Verification Report for: Aggregation Project (1090-6410) · Alberta REMVue Engine Fuel Management...
Transcript of Verification Report for: Aggregation Project (1090-6410) · Alberta REMVue Engine Fuel Management...
Alberta REMVue Engine Fuel Management and Vent Gas Capture Aggregation Project (1090-6410)
February 2020
Version 3.0 Offset Verification Report Form
Verification Report for: Alberta REMVue Engine Fuel Management and Vent Gas Capture
Aggregation Project (1090-6410)
Proponent Name and Proponent Project Number:
Blue Source Canada ULC (1090-6410)
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 ............................................................................................................ 9 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 ................................................................................. 36 4.4 Evaluation of the GHG Assertion .......................................................................... 44 4.5 Summary of Findings .......................................................................................... 44 4.6 Opportunity for Improvement .............................................................................. 47
5.0 Closure ............................................................................................................. 47 5.1 Verification Statement ........................................................................................ 47 5.2 Limitation of Liability .......................................................................................... 47 5.3 Confirmations .................................................................................................... 47
6.0 References ........................................................................................................ 49 Appendix A: Final Verification Plan and Sampling Plan ............................................................ 50 Appendix B: Statement of Qualifications .............................................................................. 76 Appendix C: Findings and Issues ......................................................................................... 79 Appendix D: Statement of Verification ................................................................................. 84 Appendix E: Conflict of Interest Checklist ............................................................................. 87 Appendix F: Supplemental Diagrams/Tables/Figure ............................................................... 90
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 ............................................................... 37 Table 5: Offset Criteria Assessment ..................................................................................... 42 Table 6: Summary of Findings ............................................................................................ 45 Table 7: Confirmation Findings ........................................................................................... 48 Table 8: Detailed Findings and Issues Log ............................................................................ 80 Table 9: Supporting Documentation Reviewed ...................................................................... 91
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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
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 25, 2005 and is a result of actions taken on, or after, January 1, 2002.
Offset Start Date
Enter the start date for offset credit generation.
January 1, 2013
Offset Crediting Period
Enter the offset crediting period, including the offset start date. Include day, month year.
January 1, 2013 – December 31, 2020
Offset Reporting Period
Enter the offset reporting period being verified.
October 1, 2018 – September 30, 2019
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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.
2018: 4,788 t CO2e
2019: 14,645 t CO2e
Total: 19,433 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.
One other change to the project was identified since the original Offset Project Plan was developed: the OPP indicated that the earliest subproject began on August 8, 2003. However, several subprojects were transferred out of the Project since the OPP was written. Of the remaining subprojects, the earliest start date is August 25, 2005. This change is described in the OPR. The Responsible Party has stated that no other changes to the original project have been identified since the OPP was developed.
No additional changes to the project boundary, emission sources, measurement and monitoring or quantification methodologies were found.
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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;
• 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
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 1, 2018 to September 30, 2019
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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 9 engines from this pool were inspected during the site visits, representing approximately 23.5% 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
The Responsible Party does not have a control specifically designed to address this inherent risk.
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
The Responsible Party does not have a control specifically designed to address this inherent risk.
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
Attributes Inherent Risk Control Risk Detection Risk
Evidence-Gathering Activity
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
The Responsible Party does not have a control specifically designed to address this inherent risk.
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
The Responsible Party does not have a control specifically designed to address this inherent risk.
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
The Responsible Party does not have a control specifically designed to address this inherent risk.
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
Attributes Inherent Risk Control Risk Detection Risk
Evidence-Gathering Activity
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
The Responsible Party does not have a control specifically designed to address this inherent risk.
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
The Responsible Party does not have a control specifically designed to address this inherent risk.
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
Attributes Inherent Risk Control Risk Detection Risk
Evidence-Gathering Activity
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
The Responsible Party does not have a control specifically designed to address this inherent risk.
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
Attributes Inherent Risk Control Risk Detection Risk
Evidence-Gathering Activity
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
The Responsible Party does not have a control specifically designed to address this inherent risk.
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
Attributes Inherent Risk Control Risk Detection Risk
Evidence-Gathering Activity
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
The Responsible Party does not have a control specifically designed to address this inherent risk.
Medium Substantive test: Review completeness of gas composition data.
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Source or Risk Area
Attributes Inherent Risk Control Risk Detection Risk
Evidence-Gathering Activity
Fuel Index Accuracy
Completeness
Low
The fuel index values may include invalid or incomplete data.
