Verification Report for: Aggregation Project (Bluesource ...€¦ · Alberta REMVue Engine Fuel...

Alberta REMVue Engine Fuel Management and Vent Gas Capture Aggregation Project (Bluesource Pool A) (8056-2592)

February 2020

Version 3.0 Offset Verification Report Form

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

Aggregation Project (Bluesource Pool A) (8056-2592)

Proponent Name and Proponent Project Number:

Blue Source Canada ULC (8056-2592)

Prepared by:

Brightspot Climate Inc.

Prepared for:

Alberta Environment and Parks

Version: Final

Date:

February 12, 2020


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Table of Contents 1.0 Summary of Offset Project .................................................................................... 4 2.0 Introduction ........................................................................................................ 8

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

3.0 Methodology ..................................................................................................... 11 3.1 Procedures ........................................................................................................ 11 3.2 Team ............................................................................................................... 26 3.3 Schedule .......................................................................................................... 27

4.0 Results ............................................................................................................. 28 4.1 Assessment of Internal Data Management and Controls .......................................... 28 4.2 Assessment of GHG Data and Information ............................................................. 30 4.3 Assessment against Criteria ................................................................................. 35 4.4 Evaluation of the GHG Assertion .......................................................................... 43 4.5 Summary of Findings .......................................................................................... 43 4.6 Opportunity for Improvement .............................................................................. 46

5.0 Closure ............................................................................................................. 46 5.1 Verification Statement ........................................................................................ 46 5.2 Limitation of Liability .......................................................................................... 46 5.3 Confirmations .................................................................................................... 46

6.0 References ........................................................................................................ 47 Appendix A: Final Verification Plan and Sampling Plan ............................................................ 48 Appendix B: Statement of Qualifications .............................................................................. 74 Appendix C: Findings and Issues ......................................................................................... 77 Appendix D: Statement of Verification ................................................................................. 80 Appendix E: Conflict of Interest Checklist ............................................................................. 83 Appendix F: Supplemental Diagrams/Tables/Figure ............................................................... 86

List of Tables Table 1: Risk Assessment .................................................................................................. 16 Table 2: Findings of Data Integrity Verification Procedures ..................................................... 29 Table 3: Findings of GHG Data and Information Verification Procedures .................................... 30 Table 4: Findings of Criteria Verification Procedures ............................................................... 36 Table 5: Offset Criteria Assessment ..................................................................................... 41 Table 6: Summary of Findings ............................................................................................ 44 Table 7: Confirmation Findings ........................................................................................... 46 Table 8: Detailed Findings and Issues Log ............................................................................ 78 Table 9: Supporting Documentation Reviewed ...................................................................... 87


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Instructions for Offset Verification Report Form • As of January 1, 2020 the Alberta emission offset system is enabled under the Technology

Innovation and Emission Reduction (TIER) Regulation. • Starting January 1, 2020, the Alberta Emissions Offset Registry will only accept verification

reports completed using version 3.0 of this form. From November 14, 2019 to December 31, 2019, the Alberta Emissions Offset Registry will only accept will only accept verification reports completed using version 2.0 (December 2018) of this form.

• Instructions in italics are provided for each heading throughout the report. The document is not restricted but Users must not alter the format, layout, and the headings.

o Branding is not accepted (i.e. company logos). o Additional headings may be inserted should the verifier want to provide additional

information that is not covered in the current headings. o If an instruction or a section does not apply to a specific report, do not leave it blank.

Instead, enter N/A for not applicable and, if practical, provide an explanation as to why it is not applicable.

• Complete report in Verdana 10pt font (no italics). • Drop down menus labelled “Choose an item” are used in some sections of the form. Please

select one of the options from the drop down list. • After the report is complete, right click the table of contents and ‘update field’ and then ‘update

page numbers only. • Appendix F is available for additional information, tables, diagrams, etc. and is not mandatory.


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1.0 Summary of Offset Project

Item Description

Project Title

Enter project title (must match the registry listed project title).

Alberta REMVue Engine Fuel Management and Vent Gas Capture Aggregation Project (Bluesource Pool A)

Project Description

Provide a brief description of the project and baseline conditions.

This Project endeavours to reduce emissions of greenhouse gases at a number of oil and gas production and processing sites by improving fuel use efficiency in engines and by reducing or eliminating vented gas emitted from engine packing, casing or other sources. This is achieved by implementing engine fuel management systems that control engine air-fuel ratios to improve fuel use efficiency, and by implementing vent gas capture systems to reduce or eliminate vented gas. The Project is an aggregation of installations at multiple project sites.

Project Location

Include the unique location of the activity or installation, including latitude and longitude. Include legal land location if applicable and other information identifying the unique location. Project developers may choose to list multiple subproject if project is aggregated.

The subprojects are located at various locations throughout Alberta. All emission reduction activities related to this project will occur within Alberta. The location of each subproject is tabulated in the Aggregated Project Planning sheet.

Project Start Date

Enter the project start date.

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

Offset Start Date

Enter the start date for offset credit generation.

October 3, 2018

Offset Crediting Period

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

Original Offset Crediting Period: October 3, 2018 – December 31, 2018 Extension Period: January 1, 2019 – December 31, 2023

Offset Reporting Period

Enter the offset reporting period being verified.

October 3, 2018 – December 31, 2018


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GHG Assertion (Actual Emission Reductions/Sequestration Achieved)

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

1,521 t CO2e

Government Approved Quantification Protocol

Indicate the relevant protocol and version applied to project/offset reporting period.

Quantification Protocol for Engine Fuel Management and Vent Gas Capture Projects, Version 2.0, June 2018

Ownership

List the emission offset project developer. If applicable, the Authorized Project Contact.

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

Project Activity

State how the project activity meets the eligibility requirements under the TIER Regulation section 19(1).

The project must meet the eligibility criteria stated in Part 1, Section 19 of the Technology Innovation and Emissions Reduction (TIER) Regulation. 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; • Must not be required by law at the time the reduction occurs; • Result from actions taken on or after January 1, 2002; • Occur on or after January 1, 2002; • Be real and demonstrable; • Be quantifiable and measurable, directly or by accurate estimation using replicable techniques; • Must not have had an effect on the determination of a regulated facility’s total regulated emissions

The verification included an evaluation of these criteria as well as the specific applicability criteria


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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.

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

Lead Verifier

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

Aaron Schroeder, P.Eng. Brightspot Climate 401 – 409 Granville Street Vancouver BC V6C 1T2 +1 (604) 353-0264 [email protected]

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

Deepika Mahadevan, P.Eng. Role: Peer Reviewer Training: Greenhouse Gas Verification – ISO 14064-3, Canadian Standards Association, 2012

Designated Signing Authority

Enter the designated signing authority for this verification.

Aaron Schroeder, P.Eng. Brightspot Climate 401 – 409 Granville Street Vancouver BC V6C 1T2 +1 (604) 353-0264 [email protected]

Verification Strategy

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

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

The Aggregator has controls in place to address inherent risks from any subproject. Therefore our controls approach was largely testing the controls of the aggregator, rather than the individual


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subprojects. Please refer to the Verification and Sampling Plan for more specific details on the specific Verification Procedures that were applied.

Verification Conclusion The verification conclusion is: Positive


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

Provide a summary of the offset project baseline, changes to the baseline since the project start date and a summary of changes to the project since the offset project start date or baseline period.

Summary of Offset Project Baseline

This Project endeavours to reduce emissions of greenhouse gases at a number of oil and gas production and processing sites by improving fuel use efficiency in engines and by reducing or eliminating vented gas emitted from pneumatic devices, compressor seals and other sources. This is achieved by implementing an engine control system that allows an engine to operate at a different range of air fuel ratios from that of the original engine design. This can result in a reduction in fuel consumption for the same work done, which leads to a reduction in GHG emissions.

