Verification Report for: Prepared by: Prepared for: Version

Modern Resources Pneumatic Device Electrification Project 1714-3474 March 2020

Version 3.0 Offset Verification Report Form

Verification Report for: Modern Resources Pneumatic Device Electrification Project 1714-3474

Proponent Name and Proponent Project Number:

Modern Resources Inc. 1714-3474

Prepared by:

Brightspot Climate Inc.

Prepared for:

Alberta Environment and Parks

Version: Final

Date:

March 30, 2020


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Table of Contents 1.0 Summary of Offset Project .................................................................................... 3 2.0 Introduction ........................................................................................................ 6

2.1 Objective ............................................................................................................ 6 2.2 Scope ................................................................................................................ 6 2.3 Level of Assurance ............................................................................................... 7 2.4 Criteria ............................................................................................................... 7 2.5 Materiality .......................................................................................................... 7

3.0 Methodology ....................................................................................................... 8 3.1 Procedures ......................................................................................................... 8 3.2 Team ............................................................................................................... 16 3.3 Schedule .......................................................................................................... 17

4.0 Results ............................................................................................................. 18 4.1 Assessment of Internal Data Management and Controls .......................................... 18 4.2 Assessment of GHG Data and Information ............................................................. 19 4.3 Assessment against Criteria ................................................................................ 24 4.4 Evaluation of the GHG Assertion .......................................................................... 29 4.5 Summary of Findings ......................................................................................... 30 4.6 Opportunity for Improvement .............................................................................. 31

5.0 Closure ............................................................................................................ 31 5.1 Verification Statement ........................................................................................ 31 5.2 Limitation of Liability .......................................................................................... 31 5.3 Confirmations .................................................................................................... 31

6.0 References ........................................................................................................ 32 Appendix A: Final Verification Plan and Sampling Plan ........................................................... 33 Appendix B: Statement of Qualifications .............................................................................. 55 Appendix C: Findings and Issues ........................................................................................ 58 Appendix D: Statement of Verification ................................................................................. 60 Appendix E: Conflict of Interest Checklist ............................................................................. 64 Appendix F: Supplemental Diagrams/Tables/Figure ............................................................... 67

List of Tables Table 1: Risk Assessment .................................................................................................. 12 Table 2: Findings of Data Integrity Verification Procedures ..................................................... 18 Table 3: Findings of GHG Data and Information Verification Procedures ................................... 19 Table 4: Findings of Criteria Verification Procedures .............................................................. 24 Table 5: Offset Criteria Assessment ..................................................................................... 28 Table 6: Summary of Findings ............................................................................................ 30 Table 7: Confirmation Findings ........................................................................................... 31 Table 8: Detailed Findings and Issues Log ............................................................................ 59 Table 9: Supporting Documentation Reviewed ...................................................................... 68


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1.0 Summary of Offset Project

Item Description

Project Title Modern Resources Pneumatic Device Electrification Project

Project Description

This project quantifies greenhouse gas (GHG) emission reductions resulting from the conversion and installations of gas driven pneumatic devices to solar powered devices. The Modern Resources Pneumatic Device Electrification Project has two components: Pneumatic pump electrification and pneumatic controller electrification.

Both project components will use electric energy produced by zero emissions renewable source in place of pneumatic pressure to drive the pneumatic devices. This eliminates methane and carbon dioxide which would have been vented from pneumatically driven devices had the project not occurred.

Project Location All subprojects are located throughout Alberta’s provincial boundary

Project Start Date May 8, 2018

Offset Start Date May 8, 2018

Offset Crediting Period May 8, 2018 – December 31, 2022

Offset Reporting Period January 1, 2019 - December 31, 2019

GHG Assertion (Actual Emission Reductions/Sequestration Achieved)

13,107 tonnes CO2e

Government Approved Quantification Protocol

Quantification Protocol for Greenhouse Gas Emission Reductions from Pneumatic Devices, Version 2.0, January 2017

Ownership Modern Resources Inc. owns and operates all the subprojects pertaining to the aggregated project.

Project Activity

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;


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• 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 described in the Protocol. The results of this analysis are described in Section 4.3 of this report.

Project Contact

Nigel Campbell Modern Resources Inc. 200, 110 – 8th Avenue SW Calgary, AB, T2P 1B3, Canada +1 (403) 471-8190 [email protected]

Lead Verifier and Designated Signing Authority

Aaron Schroeder, P.Eng. Brightspot Climate 401 – 409 Granville Street Vancouver, British Columbia V6C 1T2 604.353.0264 [email protected]

Verification Team Members

Aaron Schroeder, P.Eng. Role: Lead Verifier Training: Greenhouse Gas Verification – ISO

14064-3, Canadian Standards Association, 2012

Rodrigo Cubedo, EIT Role: Associate Verifier Training: Greenhouse Gas Validation and

Verification, ISO 14064-3, University of Toronto, 2019

Ayla Nguyen, Co-op Student Role: Associate Verifier Training: Verifier in Training


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Jeanna Brown, P.Eng. Role: Technical Expert Training: Greenhouse Gas Validation and

Verification, ISO 14064-3, University of Toronto, 2017

Sheldon Fernandes, P.Eng. Role: Peer Reviewer Training: Greenhouse Gas Verification

– ISO 14064-3, University of Toronto, 2019

Verification Strategy

The verification strategy applied a largely substantive approach. The verification procedures, which are detailed later in this section, were designed to test the activity data directly, wherever practical. By applying this approach, the verification did not rely heavily on the Responsible Party’s controls, but rather relied on the substantive evidence collected from verification procedures that reviewed metered data, data directly from invoices and independent laboratory reports, for example.

Verification Conclusion The verification conclusion is: Positive


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2.0 Introduction

Summary of Offset Project Baseline

The project will reduce greenhouse gas emissions by eliminating the volume of natural gas (methane) vented to atmosphere from pneumatic devices. In the baseline condition, existing devices would continue to vent higher volumes of natural gas, consisting primarily of methane, to atmosphere. In the project condition, these high venting pneumatic devices are replaced with functionally equivalent devices or systems that operate on electricity generated on-site through solar panels.

