verification report encana vgc v1 - csa registries€¦ · brightspot climate inc. – verification...

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

Vent Gas Capture Aggregation Projects

ENCANA CORPORATION Verification Report

December 16, 2016

This page intentionally blank


Statement of Verification

December 16, 2016

Alberta Environment and Parks

12th Floor, Baker Centre

10025 – 106 Street�

Edmonton, Alberta T5J 1G4

Introduction

Encana Corporation (the “Responsible Party”) engaged Brightspot Climate Inc. (Brightspot Climate) to

review their greenhouse gas (GHG) emission reduction and removal projects, Vent Gas Capture

Aggregation Project, Vent Gas Capture Aggregation Project Phase 2, and Vent Gas Capture

Aggregation Project Phase 3 (collectively, the “Projects”). The Projects were developed in accordance

with the Quantification Protocol for Engine Fuel Management and Vent Gas Capture Projects, Version

1.0, October 2009 (the “Protocol”).

The Responsible Party’s “GHG Assertion” is comprised of the Offset Project Plan, Offset Project Report

and supporting documentation for each Project. The GHG Assertions cover the reporting period

January 16, 2015 – July 31, 2016 and states an emission reduction and removal claims as follows:

GHG Emission

Reduction

Encana Corporation’s Vent Gas Capture

Aggregation Project

2015: 25,621 tonnes CO2e

2016: 15,689 tonnes CO2e


Aggregation Project Phase 2

2015: 5,971 tonnes CO2e

2016: 4,195 tonnes CO2e



2015: 23,277 tonnes CO2e

2016: 13,572 tonnes CO2e

The Responsible Party is responsible for the preparation and presentation of the information within the

GHG Assertions. Our responsibility as the verifier is to express an opinion as to whether the GHG

Assertions are materially correct, in accordance with approved Protocol, the Specified Gas Emitters

Regulation (Alta. Reg.139, 2007) (the “Regulation”), and the Alberta Environment and Parks Technical

Guidance for Offset Project Developers, Version 4.0, February 2014.

Scope

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 discrepancies detected 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.

Sincerely,

Aaron Schroeder, P.Eng.

Brightspot Climate Inc.

Vancouver, British Columbia

Brightspot Climate Inc. – Verification Report

Encana Corporation – Vent Gas Capture Aggregation Projects

1

Verification Summary

This Verification Report follows the standardized format prescribed in the Alberta Environment and

Parks guidance document, Section 5.2.1

Table 1: Verification Summary

Project Information:

Project Name: Vent Gas Capture Aggregation Project,

Vent Gas Capture Aggregation Project Phase 2,

Vent Gas Capture Aggregation Project Phase 3

Geographic Boundary: Various project sites throughout Alberta

Project Contact Information:

Vince Elenko

Encana Corporation

500 Centre Street SE, PO Box 2850

Calgary, Alberta T2P 2S5

(p) 403.645.2210

(e) [email protected]

Alberta Offset System

Criteria Evaluated (see

Verification Activities):

The project must meet the eligibility criteria stated in Section 7 of the Specified Gas Emitters Regulation (SGER). In order to qualify, emission reductions must:

• Occur in Alberta;

• Result from actions not otherwise required by law and be

beyond business as usual and sector common practices;

• Result from actions taken on or after January 1, 2002;

• Occur on or after January 1, 2002;

• Be real, demonstrable, quantifiable and verifiable;

• Have clearly established ownership; and

• Be counted once for compliance purposes.

Verification 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 Verification Guidance Document, Section 5.4, Table 26.

Verification Summary: There were no unresolved discrepancies detected in the final GHG

Assertion. An unqualified verification statement was issued.

Verification Team Members: Lead Verifier: Aaron Schroeder, P.Eng.

Peer Reviewer: Nathan Muegge, P.Eng. 1 Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance, Version 1.0, January 2013. Alberta Environment and Parks.



2

Project Start Date:

Vent Gas Capture Aggregation Project: Jan. 10, 2012

Vent Gas Capture Aggregation Project Phase 2: Jun. 4, 2013

Vent Gas Capture Aggregation Project Phase 3: Jan. 16, 2014

Credit Start Date:

Vent Gas Capture Aggregation Project: Jan. 10, 2012

Vent Gas Capture Aggregation Project Phase 2: Jun. 4, 2013

Vent Gas Capture Aggregation Project Phase 3: Jan. 16, 2014

Credit Period:

Vent Gas Capture Aggregation Project: Jan. 10, 2012 –

Jan. 9, 2020

Vent Gas Capture Aggregation Project Phase 2: Jun. 4, 2013 –

Jun. 3, 2021

Vent Gas Capture Aggregation Project Phase 3: Jan. 16, 2014 –

Jan. 15, 2022

Offset Project Report Date:

Vent Gas Capture Aggregation Project: Jan. 16, 2015 – July

31, 2016

Vent Gas Capture Aggregation Project Phase 2: Jan. 16, 2015 – July

31, 2016

Vent Gas Capture Aggregation Project Phase 3: Jan. 16, 2015 –

July 31, 2016

Expected Lifetime of

Project:

Vent Gas Capture Aggregation Project: 20 years

Vent Gas Capture Aggregation Project Phase 2: 20 years

Vent Gas Capture Aggregation Project Phase 3: 20 years

Actual Emissions

Reductions Achieved:

Vent Gas Capture Aggregation Project:

2015: 25,621 t CO2e 2016: 15,689 t CO2e


2015: 5,971 t CO2e 2016: 4,195 t CO2e

Vent Gas Capture Aggregation Project Phase 3:

2015: 23,277 t CO2e 2016: 13,572 t CO2e

Other Env. Attributes: No other environmental attributes are being claimed from the Projects.

Ownership: Encana Corporation, Ember Resource Inc., Canstone Energy Ltd.

Project Registration:

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.

Verification Report Date: December 16, 2016



3

Introduction

This document provides details of the independent verification of the 2015 Specified Gas Emitters Regulation compliance report for the project described below.

This document contains the following six sections:

1. Verification Summary: as shown in Table 1 above.

2. Verification Report Introduction: this section defines the parties associated with this verification, a description of the project and the verification objective, scope and criteria applied to the verification. A list of the Responsible Party’s documents reviewed through the course of the verification is also provided in this section.

3. Verification Schedule: lists important verification activities and dates.

4. Verification Findings: this section includes a discussion of the results of each verification procedure and each qualitative and quantitative discrepancy identified as well as a summary of the total materiality of discrepancies.

5. Confirmations: a table provides details of the “confirmation” activities completed by the verifier, as required by Alberta Environment and Parks2.

6. Statements: Verification team biographies, Statement of Verification, Conflict of Interest statement and Statement of Qualifications.

The final Verification Plan is a separate document that was developed at the outset of the verification.

The Verification Plan includes a description of the final verification strategy, verification procedures and

sampling that was applied to the verification. The final Verification Plan is appended to this report.

Parties Associated with the Verification

ISO 14064-3 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 Technical Guidance Document extends this definition to

include the information included in the Baseline Emissions Inventory Application and the

Specified Gas Compliance Report.

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

which cause GHG emission reductions or GHG removal enhancements.

The GHG Projects that are the subject of this verification are Vent Gas Capture Aggregation

Project, Vent Gas Capture Aggregation Project Phase 2, and Vent Gas Capture Aggregation

Project Phase 3, which will be referred to throughout this document collectively as “the

Projects”.

ISO 14064-3 defines the following parties associated with the verification:

2 See Section 5.4 of Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance, Version 1.0, January 2013. Alberta Environment and Parks.



4

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 Encana Corporation.

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 Alberta Environment and Parks.

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

reporting on the verification process.

The Verifier for this verification is Brightspot Climate Inc. The members of the verification team

are provided in section 3 of this document.

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 requiring appropriate training for all

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

A final “Conflict of Interests Checklist” is included in Section 6 of this report.

Project Description

The Projects reduce emissions of greenhouse gases at natural gas compressor stations by utilising

“SlipStream” technology that captures and combusts natural gas that otherwise would have been

vented to the atmosphere from various control devices. The technology directs this vent gas into the air

intake of a reciprocating engine where it is combusted as a supplemental fuel source.

The Projects are an aggregation of installations at multiple project sites.

Metered data is collected from each project site using a centralized SCADA system. Gas composition is

analyzed annually in a third-party laboratory for each project site.



5

Verification Parameters

Table 2: Verification Objectives, Criteria and Scope

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 Document3, Section 5.4, Table

26.

Criteria

• Climate Change and Emissions Management Act

• Specified Gas Emitters Regulation

• Technical Guidance for Offset Project Developers, Version 4.0,

February 2013

• Technical Guidance for Greenhouse Gas Verification at Reasonable

Level Assurance, Version 1.0, January 2013

• Quantification Protocol for Engine Fuel Management and Vent Gas

Capture Projects” Version 1.0, October 2009

Scope

Project Name: Vent Gas Capture Aggregation Project,

Vent Gas Capture Aggregation Project Phase 2,


Geographic Boundary: Various project sites throughout Alberta

Physical Operations: Natural gas processing and compression

Pneumatic devices

Engine venting

Emission Sources: Vent Gas Capture:

• B5 Fuel Extraction and Processing

• B5b Venting of Emissions Captured

in Project

IPCC GHGs Emitted: Carbon Dioxide (CO2)

Methane (CH4)

Nitrous Oxide (N2O)

Reporting Period: January 16, 2015 – July 31, 2016

Materiality Quantitative materiality threshold: 5% of asserted GHG emission reduction

3 Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance, Version 1.0, January 2013. Alberta Environment and Parks.