The baseline condition is quantified as the GHG emissions from the fuel consumption of the unit under its original configuration, prior to the installation of the new engine control system. Fuel consumption is defined in terms of the brake specific fuel consumption (BSFC) which is a ratio of the fuel energy flow into the engine to the mechanical power produced by the engine. The quantification methodology in the Protocol requires direct measurement to determine the BSFC before the engine control system is installed (pre-audit) and after the engine modification is completed (post-audit). The fractional fuel consumption is calculated from the pre-audit and post-audit BSFC values as a function of engine load and RPM. The fuel consumption in the project condition is measured directly and used along with the average change in fuel consumption at the specific engine load and RPM to calculate the reduction in fuel consumption from the baseline, and subsequently the reduction in emissions.

Summary of Changes

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

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

Since the last reporting period, the project has been updated to reference and meet the requirements of the new version of the Protocol. The Responsible Party has stated that no other changes to the original project have been identified since the Offset Project Plan was developed.

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 which includes the requirement to provide an opinion for the verification at the required assurance level.

The objective of the verification is as follows:

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


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• to issue a verification report that provides details of the verification activities; and • to complete the “confirmations” activities defined in the Alberta Environment and Parks

Standard for Validation, Verification and Audit, Section 5.1.3.

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, and offset reporting period.

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 reverification a serial range will be available, otherwise not applicable).

Project Name: Alberta REMVue Engine Fuel Management and Vent Gas Capture Aggregation Project (Bluesource Pool A)

Serial Range: To be assigned at registration.

Geographic Boundary: All subprojects are located within Alberta’s provincial boundary.

Physical Operations: Natural gas processing and compression:

• Reciprocating engines • Pneumatic devices and controllers

Emission Sources: Engine Fuel Management and Vent Gas Capture

• B1: Fuel Extraction and Processing • P1: Fuel Extraction and Processing • B4: Unit Operation • P4: Unit Operation • B5b: Venting of Emissions Captured in Project • P5b: Capture of Vent Gases

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: October 3, 2018 to December 31, 2018*

* Note: The original crediting period for the Project ended on December 31, 2018. The Project was granted an extension. Based on guidance from AEP, the Responsible Party split what was originally one reporting period for this project into two separate reporting periods; one ending on the last day of the original crediting period and the other starting on the first day of the extension. The verification for these two reporting periods was conducted simultaneously.


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

Choose type of verification from the dropdown box above.

Provide explanation and expectations for the verification at the required level of assurance.

The Standard for Validation, Verification and Audit, Version 4.0, November 2019 requires that verifications must be designed and completed to a reasonable level of assurance.

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

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

• Climate Change and Emissions Management Act • Technology Innovation and Emissions Reduction Regulation 133/2019 • Standard for Validation, Verification and Audit, Version 4.0, November 2019 • Standard for Greenhouse Gas Emission Offset Project Developers, Version 3.0,

November 2019 • Technical Guidance for the Assessment of Additionality, Version 1.0, May 2018 • Quantification Protocol for Engine Fuel Management and Vent Gas Capture, Version 2.0,

June 2018

2.5 Materiality Define the materiality of the verification based on the requirements in Part 1 of the Standard for Validation, Verification, and Audit.

The materiality threshold is defined in The Standard for Validation, Verification and Audit, Version 4.0, November 2019. For this verification, the materiality threshold is 5%.


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3.0 Methodology Statement on how the verification is performed according to Standard requirements.

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 a sample of the project sites to observe emission sources, metering, and data systems used for recording metered quantities;

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

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

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

• Analytical procedures: a comparison of overall emissions offsets to previous reporting periods was performed.

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

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

Regarding the scale and complexity of the verification procedures, the verification risk assessment was leveraged to design verification activities appropriate to address the inherent, controls and detection risk evaluated in relation to each activity data and boundary condition. In most cases, these verification procedures involved review of documentation, recalculation or


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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.

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.

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 a general description of the Project, documents operational and


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organizational changes that have occurred since the previous verification, explains the Project’s control environment, and describes the safety requirements of the site visit.

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” as described in the Standard for Validation, Verification and Audit.

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

Site Visit

Jeanna Brown conducted site visits to a sample of the subproject sites within the aggregated project over a two-day duration. The selection of sites to be visited was made during the verification risk assessment process. The selection considered site ownership and subproject types, sites visited during the previous verification, and the magnitude of the emission reduction for each site within the aggregated assertion. A total of 2 engines from this pool were inspected during the site visits, representing approximately 25.6% of the total emission reduction claim.

During the site visits, completeness of data sources, accuracy of measurement and data system integrity were tested through observation and interviews with site operations and instrumentation personnel.

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

Verification Procedures

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

The desk review included an independent recalculation of the emissions reduction assertion, as well as a review of supporting documentation for a sample of subproject sites within the aggregated project. The selection of sites reviewed during the supporting documentation review considered site ownership and subproject types, and the magnitude of the emission reduction for each site within the aggregated assertion. Documents reviewed included gas analysis reports and meter calibration reports.

Through the course of the assessment phase of the verification, Brightspot Climate issued questions and requests for additional documentation and data. These requests were


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consolidated in a simple electronic tracking system 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 AEP 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.

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.


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Inherent Risk × Control Risk × Detection Risk = Verification Risk

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

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

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

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

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

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

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

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

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

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

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


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Table 1: Risk Assessment

Source or Risk Area

Attributes Inherent Risk Control Risk Detection Risk

Evidence-Gathering Activity

PROTOCOL APPLICABILITY REQUIREMENTS

Determination of BSFC and fractional change in fuel consumption must be completed according to Protocol guidelines

Accuracy Low

Equipment modifications could impact the measured BSFC and therefore the validity of the calculated fuel savings.

High

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

Medium Substantive test: Observe operations and interview operations staff during site visit to determine if any modifications have been made to equipment that may impact the measured BSFC.

Functional equivalence must be demonstrated; engine performance must not be impaired because of the project

Occurrence High

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

High


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

Capture of vent gas must not be required by regulation

Relevance High

Vent gas capture may be required by Directive 60.

High


Low Substantive test: Review venting sources and volumes for each site and compare against the Directive 60 requirements.


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Source or Risk Area



The project must comply with all air emission regulations in Alberta

Relevance High

Vent gas capture may be required to be flared or captured.

High


Low Substantive test: Review the daily gas volume captured for each site and compare against the Directive 60 requirements.

For projects that include the capture and combustion of solution gas, the project proponent must justify that the Solution Gas Protocol is not applicable.

N/A N/A N/A N/A Not applicable: No subprojects are capturing and combustion solution gas.

Quantification must be based on actual measurements and monitoring.

Relevance High

Estimates may have been applied, particularly for missing data.

High


Low Substantive test: Review quantification data for anomalies or missing data.

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.

High


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


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Source or Risk Area



PROTOCOL FLEXIBILITY

Fractional fuel savings data from other engines of the same make and classification may be applied for engine fuel management projects where pre and post audit data is not available.

Accuracy

Occurrence

Medium

Available data may not be sufficient or may be applied incorrectly.

High


Low Substantive test: Review instances where pre and post audit data are not available, and evaluate if fractional fuel savings was applied appropriately.

Substantive test: Recalculate the emission reduction from original data applying the fractional fuel savings method where appropriate.

Implementation of vent gas capture at multiple facilities.

Completeness Medium

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

High


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


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Source or Risk Area



For engines that operate at constant speed, the simple or advanced approaches may be altered to include measurement at one rpm for each load.

N/A N/A N/A N/A Not applicable for this project (no constant speed engines are included in the aggregated project).

Site specific emission factors may be applied

Accuracy

Occurrence

Low

Site specific emission factors may not be calculated correctly or may be based on invalid data.

High


Low Substantive test: Confirm validity of gas composition data and recalculate site specific emission factors from original data.

