gas
Accuracy (low)
Reported gas
compositions may not
accurately represent
the gas composition
or may be incorrectly
transcribed into the
emission reduction
calculation.
Control: Gas analysis
is conducted by an
independent lab. An
internal process is
used to validate
results.
Control Risk:
Validation process
may not be properly
implemented or
transcription errors
may be introduced
(low).
High Low Substantive test: Analyze gas
compositions for significant
fluctuations or abnormal gas
concentrations. Confirm the
accurate transcription of the
gas analysis into the emission
reduction calculation.
Low
Completeness (low)
The gas compositions
may not include a
valid gas composition
for each period at the
required frequency.
The Responsible
Party does not have a
control specifically
designed to address
this inherent risk.
High Medium Substantive test: Review
completeness of gas
composition data.
Low
Brightspot Climate Inc. – Verification Plan Ember Resources Inc. – Instrument Air Conversion Aggregation Projects
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Activity Data /
Inventory
Component
Inherent Risk Control Risk Max
Detection
Risk
Designed
Detection
Risk
Description of Verification
Procedure
Verification
Risk
Reference density of
methane at STP
conditions
Accuracy (low)
The density of
methane applied in
the calculation may
not represent the
density at STP
conditions.
The Responsible
Party does not have a
control specifically
designed to address
this inherent risk.
High Low Substantive test: Compare the
density of methane applied in
the calculations to the
reference value provided in the
relevant reference documents.
Low
Alberta electricity grid
factor
Accuracy (low)
The Alberta electricity
grid factor applied in
the calculation may
be incorrect.
The Responsible
Party does not have a
control specifically
designed to address
this inherent risk.
High Low Substantive test: Compare the
Alberta electricity grid factor
applied in the calculations to
the reference value provided in
the relevant reference
documents.
Low
Brightspot Climate Inc. – Verification Plan Ember Resources Inc. – Instrument Air Conversion Aggregation Projects
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Activity Data /
Inventory
Component
Inherent Risk Control Risk Max
Detection
Risk
Designed
Detection
Risk
Description of Verification
Procedure
Verification
Risk
EMISSION REDUCTION QUANTIFICATION
Application of the
approved
quantification protocol
Accuracy (high)
The project developer
may not have
implemented
approved
quantification
methodologies or
applied additional
methodologies.
Control: Responsible
Party has developed
an Offset Project Plan
that is intended to
conform to the
requirements of the
approved
quantification
protocol.
Control Risk: The
protocol requirements
may not have been
implemented correctly
(medium).
Medium Low Controls test: Compare the
methodologies described in the
Responsible Party’s Offset
Project Plan to the
methodologies described in the
approved quantification
protocol.
Low
Substantive test: Recalculate
the emission reduction using
original metered data and
methods described in the
approved quantification
protocol.
Low
Brightspot Climate Inc. – Verification Plan Ember Resources Inc. – Instrument Air Conversion Aggregation Projects
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Activity Data /
Inventory
Component
Inherent Risk Control Risk Max
Detection
Risk
Designed
Detection
Risk
Description of Verification
Procedure
Verification
Risk
Quantification of
emission reduction
Accuracy (high)
Emission reduction
calculation may
contain arithmetic
errors.
The Responsible
Party does not have a
control specifically
designed to address
this inherent risk.
Low Low Substantive test: Recalculate
the emission reduction using
original metered data.
Low
DATA INTEGRITY
Activity data and
emission factor data
integrity
Accuracy (high)
Data may not have
been accurately
transferred between
electronic systems
and calculation
sheets.
Control: The
Responsible Party
uses electronic data
transfers whenever
possible to maintain
data integrity.
Control Risk:
Electronic data
transfers may result in
errors or may not be
available for all data
(medium).
Low Low Controls test: Analyze all
metered data for abnormal
data (zeros, missing data,
values outside range).
Low
Substantive test: Recalculate
the complete emission
reduction using original data.