High
The Responsible Party does not have a control specifically designed to address this inherent risk.
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
The Responsible Party does not have a control specifically designed to address this inherent risk.
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
The Responsible Party does not have a control specifically designed to address this inherent risk.
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
The Responsible Party does not have a control specifically designed to address this inherent risk.
Low Substantive test: Confirm transcription of all referenced engine load and speed ratings from manufacturers’ specifications.
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Source or Risk Area
Attributes Inherent Risk Control Risk Detection Risk
Evidence-Gathering Activity
Emission factors (combustion and fuel extraction and processing)
Accuracy Low
The emission factors may be incorrectly transcribed from the reference documentation.
High
The Responsible Party does not have a control specifically designed to address this inherent risk.
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.
Control Risk: Medium
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
Attributes Inherent Risk Control Risk Detection Risk
Evidence-Gathering Activity
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
The Responsible Party does not have a control specifically designed to address this inherent risk.
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.
Control Risk: Medium
Low Controls test: Analyze all metered data for abnormal data (zeros, missing data, values outside range).
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Source or Risk Area
Attributes Inherent Risk Control Risk Detection Risk
Evidence-Gathering Activity
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
The Responsible Party does not have a control specifically designed to address this inherent risk.
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 4, 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
There were no unresolved discrepancies identified in the previous verification report.
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 29 tonnes CO2e (0.15% of the total emission reduction claim).
Substantive test: Recalculate the complete emission reduction using original data.
The recalculated emission reductions matched the quantities asserted by the Responsible Party. It is therefore a reasonable conclusion that data integrity has been maintained from points of metering through reporting.
No discrepancies were detected in the accuracy of the emission reduction quantification.
Transcription of final emission reduction into Offset Project Report
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 Procedures
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
Verification Procedures
Verification Findings
Substantive test: Review completeness of gas composition data.
Gas composition data was complete for all subprojects with four exceptions.
Four subprojects did not have gas analyses with sample dates within the reporting period. The most current available gas analyses were used for these subprojects. This approach does not meet the Protocol requirements, resulting in a quantitative discrepancy.
In order to estimate the error associated with this discrepancy, the verification team calculated a default gas composition from the dataset of valid gas analysis data, and applied it to the four subprojects that do not have valid gas analyses.
The resulting estimated discrepancy is an overstatement of approximately 150 tonnes CO2e (0.77% of the total emission reduction claim).
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.
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GHG Report Element
Verification Procedures
Verification Findings
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.
No discrepancies were detected in the gas composition analyses used in the quantification.
Substantive test: Review completeness of gas composition data.
No discrepancies were detected in the completeness of the gas composition data used in the quantification.
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. For one EFM subproject, fuel index data was not captured. For this subproject, the calculated average fractional change and adjustment factor were applied as per the flexibility mechanism outlined in the Protocol.
No discrepancies were detected in the fuel index data used in the quantification.
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GHG Report Element
Verification Procedures
Verification Findings
Engine runtime Substantive test: Analyze engine runtime data for abnormal values and completeness.
For most of the engines in this aggregated project, engine runtime is automatically recorded by the GHG data logger.
For engines that are not equipped with a GHG data logger, engine downtime is recorded monthly by operators in the Detechtion system. The verification team recalculated the engine runtime from this data.
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
Verification Procedures
Verification Findings
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.
No discrepancies detected.
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
Verification Procedures
Verification Findings
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
Verification Procedures
Verification Findings
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
Substantive test: Recalculate the complete emission reduction using original data.
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
Verification Procedures Verification Findings
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
Verification Procedures Verification Findings
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.
Most 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. For subprojects without a GHG data logger unit, relevant parameters are recorded monthly by a compressor management and optimization software tool (“Detechtion – Enalysis”).
No discrepancies were detected in the source or basis of the data used in the quantification.
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GHG Report Element
Verification Procedures Verification Findings
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
Verification Procedures Verification Findings
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.
No discrepancies detected.
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
Verification Procedures Verification Findings
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 with four exceptions (described above in the previous Verification Findings).
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 three 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
19-04 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 -29 tonnes CO2e
-0.15%
29 tonnes CO2e
0.15%
19-11 Quantitative Gas composition data was complete for all subprojects with four exceptions. Four subprojects did not have gas analyses with sample dates within the reporting period. The most current available gas analyses were used for these subprojects. This approach does not
Overstatement 150 tonnes CO2e
0.77%
150 tonnes CO2e
0.77%
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meet the Protocol requirements, resulting in a quantitative discrepancy.