ACTIVITY DATA

Mass of fuel gas consumed in the engine

Accuracy High

The metered fuel gas 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: Low

The maintenance program may not be operating effectively.

Low Controls test: Review meter calibration reports to determine if the meter maintenance program is operating effectively.


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Source or Risk Area



Fuel gas analysis (density, % CnHm)

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: Low

Validation process may not be properly implemented, or transcription errors may be introduced.

Low Substantive test: Analyze gas compositions for abnormal gas concentrations. Confirm the accurate transcription of the gas analysis into the emission reduction calculation.

Completeness Low

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

High


Medium Substantive test: Review completeness of gas composition data.

Mass of vent gas consumed in the engine

Accuracy High

The metered captured vent gas may be incorrect if meters are not properly maintained.

Control: The Responsible Party has implemented a meter maintenance program that includes periodic meter calibration.

Low Controls test: Review meter calibration reports to determine if the meter maintenance program is operating effectively.


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Source or Risk Area



Control Risk: Low

The maintenance program may not be operating effectively.

Vent gas analysis (density, % CnHm)

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: Low Validation process may not be properly implemented, or transcription errors may be introduced.

Low Substantive test: Analyze gas compositions for abnormal gas concentrations. Confirm the accurate transcription of the gas analysis into the emission reduction calculation.

Completeness Low

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

High


Medium Substantive test: Review completeness of gas composition data.


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Source or Risk Area



Fuel Index Accuracy

Completeness

Low

The fuel index values may include invalid or incomplete data.

High


Medium Substantive test: Analyze fuel index data for abnormal values and completeness.

Engine runtime Accuracy

Completeness

Low

The engine runtime values may include invalid or incomplete data.

High


Medium Substantive test: Analyze engine runtime data for abnormal values and completeness.

Engine speed Accuracy

Completeness

Low

The engine speed values may include invalid or incomplete data.

High


Medium Substantive test: Analyze engine speed data for abnormal values and completeness.

Rated engine load and speed

Accuracy Low

The rated engine load and engine speed values may be incorrectly transcribed from the manufacturers’ documentation.

High


Low Substantive test: Confirm transcription of all referenced engine load and speed ratings from manufacturers’ specifications.


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Source or Risk Area



Emission factors (combustion and fuel extraction and processing)

Accuracy Low

The emission factors may be incorrectly transcribed from the reference documentation.

High


Low Substantive test: Confirm transcription of all emission factors from reference documentation.

EMISSION REDUCTION QUANTIFICATION

Inclusion of applicable emission sources

Completeness

Occurrence

Low

Emission sources may be excluded from the Project.

Control: OPP is used to document emission sources that are included in the Project.

Control Risk: Medium

OPP may be inaccurate or out of date.

Low Substantive test: Observe emission sources during site tour and review against included SSs in the Protocol.

Application of 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.


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


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Source or Risk Area



The protocol requirements may not have been implemented correctly.

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

Quantification of emission reduction

Accuracy High

Emission reduction calculation may contain arithmetic errors.

High


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

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.


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


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Source or Risk Area



Electronic data transfers may result in errors or may not be available for all data.

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

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.

High


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


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3.2 Team List verification team members including peer reviewer(s). Identify the qualifications of the lead verifier per Standard requirements.

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

Complete the sample Statement of Qualification provided and included 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 Verifier and Designated Signing Authority. His extensive experience quantifying and verifying greenhouse gas emissions satisfies all sixteen subject matter areas defined in the standard.

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

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

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

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

Associate Verifier: Jeanna Brown, P.Eng.

Biography: Jeanna Brown is a professional engineer with thirteen years of experience in the oil and gas industry. Since joining Brightspot, Jeanna has gained experience working on GHG 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.


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Peer Reviewer: Deepika Mahadevan, P.Eng.

Biography: Deepika Mahadevan, P.Eng. has more than five years of experience conducting greenhouse gas verifications for industrial facilities and emission reduction (offset) projects in jurisdictions across Canada. Her experience includes verifications in the following sectors/project types: Natural gas production (upstream), Oil sands in-situ production, Natural gas processing (midstream), Oil upgrading and refining, Electricity production (natural gas/biomass), Electricity production (renewables), Metals Refining, Wastewater Treatment, Aerobic Composting, and Landfill Gas Capture and Combustion.

Training: Greenhouse Gas Verification – ISO 14064-3, Canadian Standards Association, 2012

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

Verification Kickoff Meeting November 5, 2019

Draft Verification Plan January 8, 2020

Site Visit January 13, 2020 and February 4, 2020

Supplementary Information Request December 5, 2019

Draft Verification Report February 6, 2020

Final Verification Report February 12, 2020


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

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

4.1 Assessment of Internal Data Management and Controls Provide a summary of 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 (as applicable).

The Responsible Party’s GHG quantification is primarily performed in an Excel spreadsheet. All data required to quantify emissions reductions for the Project is either manually transcribed into this spreadsheet or electronically transferred from other spreadsheets. The final calculated quantities 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 laboratory reports or manufacturer specifications.

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, and a discussion of GHG data management.

Findings from Previous Verification

The subprojects included in this Project were transferred from another Project Developer’s project. There were four unresolved discrepancies noted in the previous Verification Report but three of them were specific to the other Project Developer’s methodology and do not apply to this quantification or verification.

One of the findings from the previous verification is relevant and was found to persist in this reporting period: Some EFM / vent gas capture systems involve the installation of additional pneumatic devices which, if supplied by instrument gas, may result in additional venting in the project condition, or an inflated baseline condition (if they are tied into the VGC system). The impact of incremental venting emissions from additional pneumatic devices would have a very small impact on the total emissions reduction.

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.


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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.

For most of the subprojects, the engine parameters used in the quantification are recorded by a GHG data logger. The data logger reports “Yesterday Uptime hours”, “Yesterday Engine Fuel Mass” and “Yesterday Slipstream Fuel Mass”, meaning that the data for the last day of the reporting period is reported the following day. The Responsible Party excluded the data for the last day of the reporting period, even when it was provided in the GHG output files.

The exclusion of the emission reduction for the last day of the reporting period results in an immaterial quantitative discrepancy of approximately 4 tonnes CO2e (0.26% of the total emission reduction claim).


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

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

Transcription of final emission reduction into Offset Project Report

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

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

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


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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.

Confirm that the quantification methodologies that were used by the project proponent are the same as those described in the Emission Offset Project Plan. Indicate which quantification methodologies were used by the project proponent. Indicate if there were any deviations from the approved quantification protocol.

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 Findings

Quantification Data

Mass of fuel gas consumed in the engine

Controls test: Review meter calibration reports to determine if the meter maintenance program is operating effectively.

Meter calibration records were provided for some of the subprojects’ fuel gas meters. These records were reviewed and no discrepancies were identified.

For a number of subprojects, meter calibration records were not available. Since these meters cannot be calibrated or proved in the field, the Protocol allows for the implementation and use of an alternative meter maintenance program. The Responsible Party developed and documented an alternative program for meter verification which was reviewed and accepted by the verification team.

No discrepancies were detected in the accuracy of fuel gas measurement.

Fuel gas analysis (density, % CnHm)

Substantive test: Analyze gas compositions for abnormal gas concentrations. Confirm the accurate transcription of the gas analysis into the emission reduction calculation.

Review of the gas compositions did not reveal significant fluctuations or abnormal concentrations, and no transcription errors were identified.

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


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GHG Report Element



Substantive test: Review completeness of gas composition data.

Gas composition data was complete for all subprojects.


Mass of vent gas consumed in the engine

Controls test: Review meter calibration reports to determine if the meter maintenance program is operating effectively.

Meter calibration records were provided for some of the subprojects’ vent gas meters. These records were reviewed and no discrepancies were identified.

For a number of subprojects, meter calibration records were not available. Since these meters cannot be calibrated or proved in the field, the Protocol allows for the implementation and use of an alternative meter maintenance program. The Responsible Party developed and documented an alternative program for meter verification which was reviewed and accepted by the verification team.

