In this section:
EPAP – Basics
Question: What does Level of Assurance really mean?
Answer: Level of assurance is the confidence a person has in any assertion. For example, consider the assertion that the Earth is a sphere. Today this assertion is almost universally accepted while centuries ago this assertion was deemed false. In an EPAP context, operators are asked to demonstrate that their assertion about their state of compliance, as submitted on their declaration, is true to a reasonable level of assurance.
Question: What's in EPAP for me?
Answer: EPAP is intended to help operators to continuously improve their measurement and reporting processes. These improvements will increase compliance and reduce the number of field inspection and audit findings.
Question: I am a busy person. Please tell me what I need to do to comply with EPAP.
- Review the Compliance Assessment Report, likely monthly, for problems that you need to address
- Conduct evaluations of controls to support your declaration.
- Submit a declaration annually for all your operated facilities.
Question: What happens if I do nothing?
Answer: As occurs when operators ignore other AER Directives, you will receive notice of noncompliance for failing to submit a declaration, as described in Directive 019: Compliance Assurance
. The noncompliance process undermines an operator's reputation.
Question: How can I increase my compliance?
Answer: The following actions will increase your compliance:
- Improve your business processes.
- Improve the design and operation of your controls. This may require increasing the number of controls and increasing the frequency of operations of the controls.
- Increase the frequency of your evaluations of controls.
- Proactively fix the problems identified by your evaluations of controls.
Question: What assistance is available?
Answer: Under EPAP, every Operator is assigned a specific Production Audit Team (PAT) member. That person will contact you shortly after the program goes live to provide you access to the EPAP System and to answer any questions you may have. From then on, you can call that person any time you need help with understanding the Enhanced Production Audit Program or using the EPAP System. If you need help of a more technical nature, in the area of designing and evaluating controls, you may find some of the links on our References and Resources page helpful.
Question: I have high confidence in the quality of work of our field staff and our production accountants. Why do I need to do more work?
Answer: Perhaps you don't. If you have reason to be confident, you probably already have a System of controls in place. All that is required is to evaluate your controls to the extent that your company is can be confident in declaring its state of compliance to the AER.
The best way to confirm your confidence is by conducting some evaluations of controls. In the case of small operators, where senior executives are intimately involved in operations, their daily work often includes the exercise of informal controls that provide adequate assurance. In this situation more work will not be required.
Question: How does the AER know that industry is operating with low measurement and reporting compliance?
Answer: AER production audit findings over many years show a pattern of consistent and continuing noncompliance. The PAT has not completed a production audit in many years that has not resulted in significant audit findings.
Question: EPAP sounds expensive for my company
Answer: EPAP requires you to perform some evaluations of controls to determine their effectiveness in ensuring compliance. How many evaluations of controls must be conducted is largely left to your judgment but it must be sufficient to conclude the declaration process with confidence. There may be some costs associated with this, but we believe these will be manageable and that these are part of good management. If you can already demonstrate compliance with AER measurement and reporting requirements, then EPAP itself is quite inexpensive.
If you find, however, that you are not compliant, there may be costs associated with becoming compliant. These are not costs of EPAP; they are costs related to fulfilling the AER compliance you agreed to when you became an industry operator or were issued an AER license.
Beyond this, EPAP requires only that you comply with the declaration process; an effort of a half-day or less per year.
Question: How do I demonstrate that I'm compliant to a reasonable level of assurance?
- Document your business processes.
- Design and operate controls over the business processes.
- Evaluate enough of the controls that you can confidently describe the state of your compliance.
- Fix problems identified by your evaluations of controls.
Question: The directive makes it sound like we are being required to declare that we are in compliance with all measurement and reporting requirements. Is this right?
Answer: No, it is not. You are required to declare only that you are confident that you know the state of compliance in the facilities you operate. Evidence to support that declaration consists of having designed controls to ensure compliance, operating those controls and conducting evaluations of these controls to ensure that they are effective. If your evaluation of your controls determines that they are not effective, and you are working towards remediating the problems, then that becomes part of your declaration.
Question: Does my compliance have to be perfect or very close to perfect before I can declare?
Answer: No. You are asked to declare the state of your infrastructure to ensure compliance, not your state of compliance.
Initially, you may find that the state of your infrastructure is not good. In this case, the AER expects you to fix the problems.
Question: How do I know I can declare?
Answer: You can submit your declaration when you are confident about the state of your compliance. You gain this confidence by conducting evaluations of your controls.
Question: How is an operator's EPAP Declaration month determined?
Answer: Operators are encouraged to choose a declaration month that is convenient to their operation. The AER Production Audit Team suggests that operators choose a declaration month other than the month of their financial year-end.
The AER Production Audit Team:
- Wants to ensure that operators have a significant preparation time before their first declaration must be submitted. .
- Wants to avoid the situation where most operators declare in the 4th quarter of the calendar year.