6

Documents Reviewed

The following Responsible Party’s documents were reviewed through the course of the verification (only

the most recent version is listed in instances where multiple versions were reviewed):

• VGC Phase 1,2&3 Master Calculator_Oct 31, 2016 Final.xlsx

• OPP Vent Gas Capture Phase 1.pdf, OPP Vent Gas Capture Phase 2.pdf, OPP Vent Gas

Capture Phase 3.pdf

• VGC Phase 1_OPR_Oct 31, 2016_Final.pdf



• Calibration reports for each site

• Maxxam Labs – gas analysis for each site

• 2015 – 2016 Canstone Offset Ownership Letter – Signed.pdf

• 2016-11-10 – Encana & Ember Confirmation of Ownership of Carbon Offsets Letter

Agreement.pdf

• VGC Ownership Summary Breakdown.xlsx

Verification Schedule

The verification was completed according to the schedule established between the Responsible Party

and the Verifier in the Verification Plan. The verification reached important milestones on the following

dates:

• Verification Kickoff Meeting August 8, 2016

• Draft Verification Plan August 8, 2016

• Site Visits August 8 – 9, 2016

• Final GHG Assertion December 7, 2016

• Draft Verification Report December 8, 2016

• Peer Review December 9, 2016

• Final Verification Report December 16, 2016

Note: there was a significant delay in the verification schedule due to outstanding ownership

documentation, which was received December 7, 2016 along with the final GHG assertion.



7

Verification Findings

The results of the verification risk assessment provided the basis for the verification procedures. Table 3, below, provides a summary of the

verification procedures where discrepancies were detected. Table 4, which follows, provides a description of every verification procedure that

was completed.

Table 3: Verification Findings Summary

Activity Data / Inventory

Component Description Discrepancy Description

Discrepancy

Type

Discrepancy

Magnitude

There were no discrepancies detected in the final GHG Assertion.



8

Table 4: Findings of Verification Procedures

Activity Data / Inventory Component Description

Verification Procedures Verification Findings

PROTOCOL APPLICABILITY REQUIREMENTS

Determination of brake

specific fuel consumption

Not applicable for this project.

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 visit, the verification team observed the vent gas

capture systems and found that an equivalent level of service is

provided by all installations and that these installations do not impair

the engine performance.

When the vent gas capture systems are not operational, gas is

vented, equivalent to the baseline condition. This vented gas is not

metered and therefore, it is appropriately excluded from the

emission reduction calculation.

Site staff indicated that following the commissioning stage, the

systems work well. Ongoing maintenance is performed during

regular maintenance of the full facility.

No discrepancies detected.

Capture of vent gas must

not be required by

regulation

Substantive test: Review the daily gas

volume captured for each site and compare

against the Directive 60 requirements. If

necessary, review the economic analysis

defined in Directive 60 for each site.

Vent gas volumes for each site are well below the thresholds that

require capture, which are described in Directive 60.


The project must comply

with all air emission

regulations in Alberta

Substantive test: Review the daily gas

volume captured for each site and compare

against the Directive 60 requirements.

Vent gas volumes for each site are well below the thresholds that

require capture, which are described in Directive 60.




9



Substantive test: Determine if vent gas is

captured from glycol dehydrators and if the

requirements of Directive 60, Section 8.3

apply, which may disqualify the site.

The verification team confirmed that this requirement is not

applicable because there are no glycol dehydrators located on the

sites included in the project.


Projects must use “flaring”

as the baseline condition if

flaring is required by any

regulation.

Refer to the Protocol Applicability requirement, “Capture of vent gas must not be required by regulation”, above.

The project must not

occur within the boundary

of a site that is regulated

by the Specified Gas

Emitters Regulation.

Substantive test: Compare the project

locations to the list of facilities regulated by

the Specified Gas Emitters Regulation.

Based on the analysis of the verification team, none of the project

sites are within the boundary of facilities regulated by the Specified

Gas Emitters Regulation.


Quantification must be

based on actual

measurements and

monitoring.

Substantive test: Review quantification data

for anomalies or missing data.

All data used to quantify the emission reduction are metered values

(refer to the Quantification Data section of this table for further

details regarding the specific data used to quantify the emission

reduction).

An analysis of the datasets used for quantification did not reveal any

anomalous data.




10

The project must meet the

requirements of the


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 within

Alberta, as confirmed by project documentation.