No discrepancies were detected in the accuracy of vent gas measurement.

Vent gas analysis (density, % CnHm)

Substantive test: Analyze gas compositions for abnormal gas concentrations. Confirm the accurate transcription of the gas analysis into the emission reduction calculation.

For all vent gas capture subprojects in this aggregated project, the captured vent gas was assumed to have the same composition as the engine fuel gas. Through interviews with site operations personnel, the verification team confirmed that this approach is appropriate, as the gas supplied to all venting sources is fuel gas.

Review of the gas compositions did not reveal significant fluctuations or abnormal concentrations, and no transcription errors were identified.


Substantive test: Review completeness of gas composition data.

Gas composition data was complete for all subprojects.



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GHG Report Element



Fuel Index Substantive test: Analyze fuel index data for abnormal values and completeness.

Review of the fuel index data for EFM subprojects did not reveal significant fluctuations or abnormal values.

No discrepancies were detected in the fuel index data used in the quantification.

Engine runtime Substantive test: Analyze engine runtime data for abnormal values and completeness.

For all of the engines in this aggregated project, engine runtime is automatically recorded by the GHG data logger. Review of the engine runtime data did not reveal significant fluctuations or abnormal values.

No discrepancies were detected in the engine runtime data used in the quantification.

Engine speed Substantive test: Analyze engine speed data for abnormal values and completeness.

Review of the engine speed data did not reveal significant fluctuations or abnormal values.

No discrepancies were detected in the engine speed data used in the quantification.

Rated engine load and speed

Substantive test: Confirm transcription of all referenced engine load and speed ratings from manufacturers’ specifications.

No discrepancies detected.


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GHG Report Element



Emission factors (combustion and fuel extraction and processing)

Substantive test: Confirm transcription of all emission factors from reference documentation.

The emission factors applied in the calculations were correctly transcribed from the Carbon Offset Emission Factors Handbook, Version 2.0, November 2019.

The Responsible Party has applied the CH4 and N2O “industrial” emission factors for combustion of natural gas for some engines, and the “non marketable” emission factors for others. The emission factor selection was made based on a comparison of the calculated site specific CO2 emission factor to the reference CO2 emission factor. Although this approach follows the Quantification Procedures in the Protocol, the emission factors in the Carbon Offset Emission Factors Handbook do not align with CH4 and N2O emission factors that have been published by AEP for engines.


Emission Quantification and Reporting

Inclusion of applicable emission sources

Substantive test: Observe emission sources during site tour and review against included SSs in the Protocol.

Some EFM / vent gas capture systems involve the installation of additional pneumatic devices which, if supplied by instrument gas, may result in additional venting in the project condition, or an inflated baseline condition (if they are tied into the VGC system).

The Verification Team was not able to confirm definitively that additional pneumatics have not been installed as a result of implementing the Project.

The impact of incremental venting emissions from additional pneumatic devices would have a very small impact on the total emissions reduction and is noted as an immaterial qualitative discrepancy.


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GHG Report Element



Application of approved quantification protocol

Substantive 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 Responsible Party has generated comprehensive pre-installation and post-installation engine performance maps using a dataset of measured engine speeds and loads for the specific engine make and classification applicable for this aggregated project. These performance maps are used to estimate the pre- and post-installation Brake Specific Fuel Consumption (BSFC) for each engine in the aggregated project based on actual operating parameters (engine speed and load) during the reporting period. Occasionally the performance map does not encompass the actual operating conditions of a specific engine. In these cases, an average fractional change and associated adjustment factor are applied in accordance with the flexibility mechanism described in the Protocol.

Although the Verification Team was not able to replicate the construction of the performance map, we reviewed the methodology in detail, performed correlation checks on the performance map, and independently replicated the output values from it, that were used in the quantification.

The Verification Team has concluded that the quantification methods have been implemented in the Responsible Party’s quantification appropriately.

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


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GHG Report Element



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

The independent recalculation of the emission reduction reasonably matched the emission reduction quantity asserted by the Responsible Party. Therefore, the Verification Team concluded that the approved Protocol quantification methods were applied in the Responsible Party’s emission reduction quantification.

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

Quantification of emission reduction


Other than the discrepancy described above (exclusion of the emission reduction attributed to the last day of the reporting period), the independent recalculation of the emission reduction reasonably matched the emission reduction quantity asserted by the Responsible Party. Therefore, the Verification Team concluded that no arithmetic or calculation errors were made by the Responsible Party in the emission reduction quantification.

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

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

Complete Table 1 to indicate if the GHG assertion conforms to the Technology Innovation and Emission Reduction Regulation and the Standard for Greenhouse Gas Emission Offset Project Developers eligibility criteria.


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Table 4: Findings of Criteria Verification Procedures

GHG Report Element


Protocol Applicability Requirements

Determination of BSFC and fractional change in fuel consumption must be completed according to Protocol guidelines

Substantive test: Observe operations and interview operations staff during site visit to determine if any modifications have been made to equipment that may impact the measured BSFC.

During the site visits, equipment was observed and operations personnel were interviewed to determine if any modifications have been made since the installation of the engine fuel management systems.

No discrepancies were detected in the determination of BSFC and fractional change in fuel consumption.

Functional equivalence must be demonstrated; engine performance must not be impaired because of the project

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

During the site visits, the verification team observed the engine fuel management and vent gas capture systems, and found that an equivalent level of service is provided by all installations.

Operations personnel indicated that the systems work well and reliably, and that engine performance and level of service have not been impacted.

No discrepancies were detected in the functional equivalence of the baseline and project conditions.

Capture of vent gas must not be required by regulation

Substantive test: Review the venting sources and volumes for each site and compare against the Directive 60 requirements.

All vent gas captured by the subprojects in this aggregated project is from pneumatic devices and compressor seals which are exempt from Directive 60 requirements until January 1, 2023. No regulations requiring the capture and destruction or conservation of vent gas emissions were found to apply to the subprojects included in this aggregated project.

No discrepancies were detected in the eligibility of captured vent gas.


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GHG Report Element


The project must comply with all air emission regulations in Alberta

Substantive test: Review the venting sources and volumes for each site and compare against the Directive 60 requirements.

No regulations requiring the capture and destruction or conservation of vent gas emissions were found to apply to the subprojects included in this aggregated project.

No discrepancies were detected in the compliance of the Project with air emission regulations in Alberta.

For projects that include the capture and combustion of solution gas, the project proponent must justify that the Solution Gas Protocol is not applicable.

Not applicable: No subprojects are capturing and combustion solution gas.

Not applicable

Quantification must be based on actual measurements and monitoring.

Substantive test: Review quantification data for anomalies or missing data.

All of the subprojects included in this aggregated project are equipped with a GHG data logger unit which records the relevant parameters used in the quantification on a daily frequency.

No discrepancies were detected in the source or basis of the data used in the quantification.


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GHG Report Element


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

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

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

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

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

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


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GHG Report Element


Protocol Flexibility

Fractional fuel savings data from other engines of the same make and classification may be applied for engine fuel management projects where pre and post audit data is not available.

Substantive test: Review instances where pre and post audit data are not available, and evaluate if fractional fuel savings was applied appropriately.

The Responsible Party has generated comprehensive pre-installation and post-installation engine performance maps using a dataset of measured engine speeds and loads for a specific engine make and classification. These performance maps are used to estimate the pre- and post-installation Brake Specific Fuel Consumption (BSFC) for each engine in the aggregated project based on actual operating parameters (engine speed and load) during the reporting period. Occasionally the performance map does not encompass the actual operating conditions of a specific engine. In these cases, an average fractional change and associated adjustment factor are applied in accordance with the flexibility mechanism described in the Protocol.


Substantive test: Recalculate the emission reduction from original data applying the fractional fuel savings method where appropriate.