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.

No changes to the project boundary, emission sources, measurement and monitoring or quantification methodologies were found.

2.1 Objective 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

Project Name: Modern Resources Pneumatic Device Electrification Project

Serial Range: To be assigned at registration.

Organizational Boundary: Modern Resources Inc.

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

Physical Operations: Natural gas processing

Pneumatic devices and controllers

Emission Sources: Fuel Extraction & Processing

Process Control Electricity

Process venting


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Vented Fuel Gas

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: January 1, 2019 - December 31, 2019

2.3 Level of Assurance The verification was conducted to a reasonable 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 The program criteria used, and relevant supporting documentation is as follows:

• Climate Change and Emissions Management Act • Technology Innovation and Emission Reduction Regulation (133/2019) • Standard for GHG Emission Offset Project Developers, Version 3.0, Nov. 2019 • Standard for Validation, Verification and Audit, version 4.0, Nov. 2019 • Quantification Protocol for Greenhouse Gas Emission Reductions from Pneumatic

Devices, Version 2.0, January 2017

2.5 Materiality 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

This verification was designed and completed according to the requirements of the ISO 14064-3 Standard.

The following verification activities (assessments/tests/reviews/evaluations) were conducted through the course of this verification. The specific verification activities that were conducted are detailed in the Verification Plan, which is appended to this report. They are also listed with the verification findings throughout section 4 of this report.

• Observations: the site visit included a tour of the project sites to observe emission sources, observation of the centralized meter data collection, and observation of the meter normalization for standard temperature and pressure;

• Review of documentation: the site visit included a review of the site metering diagram and process flow diagram, documentation supporting the activity data was reviewed, including review of any manual transcription that was applied between documents and the emission quantification software, meter calibration reports were reviewed for completeness and to identify any metering issues;

• Recalculation: the emissions 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, production accounting personnel, and environmental reporting personnel.

• Analytical procedures: a year-over-year comparison of overall emissions offsets was performed.

3.1 Procedures The verification strategy applied a largely substantive approach. The verification procedures, which are detailed later in this section, were designed to test the activity data directly, wherever practical. By applying this approach, the verification did not rely heavily on the Responsible Party’s controls, but rather relied on the substantive evidence collected from verification procedures that reviewed metered data, data directly from invoices and independent laboratory reports, for example.

Regarding the scale and complexity of the verification procedures, the verification risk assessment was leveraged to design verification activities appropriate to address the inherent, controls and detection risk evaluated in relation to each activity data and boundary condition. In most cases, these verifications involved review of documentation, recalculation or analytical procedures designed to produce verification evidence to support the accuracy, completeness and consistency of the information. All activity data and boundary conditions were evaluated through the verification risk assessment, and verification activities were designed and completed commensurate with the verification risk assessed.

In a similar way, the data integrity, quantification methodologies and quantification itself were assessed through the verification risk assessment. Verification procedures were designed and completed to address each of these key areas.


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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.

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.

Generally, a substantive approach was applied to the verification. Therefore, the verification procedures relied more heavily on data analysis than on controls testing.

Verification Plan

Brightspot Climate developed a Verification Plan that documents the level of assurance, verification objective, verification criteria, verification scope, and materiality. Additionally, the Verification Plan provides a general description of the Project, documents operational and organizational changes that have occurred since the previous verification, explains the Project’s control environment, and describes the safety requirements of the site visit.

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;


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c) The accuracy and level of transparency of measured and estimated data sources, data integrity of electronic and manual data transfers and transcription between data systems and the GHG calculation;

d) The accuracy of the GHG emissions reduction calculations;

e) The completeness, accuracy and transparency of information presented in the Offset Project Plan and Offset Project Report documents, including the implementation of stated methodologies and emission factors in the quantification of emissions reductions; and

f) The accuracy of transcription of final calculated values into the GHG Assertion, including the “confirmations” required by AEP 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

Rodrigo Cubedo attended a full day site visit to the Project, where completeness of data sources, accuracy of measurement and data system integrity was tested through observation and interviews with site operations and production accounting personnel. The site visit included a closing meeting to review outstanding action items and to provide site operations personnel with an overview of the verifier’s observations.

The following Responsible Party personnel were interviewed regarding various aspects of the Project: Zainab Dadashi, Production Foreman, and Ryan Adams, Site Operator.

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.

Through the course of the assessment phase of the verification, Brightspot Climate issued questions and requests for additional documentation and data. These requests were consolidated in a simple electronic tracking 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.


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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.

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

• The Project’s inherent risks; • The Responsible Party’s control risks; and • The detection risks associated with the verifier’s verification procedures.

Inherent Risk × Control Risk × Detection Risk = Verification Risk

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

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

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.


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• 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.

Table 1: Risk Assessment

Source or Risk Area

Attributes Inherent Risk

Control Risk

Det. Risk

Procedure to Mitigate Risk

PROTOCOL APPLICABILITY REQUIREMENTS

Functional equivalence must be demonstrated

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

Protocol is applicable to methane vent reductions; not applicable to reduction of propane or conversion from propane to methane

Occurrence Low High Low Substantive test: Observe equipment and interview operations staff to determine if any propane devices are, or have been, installed.

Project must be a conversion (brownfield) or an acceptable install (greenfield)

Occurrence High High Low Substantive test: Review documentation for a sample of sites that establishes eligibility according to Table 1 of the Protocol.

Pneumatic devices must be properly maintained and inspected

Consistency Low Low Low Control Test: Review the Responsible Party’s management system and records to determine if inspection and maintenance procedures have been


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Source or Risk Area


Control Risk

Det. Risk


implemented for all sites and have been maintained through the reporting period. Substantive test: Observe equipment and interview operations staff to determine if inspection and maintenance procedures have been done.

An inventory of devices must be maintained

Completeness

Medium Low Low Substantive test: Observe devices during site visit and compare against project inventory to evaluate completeness.

Accuracy Medium Low Low Substantive test: Review documentation supporting the record of conversion (installation/conversion date) and device specifications for a sample of subprojects.