19-12 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 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.
Overstatement or understatement
N/A N/A
Total % Error 121 tonnes CO2e
0.62%
179 tonnes CO2e
0.92%
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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.
One Opportunity for Improvement was identified through the course of the verification: For one of the subprojects, fuel gas composition was measured daily by a gas chromatograph. The Responsible Party calculated a straight annual average from the gas chromatograph data. Calculating a weighted average rather than a straight average would have been a more accurate method and a best practice approach.
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.
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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.
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
This requirement is not applicable to Offset Projects.
For oil sands facilities, the area fugitive calculations are accounted for, as required
This requirement is not applicable to Offset Projects.
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.
This requirement is not applicable to Offset Projects.
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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
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Terminology
ISO 14064-2 defines the following terms used in the context of a GHG verification:
GHG Assertion: a declaration or factual and objective statement made by the Responsible
Party.
The Alberta 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]
• Alberta REMVue Engine Fuel Management and Vent Gas Capture Aggregation Project
(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.
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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
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Verification
Verification Principles
ISO 14064-3 defines four fundamental principles to conducting a greenhouse gas verification, namely
independence, ethical conduct, fair presentation and due professional care.
Brightspot Climate has implemented processes, including mandatory training for all verification team
members, to ensure the application of these principles for this verification.
Regarding the principle of independence, Brightspot Climate conducted an assessment of threats to
independence prior to initiating this verification. No real or perceived threats to independence were
identified. Brightspot Climate will continue to monitor for threats to independence throughout the
course of this verification. A final “Conflict of Interests Checklist” will be appended to the Verification
Statement.
Verification Parameters
The verification will be conducted according to the parameters defined in the following table:
Table 1: Verification Parameters
Level of Assurance Reasonable assurance
Objectives
• issue a verification statement on whether the GHG assertion is
without material discrepancy;
• issue a verification report that provides details of the verification
activities; and
• complete the “confirmations” activities defined in the 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.
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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]
• Alberta REMVue Engine Fuel Management and
Vent Gas Capture Aggregation Project (Bluesource
Pool A) (ID#8056-2592) [P3]
• Alberta REMVue Engine Fuel Management and
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
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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.
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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
>> Bluesource Calculator
Mass of vent gas consumed in
the engine
Metered Metered quantity
>> GHG Logger file
>> Bluesource Calculator
Vent gas analysis (density, %
CnHm)
Third party laboratory
analysis;
Annual or semiannual
vent gas sampling
Laboratory report
>> Manual transfer
>> Bluesource Calculator
Fuel Index Continuous monitoring Measured quantity
>> GHG Logger file
>> Bluesource Calculator
Engine runtime Continuous monitoring Measured quantity
>> GHG Logger file
>> Bluesource Calculator
Engine speed Continuous monitoring;
averaged monthly
Measured quantity
>> GHG Logger file
>> Bluesource Calculator
Rated engine load and speed Manufacturer
specifications
Reference values
>> Manual transfer
>> Bluesource Calculator
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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
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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:
• Alberta REMVue Engine Fuel Management and Vent Gas Capture Aggregation Project
(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.
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Verification Risk Assessment and Verification Procedures
Verification risk is defined as the risk of an incorrect verification conclusion. It can be calculated as the
product of
• 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.
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Table 3: Verification Risk Assessment Summary
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
The Responsible Party
does not have a control
specifically designed to
address this inherent risk.
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
The Responsible Party
does not have a control
specifically designed to
address this inherent risk.
Low Substantive test: Review the
venting sources and volumes
for each site and compare
against the Directive 60
requirements.
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Source or Risk Area Attributes Inherent Risk Control Risk Detection
Risk
Evidence-Gathering Activity
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
The Responsible Party
does not have a control
specifically designed to
address this inherent risk.
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
The Responsible Party
does not have a control
specifically designed to
address this inherent risk.
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
The Responsible Party
does not have a control
specifically designed to
address this inherent risk.
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 Attributes Inherent Risk Control Risk Detection
Risk
Evidence-Gathering Activity
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
The Responsible Party
does not have a control
specifically designed to
address this inherent risk.
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
The Responsible Party
does not have a control
specifically designed to
address this inherent risk.