The independent recalculation of the emissions reduction confirmed that the average fractional fuel savings method has been applied correctly where appropriate.

No discrepancies were detected in the use of average fractional fuel savings data.

Implementation of vent gas capture at multiple facilities.

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

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

No discrepancies were detected in the completeness of the data and documentation for the vent gas capture system installations included in this aggregated project.


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GHG Report Element


For engines that operate at constant speed, the simple or advanced approaches may be altered to include measurement at one rpm for each load.

Not applicable for this project (no constant speed engines are included in the aggregated project).

Not applicable

Site specific emission factors may be applied

Substantive test: Confirm validity of gas composition data and recalculate site specific CO2 emission factors from original data.

Gas composition data was complete for all subprojects. Site specific CO2 emission factors were independently recalculated from the original gas analysis data.

No discrepancies were detected in the site specific emission factors applied in the quantification.


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Table 5: Offset Criteria Assessment

Offset Eligibility Criteria

Assessment

The reduction or sequestration must occur in Alberta;

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

The reduction or sequestration

(i) must result from an action taken that is not required by law at the time the action is taken, and

(ii) must not be required by law at the time the reduction or sequestration occurs;

The project activity is not required by municipal, provincial or federal regulations or directives and did not result from an action that was required by law at the time the action was taken.

The reduction or sequestration must (i) result from an action taken on or after January 1, 2002, and

(ii) occur on or after January 1, 2002;

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

The reduction or sequestration must be 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.

The reduction or sequestration must be quantifiable and measurable, directly or by accurate estimation using replicable techniques;

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.

The specified gas emissions that were reduced or the carbon dioxide that was sequestered must not have had an effect on the determination of a regulated facility’s total regulated emissions under section 13(3) or (4).

None of the subprojects included in this aggregated project are located at Regulated Facilities. None of the emission reductions occur at Regulated Facilities.


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If reverification confirm the project was verified by a third party verifier that meets the requirements in Part 1 for the Standard for Validation, Verification, and Audit.

Not applicable. This is not a reverification.


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4.4 Evaluation of the GHG Assertion The verification assessment is that the GHG Assertion meets the requirements of the Technology Innovation and Emissions Reduction 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 upon 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 two discrepancies detected through the course of the verification that have not been corrected in the final GHG Assertion. These discrepancies are described in the following section. The aggregate of these discrepancies is within the materiality threshold established at the outset of the verification.

4.5 Summary of Findings Provide a summary of any material and all 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”. The “Issues Log” will include both resolved and unresolved issues from the verification. Only 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. Indicate if the finding was resolved or unresolved.

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 finding. If the finding is a resolved immaterial or material finding, then record the finding in Appendix C. .

Indicate the type of error (qualitative or quantitative).

Indicate the Project or Baseline Source/Sink.

Indicate if the finding is an understatement or overstatement.

Provide both net and absolute error in tonnes of CO2 eq and as a % of the assertion.

Provide the total net error and the total absolute error in tonnes of CO2 eq and as a % of the assertion.

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

Understatement/Overstatement

Tonnes CO2 eq % net

Tonnes CO2 eq % absolute

18-02 Quantitative For most of the subprojects, the engine parameters used in the quantification are recorded by a GHG data logger. The data logger reports “Yesterday Uptime hours”, “Yesterday Engine Fuel Mass” and “Yesterday Slipstream Fuel Mass”, meaning that the data for the last day of the reporting period is reported the following day. The Responsible Party excluded the data for the last day of the reporting period, even when it was provided in the GHG output files.

Understatement -4 tonnes CO2e

-0.26%

4 tonnes CO2e

0.26%

18-05 Qualitative Some EFM / vent gas capture systems involve the installation of additional pneumatic devices which, if supplied by instrument gas, may result in additional venting in the project condition, or an

Overstatement or understatement

N/A N/A


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inflated baseline condition (if they are tied into the VGC system).


The impact of incremental venting emissions from additional pneumatic devices would have a very small impact on the total emissions reduction.

Total % Error -4 tonnes CO2e

-0.26%

4 tonnes CO2e

0.26%


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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.

Identify opportunities for improvement that may improve the report. Identify ways in which the project 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 Complete and include a signed Verification Statement in Appendix D.

Note: To insert a PDF, click Insert and then Object. In the Object dialog box, click Create from File, and then click Browse. Find the PDF you want to insert then click Insert. Click OK.

Provide the verification conclusion in the drop down box below:

The verification conclusion is: Positive

5.2 Limitation of Liability Complete and include a signed Conflict of Interest Checklist in Appendix E.

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

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

Table 5: 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 project and legal location information is complete and accurate.


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Quantification Methodology document is provided and consists of the required components

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

Simplified process flow diagrams and energy diagrams

The Responsible Party’s Offset Project Plan and Offset Project report provide process flow diagrams, which were reviewed and found to accurately represent the Project.

Fuel usage This requirement is not applicable to Offset Projects.

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

The Statutory Declaration was reviewed and found to be complete.

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

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

This requirement is not applicable to Offset Projects.

For forecasting facilities, the fund to credit ratio was met


For oil sands facilities, the area fugitive calculations are accounted for, as required


For emission offset projects, confirm alignment with project report plan and project report form requirements

The Responsible Party has prepared an Offset Project Plan and an Offset Project Report that meet all the requirements specified in the Standard for Greenhouse Gas Emission Offset Project Developers, Version 2.0, July 2018

For an aggregate facility, confirm that the compliance report or application includes all of the individual facilities.


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

List N/A if there are no references.

No reference documents, other than the criteria documents listed in Section 2.4, were used to complete this verification.

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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 include but not limited to:

Revisions to the sampling plan

Date originally sent to project developer

Level of assurance agreed with the 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: outlines risks of potential errors, omissions or misrepresentations that are identified throughout the verification process including:

• Details of site visit • Offset 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, GHG 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]

Blue Source Canada ULC

Alberta REMVue Engine Fuel Management and Vent Gas Capture Aggregation Projects

Verification Plan

January 8, 2020

This page intentionally blank

Brightspot Climate Inc. – Verification Plan Blue Source Canada ULC – Alberta REMVue EFM and VGC Aggregation Projects

i

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 Environment and Parks Standard for Validation, Verification and Audit1 extends this

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

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

time.

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

cause greenhouse gas emission reductions or greenhouse gas removal enhancements.

The GHG Assertion subject of this verification is for the following projects, which will be referred

to throughout this document as “the Projects”:

• Alberta REMVue Engine Fuel Management and Vent Gas Capture Aggregation Project

(ID# 1090-6410) [P1]

• Alberta REMVue Engine Fuel Management and Vent Gas Capture 2015-2022

Aggregation Project (ID# 3457-6570) [P2]


(Bluesource Pool A) (ID#8056-2592) [P3]

• Alberta REMVue Engine Fuel Management and Vent Gas Capture 2019-2027

Aggregation Project (ID# 9038-9497) [P4]

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 Blue Source Canada ULC (Bluesource).

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 Environment and Parks (AEP).

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

and reporting on the verification process.