Actions not otherwise required by law – confirmed that none of

the sites are defined as “regulated facilities” under the Specified

Gas Emitters Regulation. No other 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 – commissioning of all

instrument air systems occurred after this date, as confirmed by

project documents and inquiries of site operations staff.

Real, demonstrable, quantifiable – the verification procedures

confirmed that the emission reductions in the aggregated assertion

meet these requirements. The specific verification procedures

supporting this conclusion include observation during the site visits,

review of supporting meter calibration reports and documentation

and the recalculation of the emission reduction.

Clearly established ownership – Encana and Ember are the

majority owners for each of the sites and Ember has authorized

Encana to act as the primary Responsible Party for the purpose of

quantification and reporting of the GHG emission reduction. One

minority owner has signed documents establishing ownership of

the emission reduction relative to their ownership in the respective

sites.

Counted once for compliance purposes – The Responsible Party

provided a Statutory Declaration that the emission reduction will be

registered only in the Alberta Offset System.




11



Project developer must

establish the ownership of

the emission reduction for

each site within the

aggregated project

Substantive test: Review ownership

documents for each project site within the

aggregated project.

Encana and Ember are the majority owners for each of the sites

and Ember has authorized Encana to act as the primary

Responsible Party for the purpose of quantification and reporting of

the GHG emission reduction. One minority owner has signed

documents establishing ownership of the emission reduction

relative to their ownership in the respective sites.

Ownership documentation was reviewed by the verification team.


PROTOCOL FLEXIBILITY

Changes in the quantity of

waste gas or process

emissions may be

quantified.


Fractional fuel savings

data may be applied for

engine fuel management

projects.


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 sites has been included in the

aggregated project. Site specific gas compositions were applied to

each site.


The simple or advanced

approach may be applied

for engine fuel

management projects.




12



Site specific emission

factors may be applied


QUANTIFICATION DATA

Metered captured vent

gas

Controls test: Review meter calibration

reports to determine if the meter

maintenance program is operating

effectively.

The verification team reviewed a sample of meter calibration reports

and found that the Responsible Party’s control system for meter

calibration is functioning effectively.


Methane concentration in

gas; Density of vent gas

Substantive test: Analyze gas compositions

for significant fluctuations or abnormal gas

concentrations. Confirm the accurate

transcription of the gas analysis into the


Analysis of previous gas analysis for each site indicates that the gas

composition is very consistent from previous years.

The transcription of gas analysis into the emission reduction

calculation was completed accurately.


Substantive test: Review completeness of

gas composition data.

Gas composition data is available for all sites in the aggregated

project.


Reference density of

methane at STP

conditions

Substantive test: Compare the density of

methane applied in the calculations to the

reference value provided in the relevant

reference documents.

Alberta Environment and Parks does not publish the density of

methane at STP. The Responsible Party applied a density of 0.6797

kg/m3, referenced from an AirLiquide MSDS. This value is

reasonable, when compared to other sources.




13



EMISSION QUANTIFICATION AND REPORTING

Quantification of emission

reduction

Substantive test: Recalculate the complete

emission reduction using original data.

The independent recalculation of the emission reduction resulted in

the same emission reduction quantity asserted by the Responsible

Party. Therefore, the verification team concluded that no arithmetic

or calculation errors were made by the Responsible Party in the

emission reduction quantification.


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 quantification methods described in the Responsible Party’s

Offset Project Plan adhere to the methods described in the

approved Quantification Protocol.



emission reduction using original data and

methods described in the approved


The independent recalculation of the emission reduction resulted in

the same emission reduction quantity asserted by the Responsible

Party. Therefore, the approved Protocol quantification methods

were applied in the Responsible Party’s emission reduction

quantification.




14



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.

The emission reduction quantity was accurately transcribed into the

Offset Project Report.




15

Confirmations

Section 5.4 of the Alberta Environment and Parks Verification Technical Guidance document lists six

activities that are beyond the scope of a typical greenhouse gas verification, but are required by Alberta

Environment and Parks.

The “confirmations” refer to information contained in the Specified Gas Compliance Report (Excel

spreadsheet) submitted by the Responsible Party.

Table 5: Confirmation Findings

Confirmation Confirmation Findings

Consistency of offset project information

across offset project documentation

Offset project information in the Offset Project Plan is

consistent with the information in the Offset Project

Report. All of this information is consistent with the

requirements described in the relevant criteria.

Offset project location and any

applicable approvals information

All sites in the aggregated project are within Alberta. No

additional approvals were required to implement the

Project.

Methodology documents or procedures

manual exist

The Responsible Party has documented all relevant

methodologies, procedures and controls in the Offset

Project Plan.