Question: How should Operators select their Declaration reporting month?
Answer: When selecting their Declaration month, Operators should consider other business activities that may impact their ability to declare. These activities could include fiscal and/or financial year-end, resource availability (e.g., employee vacation), financial audit period, etc.
When choosing their Declaration month (e.g., October), Operators should note that the submission deadline for the Operator’s Declaration is by the end of the month following that Declaration month (e.g., November 30).
Question: I have completed entering my evaluation of controls results for each theme. How do I submit my declaration?
Answer: For detailed instructions on how to submit your declaration, please see the document titled “Steps to submit annual Declaration in the EPAP System”
Question: How do I export, save, and print the Declaration Report?
Answer: For detailed instructions on how to submit your declaration, please see the document titled “Steps to Access and Print Declarations in the EPAP System”.
Question: How do I assign my Primary Contact and Report Recipients?
Answer: For detailed instructions on how to assign a Primary Contact or Report Recipient, please see the document titled “Steps to designate a Primary Contact OR Report Recipient in the EPAP System”.
Question: How do I enter my Signing Executives for the Declaration?
For detailed instructions on how to enter Signing Executives, please see the document titled “Steps to designate Signing Executives in the EPAP System”.
Question: How do I complete the data entry required for my annual Declaration within the EPAP System?
Answer: For detailed instructions on how to complete the data entry required for you Declaration, please see the document titled “How an Operator Completes and Submits a Declaration within the EPAP System”.
Question: Are Compliance Assessment Indicators the same as Noncompliance events?
Answer: No, they are not. As the name suggests, noncompliance events are actual non-compliances, the result of what happens if an operator is not meeting a directive requirement. On the other hand, Compliance Assessment Indicators are signs that there may be a problem – as the name suggests, they are indicators of potential noncompliance.
Question: There are compliance assessments listed on the EPAP report that are also e-mailed to us monthly by the PETRINEX– are we required to respond to both the PETRINEX and AER?
Answer: If I understand your question correctly, what you are asking about pertains to the AER Noncompliance Reports that are issued by the PETRINEX on a monthly basis. These are associated with VME Reporting Errors and are subject to noncompliance fees and are not the same as the CAI Reports issued by the EPAP RSAM System. Therefore, your company would still be required to respond to the PETRINEX and take corrective actions as needed.
Controls and Evaluations of Controls
Question: How many evaluations of controls are enough?
Answer: This is left to operator judgment. The Operator's Handbook provides guidance; however, if your facilities show high scores on the Compliance Assessment Report, Production Audit Team (PAT) will ask you to do more.
Question: We are a small operator. We don't have formal processes and controls. The evaluation of controls concept feels excessive.
Answer: At small operators, we anticipate that senior management will have direct knowledge of the state of its compliance. That direct knowledge may enable you to conclude the declaration process with confidence without additional effort.
Working with the Production Audit Team (PAT)
Question: How often can I expect to hear from my Production Audit Team (PAT) member?
Answer: Our goal is continuous auditing and continuous improvement. We expect that each PAT member will review the Compliance Assessment results for all of their assigned operators every month, and then contact most of them. We expect these contacts to be reasonably brief and focused on one or two major issues at specific facilities with high scores or outstanding issues. The contacts may be about remediation of deficiencies identified on your Declaration, they may be about troublesome scores on your Compliance Assessment report, or they may even be about acknowledging that your scores have improved. But we hope you'll hear from them often and that your state of compliance will continuously improve.
Question: How do I know whether to email epapsupport@AER.ca or try to connect with my PAT contact?
Answer: The email address epapsupport@AER.ca
exists to provide a centralized mailbox for technical questions related to the EPAP System. For example, questions related to inability to access the System, memory issues, slow navigation, DDS issues, etc. For all other inquiries, please contact your assigned PAT member.
Question: Can I designate more than one Primary Contact?
Answer: Yes; however, the PAT strongly discourages assigning more than one Primary Contact. This is because:
PAT members have no way of distinguishing among multiple Primary Contacts and will always call the first name on the list.
It is more effective and efficient to have one single point of contact.
Question: I originally sent an email to my PAT member 3 days ago, and did not receive a response. I called yesterday and left a message, and still have not heard from anyone. How long should I expect to wait before receiving a response?
Answer: PAT members, as well as Industry personnel, are in the process of implementing EPAP. During this transition, although providing a timely response to Industry inquiries IS one of the priorities of the PAT, PAT members are tasked with numerous EPAP-related responsibilities, including daily morning-long team meetings. Therefore, the time required to address such tasks may, on occasion, delay a response to Industry from the PAT member.
Question: How do Authorized Contacts access the EPAP Website?
Answer: For detailed instructions on how Authorized Contacts may access the EPAP System, please see the document titled “EPAP System Access Log On Instructions