The project must meet the requirements of the Alberta Offset System

Occurrence High High Low Substantive test: Evaluate the Responsible Party’s evidence regarding the general requirements of the Alberta Offset System.

PROTOCOL FLEXIBILITY

Implementation of multiple pneumatic device conversions

Completeness

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

Statistically relevant comparisons or emission factors may be used

Accuracy Medium Low Low Substantive Test: Assess the statistically relevant emission factors applied in the quantification and their reference documentation to ensure they are correctly applied.

Site-specific and make and model-specific emission factors may be applied

Accuracy Medium Low Low Substantive test: Assess the emission factors applied in the calculations to the preferential selection method documented in the OPP, and compare to reference values provided in the relevant reference documents.


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Source or Risk Area


Control Risk

Det. Risk


Preferential order of methods for baseline and project activity quantification for certain project types

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

QUANTIFICATION DATA Equipment inventory

Accuracy Low Low Low Review equipment inventory recorded with SCADA and confirm at site visits.

Completeness

Low Low Low Review equipment inventory recorded with SCADA and confirm at site visits.

Stroke count Accuracy Low Low Low Review stroke count measured with SCADA and confirm at site visits.

Completeness

Low Low Low Review stroke count measured with SCADA and confirm at site visits.

Injection pressure Accuracy Low Low Low Review injection pressure measured with SCADA and confirm at site visits.

Completeness

Low Low Low Review injection pressure measured with SCADA and ensure data is complete.

Gas analysis (% CH4 and % CO2)

Accuracy Low Low Low Substantive test: Analyze gas compositions for significant fluctuations or abnormal gas concentrations.

Completeness

Low High Low Substantive test: Confirm the accurate transcription of the gas analyses into the emission reduction calculation.

Operating hours Accuracy Medium High Low Substantive test: Compare operating hours used in calculations with government reported values.

Device vent rates Accuracy Medium Medium Low Substantive test: Review and confirm selected specified vent rate values using recalculation spreadsheet.


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Source or Risk Area


Control Risk

Det. Risk


Completeness

Medium Medium Low Substantive test: Review and confirm transcription of device specifications from supporting documentation.

Emission factors – natural gas extraction and processing

Accuracy

Low Low Low Review reference document and make sure the emission factors are up to date.

Completeness

Low Low Low Review reference document and make sure the emission factors are all included in the project plan.

Reference density of methane and carbon dioxide at STP conditions

Accuracy Low Low Low Substantive test: Compare the emission factors applied in the calculations to the values provided in the relevant reference documents.

Completeness

Low Low Low Substantive test: Compare the densities of methane and carbon dioxide applied in the calculations to the values provided in the relevant reference documents.

EMISSION REDUCTION QUANTIFICATION

Application of the approved quantification protocol

Accuracy Medium Medium Low Controls test: Compare the methodologies described in the Responsible Party’s Offset Project Plan to the methodologies described in the approved quantification protocol. Substantive test: Recalculate the emission reduction using original metered data and methods described in the approved quantification protocol.

Quantification of emission reduction

Accuracy Medium High Low Substantive test: Recalculate the emission reduction using original metered data.

DATA INTEGRITY

Activity data and emission factor data integrity

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


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Source or Risk Area


Control Risk

Det. Risk


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

Transcription of final emission reduction into Offset Project Report

Accuracy

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

3.2 Team 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 twelve 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: Rodrigo Cubedo, B.Eng.

Biography: Rodrigo Cubedo has a background in mechanical engineering, specializing in aerospace projects. Rodrigo has leveraged his engineering experience to understand and


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systematically improve the processes used to work with international clients. He is fluent in Spanish, English, French and basic Mandarin. His experience working with a large accounting firm through an in-house deployment of analytical software exposed him to a systematic research framework, which he has recently used to complete GHG verifications.

Training: Rodrigo Cubedo graduated as a mechanical engineer from McGill University in June of 2016.

Associate Verifier: Ayla Nguyen, Co-op Student

Biography: Ayla Nguyen is a co-op student at Brightspot Climate. She is completing her Bachelor of Science in Earth Sciences at Simon Fraser University. Throughout her studies, she had experience composing a hydrogeology consultation project at Southern Ontario waste landfill site where blasting of site resulted in fractures in the unconfined rock layer. The project includes determining the confined and unconfined aquifer parameters to determine the rate and direction of contaminated groundwater. At Brightspot,

Training: Verifier in Training

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.

Peer Reviewer: Sheldon Fernandes, P.Eng.

Biography: Sheldon Fernandes is a Consultant for Brightspot Climate and has over 6 years of experience implementing innovative policies, programs, and technology focused on addressing energy and sustainability issues. He has strong experience in carbon market analysis, regulatory analysis, financial analysis, sustainability reporting, greenhouse gas (GHG) quantification and verification and energy efficiency program design and delivery in a wide variety of jurisdictions worldwide.

Training: Greenhouse Gas Verification – ISO 14064-3, Canadian Standards Association, 2019

3.3 Schedule Verification Kickoff Meeting January 13, 2020

Verification Plan January 24, 2020

Site Visit January 17, 2020

Draft Verification Report March 25, 2020

Final Verification Report March 30, 2020


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4.0 Results 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 The Project’s GHG quantification is primarily performed in Excel spreadsheets: “ERC_Pneumatic_Controllers_Modern_Resources_2019_updated_March_16.xlsx” and “ERC_Pneumatic_Pumps_Modern_Resources_2019_updated_March_16.xlsx”. All data required to quantify emissions reductions for the Project is either manually transcribed into these spreadsheets or electronically transferred from other spreadsheets. The final calculated quantities from these spreadsheets 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 supplier invoices. Meters are maintained on a preventative maintenance program, including periodic calibration. Calibration records are filed on-site.

The Responsible Party maintains an Offset Project Plan (OPP) and produces an Offset Project Report (OPR), which document the emission sources, processes for collecting GHG activity data, equations applied to quantify emissions reduction, calculation assumptions, meter calibration procedure and schedule, the averaging method applied to quantification, and a discussion of GHG data management.