Offset project contact, report dates,

emission reduction numbers, etc. (part

of one above)

The Offset Project Reports contain all GHG information

required by the Alberta Offset System. The final emission

reduction quantities were transcribed accurately into the

Offset Project Reports.

Completeness and accuracy of process

and data flow diagrams

The Responsible Party’s data flow chart, which is

included in the Offset Project Plan, accurately describes

the data flows within the project.



16

Appendices

The following documents are appended to this report, as follows:

Peer Review Report

Statement of Qualifications

Conflict of Interest Statement

Final Verification Plan

Peer Review Report

Verification Activities Reviewed

Verification Process Comments

Verification Risk Assessment

The verification risk assessment identified all relevant emission sources described in the Quantification Methodology Document and site visit notes.

Verification activities were designed to mitigate the inherent and control risks defined during the risk assessment.

Data Sampling In lieu of data sampling, data sources and management practices were reviewed. The original data set in its entirety was then used to perform a recalculation.

Verification Activities Working notes provide sufficient detail to demonstrate that all verification activities were completed through the course of the verification.

Issues raised during the verification

All questions and issues raised during the verification were sufficiently addressed by the Responsible Party.

Conflict of Interest An assessment for threats to independence was conducted before the verification began and after the verification was completed. No real or perceived conflicts of interest were identified.

Verification Conclusion

Verification Evidence Comments

Eligibility Evaluation Sufficient evidence supporting the eligibility of the project was provided by the Responsible Party.

Sufficient and Appropriate Evidence

The evidence collected through the verification activities reduces the overall verification risk and supports the verification conclusion.

Discrepancy Analysis No discrepancies detected.

Verification Report All documentation required in the Verification Report is included and complete.

Based on the documentation reviewed during the peer review process, I believe the verification of the 2015 and 2016 Vintages of the Phase 1, 2 and 3 Vent Gas Capture projects were completed in accordance with the ISO 14064-3 standard and the criteria established in the Alberta Environment and Parks document, ”Technical Guidance for Greenhouse Gas Verification at Reasonable Level of Assurance, Version 1.0 January 2013.” Sincerely, Nathan Muegge, P.Eng. (p)

Responsible Party: Encana Corporation

Facility: Various Vent Gas Capture Project Sites Throughout Alberta

Date Peer Review Completed: December 12, 2016

Statement of Qualifications

Lead Verifier Details

Lead Verifier Name: Aaron Schroeder

Professional Designation: Professional Engineer

Email: [email protected]

Phone Number: +1 (604) 353-0264

Verifying Company Name: Brightspot Climate Inc.

Lead Verifier Training

• GHG Verification - ISO 14064-3, Canadian Standards Association, 2012

• CCP 403 - GHG Validation and Verification, University of Toronto, 2016 (Instructor)

Verification Team Biographies

Lead Verifier: Aaron Schroeder, P.Eng. has eleven years of professional experience analyzing,

quantifying and auditing greenhouse gas emissions in North America. Mr. Schroeder’s hands on

experience conducting over 150 greenhouse gas verifications includes numerous engagements for

industrial facilities in power generation, oil and gas production and processing, natural gas pipelines and

a wide range of emission reduction projects in beef and dairy management, conservation cropping

(zero-tillage) and nitrogen fertilizer management in addition to renewable energy and waste

management. Mr. Schroeder is a sessional instructor at the University of Toronto’s School of

Environment for professional development. He instructs the school’s greenhouse gas quantification and

verification courses.

Peer Reviewer: Nathan Muegge, P.Eng. has a broad background in the application and evaluation of

conventional and emerging energy technologies with over a decade of experience in the fields of energy

& environment. He has completed over 30 greenhouse gas verifications of annual SGER compliance

reports as Lead Verifier or Technical Expert, including reports for several natural gas processing and

power generation facilities. Nathan completed verification through the Canadian Standards Association

in 2009 – Verification of Greenhouse Gas Reports using ISO 14064 as well as additional training

through the Jacques Whitford Training Institute in 2008 – Environmental Auditing, Legislation, Regulations and other Canadian Requirements.

Statement

I, Aaron Schroeder, meet or exceed the qualifications of third party auditors described in Section 18 of

the Specified Gas Emitters Regulation.

Signed: Date:

Aaron Schroeder, P.Eng.

Brightspot Climate Inc.

Vancouver, British Columbia

December 16, 2016

Conflict of Interest

Encana Corporation: Vent Gas Capture Aggregation Projects

Brightspot Climate monitored threats to independence throughout the duration of the project. The following declaration affirms that:

1. The verifying organization or the verification team members do not financially benefit directly from the Project Developer or the Project Developer’s Project.