Low
Brightspot Climate Inc. – Verification Plan Ember Resources Inc. – Instrument Air Conversion Aggregation Projects
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Activity Data /
Inventory
Component
Inherent Risk Control Risk Max
Detection
Risk
Designed
Detection
Risk
Description of Verification
Procedure
Verification
Risk
Transcription of final
emission reduction
into Offset Project
Reports
Accuracy (high)
Final emission
reduction may not
have been transcribed
accurately from
calculation
spreadsheets into the
Offset Project
Reports.
The Responsible
Party does not have a
control specifically
designed to address
this inherent risk.
Low Low Substantive test: Compare the
final emission reduction
quantity reported by the
Responsible Party to the
quantity reported in the Offset
Project Reports. Also, compare
these quantities to the
recalculated quantity in
previous verification
procedures.
Low
Brightspot Climate Inc. – Verification Plan Ember Resources Inc. – Instrument Air Conversion Aggregation Projects
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Sampling Plan
The verification procedures that could apply sampling of the project data are listed in the following table.
The sampling size, the sampling methodology and their respective justifications are also described in the following table.
Table 4: Sampling Plan
Activity Data /
Inventory
Component
Designed
Detection
Risk
Description of Verification
Procedure
Sampling Methodology and
Justification
Sample Size
Air compressor
equipment
nameplate capacity
Low Substantive test: Observe the
nameplate information for the air
compressors during the site visit
and review supporting
documentation.
Four of the nine subproject sites
were visited, including minimum
one site from each of the three
registered projects, and minimum
one site from each majority
working interest operator.
Supporting documentation for all
sites was reviewed.
Site Visits:
• 08-34-29-22W4
• 01-24-28-24W4
• 10-07-28-23W4
• 09-27-24-25W4
Metered
compressed air
volume
Low Controls test: Review meter
calibration reports to determine if
the meter maintenance program is
operating effectively.
Review of full dataset has lower
detection risk than sampling.
Annual calibration for each of the
nine sites.
Methane
concentration in
gas
Low Substantive test: Analyze gas
compositions for significant
fluctuations or abnormal gas
concentrations. Confirm the
accurate transcription of the gas
analysis into the emission reduction
calculation.
There is only one sample per site
per year. Review of full dataset has
lower detection risk than sampling.
Annual sample for each of the nine
sites.
Brightspot Climate Inc. – Verification Plan Ember Resources Inc. – Instrument Air Conversion Aggregation Projects
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Activity Data /
Inventory
Component
Designed
Detection
Risk
Description of Verification
Procedure
Sampling Methodology and
Justification
Sample Size
Methane
concentration in
gas
Low Substantive test: Review
completeness of gas composition
data.
There is only one sample per site.
Review of full dataset has lower
detection risk than sampling.
Annual sample for each of the nine
sites.
Page 64 of 76
Appendix B: Statement of Qualifications
Ember Resources Instrument Air Conversion at Strathmore (1665-4576) August 2018
Page 65 of 76
Statement of Qualifications
Offset Report
Project Name Offset Project ID
Ember Resources
Instrument Air Conversion at
Strathmore, Phase 1 1665-4576
Reporting Company Legal
Name Report Type
Reporting
Period
Ember Resources Inc.
Offset Report
from
August 1, 2016
– December
31, 2017
to
Signature of Third Party Verifier
I
, Aaron Schroeder
(Third Party Verifier), meet or exceed the qualifications of
third party
Third-party verifiers described in Section 29 of the Carbon Competitiveness Incentive Regulation.
Verifying Company Name
Brightspot Climate Inc. Per:
Signature of Third Party
Verifier Date
Training Received Under ISO 14064 Part 3
• Greenhouse Gas Verification – ISO 14064-3, Canadian Standards Association, 2012;
• Instructor – Greenhouse Gas Verification – ISO 14064-3, University of Toronto, 2015 – 2018
First Name Last Name
Aaron
Schroeder
Professional Designation E-mail Address Phone Number
Professional Engineer
(604) 353-0264
Lead Verifier
� Same as third party
verifier??