Findings from Previous Verification

There were no discrepancies detected in the previous verification of Modern Resources Pneumatic Device Electrification.

Results of Verification Procedures

There were three verification procedures completed to test data integrity. The results of these procedures are provided in the following table.

Table 2: Findings of Data Integrity Verification Procedures

GHG Report Element

Verification Procedures Verification Findings

Activity data and emission factor data integrity

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

The activity data was reviewed to detect any missing, zeroes or missing data amongst the data provided. Relevant activity data such as gas analyses were evaluated for completeness and abnormal values. No discrepancies were detected in the integrity of the activity data.


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GHG Report Element

Verification Procedures Verification Findings

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 data collection 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.

4.2 Assessment of GHG Data and Information The GHG information consists of the activity data applied to quantify emissions reductions, the source documentation for the activity data, the information in the Offset Project Plan, as described in the previous section of this report, and the documentation supporting the boundary, methodologies, meter calibration, and emission factors.

Table 3: Findings of GHG Data and Information Verification Procedures

GHG Report Element


Verification Findings

Quantification Data

Equipment Inventory Substantive test: review that the field operation logs match the values in the emission reduction calculator.

The pumps and controllers logged by the Responsible Party match the devices used in the quantification spreadsheet. Furthermore, the pump dimensions were confirmed during the site visit and through additional clarification with the Responsible Party. No discrepancies were identified between the devices logged by the Responsible Party, the quantification spreadsheet and project report.


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GHG Report Element



Stroke Count Substantive test: review that the field operation logs match the values in the emission reduction calculator.

The stroke count was obtained from a SCADA report. The stroke counts were accurately transcribed to the Responsible Party’s quantification. No discrepancies were detected between the pressure logs and the Responsible Party’s quantification spreadsheet.

Injection Pressure Reasonableness test: review that the injection pressures fall within a reasonable range.

The injection pressure was obtained from a SCADA report and used to determine the correct emission factor from the manufacturing spreadsheet. No discrepancies were detected between the pressure logs and the Responsible Party’s quantification spreadsheet.

Gas analysis (% CH4 and % CO2)

Substantive test: Analyze gas compositions for significant fluctuations or abnormal gas concentrations.

Review of the gas compositions did not reveal significant fluctuations or abnormal concentrations. No discrepancies were detected in the gas composition analyses used in the quantification.

Substantive test: Confirm the accurate transcription of the gas analyses into the emission reduction calculation.

Third party gas analyses were compared against the values used to quantify emission reductions. Transcription of the gas analysis data to the emission reduction calculation was completed accurately. No discrepancies were identified. Gas analyses were correctly transcribed.

Substantive test: Review completeness of gas composition data.

A review of gas compositions applied in the quantification confirmed that monthly gas composition data was used. Various devices did not use the gas composition associated to the downhole location. The responsible party explained that these locations had the equivalent gas composition as the nearby plant. As a result, the responsible party used the gas composition from this plant to estimate the methane composition of the gas that would have been otherwise used to power the baseline pneumatic devices. No discrepancies were detected in the completeness of the gas composition data.


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GHG Report Element



Operating hours Substantive test: Compare operating hours used in calculations with government reported values and/or raw data from the subproject participant’s data collection software.

The operating hours data for each site were reviewed against participant’s data collection software (SCADA), and were found to be complete. Reported operating hours reflect production downtime during which fuel gas systems (supplying the pneumatic instruments) often remain energized. This is therefore a conservative approach to accounting for operating hours in the quantification. No discrepancies were detected in the operating hours data used in the quantification.

Device vent rates Substantive test: Review and confirm selected specified vent rate values using recalculation spreadsheet.

The vent rate values used in the quantification were taken from the Protocol and manufacturer specifications. For two conversion types, vent rates were derived from a statistically relevant set of field measurements as described in the Protocol. CO2 emission factor for CVS4150 controller was not thoroughly applied. The responsible party fixed this quantification error and updated the total GHG assertion. No discrepancies were identified. The vent rates were obtained from sources that met the protocol criteria.

Substantive test: Review and confirm transcription of device specifications from supporting documentation (field technician installation record) into the data management system.

The vent rates quoted by the Responsible party match the rates used in the quantification spreadsheet. No discrepancies were detected in the transcription of device specifications.


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GHG Report Element



Emission factors – natural gas extraction and processing

Substantive test: Compare the emission factors applied in the calculations to the values provided in the relevant reference documents. Substantive test: Review reference document and make sure the emission factors are all included in the project plan.

The verification team compared the emission factors mentioned in the Offset Project Plan to the emission factors described in the approved Quantification Protocol. The quantification methods described in the Responsible Party’s Offset Project Plan adhere to the methods described in the approved Quantification Protocol. No discrepancies were detected in the emission factors of natural gas extraction and processing.

Reference density of methane and carbon dioxide at STP conditions

Substantive test: Compare the densities of methane and carbon dioxide applied in the calculations to the values provided in the relevant reference documents.

The Responsible Party calculated the density for methane and carbon dioxide using STP conditions. The same value was calculated in the independent recalculation. No discrepancies were detected in the calculated densities for methane and carbon dioxide used in the quantification.

Emission Quantification and Reporting

Application of the approved quantification protocol

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

The verification team compared the methods described in the Offset Project Plan to the methods described in the approved Quantification Protocol. The quantification methods described in the Responsible Party’s Offset Project Plan adhere to the methods described in the approved Quantification Protocol. No discrepancies were detected in the methodologies described in the Offset Project Plan.


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GHG Report Element



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

Recalculation of emissions reduction was performed using the quantification methodology described by Alberta’s pneumatic devices protocol. The independent recalculation resulted in the same emission reduction quantity asserted by the Responsible Party. No discrepancies were detected in the application of the approved quantification protocol.