2. The verifying organization or verification team members are not in a position of assessing their own work.

3. The verifying organization, members of the verification team, or persons in the chain of command for the verification do not promote, nor can be perceived to promote, the Project Developer's position or opinion to the point that objectivity may, or may be perceived to be, compromised.

4. No member of the verification team is too sympathetic to the Project Developer's interests by virtue of a close relationship with the Project Developer, its directors, officer or employees.

5. No member of the verification team or person in the chain of command is deterred from acting objectively and exercising professional skepticism by threats, actual or perceived, from the directors, officers or employees of the Project Developer.

Date: Location: Vancouver, BC Signed:

Aaron Schroeder Lead Verifier. Brightspot Climate


Vent Gas Capture Aggregation Projects

ENCANA COPRPORTATION Verification Plan

August 8, 2016

This page intentionally blank

Brightspot Climate Inc. – Verification Plan


i

Terminology

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

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

Party.

The Alberta Environment and Parks Technical Guidance Document1 extends this definition to

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

and offset credits being claimed by the offset project over a defined period.

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 Encana Corporation’s Vent Gas Capture

Aggregation Projects, namely:

• Encana Corporation’s Vent Gas Capture Aggregation Project

• Encana Corporation’s Vent Gas Capture Aggregation Project Phase 2

• Encana Corporation’s Vent Gas Capture Aggregation Project Phase 3

Collectively, these three emission reduction projects will be referred to throughout this proposal

as “The Projects”.

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

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

assertion and supporting GHG information.

The Responsible Party for this verification is Encana Corporation (Encana).

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 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 3 of this document.




1

Introduction

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

independent verification of the Offset Project Report for Vent Gas Capture Aggregation Projects.

This document contains three sections:

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

2. The GHG Assertion, which describes the subject matter of the verification; and

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

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

verification team and any findings from previous verifications for the Projects.

The verification procedures, including the sampling plan and the results of the verification risk

assessment, will be appended to this verification plan in the final verification report.

The Responsible Party developed the Projects in accordance with the requirements of the Alberta

Government’s Quantification Protocol for Instrument Gas to Instrument Air Conversion in Process

Control Systems” Version 1.0, October 2009 (the Protocol).

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 assessed 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.



2

GHG Assertion

Projects Subject Matter

The Technical Guidance Document2 defines “subject matter” in Section 2.2.3.2 as follows:

“The subject matter for an offset project is the greenhouse gas emissions from the offset project

and baseline, including the total greenhouse gas emission reduction, and/or removals achieved

by the offset project that can be appropriately evaluated against the program criteria.”

The subject matter for the Projects is defined in the verification scope, which is described in Table 4.

GHG Assertion

The Responsible Party’s asserted emission reduction is provided in the following table:

Table 1: Baseline and Previous GHG Assertions

GHG Emission

Reduction


Aggregation Project

2015: 25,621 tonnes CO2e

2016: 15,689 tonnes CO2e



2015: 5,971 tonnes CO2e

2016: 4,195 tonnes CO2e



2015: 23,277 tonnes CO2e

2016: 13,572 tonnes CO2e

Source: Encana Corporation – Vent Gas Capture Aggregation Projects – Offset Project Reports

Changes to Operations and Boundaries

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

In 2015, Encana sold several sites in each of the Projects to Ember Resources Inc. (Ember). Encana

and Ember entered an agreement on November 10 that nominated Encana to register, coordinate

verification and serialize all emission reductions across the projects. Encana and Ember have a

commercial agreement to reconcile offset ownership after serialization of the offsets is complete.

Additionally, Canstone Energy Ltd. (Canstone) hold a minority interest in some of the project sites.

Canstone entered an agreement with the majority owner of these sites, nominating Encana with the

right to serialize all emission reductions for Canstone’s project sites.




3

Responsible Party’s Data Management Systems

Table 2, below, describes the data measurement, estimation and data storage locations for all GHG

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

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

inventory.

Table 2: GHG Inventory Data Management

Activity Data Description Measurement Type Data Storage Location / Path

Metered captured vent gas Direct metering Metered quantity

>> SCADA system

>> PI system

>> Encana calculation spreadsheet

Methane concentration in

gas

Third-party analysis Laboratory analysis


Density of vent gas Third-party analysis Laboratory analysis



methane at STP conditions

Third-party reference Third party reference value




4

Responsible Party’s Control Environment

The following table describes the Responsible Party’s quality assurance controls applied to the GHG

information used to produce the GHG inventory. Note that the verification procedures may not rely

upon these controls to establish sufficient and appropriate evidence to support the GHG Assertion.

Table 3: Responsible Party Data Controls

Activity Data Description Responsible Party Controls

Metered captured vent gas The Responsible Party has implemented a meter

maintenance program that includes periodic meter

calibration.