First Name Last Name
Professional Designation E-mail Address Phone Number
Training Received Under ISO 14064 Part 3
Peer Reviewer
First Name Last Name
Chris Caners
E-mail Address Phone Number
[email protected] (647) 468-4332
Training Received Under ISO 14064 Part 3
• Greenhouse Gas Verification – ISO 14064-3, Canadian Standards Association, 2008
Aaron Schroeder
August 22, 2018
Page 66 of 76
Appendix C: Findings and Issues
Ember Resources Instrument Air Conversion at Strathmore (1665-4576) August 2018
Page 67 of 76
Table 8: Detailed Findings and Issues Log
Number the issue with the year and provide a unique # for the issue. If the issue resolved during the verification, indicate that in the resolution column. If the issue is not resolved during the verification, or if the issue was material (whether resolved or not) record it as a finding in Table 2 and provide a cross reference to the finding # in the resolution column. Describe the issues investigated. State the verification criteria that are not met. Provide a description of how it is not met and provide the evidence. Indicate the Source Category (for facilities) or the Source/Sink (for offsets). Indicate if the finding is an understatement or overstatement. Summarize information between verifier and client. Provide a conclusion including % discrepancy, if applicable.
Item (YR-##)
Description of the Issues Investigated During the Verification
Summary of information exchanged between Verifier and Responsible Party
Resolution Conclusion
There were no material or immaterial discrepancies detected in the final GHG assertion.
Page 68 of 76
Appendix D: Statement of Verification
Ember Resources Instrument Air Conversion at Strathmore (1665-4576) August 2018
Page 69 of 76
Statement of Verification Associated SGER Submission
Offset Project Protocol Project ID #
Ember Resources Instrument Air Conversion at Strathmore Phase 1
Quantification Protocol for Instrument Gas to Instrument Air Conversions in Process Control Systems, Version 1.0, October 2009
1665-4576
Project Developer Serial Range Start Report Period
Ember Resources Inc. TBD
August 1, 2016 – December 31, 2017
Serial Range End
TBD
Statement of Verification GHG Assertion
Value Units
Total Baseline Emissions 356 tonnes CO2e
Total Project Emissions 1 tonnes CO2e
Other 0 tonnes CO2e
Net Reductions 355 tonnes CO2e
Statement of Assertion
The Responsible Party’s GHG Assertion is comprised of the Offset Project Plan, Offset Project Report and supporting documentation.
The GHG Assertion covers the reporting period August 1, 2016 to December 31, 2017 and states an emission reduction and removal claim of 355 tonnes CO2e over this period.
The emission reduction and removal claim consists of 2016 and 2017 vintage credits.
Ember Resources Instrument Air Conversion at Strathmore (1665-4576) August 2018
Page 70 of 76
Responsibilities of Project Developer and Third Party Verifier
Our responsibility as the Verifier is to express an opinion as to whether the GHG Assertion is materially correct, in accordance with approved Protocol, the Carbon Competitiveness Incentive Regulation (the “Regulation”), and the Alberta Climate Change Office – Standard for Greenhouse Gas Emission Offset Project Developers, Version 2.0, July 2018.
We completed our review in accordance with the ISO 14064 Part 3: Greenhouse Gases: Specification with Guidance for the Validation and Verification of Greenhouse Gas Assertions (ISO, 2006). As such, we planned and performed our work in order to provide positive, but not absolute assurance with respect to the GHG Assertion.
The verification procedures that were performed through the course of the verification were developed based on the results of a risk assessment that was completed during the verification planning stage. These verification procedures are described in the Verification Plan. Certain verification procedures included data sampling. The sampling type, sample size and the justification for the planned sampling type and size are detailed in a Sampling Plan, which is included in the Verification Plan.
Conclusion
I believe our work provides a reasonable basis for my conclusion.
There were no unresolved misstatements in the final GHG Assertion.
Based on our review, it is my opinion at a reasonable level of assurance that the GHG Assertion is materially correct and presented fairly in accordance with the relevant criteria.