Quantification of emission reduction

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

The independent recalculation of the emission reduction resulted in the same emission reduction quantity asserted by the Responsible Party. Therefore, the Verification Team concluded that no arithmetic or calculation errors were made by the Responsible Party in the emission reduction quantification. Alternative sources of energy (methanol and gasoline) to power the electric devices were noted during the site visit. The responsible party explained that these were only used if there were not to be enough solar energy to power the device. The responsible party provided a conservative estimate of emissions generated by these sources on the project condition. No discrepancies were detected in the recalculation of the emission reduction quantification.


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4.3 Assessment against Criteria Table 4: Findings of Criteria Verification Procedures

GHG Report Element Verification Procedures



Functional equivalence must be demonstrated

Substantive test: Observe equipment 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 pneumatic controllers and pumps, and found that an equivalent level of service is provided by all installations. Site staff indicated that the systems work well and reliably. Ongoing maintenance is performed during regular facility maintenance. Manufacturer specifications indicate that the electric devices can perform equivalent operational function when compared to the high bleed devices present in the baseline condition, further supporting functional equivalence. No discrepancies were detected in the functional equivalence of the converted devices.

Protocol is applicable to methane vent reductions; not applicable to reduction of propane or conversion from propane to methane

Substantive test: Observe equipment and interview operations staff to determine if any propane devices are, or have been, installed.

During the site visits and interviews with site personnel no propane devices were observed, and there were no indications of the use of propane. No discrepancies were detected in the applicability of the Protocol to methane vent reductions only.

Project must be a conversion (brownfield) or an acceptable install (greenfield)

Substantive test: Review documentation for a sample of sites that establishes eligibility according to Table 1 of the Protocol.

All documentation was reviewed to ensure compliance with Table 1 of the Protocol. No discrepancies were identified. The project includes electrification of pneumatic devices in accordance with Table 1 in section “1.2 Protocol Applicability” of the protocol.


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Pneumatic devices must be properly maintained and inspected

Control Test: Review the Responsible Party’s management system and records to determine if inspection and maintenance procedures have been implemented for all sites and have been maintained through the reporting period.

Although this criterion is not applicable for Pneumatic Device Electrification, the Responsible Party performs annual maintenance through a third-party service provider for all their devices. No discrepancies were detected in the maintenance and inspection of pneumatic devices.

An inventory of devices must be maintained

Substantive test: Observe devices during site visit and compare against project inventory to evaluate completeness.

The Responsible Party maintains a comprehensive inventory list of subprojects included in the aggregated project. Installed equipment observed during site visits were compared against the Responsible Party’s inventory. No discrepancies were detected in the project device inventory.

Substantive test: Review documentation supporting the record of conversion (installation/conversion date) and device specifications.

Installation Records (IRs) were reviewed for a sample of subprojects. Device specifications and installation dates were compared between the IRs and the calculation sheets No discrepancies were detected in the transcription of device specifications.


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The project must meet the requirements of the Alberta Offset System

Substantive test: Evaluate the Responsible Party’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 documentation, installation records, 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 documentation, and the recalculation of the emission reduction. Clearly established ownership – Modern Resources Inc. owns and operates the facilities at which the Project is implemented and asserts that it has ownership of the emissions reductions. 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.


Implementation of multiple pneumatic device conversions

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. No discrepancies were detected in the completeness of the data and documentation for the device conversions included in this project.


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Statistically relevant comparisons or emission factors may be used

Substantive Test: Assess statistically relevant emission factors applied in the quantification, and review source data and documentation used in their derivation.

Emission factors derived from a statistically relevant set of field measurements was applied for two device conversion types in the aggregated project. The field measurements and determination of the emission factors were done by a third party. No discrepancies were detected in the use of statistically relevant emission factors.

Site-specific and make and model-specific emission factors may be applied

Substantive test: Assess the emission factors applied in the calculations to the preferential selection method documented in the OPP and compare to reference values provided in the relevant reference documents.

The calculation of the site-specific and make and model-specific emission factors resulted in the estimated emission factors from the manufacturer specification tables. The quantity asserted by the Responsible Party reasonably matches the quantity recalculated. 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 site-specific and make and model-specific emission factors.

Preferential order of methods for baseline and project activity quantification for certain project types

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 resulted in the same emission reduction quantity asserted by the Responsible Party. Therefore, the approved Protocol quantification methods and preferential order of methods were applied in the Responsible Party’s emission reduction quantification.

No discrepancies detected.


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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 subprojects 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;

The project start date is May 8, 2018.

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.

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

The results of each verification procedure are provided in the preceding three subsections (4.1 – 4.3). Sufficient and appropriate evidence was collected through the verification procedures to reach the verification conclusion at a reasonable level of assurance, which is provided in the Verification Statement.

The data and GHG information provided by the Responsible Party is sufficient to support the GHG assertion.

There were no material or immaterial discrepancies detected in the final GHG assertion.


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4.5 Summary of Findings Table 6: Summary of Findings

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

Understatement/Overstatement

Tonnes CO2 eq % net

Tonnes CO2 eq % absolute

NA NA There were no discrepancies detected in the verification of Modern Resources Pneumatic Device Electrification Project.

NA NA NA

Total % Error N/A


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4.6 Opportunity for Improvement Overall, the GHG information was orderly and thoroughly presented.

The quantification spreadsheets were satisfactorily organized and sufficiently transparent to conduct the verification procedures.

Sufficient and appropriate evidence was provided by the Responsible Party to conduct each of the verification procedures.

The Offset Project Plan and Offset Project Report thoroughly document the emission sources, quantification approach, equations, data collection and information controls.

5.0 Closure 5.1 Verification Statement The verification conclusion is: Positive

5.2 Limitation of Liability

5.3 Confirmations

Table 7: Confirmation Findings

Confirmation Confirmation Finding

Correct entry of administrative fields such as facility codes and legal locations

The Offset Project Report was reviewed for completeness and accuracy. All 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


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Planning Sheet and accurately describe the subprojects included in the Project.

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

This requirement is not applicable to Offset Projects.

For forecasting facilities, the fund to credit ratio was met


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


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

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

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


6.0 References The documents reviewed through the course of the verification include: None.

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Appendix A: Final Verification Plan and Sampling Plan

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

Modern Resources Inc.