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

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

1 Standard for Validation, Verification and Audit, Version 4.0, November 2019, Alberta Environment and Parks.


1

Introduction

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

independent verification of the Offset Project Report for the Alberta REMVue EFM and VGC

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

Protocol for Engine Fuel Management and Vent Gas Capture, Version 2.0, June 2018 (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 14064-2 defines these principles as follows:

Accuracy: reduce bias and uncertainty as far as practical

Completeness: include all relevant emission sources

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

emission reductions or removal enhancements are not over-estimated

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

between facilities or between companies)

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

appropriate to the needs of the intended user

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

to allow intended users to make decisions with relative confidence


2

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 Alberta

Environment and Parks Guidance Document2, Section 5.1.3

Criteria

• Climate Change and Emissions Management Act

• Technology Innovation and Emissions Reduction Regulation

133/2019

• Standard for Validation, Verification and Audit, Version 4.0,

November 2019

• Standard for Greenhouse Gas Emission Offset Project Developers,

Version 3.0, November 2019

• Quantification Protocol for Engine Fuel Management and Vent Gas

Capture, Version 2.0, June 2018

2 Standard for Validation, Verification and Audit, Version 4.0, November 2019. Alberta Environment and Parks.


3

Scope

Project Names: Alberta REMVue Engine Fuel Management and

Vent Gas Capture Aggregation Project (ID# 1090-

6410) [P1]

• Alberta REMVue Engine Fuel Management and

Vent Gas Capture 2015-2022 Aggregation Project

(ID# 3457-6570) [P2]


Vent Gas Capture Aggregation Project (Bluesource

Pool A) (ID#8056-2592) [P3]


Vent Gas Capture 2019-2027 Aggregation Project

(ID# 9038-9497) [P4]

Geographic Boundary: All subprojects are located within Alberta’s

provincial boundary.

Physical Operations: Natural gas processing and compression:

• Reciprocating engines

• Pneumatic devices and controllers

Emission Sources: Engine Fuel Management and Vent Gas Capture

• B1: Fuel Extraction and Processing

• P1: Fuel Extraction and Processing

• B4: Unit Operation

• P4: Unit Operation

• B5b: Venting of Emissions Captured in Project

• P5b: Capture of Vent Gases

IPCC GHGs Emitted: Carbon Dioxide (CO2)

Methane (CH4)

Nitrous Oxide (N2O)

Reporting Period: P1: October 1, 2018 - September 30, 2019

P2: October 1, 2018 - September 30, 2019

P3a: October 3, 2018 – December 31, 2018

P3b: January 1, 2019 – September 30, 2019*

P4: February 1, 2019 - September 30, 2019

* The original crediting period for the Alberta REMVue Engine Fuel

Management and Vent Gas Capture Aggregation Project (Bluesource Pool

A) project [P3] ended on December 31, 2018. The Project was granted an

extension. The Responsible Party has split what was originally one reporting

period for P3 into two separate reporting periods; one ending on the last

day of the original crediting period and the other starting on the first day of


4

the extension. The verification for these two reporting periods will be

conducted simultaneously.

Materiality Quantitative materiality threshold is 5% of asserted greenhouse gas

emission reduction.

Preliminary Verification

Schedule

Verification Kickoff Meeting November 5, 2019

Draft Verification Plan January 8, 2020

Site Visits January 13-14, 2020

Draft Verification Report January 24, 2020

Final Verification Report January 31, 2020

Verification Team

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

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

matter areas defined in the ISO 14064-3.

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

the verification procedures and the development of the Verification Report.

Deepika Mahadevan, P.Eng., will conduct an independent peer review of the verification.

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

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

Site Visit Safety Requirements

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

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

be completed before entering the site.


5

Responsible Party Data Management and Controls

Data Management Systems

The Carbon Solutions Analyst from Blue Source Canada, as the project aggregator, has the primary

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

required documentation.

The Responsible Party uses a set of Excel spreadsheets to manage GHG information and quantify the

emission reduction. Table 2, below, describes the data measurement, estimation and data storage

locations for all GHG information used by the Responsible Party to produce the GHG inventory. The

final column in this table describes the data storage location and the path (intermediate data transfer)

prior to use in the GHG inventory.

Table 2: GHG Information Data Management

Activity Data Description Measurement Type Data Storage Location / Path

Mass of fuel gas consumed in

the engine

Metered Metered quantity

>> GHG Logger file

>> Bluesource Calculator

Fuel gas analysis (density, %

CnHm)

Third party laboratory

analysis;

Annual fuel gas

sampling

Laboratory report

>> Manual transfer


Mass of vent gas consumed in

the engine

Metered Metered quantity

>> GHG Logger file


Vent gas analysis (density, %

CnHm)

Third party laboratory

analysis;

Annual or semiannual

vent gas sampling

Laboratory report

>> Manual transfer


Fuel Index Continuous monitoring Measured quantity

>> GHG Logger file


Engine runtime Continuous monitoring Measured quantity

>> GHG Logger file


Engine speed Continuous monitoring;

averaged monthly

Measured quantity

>> GHG Logger file


Rated engine load and speed Manufacturer

specifications

Reference values

>> Manual transfer



6

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.

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

with manufacturer guidelines.

• Data is transferred electronically between systems to reduce transcription errors.

• Gas composition is analyzed by a third-party laboratory.

• The Responsible Party has implemented a QA/QC and senior review process to validate data,

transcription, calculations, references and methodologies.

• All quantification data is stored on the Responsible Party’s corporate server in a unique project

folder under the date it was downloaded. Electronic data is backed up by a third-party service

provider.

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

of the Regulation.

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

relevance and transparency. The OPP documents:

• Project boundary

• Project processes

• Emission sources, including negligible emission sources

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

• Activity data used to quantify emissions

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

quantification of emissions and production

• Emission factors and references

• Meter maintenance processes

• Data management

• Data quality controls and procedures


7

Previous GHG Assertions

Changes to Operations and Boundaries

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

The Offset Project Plans for the Projects have been updated to reference Version 2.0 of the Protocol.

Otherwise no changes to the Projects have been identified.

Findings from Previous Verifications

This is the first verification for the following two projects, and there are therefore no previous

verifications or findings:


(Bluesource Pool A) (ID#8056-2592)

• Alberta REMVue Engine Fuel Management and Vent Gas Capture 2019-2027 Aggregation

Project (ID# 9038-9497)

The previous verification report for the Alberta REMVue Engine Fuel Management and Vent Gas

Capture Aggregation Project (ID# 1090-6410) project did not note any unresolved findings.

The previous verification report for the Alberta REMVue Engine Fuel Management and Vent Gas

Capture 2015-2022 Aggregation Project (ID# 3457-6570) project identified the following findings:

• The fuel gas meter for engine 0928S may not be accurate based on the verifier’s observation

that the REMVue panel was reading fuel usage for the engine while the unit was shut down.

• The average engine speed, fuel use and engine load data for the Canlin P3U2 and P1B engines

include data that are not representative of operating conditions.

• The raw engine speed and Fuel Index data aggregated by Bluesource for the Canlin P3B

engine included zeroes on two days.

• The raw engine speed and Fuel Index data aggregated by Bluesource for the Canlin 0908N

engine included zeroes on one day.

• The Canlin engine P3U2 had negative fuel use on one day despite having 24 hour uptime.

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

underlying issues have been addressed.


8

Verification Risk Assessment and Verification Procedures

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

product of

• The Facility’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 auditor.

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

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

reporting activity being evaluated.

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

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

transparency)

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

and the verifier’s evaluation of control risks.

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

verification risk that meets the agreed level of assurance.

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

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

maximum detection risk.

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

the equation above.

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

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

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

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

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

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

control test.


9

Table 3: Verification Risk Assessment Summary

Source or Risk Area Attributes Inherent Risk Control Risk Detection

Risk


PROTOCOL APPLICABILITY REQUIREMENTS

Determination of BSFC

and fractional change in

fuel consumption must

be completed according

to Protocol guidelines

Accuracy Low

Equipment modifications

could impact the

measured BSFC and

therefore the validity of the

calculated fuel savings.

High

The Responsible Party

does not have a control

specifically designed to

address this inherent risk.

Medium Substantive test: Observe

operations and interview

operations staff during site

visit to determine if any

modifications have been made

to equipment that may impact

the measured BSFC.

Functional equivalence

must be demonstrated;

engine performance

must not be impaired

because of the project

Occurrence High

Level of service may have

changed between the

baseline and project

conditions.

High





Low Substantive test: Observe

operations and interview

operations staff during site

visit to determine level of

service provided by project

implementation.