Methane concentration in gas An independent lab conducts gas analysis.

Density of vent gas An independent lab conducts gas analysis.

Application of approved quantification protocol The Responsible Party has developed an Offset

Project Plan that is intended to conform to the

approved quantification protocol.

Verification

Principles

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

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

Responsible Party’s inventory, accounting and reporting processes.

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

Accuracy: reduce bias and uncertainty as far as practical

Completeness: include all relevant emission sources

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

emission reductions or removal enhancements are not over-estimated

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

between facilities or between companies)

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

appropriate to the needs of the intended user

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

to allow intended users to make decisions with relative confidence

Verification Parameters

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



5

Table 4: 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 Document3, Section 5.4, Table

26.

Criteria

• Climate Change and Emissions Management Act

• Specified Gas Emitters Regulation

• Technical Guidance for Offset Project Developers, Version 4.0,

February 2013

• Technical Guidance for Greenhouse Gas Verification at Reasonable

Level Assurance, Version 1.0, January 2013

• Quantification Protocol for Engine Fuel Management and Vent Gas Capture Projects” Version 1.0, October 2009

Scope

Project Name: Vent Gas Capture Aggregation

Projects

Geographic Boundary: Natural gas processing and

compression facilities in Encana

Corporation’s natural gas network in

Central Alberta

Physical Operations: Natural gas processing and

compression

Pneumatic devices

Engine venting

Emission Sources: Vent Gas Capture:

• B5b Venting of Emissions Captured

in Project

IPCC GHGs Emitted: Carbon Dioxide (CO2)

Methane (CH4)

Nitrous Oxide (N2O)

Reporting Period: January 16, 2015 – July 31, 2016




6

Materiality Quantitative materiality threshold is 5% of asserted greenhouse gas

emission reduction

Tolerable Error

Thresholds

An unqualified verification conclusion may be issued despite immaterial

quantitative discrepancies that do not exceed the materiality threshold in

aggregate (calculated as both net and gross overall discrepancy).

The tolerable error threshold per issue in either the baseline or project

condition will be graduated as follows for emission sources:

• 2% for emission sources greater than 50% of total baseline or

project emissions;

• 5% for emission sources between 20% and 50% of total baseline

or project emissions; and

• 10% for emission source less than 20% of total baseline or project

emissions.

All discrepancies will be described in the Verification Report.

Preliminary Verification

Schedule

Verification kickoff meeting: August 8, 2016

Delivery of draft verification plans: August 8, 2016

Site visits: August 8 – 9, 2016

Final Offset Project Reports to Brightspot: August 15, 2016

Draft verification reports to Encana: August 22, 2016

Final verification reports to Encana: August 24, 2016

Findings from Previous Verifications

There were no unresolved discrepancies described in the previous verification report (previous

verification was conducted by Tetra Tech EBA Inc.).

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.

Nathan Muegge, P.Eng., will conduct an independent peer review of the verification. Mr. Muegge has

completed over 30 greenhouse gas verifications of annual SGER compliance reports as Lead Verifier or

Technical Expert, including reports for several natural gas processing facilities.

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.



7

Site Safety Requirements

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

boots, flame-resistant coveralls, hard hat, safety glasses with side shields and gloves.

A site orientation must be completed before entering the site.



8

Verification Risk Assessment and Verification Procedures

The Verification Risk Assessment was completed prior to issuing the draft version of this document.

Verification procedures were developed to reduce the overall verification risk to facilitate the objectives

of the verification. Each inherent and control risk is provided with the risk evaluation (high/medium/low).

The risk evaluation 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.

In instances where a substantive approach is applied in the verification procedure (i.e. the procedure

tests the data, rather than the Responsible Party’s controls), the Responsible Party’s control is not

listed, but is denoted “N/A”; however, this does not imply that the Responsible Party does not have a

control in place.

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

product of the Projects’ inherent risks, the Responsible Party’s control risks and the Verifier’s detection

risks. 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.



9

Table 5: Verification Risk Assessment Summary


Component

Inherent Risk Control Risk Detection

Risk Design

Description of Verification Procedure

PROTOCOL APPLICABILITY REQUIREMENTS

Determination of brake

specific fuel consumption

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

Functional equivalence

must be demonstrated;

engine performance

must not be impaired

because of the project

Relevance (high)

Level of service may have

changed between the

baseline and project

conditions.

N/A (controls not

considered for

verification)

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,

Section 2.8.

N/A (controls not

considered for

verification)

Low Substantive test: Review the daily gas volume

captured for each site and compare against the

Directive 60 requirements. If necessary, review

the economic analysis defined in Directive 60

for each site.