Pneumatic Device Electrification Project Verification Plan

January 24, 2020

This page intentionally blank

Brightspot Climate Inc. – Verification Plan Modern Resources Inc. – Pneumatic Device Electrification Project

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 Climate Change Office 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 Modern Resources Pneumatic Device

Electrification Project which will be referred to throughout this document as “the Project”.

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 Modern Resources Inc. (Modern).

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 2 of this document.

1 Standard for Validation, Verification and Audit, Version 3.0, December 2018, Alberta Climate Change Office.


1

Introduction

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

independent verification of the Offset Project Report for the Modern Resources Pneumatic Device

Electrification Project.

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 Greenhouse Gas Emission Reductions from Pneumatic Devices, Version

2.0, January 2017 (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


2

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


3

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

Climate Change Office Guidance Document2, Section 5.1.3

Criteria

• Climate Change and Emissions Management Act

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

November 2019

• Standard for Greenhouse Gas Emission Offset Project Developers,

Version 3.0, November 2019

• Technology Innovation and Emission Reductions Regulation (A.R.

133/2019, as amended)

• Quantification Protocol for Greenhouse Gas Emission Reductions

from Pneumatic Devices, Version 2.0, January 2017

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


4

Scope

Project Name: Modern Resources Pneumatic Device

Electrification Project

Geographic Boundary: All subprojects are located throughout Alberta’s

provincial boundary.

Physical Operations: Natural gas processing and compression

Pneumatic devices and controllers Emission Sources: Pneumatic pump and controller electrification

• B7: Vented Fuel Gas

• P7: Project Vented Gas

• P8: Process Control Electricity

• P9: Fuel Extraction and Processing

IPCC GHGs Emitted: Carbon Dioxide (CO2)

Methane (CH4)

Nitrous Oxide (N2O)

Reporting Period: January 1, 2019 – December 31, 2019

Materiality Quantitative materiality threshold is 5% of asserted greenhouse gas

emission reduction.

Preliminary Verification

Schedule

Verification Kickoff Meeting January 13, 2020

Draft Verification Plan January 24, 2020

Site Visit February 25, 2020

Draft Verification Report March 25, 2020

Final Verification Report March 30, 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 be the technical expert and will provide analytical support to the verification

team through the completion of the verification procedures and the development of the Verification

Report.

Rodrigo Cubedo, EIT will provide analytical support to the verification team through the completion of

the verification procedures and the development of the Verification Report.

Ayla Nguyen, Co-op student, will provide analytical support to the verification team through the

completion of the verification procedures and the development of the Verification Report.

Sheldon Fernandes, P.Eng., will conduct an independent peer review of the verification.


5

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 must be clean shaven and are required to wear personal protective

equipment including CSA approved hard hat, steel toed boots, fire retardant coveralls, work gloves,

hearing protection and eye protection with side shields. A site orientation must be completed before

entering the site.


6

Responsible Party Data Management and Controls

Data Management Systems

Modern Resources Inc., as the project developer, has the primary responsibility of collecting GHG

information, quantifying the emission reduction and completing required documentation.

The Responsible Party uses a 3rd party electronic data management software system to collect, record

and manage GHG information to support the emission reduction quantification. The Responsible Party

uses an Excel based calculator to perform the emission reduction calculations. 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

Equipment Inventory

(make, model, plunger

size, stroke length, etc.)

Field Operations Staff

Collection

Field Operations

>>Internal Data Management System Digital

Action Tracking System (DATS)

>>Emission Reduction Calculator (ERC)

Stroke Count Field Operations Staff

Collection

Field Operations

>> DATS

>> ERC

Injection Pressure Automated Collection

Supervisory Control and Data Acquisition (SCADA)

– Remote/on-site data collection

>> Production Manager – Internal Production

Data Management System (ProdMan)

>>ERC

Gas Analysis Third party analysis

Field Operations arrange with AGAT Laboratories

to complete on-site samples

>>Upload analysis on WebFluids database

>>Data populated into ERC

Operating Hours Automated Collection

SCADA

>> Production Volumes Reporting (PVR) – Field

Data Capture System

>>ProdMan

>> ERC


7

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.

• 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

• 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

• Emission factors and references

• Data management

• Data quality controls and procedures


8

Previous GHG Assertions

Changes to Operations and Boundaries

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

There are new pneumatic devices installed and aggregated as part of the Offset Project. Brightspot

Climate Inc. will consider these new devices during site visits and throughout the verification process.

Findings from Previous Verifications

There were no discrepancies identified in previous verification results.


9

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



Functional equivalence

must be demonstrated

Occurrence Medium High Low Substantive test: Observe equipment and interview

operations staff during site visit to determine level of

service provided by project implementation.

Protocol is applicable to

methane vent reductions;

not applicable to reduction

of propane or conversion

from propane to methane

Occurrence Low High Low Substantive test: Observe equipment and interview

operations staff to determine if any propane devices are,

or have been, installed.

Project must be a

conversion (brownfield) or

an acceptable install

(greenfield)

Occurrence High High Low Substantive test: Review documentation for a sample of

sites that establishes eligibility according to Table 1 of the

Protocol.

Pneumatic devices must

be properly maintained and

inspected

Consistency Low Low Low Control Test: Review the Responsible Party’s

management system and records to determine if

inspection and maintenance procedures have been

implemented for all sites and have been maintained

through the reporting period.

Substantive test: Observe equipment and interview

operations staff to determine if inspection and

maintenance procedures have been done.

An inventory of devices

must be maintained

Completeness Medium Low Low Substantive test: Observe devices during site visit and

compare against project inventory to evaluate

completeness.


11


Risk

Control

Risk

Detection

Risk


Accuracy Medium Low Low Substantive test: Review documentation supporting the

record of conversion (installation/conversion date) and

device specifications for a sample of subprojects.

The project must meet the

requirements of the Alberta

Offset System

Occurrence High High Low Substantive test: Evaluate the Responsible Party’s

evidence regarding the general requirements of the Alberta

Offset System.


Implementation of multiple

pneumatic device

conversions

Completeness Medium Low Low Substantive test: Evaluate the completeness of the

required data and documentation for all project sites

included in the aggregated project.