Low Substantive test: Evaluate the
completeness of the required
data and documentation for all
project sites included in the
aggregated project.
Brightspot Climate Inc. – Verification Plan Blue Source Canada ULC – Alberta REMVue EFM and VGC Aggregation Projects
12
Source or Risk Area Attributes Inherent Risk Control Risk Detection
Risk
Evidence-Gathering Activity
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
The Responsible Party
does not have a control
specifically designed to
address this inherent risk.
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.
Brightspot Climate Inc. – Verification Plan Blue Source Canada ULC – Alberta REMVue EFM and VGC Aggregation Projects
13
Source or Risk Area Attributes Inherent Risk Control Risk Detection
Risk
Evidence-Gathering Activity
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
The Responsible Party
does not have a control
specifically designed to
address this inherent risk.
Medium Substantive test: Review
completeness of gas
composition data.
Brightspot Climate Inc. – Verification Plan Blue Source Canada ULC – Alberta REMVue EFM and VGC Aggregation Projects
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Source or Risk Area Attributes Inherent Risk Control Risk Detection
Risk
Evidence-Gathering Activity
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.
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.
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.
Brightspot Climate Inc. – Verification Plan Blue Source Canada ULC – Alberta REMVue EFM and VGC Aggregation Projects
15
Source or Risk Area Attributes Inherent Risk Control Risk Detection
Risk
Evidence-Gathering Activity
Completeness Low
The gas compositions may
not include a valid gas
composition for each
period at the required
frequency.
High
The Responsible Party
does not have a control
specifically designed to
address this inherent risk.
Medium Substantive test: Review
completeness of gas
composition data.
Fuel Index Accuracy
Completeness
Low
The fuel index values may
include invalid or
incomplete data.
High
The Responsible Party
does not have a control
specifically designed to
address this inherent risk.
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
The Responsible Party
does not have a control
specifically designed to
address this inherent risk.
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
The Responsible Party
does not have a control
specifically designed to
address this inherent risk.
Medium Substantive test: Analyze
engine speed data for
abnormal values and
completeness.
Brightspot Climate Inc. – Verification Plan Blue Source Canada ULC – Alberta REMVue EFM and VGC Aggregation Projects
16
Source or Risk Area Attributes Inherent Risk Control Risk Detection
Risk
Evidence-Gathering Activity
Rated engine load and
speed
Accuracy Low
The rated engine load and
engine speed values may
be incorrectly transcribed
from the manufacturers’
documentation.
High
The Responsible Party
does not have a control
specifically designed to
address this inherent risk.
Low Substantive test: Confirm
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
be incorrectly transcribed
from the reference
documentation.
High
The Responsible Party
does not have a control
specifically designed to
address this inherent risk.
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.
Brightspot Climate Inc. – Verification Plan Blue Source Canada ULC – Alberta REMVue EFM and VGC Aggregation Projects
17
Source or Risk Area Attributes Inherent Risk Control Risk Detection
Risk
Evidence-Gathering Activity
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.
Control Risk: Medium
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.
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
The Responsible Party
does not have a control
specifically designed to
address this inherent risk.
Low Substantive test: Recalculate
the complete emission
reduction using original data.
Brightspot Climate Inc. – Verification Plan Blue Source Canada ULC – Alberta REMVue EFM and VGC Aggregation Projects
18
Source or Risk Area Attributes Inherent Risk Control Risk Detection
Risk
Evidence-Gathering Activity
DATA INTEGRITY
Activity data and
emission factor data
integrity
Accuracy High
Data may not have been
accurately transferred
between electronic
systems and calculation
sheets.
Control: The Responsible
Party uses electronic data
transfers whenever
possible to maintain data
integrity.
Control Risk: Medium
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).
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
The Responsible Party
does not have a control
specifically designed to
address this inherent risk.
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.
Brightspot Climate Inc. – Verification Plan Blue Source Canada ULC – Alberta REMVue EFM and VGC Aggregation Projects
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
Low Controls test: Review meter
calibration reports to determine if
the meter maintenance program is
operating effectively.
Review of full dataset has lower
detection risk than sampling.
Annual calibration report for each
of the sites.
Fuel gas analysis
(density, % CnHm)
Low Substantive test: Analyze gas
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.
Review of full dataset has lower
detection risk than sampling.
Annual samples for each of the
sites.
Medium Substantive test: Review
completeness of gas composition
data.
There is only one sample per site.
Review of full dataset has lower
detection risk than sampling.