Capture of vent gas must

not be required by

regulation

Relevance High

Vent gas capture may be

required by Directive 60.

High





Low Substantive test: Review the

venting sources and volumes

for each site and compare

against the Directive 60

requirements.


10


Risk


The project must comply

with all air emission

regulations in Alberta

Relevance High

Vent gas capture may be

required to be flared or

captured.

High





Low Substantive test: Review the

venting sources and volumes

for each site and compare

against the Directive 60

requirements.

For projects that include

the capture and

combustion of solution

gas, the project

proponent must justify

that the Solution Gas

Protocol is not

applicable.

N/A N/A N/A N/A Not applicable: No

subprojects are capturing and

combustion solution gas.

Quantification must be

based on actual

measurements and

monitoring.

Relevance High

Estimates may have been

applied, particularly for

missing data.

High





Low Substantive test: Review

quantification data for

anomalies or missing data.

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.

High





Low Substantive test: Evaluate the

project developer’s evidence

regarding the general

requirements of the Alberta

Offset System.


11


Risk


PROTOCOL FLEXIBILITY

Fractional fuel savings

data from other engines

of the same make and

classification may be

applied for engine fuel

management projects

where pre and post audit

data is not available.

Accuracy

Occurrence

Medium

Available data may not be

sufficient or may be

applied incorrectly.

High





Low Substantive test: Review

instances where pre and post

audit data are not available,

and evaluate if fractional fuel

savings was applied

appropriately.

Substantive test: Recalculate

the emission reduction from

original data applying the

fractional fuel savings method

where appropriate.

Implementation of vent

gas capture at multiple

facilities.

Completeness Medium

The project aggregates

installations at multiple

project sites. The data and

documentation may not be

complete for all sites.

High





Low Substantive test: Evaluate the

completeness of the required

data and documentation for all

project sites included in the

aggregated project.


12


Risk


For engines that operate

at constant speed, the

simple or advanced

approaches may be

altered to include

measurement at one rpm

for each load.

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

(no constant speed engines

are included in the aggregated

project).

Site specific emission

factors may be applied

Accuracy

Occurrence

Low

Site specific emission

factors may not be

calculated correctly or may

be based on invalid data.

High





Low Substantive test: Confirm

validity of gas composition

data and recalculate site

specific emission factors from

original data.

ACTIVITY DATA

Mass of fuel gas

consumed in the engine

Accuracy High

The metered fuel gas 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: Low

The maintenance program

may not be operating

effectively.

Low Controls test: Review meter

calibration reports to

determine if the meter

maintenance program is

operating effectively.


13


Risk


Fuel gas analysis

(density, % CnHm)

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: Low

Validation process may

not be properly

implemented, or

transcription errors may be

introduced.

Low Substantive test: Analyze gas

compositions for abnormal

gas concentrations. Confirm

the accurate transcription of

the gas analysis into the

emission reduction calculation.

Completeness Low

The gas compositions may

not include a valid gas

composition for each

period at the required

frequency.

High





Medium Substantive test: Review

completeness of gas

composition data.


14


Risk


Mass of vent gas

consumed in the engine

Accuracy High

The metered captured

vent gas may be incorrect

if meters are not properly

maintained.


Party has implemented a

meter maintenance

program that includes

periodic meter calibration.

Control Risk: Low

The maintenance program

may not be operating

effectively.


calibration reports to

determine if the meter

maintenance program is


Vent gas analysis

(density, % CnHm)

Accuracy Low

Reported gas

compositions may not

accurately represent the

gas composition or may


into the emission reduction

calculation.

Control: Gas analysis is

conducted by an

independent lab. An

internal process is used to

validate results.

Control Risk: Low

Validation process may

not be properly

implemented, or

transcription errors may be

introduced.


compositions for abnormal

gas concentrations. Confirm

the accurate transcription of

the gas analysis into the

emission reduction calculation.


15


Risk


Completeness Low

The gas compositions may

not include a valid gas

composition for each

period at the required

frequency.

High






completeness of gas

composition data.

Fuel Index Accuracy

Completeness

Low

The fuel index values may

include invalid or

incomplete data.

High





Medium Substantive test: Analyze fuel

index data for abnormal values

and completeness.

Engine runtime Accuracy

Completeness

Low

The engine runtime values

may include invalid or

incomplete data.

High





Medium Substantive test: Analyze

engine runtime data for

abnormal values and

completeness.

Engine speed Accuracy

Completeness

Low

The engine speed values

may include invalid or

incomplete data.

High





Medium Substantive test: Analyze

engine speed data for

abnormal values and

completeness.


16


Risk


Rated engine load and

speed

Accuracy Low

The rated engine load and

engine speed values may


from the manufacturers’

documentation.

High






transcription of all referenced

engine load and speed ratings

from manufacturers’

specifications.

Emission factors

(combustion and fuel

extraction and

processing)

Accuracy Low

The emission factors may


from the reference

documentation.

High






transcription of all emission

factors from reference

documentation.

EMISSION REDUCTION QUANTIFICATION

Inclusion of applicable

emission sources

Completeness

Occurrence

Low

Emission sources may be

excluded from the Project.

Control: OPP is used to

document emission

sources that are included

in the Project.


OPP may be inaccurate or

out of date.

Low Substantive test: Observe

emission sources during site

tour and review against

included SSs in the Protocol.


17


Risk


Application of 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


protocol.


The protocol requirements

may not have been

implemented correctly.

Low Substantive test: Compare the

methodologies described in

the Responsible Party’s Offset

Project Plan to the

methodologies described in

the approved quantification

protocol.


the complete emission

reduction using original data

and methods described in the


protocol.

Quantification of

emission reduction

Accuracy High

Emission reduction

calculation may contain

arithmetic errors.

High





Low Substantive test: Recalculate


reduction using original data.


18


Risk


DATA INTEGRITY

Activity data and

emission factor data

integrity

Accuracy High

Data may not have been

accurately transferred

between electronic

systems and calculation

sheets.


Party uses electronic data

transfers whenever

possible to maintain data

integrity.


Electronic data transfers

may result in errors or may

not be available for all

data.

Low Controls test: Analyze all

metered data for abnormal

data (zeros, missing data,

values outside range).



reduction using original data.

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.

High





Low Substantive test: Compare the

final emission reduction

quantity reported by the

Responsible Party to the

quantity reported in the Offset

Project Report. Also, compare

these quantities to the

recalculated quantity in

previous verification

procedures.


19

Sampling Plan

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

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

Table 4: Sampling Plan

Activity Data /

Inventory

Component

Detection

Risk

Design

Description of Verification

Procedure

Sampling Methodology and

Justification

Sample Size

Mass of fuel gas

consumed in the

engine


calibration reports to determine if

the meter maintenance program is


Review of full dataset has lower

detection risk than sampling.

Annual calibration report for each

of the sites.

Fuel gas analysis

(density, % CnHm)


compositions for abnormal gas

concentrations. Confirm the

accurate transcription of the gas

analysis into the emission reduction

calculation.

There is only one sample per site.



Annual samples for each of the

sites.


completeness of gas composition

data.





sites.

Mass of vent gas

consumed in the

engine


calibration reports to determine if

the meter maintenance program is




Annual calibration report for each

of the VGC sites.


20

Activity Data /

Inventory

Component

Detection

Risk

Design


Procedure


Justification

Sample Size

Vent gas analysis

(density, % CnHm)


compositions for abnormal gas

concentrations. Confirm the

accurate transcription of the gas

analysis into the emission reduction

calculation.





sites.


completeness of gas composition

data.





sites.

Fuel Index Medium Substantive test: Analyze fuel index

data for abnormal values and

completeness.



All values

Engine runtime Medium Substantive test: Analyze engine

runtime data for abnormal values

and completeness.



All values

Engine speed Medium Substantive test: Analyze engine

speed data for abnormal values

and completeness.