Statistically relevant

comparisons or emission

factors may be used

Accuracy Medium Low Low Substantive Test: Assess the statistically relevant emission

factors applied in the quantification and their reference

documentation to ensure they are correctly applied.

Site-specific and make and

model-specific emission

factors may be applied

Accuracy Medium Low Low Substantive test: Assess the emission factors applied in

the calculations to the preferential selection method

documented in the OPP, and compare to reference values

provided in the relevant reference documents.

Preferential order of

methods for baseline and

project activity

quantification for certain

project types

Accuracy Low Low Low Substantive Test: Recalculate the complete emission

reduction using original data and methods described in the

approved quantification protocol.


12


Risk

Control

Risk

Detection

Risk


QUANTIFICATION DATA

Equipment inventory Accuracy Low Low Low Review equipment inventory recorded with SCADA and

confirm at site visits.

Completeness Low Low Low Review equipment inventory recorded with SCADA and


Stroke count Accuracy Low Low Low Review stroke count measured with SCADA and confirm

at site visits.

Completeness Low Low Low Review stroke count measured with SCADA and confirm

at site visits.

Injection pressure Accuracy Low Low Low Review injection pressure measured with SCADA and


Completeness Low Low Low Review injection pressure measured with SCADA and

ensure data is complete.

Gas analysis

(% CH4 and % CO2)

Accuracy Low Low Low Substantive test: Analyze gas compositions for significant

fluctuations or abnormal gas concentrations.

Completeness Low High Low Substantive test: Confirm the accurate transcription of the

gas analyses into the emission reduction calculation.

Operating hours Accuracy Medium High Low Substantive test: Compare operating hours used in

calculations with government reported values.


13


Risk

Control

Risk

Detection

Risk


Device vent rates Accuracy Medium Medium Low Substantive test: Review and confirm selected specified

vent rate values using recalculation spreadsheet.

Completeness Medium Medium Low Substantive test: Review and confirm transcription of

device specifications from supporting documentation.

Emission factors – natural

gas extraction and

processing

Accuracy

Low Low Low Review reference document and make sure the emission

factors are up to date.

Completeness Low Low Low Review reference document and make sure the emission

factors are all included in the project plan.

Reference density of

methane and carbon

dioxide at STP conditions

Accuracy Low Low Low Substantive test: Compare the emission factors applied in

the calculations to the values provided in the relevant

reference documents.

Completeness Low Low Low Substantive test: Compare the densities of methane and

carbon dioxide applied in the calculations to the values

provided in the relevant reference documents.

EMISSION REDUCTION QUANTIFICATION

Application of the

approved quantification

protocol

Accuracy Medium Medium Low Controls test: Compare the methodologies described in

the Responsible Party’s Offset Project Plan to the

methodologies described in the approved quantification

protocol.

Substantive test: Recalculate the emission reduction using

original metered data and methods described in the

approved quantification protocol.


14


Risk

Control

Risk

Detection

Risk


Quantification of emission

reduction

Accuracy Medium High Low Substantive test: Recalculate the emission reduction using

original metered data.

DATA INTEGRITY

Activity data and emission

factor data integrity

Accuracy Medium Medium Low Controls test: Analyze all activity 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

Low High Low Substantive test: Compare the final emission reduction

quantity reported by the Responsible Party to the quantity

reported in the Offset Project Report. Also, compare these

quantities to the recalculated quantity in previous

verification procedures.


15

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

Equipment

Inventory

Low Substantive test: review that the

field operation logs match the

values in the emission reduction

calculator.

Review of full dataset has lower

detection risk than sampling.

All values

Low Review that the field operator

transcribes the data onto the data

management system are complete.



All values

Stroke Count Low Substantive test: review that the

field operation logs match the

values in the emission reduction

calculator.



All values

Low Review that the field operator

transcribes the data onto the data

management system are complete.



All values


16

Activity Data /

Inventory

Component

Detection

Risk

Design


Procedure


Justification

Sample Size

Injection Pressure Low Reasonableness test: review that

the injection pressures fall within a

reasonable range.



All values

Low Review that the injection pressures

are complete in the project plan.



All values

Gas analysis

(% CH4 and %

CO2)

Low Substantive test: Analyze gas

compositions for significant

fluctuations or abnormal gas

concentrations.

Confirm the accurate transcription

of the gas analysis into the

emission reduction calculation.



Annual sample for each site

Medium Review completeness of gas

composition data.

Review transcription for all gas

analyses has lower detection risk

than sampling.

Review gas analysis for all devices.

Operating hours Low Substantive test: Compare

operating hours used in

calculations with reported values.

Compare reported values for all

sites has lower detection risk than

sampling.

Compare operating hours for all

devices.


17

Activity Data /

Inventory

Component

Detection

Risk

Design


Procedure


Justification

Sample Size

Low Review completeness of operating

hours data.

Compare reported values for all

sites has lower detection risk than

sampling.

All values

Device vent rates Low Substantive test: Review and

confirm selected specified vent rate

values using recalculation

spreadsheet.



All values

Medium Substantive test: Review and

confirm transcription of device

specifications from supporting

documentation (work orders,

invoices, photos, etc.) into data

management system.

Stratification of subproject

participants; random sampling;

discrepancies are normally

distributed

Review vent rates for all devices.

Emission factors –

natural gas

extraction and

processing

Low Compare the emission factors

applied in the calculations to the

values provided in the relevant

reference documents.

Assess statistically relevant

emission factors applied in the

quantification, and review source

data and documentation used in

their derivation.

All values


18

Activity Data /

Inventory

Component

Detection

Risk

Design


Procedure


Justification

Sample Size

Low Review that the emission factors

are complete in the project plan.

Assess statistically relevant

emission factors applied in the

quantification, and review source

data and documentation used in

their derivation.

All values

Reference

densities of

methane and

carbon dioxide at

STP conditions

Low Substantive test: Compare the

densities of methane and carbon

dioxide applied in the calculations

to the values provided in the

relevant reference documents.