Annual samples for each of the
sites.
Mass of vent gas
consumed in the
engine
Low Controls test: Review meter
calibration reports to determine if
the meter maintenance program is
operating effectively.
Review of full dataset has lower
detection risk than sampling.
Annual calibration report for each
of the VGC sites.
Brightspot Climate Inc. – Verification Plan Blue Source Canada ULC – Alberta REMVue EFM and VGC Aggregation Projects
20
Activity Data /
Inventory
Component
Detection
Risk
Design
Description of Verification
Procedure
Sampling Methodology and
Justification
Sample Size
Vent gas analysis
(density, % CnHm)
Low Substantive test: Analyze gas
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.
Review of full dataset has lower
detection risk than sampling.
Annual samples for each of the
sites.
Medium Substantive test: Review
completeness of gas composition
data.
There is only one sample per site.
Review of full dataset has lower
detection risk than sampling.
Annual samples for each of the
sites.
Fuel Index Medium Substantive test: Analyze fuel index
data for abnormal values and
completeness.
Review of full dataset has lower
detection risk than sampling.
All values
Engine runtime Medium Substantive test: Analyze engine
runtime data for abnormal values
and completeness.
Review of full dataset has lower
detection risk than sampling.
All values
Engine speed Medium Substantive test: Analyze engine
speed data for abnormal values
and completeness.
Review of full dataset has lower
detection risk than sampling.
All values
Rated engine load
and speed
Low Substantive test: Confirm
transcription of all referenced
engine load and speed ratings from
manufacturers’ specifications.
Review of full dataset has lower
detection risk than sampling.
All values
Brightspot Climate Inc. – Verification Plan Blue Source Canada ULC – Alberta REMVue EFM and VGC Aggregation Projects
21
Activity Data /
Inventory
Component
Detection
Risk
Design
Description of Verification
Procedure
Sampling Methodology and
Justification
Sample Size
Emission factors
(combustion and
fuel extraction and
processing)
Low Substantive test: Confirm
transcription of all emission factors
from reference documentation.
Review of full dataset has lower
detection risk than sampling.
All values
Page 76 of 91
Appendix B: Statement of Qualifications
Page 77 of 91
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 1090-6410
Emission Offset Project Developer Offset Reporting Period
Blue Source Canada ULC October 1, 2018 September 30, 2019 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.
First Name Last Name
Professional Designation or Accreditation Org/Number E-mail Address Phone Number
Training Received meeting Verification Standard requirements
Februrary 12, 2020
Page 78 of 91
Peer Reviewer First Name Last Name Deepika Mahadevan E-mail Address Phone Number [email protected] (647) 633-8310
Training Received meeting Verification Standard requirements
• Greenhouse Gas Verification – ISO 14064-3, Canadian Standards Association, 2012
Page 79 of 91
Appendix C: Findings and Issues
Page 80 of 91
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)
19-01 The Responsible Party applied an average gas composition for one subproject. This approach does not meet Protocol requirements.
The Responsible Party obtained a valid gas analysis for this subproject and applied it in the revised quantification.
Resolved Resolved, no discrepancy
19-02 A discrepancy was noted between the data logger file names and the panel number indicated in the file, for two subprojects.
The Responsible Party confirmed the correct panel for these units.
Resolved Resolved, no discrepancy
19-03 Meter calibration records were requested, along with an explanation of which each meter, was associated with which site.
The Responsible Party provided the available calibration records along with an explanation of how the meters were tracked to each subproject. The Responsible Party also provided their documented alterative meter maintenance/ verification plan for meters without valid calibration records.
Resolved Resolved, no discrepancy
Page 81 of 91
19-04 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 29 tonnes CO2e (0.15% of the total emission reduction claim).
Unresolved Immaterial quantitative discrepancy (0.15% of total emission reduction claim)
19-05 A transcription error was identified in the gas analysis applied to one of the subprojects.
The Responsible Party corrected this error.
Resolved Resolved, no discrepancy
19-06 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.
Resolved Resolved, no discrepancy
Page 82 of 91
19-07 The Responsible Party used a calculated average gas composition of multiple gas samples for one of the subprojects.
The Responsible Party explained that this site has a GC that provides a daily gas composition. The Responsible Party calculated a straight average of this data and applied it in the quantification.
The verification team noted that calculating a weighted average versus straight average would have been a more accurate / best practise approach.