All values

Rated engine load

and speed


transcription of all referenced

engine load and speed ratings from

manufacturers’ specifications.



All values


21

Activity Data /

Inventory

Component

Detection

Risk

Design


Procedure


Justification

Sample Size

Emission factors

(combustion and

fuel extraction and

processing)


transcription of all emission factors

from reference documentation.



All values

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Appendix B: Statement of Qualifications

of 87

Statement of Qualifications

Alberta Emission Offset Project

Emission Offset Project Name Offset Project ID

Alberta REMVue Engine Fuel Management and Vent Gas Capture Aggregation Project (Bluesource Pool A) 8056-2592

Emission Offset Project Developer Offset Reporting Period

Blue Source Canada ULC October 3, 2018 December 31, 2018 from to

Signature of Designated Signing Authority

I, Aaron Schroeder

(Designated Signing Authority), meet or exceed the qualifications and eligibility of a third party assurance provider described in Section 27 of the Technology Innovation and Emissions Reduction Regulation.

Third Party Assurance Provider Company Name

Brightspot Climate Inc. Per:

Signature of Designated Signing Authority Date

Training Received meeting Verification Standard requirements

• Greenhouse Gas Verification – ISO 14064-3, Canadian Standards Association, 2012

• Instructor – Greenhouse Gas Verification – ISO 14064-3, University of Toronto, 2015-present

First Name Last Name

Aaron Schroeder

Professional Designation or Accreditation Org/Number E-mail Address Phone Number

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

Lead Verifier

☒ Same as designated signing authority.


Professional Designation or Accreditation Org/Number E-mail Address Phone Number


February 12, 2020

of 87

Peer Reviewer First Name Last Name

Deepika Mahadevan

E-mail Address Phone Number [email protected] (647) 633-8310


• Greenhouse Gas Verification – ISO 14064-3, Canadian Standards Association, 2012

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Appendix C: Findings and Issues

of 87

Table 8: Detailed Findings and Issues Log

Number the issue with the year and provide a unique # for the issue. If the issue is resolved during the verification, indicate that in the resolution column. If the issue is not resolved during the verification, additionally record the finding in Table 2 above.

Describe the issues investigated. State the verification criteria that are not met. Provide a description of how they are not met and provide the evidence. Indicate the Project or Baseline Source/Sink.

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 Resolution (Resolved or Unresolved)

Conclusion (including % discrepancy if applicable)

18-01 A gas analysis from the wrong location was applied in the quantification for one of the subprojects.

The Responsible Party corrected this error.

Resolved Resolved, no discrepancy

18-02 For most of the subprojects, the engine parameters used in the quantification are recorded by a GHG data logger. The data logger reports “Yesterday Uptime hours”, “Yesterday Engine Fuel Mass” and “Yesterday Slipstream Fuel Mass”, meaning that the data for the last day of the reporting period is reported the following day. The Responsible Party excluded the data for the last day of the reporting period, even when it was provided in the GHG output files.

The Responsible Party responded that the final day of the reporting period will not be included for simplicity.

The exclusion of the emission reduction for the last day of the reporting period results in an immaterial quantitative discrepancy of approximately 4 tonnes CO2e (0.26% of the total emission reduction claim).

Unresolved Immaterial quantitative discrepancy (0.26% of total emission reduction claim)

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18-03 The Responsible Party has applied the CH4 and N2O “industrial” emission factors from the Carbon Offset Emission Factors Handbook for combustion of natural gas for some engines, and the “non marketable” emission factors for others. The verification team requested an explanation of the approach to emission factor selection for natural gas combustion.

The Responsible Party explained that the emission factor selection was made based on a comparison of the calculated site specific CO2 emission factor to the reference CO2 emission factor.

Although this approach follows the Quantification Procedures in the Protocol, the verification team noted that the emission factors in the Carbon Offset Emission Factors Handbook do not align with CH4 and N2O emission factors that have been published by AEP for engines.


18-04 The Responsible Party’s alternative Calibration Plan was requested for review.

The Responsible Party provided the final version of the document.

The Verification Team reviewed the document and concluded that this approach, in combination with the producers' preventative maintenance programs, constitutes a meter maintenance program that is sufficient to meet verification requirements at a reasonable level of assurance.


18-05 Some EFM / vent gas capture systems involve the installation of additional pneumatic devices which, if supplied by instrument gas, may result in additional venting in the project condition, or an inflated baseline condition (if they are tied into the VGC system).


The impact of incremental venting emissions from additional pneumatic devices would have a very small impact on the total emissions reduction.

Unresolved Immaterial qualitative discrepancy

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Appendix D: Statement of Verification


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Statement of Verification Alberta Emission Offset Project

Emission Offset Project Title Quantification Protocol (Date/Version) Project ID #


Quantification Protocol for Engine Fuel Management and Vent Gas Capture Projects (version 2.0, June 2018)

8056-2592

Emission Offset Project Developer

Offset Reporting Period Start Serial Range (if

applicable)

Blue Source Canada ULC October 3, 2018 TBD

Authorized Project Contact (if applicable)

Offset Reporting Period End

N/A December 31, 2018

Statement of Verification

Total GHG Assertion Value Units

Total Baseline Emissions 6,847 tonnes CO2eq

Total Project Emissions 5,326 tonnes CO2eq

Other (I.e. levied) 0 tonnes CO2eq

Net Reduction 1,521 tCO2e

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 October 3, 2018 to December 31, 2018 and states an emission reduction and removal claim of 1,521 tonnes CO2e over this period.


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The emission reduction and removal claim consists of 2018 vintage credits.

Responsibilities of Project Developer and Third Party Assurance Provider

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 Technology Innovation and Emission Reduction Regulation (the “Regulation”), and the Standard for Greenhouse Gas Emission Offset Project Developers, Version 3.0, November 2019.

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.


Verification Company Name

Brightspot Climate Inc. Per: Aaron Schroeder


Date:


Aaron Schroeder

Professional Designation/ Accreditation Org & Number E-mail Address Phone Number


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Appendix E: Conflict of Interest Checklist


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Conflict of Interest Checklist Alberta Emission Offset Project Emission Offset Project Title Quantification Protocol (Date/Version)


Quantification Protocol for Engine Fuel Management and Vent Gas Capture Projects (version 2.0, June 2018)

Project Developer Offset Reporting Period Start

Offset Reporting Period End

Blue Source Canada ULC October 3, 2018 December 31, 2018

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, the Verification Report will not be acceptable to Alberta Environment and Parks.


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I, Aaron Schroeder (Designated Signing Authority), 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.

Verification Company Name Brightspot Climate Inc. Per:

Signature of Designated Signing Authority Date:

First Name Last Name Aaron Schroeder

Professional Designation/ Accreditation Org & Number E-mail Address Phone Number


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Appendix F: Supplemental Diagrams/Tables/Figure

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Table 6: Supporting Documentation Reviewed

File Name Description

prj_851_15461.pdf Offset Project Plan

REMVue_OPR_P3_2018_v1.0_01312020_app.pdf Offset Project Report

REMVue EFMVGC Agg, 8056-2592_APRS_v3 - 2018.xlsm

Aggregated Project Reporting Sheet

Gas composition reports, various Gas analysis reports for each subproject site

AFR system installation invoices, various Records of conversion for each subproject

GHG data logger files, various Raw data files from the GHG data logger unit installed on each subproject

Calibration reports, various Fuel gas and vent gas meter calibration reports for each subproject

AppA_Confidential_MasterMap_Methodology.pdf Confidential Appendix to the OPR; description the MasterMap Methodology

EMM User Guide - Rev 3 - Final.pdf MasterMap program user guide

Pre1.csv_20140922_1506_grid.csv

Post1.csv_20140922_1514_grid.csv

MasterMap output files

AB_REMVue_Data_from Spartan.xlsx Input data used to generate the master engine performance map

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.

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