Signature of Third Party Verifier Verifying Company Name
Brightspot Climate Inc. Per:
Signature of Third Party Verifier Date:
First Name Last Name
Aaron Schroeder
Professional Designation E-mail Address Phone Number
Professional Engineer [email protected] (604)353-0264
Aaron Schroeder
August 22, 218
Page 71 of 76
Appendix E: Conflict of Interest Checklist
Ember Resources Instrument Air Conversion at Strathmore (1665-4576) August 2018
Page 72 of 76
Conflict of Interest Checklist Associated SGER Submission Offset Project Protocol
Ember Resources Instrument Air Conversion at Strathmore, Phase 1
Quantification Protocol for Instrument Gas to Instrument Air Conversions in Process Control Systems, Version 1.0, October 2009
Project Developer Report Type Report Period
Ember Resources Inc. Offset Report
August 1, 2016 – December 31, 2017
Checklist Respond either "True" or "False" to each of the following statements:
1. The relationship between my firm and this reporting company poses
unacceptable threat to or compromises the impartiality of my firm.
False
2. The finances and sources of income of my firm compromise the impartiality of
my firm.
False
3. The personnel my firm has scheduled to participate in the verification may have
an actual or potential conflict of interest.
False
4. My firm participated in some manner in the development or completion of the
associated offset submission for this reporting company.
False
5. My firm provided greenhouse gas consultancy services to this reporting
company.
False
6. My firm will use personnel that have, are, or will be engaged or previously
employed by the reporting company.
False
7. My firm will outsource the Statement of Verification for the associated offset
submission.
False
8. My firm offers products or services that pose an unacceptable risk to impartiality.
False
Important: If you have checked "True" to any of the above, you may not fulfill the "independence" requirement for third party verifiers. Please contact Alberta Environment and Parks for further instruction. If the potential conflict of interest is a sufficient threat to impartiality (perceived or actual), or cannot be effectively managed, you Third Party Verification Report will not be acceptable to Alberta Environment and Parks.
Signature of Third Party Verifier
Ember Resources Instrument Air Conversion at Strathmore (1665-4576) August 2018
Page 73 of 76
I , Aaron Schroeder (Third Party Verifier), have personally examined and am familiar
with the information contained in this Conflict-of Interest Checklist, and can demonstrate freedom from any conflict of interest related to the reporting company for which the verification was performed. I hereby warrant that the information submitted in this Conflict-of Interest Checklist is true, accurate and complete to the best of my knowledge, and that all matters affecting the validity of this Conflict-of-Interest Checklist have been fully disclosed. Impartiality shall be monitored over the duration of the verification and any identified actual or potential conflict-of-interest situations will be communicated to AEP directly.
Verifying Company Name
Brightspot Climate Inc. Per:
Signature of Third Party Verifier
Date:
First Name Last Name
Aaron Schroeder Professional Designation E-mail Address Phone Number
Professional Engineer [email protected] (604) 353-0264
August 22, 2018
Aaron Schroeder
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Appendix F: Supplemental Diagrams/Tables/Figures
Ember Resources Instrument Air Conversion at Strathmore (1665-4576) August 2018
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Table 8: Supporting Documentation Reviewed
File Name Description
Ember IA SM1 Offset Project Plan_Aug 1 2018_Final.pdf
Offset Project Plan
IA Projects Master Calculator_2016-2017_Final For Verifier_June 13, 2018.xlsx
Emission reduction calculation worksheet
SM1 IA_ProjectReportForm_Final for Verifier_July 18, 2018.docx
Offset Project Report
9-27-24-25w4m 0662999 June 9 2017.xlsx Calibration report for the meter measuring the volume of compressed air consumed at the project site
09-27-024-25-W4 - 2017-10-13 - GAS^-SG7209V1-2017-10-26-21-55.pdf
Gas analysis laboratory report for the project site
Strathmore 09-27-024-25W4 Air Compressor Drawings.pdf
Facility drawing indicating the air compressor nameplate specification for the project site
Strathmore 09-27 Inspection.pdf Leak Detection and Repair survey report for the project site
Ember Resources Instrument Air Conversion at Strathmore (1665-4576) August 2018
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Limitation of Liability
This report is intended for the responsible party and the intended user as defined in the attached verification report. The sole intention of the report is to verify the GHG assertion made by the responsible party named in the report and is not intended to provide assurance of any kind for any purpose other than for reporting under the GHG program as defined in the scope of the attached report.
Brightspot Climate disclaims liability for use by any other party and for any other purpose.