There are only two values, to be

applied throughout the

quantification.

Two values

Low Review the referenced densities of

methane and carbon dioxide for

completion in the QMD.

Two values Review the two values for

referenced density that has lower


Page 55 of 69

Appendix B: Statement of Qualifications

Page 56 of 69

Statement of Qualifications

Alberta Emission Offset Project

Emission Offset Project Name Offset Project ID

Modern Resources Pneumatic Device Electrification Project 1714-3474

Emission Offset Project Developer Offset Reporting Period

Modern Resources Inc. January 1, 2019

December 31, 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


March 30, 2020

Page 57 of 69

Peer Reviewer First Name Last Name Sheldon Fernandes E-mail Address Phone Number [email protected]

Sheldon: (647)967-1649


• GHG Validation and Verification, ISO 14064-3, University of Toronto, 2019

Page 58 of 69

Appendix C: Findings and Issues

Page 59 of 69

Table 8: Detailed Findings and Issues Log

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 Alternative sources of energy (methanol and gasoline) to power the electric devices were noted during the site visit.

The responsible party explained that these were only used if there were not to be enough solar energy to power the device. The responsible party provided a conservative estimate of emissions generated by these sources on the project condition.

Resolved No discrepancy was identified with the use of alternative fuel to power the solar driven devices.

19-02 Various devices did not use the gas composition associated to the downhole location.

The responsible party explained that these locations had the equivalent gas composition as the nearby plant. As a result, the responsible party used the gas composition from this plant to estimate the methane composition of the gas that would have been otherwise used to power the baseline pneumatic devices.

Resolved No discrepancy was identified.

19-03 CO2 emission factor for CVS4150 controller was not thoroughly applied.

The responsible party fixed this quantification error and updated the total GHG assertion.

Resolved No discrepancy was identified.

Page 60 of 69

Appendix D: Statement of Verification


Page 61 of 69

Statement of Verification


Emission Offset Project Title

Quantification Protocol (Date/Version) Project ID #

Modern Resources Pneumatic Device Electrification Project


1714-3474

Emission Offset Project Developer Offset Reporting Period Start Serial Range (if applicable)

Modern Resources Inc. January 1, 2019 N/A

Authorized Project Contact (if applicable) Offset Reporting Period End

N/A December 31, 2019

Statement of Verification

Total GHG Assertion

Value Units

Total Baseline Emissions 13,111 tonnes CO2eq

Total Project Emissions 4 tonnes CO2eq

Other (I.e. levied) N/A tonnes CO2eq

Net Reduction 13,107 tCO2e

Statement of Assertion

The Responsible Party’s GHG Assertion is comprised of the Offset Project Plan, Offset Project Report and supporting documentation.


Page 62 of 69

The GHG Assertion covers the reporting period January 1, 2019 – December 31, 2019 and states an emission reduction and removal claim of 13,107 tonnes CO2e over this period.

The emission reduction and removal claim consist of 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 (the “Regulation”), and the Alberta Climate Change Office – Standard for Greenhouse Gas Emission Offset Project Developers, Version 3.0, November 2019.

We completed our review in accordance with the ISO 14064 Part 3: Greenhouse Gases: Specification with Guidance for the Validation and Verification of Greenhouse Gas Assertions (ISO, 2006). As such, we planned and performed our work in order to provide positive, but not absolute assurance with respect to the GHG Assertion.

The verification procedures that were performed through the course of the verification were developed based on the results of a risk assessment that was completed during the verification planning stage. These verification procedures are described in the Verification Plan. Certain verification procedures included data sampling. The sampling type, sample size and the justification for the planned sampling type and size are detailed in a Sampling Plan, which is included in the Verification Plan.

Conclusion

I believe our work provides a reasonable basis for my conclusion.

There were no unresolved misstatements in the final GHG Assertion.

Based on our review, it is my opinion at a reasonable level of assurance that the GHG Assertion is materially correct and presented fairly in accordance with the relevant criteria.


Verification Company Name

Brightspot Climate Inc. Per: Aaron Schroeder


Date:


Aaron Schroeder

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

March 30, 2020


Page 63 of 69

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

Page 64 of 69

Appendix E: Conflict of Interest Checklist


Page 65 of 69

Conflict of Interest Checklist


Emission Offset Project Title

Quantification Protocol (Date/Version)

Modern Resources Pneumatic Device Electrification Project 1714-3474


Project Developer Offset Reporting Period Start Offset Reporting Period End

Modern Resources Inc. January 1, 2019 December 31, 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.


Page 66 of 69


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: Aaron Schroeder


Date:


Aaron Schroeder

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

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

March 30, 2020

Page 67 of 69

Appendix F: Supplemental Diagrams/Tables/Figure

Page 68 of 69

Table 9: Supporting Documentation Reviewed

File Name Description

Project_Report_Modern_Resources_Pneumatic_

Device_Conversion_Feb_2019_updated_March_16.pdf Offset Project Report

Project Plan_Modern Resources Pneumatic Device

Conversion_March 2018.pdf Offset Project Plan

APRS_20200206_2019_updated_March_3.xlsm Aggregated Project Reporting Sheet

ERC_Pneumatic_Controllers_Modern_Resources_

2019_updated_March_16.xlsx

Quantification Spreadsheet

ERC_Pneumatic_Pumps_Modern_Resources_

2019_updated_March_16.xlsx

Quantification Spreadsheet

MCI_-_C1_Stroke_Calculator.xlsx Stroke calculator

MCIData_07-16_P1_to_Brightspot.xlsx MCI Data

Various Gas Analysis invoices (x19 folders) Gas Analysis

Various Operating Hours notepad (x6)

Well Op hours.xlsx

Controller Operating Hours

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.

Page 69 of 69

Accreditation

Brightspot Climate Inc. is an accredited verification body by the Standards Council of Canada1.

This verification was completed in conformance with the requirements of the ISO 14064-3, ISO 14065 and ISO 14066 standards.

1 The SCC Accreditation Symbol is an official symbol of the Standards Council of Canada, used under license.

Documents

Verification Report for: Prepared by: Prepared for: Version