Resolved Resolved, no discrepancy
19-08 For VGC subprojects, the Protocol requires that SSR P5b includes the CO2 emissions resulting from the combustion of all hydrocarbon components that make up >3% of the vent gas stream. The Responsible Party included this in their quantification but an error was identified in the Responsible Party’s spreadsheet formula for these calculations.
The Responsible Party corrected this error.
Resolved Resolved, no discrepancy
19-09 Discrepancies were identified in some of the Detechtion – Enalysis data used in the Responsible Party’s calculations, when compared to the Enalysis reports.
This was determined to be due to missing reports that had not been provided to the verifier; not due to transcription.
Resolved Resolved, no discrepancy
19-10 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.
Resolved Resolved, no discrepancy
Page 83 of 91
19-11 Gas composition data was complete for all subprojects with four exceptions. Four subprojects did not have gas analyses with sample dates within the reporting period. The most current available gas analyses were used for these subprojects. This approach does not meet the Protocol requirements, resulting in a quantitative discrepancy.
The Responsible Party did not provide the missing gas analyses or any approved alternative approach to meeting the Protocol requirement.
In order to estimate the error associated with this discrepancy, the verification team calculated a default gas composition from the dataset of valid gas analysis data, and applied it to the four subprojects that do not have valid gas analyses.
The resulting estimated discrepancy is an overstatement of approximately 150 tonnes CO2e (0.77% of the total emission reduction claim.
Unresolved Immaterial quantitative discrepancy (0.77% of the total emission reduction claim)
19-12 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.
Unresolved Immaterial qualitative discrepancy
Page 84 of 91
Appendix D: Statement of Verification
Alberta REMVue Engine Fuel Management and Vent Gas Capture Aggregation Project (1090-6410)
February 2020
Page 85 of 91
Statement of Verification
Alberta Emission Offset Project
Emission Offset Project Title Quantification Protocol (Date/Version) Project ID #
Alberta REMVue Engine Fuel Management and Vent Gas Capture Aggregation Project
Quantification Protocol for Engine Fuel Management and Vent Gas Capture Projects (version 2.0, June 2018)
1090-6410
Emission Offset Project Developer
Offset Reporting Period Start Serial Range (if
applicable)
Blue Source Canada ULC October 1, 2018 TBD
Authorized Project Contact (if applicable)
Offset Reporting Period End
N/A September 30, 2019
Statement of Verification
Total GHG Assertion Value Units
Total Baseline Emissions 120,086 tonnes CO2eq
Total Project Emissions 100,653 tonnes CO2eq
Other (I.e. levied) 0 tonnes CO2eq
Net Reduction 19,433 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 1, 2018 to September 30, 2019 and states an emission reduction and removal claim of 19,433 tonnes CO2e over this period.
Alberta REMVue Engine Fuel Management and Vent Gas Capture Aggregation Project (1090-6410)
February 2020
Page 86 of 91
The emission reduction and removal claim consists of 2018 and 2019 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.
Signature of Designated Signing Authority
Verification Company Name
Brightspot Climate Inc. Per: Aaron Schroeder
Signature of Designated Signing Authority
Date:
First Name Last Name
Aaron Schroeder
Professional Designation/ Accreditation Org & Number E-mail Address Phone Number
Professional Engineer [email protected] (604) 353-0264
February 12, 2020
Page 87 of 91
Appendix E: Conflict of Interest Checklist
Alberta REMVue Engine Fuel Management and Vent Gas Capture Aggregation Project (1090-6410)
February 2020
Page 88 of 91
Conflict of Interest Checklist
Alberta Emission Offset Project Emission Offset Project Title Quantification Protocol (Date/Version)
Alberta REMVue Engine Fuel
Management and Vent Gas
Capture Aggregation Project
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 1, 2018
September 30,
2019
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.
Alberta REMVue Engine Fuel Management and Vent Gas Capture Aggregation Project (1090-6410)
February 2020
Page 89 of 91
Signature of Designated Signing Authority
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
Professional Engineer [email protected] (604) 353-0264
February 12, 2020
Page 90 of 91
Appendix F: Supplemental Diagrams/Tables/Figure
Page 91 of 91
Table 6: Supporting Documentation Reviewed
File Name Description
prj_637_12794.pdf Offset Project Plan
REMVue_OPR_P1_v1.2_02062020.pdf Offset Project Report
REMVue EFMVGC Agg, 1090-6410_APRS_v3 02-12-2020.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.