The project must comply

with all air emission

regulations in Alberta

Relevance (high)

Vent gas capture may be

required to be flared or

captured.

N/A (controls not

considered for

verification)

Low Substantive test: Review the daily gas volume

captured for each site and compare against the

Directive 60 requirements.

Substantive test: Determine if vent gas is

captured from glycol dehydrators and if the

requirements of Directive 60, Section 8.3 apply,

which may disqualify the site.



10


Component


Risk Design


Projects must use

“flaring” as the baseline

condition if flaring is

required by any

regulation

Relevance (high)

The appropriate baseline

condition may not have

been applied.

N/A (controls not

considered for

verification)

Low See “Capture of vent gas must not be required

by regulation”, above.

The project must not

occur within the

boundary of a site that is

regulated by the

Specified Gas Emitters

Regulation.

Relevance (high)

The project site may be

regulated by the

Specified Gas Emitters

Regulation and therefore,

be ineligible.

N/A (controls not

considered for

verification)

Low Substantive test: Compare the project locations

to the list of facilities regulated by the Specified

Gas Emitters Regulation.

Quantification must be

based on actual

measurements and

monitoring.

Relevance (high)

Estimates may have been

applied, particularly for

missing data.

N/A (controls not

considered for

verification)

Low Substantive test: Review quantification data for

anomalies or missing data.

The project must meet

the requirements of the


Relevance (high)

The project may not have

met the requirements of

the Alberta Offset

System.

N/A (controls not

considered for

verification)

Low Substantive test: Evaluate the project

developer’s evidence regarding the general

requirements of the Alberta Offset System.



11


Component


Risk Design


Project developer must

establish the ownership

of the emission reduction

for each site within the

aggregated project

Completeness (high)

Ownership may not be

established with

documentation for all

sites within the

aggregated project.

N/A (controls not

considered for

verification)

Low Substantive test: Review ownership documents

for each project site within the aggregated

project.

PROTOCOL FLEXIBILITY

Changes in the quantity

of waste gas or process

emissions may be

quantified.


Fractional fuel savings

data may be applied for

engine fuel management

projects.


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.

N/A (controls not

considered for

verification)

Low Substantive test: Evaluate the completeness of

the required data and documentation for all

project sites included in the aggregated project.



12


Component


Risk Design


The simple or advanced

approach may be

applied for engine fuel

management projects.


Site specific emission

factors may be applied


QUANTIFICATION DATA

Metered captured vent

gas

Accuracy (high)

The metered captured

vent gas may be incorrect

if meters are not properly

maintained.

The Responsible Party

has implemented a

meter maintenance

program that includes

periodic meter

calibration. The

maintenance program

may not be operating

effectively (low).

Medium Controls test: Review meter calibration reports

to determine if the meter maintenance program

is operating effectively.

Methane concentration

in gas; Density of vent

gas

Accuracy (low)

Reported gas

compositions may not

accurately represent the

gas composition or may

be incorrectly transcribed

into the emission

reduction calculation.

Independent lab

conducts gas analysis.

An internal process is

used to validate results

(low).

High Substantive test: Analyze gas compositions for

significant fluctuations or abnormal gas

concentrations. Confirm the accurate

transcription of the gas analysis into the




13


Component


Risk Design


Completeness (low)

The gas compositions

may not include a valid

gas composition for each

period at the required

frequency.

N/A (controls not

considered for

verification)

High Substantive test: Review completeness of gas

composition data.


methane at STP

conditions

Accuracy (low)

The density of methane

applied in the calculation

may not represent the

density at STP

conditions.

N/A (controls not

considered for

verification)

Medium Substantive test: Compare the density of

methane applied in the calculations to the

reference value provided in the relevant

reference documents.

EMISSION QUANTIFICATION AND REPORTING

Quantification of

emission reduction

Accuracy (high)

Emission reduction

calculation may contain

arithmetic errors.

N/A (controls not

considered for

verification)

Low Substantive test: Recalculate the complete

emission reduction using original data.



14


Component


Risk Design


Application of approved

quantification protocol

Accuracy (high)

The project developer

may not have

implemented approved

quantification

methodologies or applied

additional methodologies.

Responsible Party has

developed an Offset

Project Plan that is

intended to conform to

the requirements of the

approved quantification

protocol. The protocol

requirements may not

have been

implemented correctly

(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.


emission reduction using original data and

methods described in the approved


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.

N/A (controls not

considered for

verification)

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.



15

Sampling Plan

The verification procedures that 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 6: Sampling Plan

Activity Data /

Inventory

Component

Detection

Risk

Design

Description of Verification

Procedure

Sampling Methodology and

Justification

Sample Size

Sampling will not be used for any of the verification activities in this verification.