Our new directive, Directive 076: Operator Declaration Regarding Measurement and Reporting Requirements, does not create any new requirements about measurement and reporting. All of those requirements can be found, as before, in the relevant directives, including the following:
Directive 017: Measurement Requirements for Upstream Oil and Gas Operations
Directive 007: Volumetric and Infrastructure Requirement
Directive 046: Production Audit Handbook
Directive 060: Upstream Petroleum Industry Flaring, Incinerating, and Venting
Directive 042: Measurement, Accounting, and Reporting Plan (MARP) Requirement for Thermal Bitumen Schemes
Integrated Compliance Assurance Framework (ICAF)
Manual 011: How to Submit Volumetric Data to the AER
Manual 013: Compliance Enforcement Program
Noncompliance Event Listing:
A comprehensive listing of all AER noncompliance events (including those related to Directive 076)
EPAP requirements apply to those which relate to production measurement and reporting which are found in the Production Audit section NCE 877-971.
EPAP Themes and Associated Noncompliance Events (NCE)
Where an NCE is linked to multiple EPAP Themes, the portion of the NCE pertaining to the theme is highlighted in blue.
To support operator efforts to comply with the requirements of Directive 076: Operator Declaration Regarding Measurement and Reporting Requirements, the EPAP Operator's Handbook includes the following topics:
- the expectations of the AER with regards to the level of assurance over compliance with AER measurement and reporting requirements
- what to consider in designing controls
- how to evaluate the effectiveness of controls
- how to maintain the design of controls to ensure their continued effectiveness in addressing risk of noncompliance relating to AER measurement and reporting requirements
- how to implement EPAP and use it for continuous improvement year after year
- how to interpret and use the compliance assessment reports to identify and track issues
- how to make your annual declaration
Using the EPAP System, for Operators
The EPAP System supports the Enhanced Production Audit Program (EPAP) of the AER.
The principal functions of the EPAP System are used by operators to
- view and export their monthly compliance assessment report,
- submit their annual declaration that describes an operator’s state of their controls over compliance with measurement and reporting requirements, and
- collaborate with the AER Production Audit Team (PAT) on action items and voluntary self-disclosures.
- The EPAP System is also used by the members of the AER PAT to operate EPAP and to review operator submissions.
The AER is trying hard not to be prescriptive about how industry complies with the new directive. Our EPAP Operator's Handbook makes many suggestions, but you may also want to consult any of the following sources. Some may be accessible by subscription only.
Compliance Assessment Indicators (CAI)
The intent of CAI is to identify instances when the volume of gas reported as fuel deviated by more than +/- 50 % from the fuel usage volume expected for various facility subtypes. Possible action(s) to be considered/taken by an operator who has this CAI appearing on their monthly Compliance Assessment Report (CAR) is to confirm the accuracy of the reported fuel gas volumes.
In consultation with the AER measurement specialist, the PAT developed the Questionable Fuel Volume – Facility CAI using two base assumptions:
- what typical equipment we might expect to see at a specific facility sub-type and
- the amount of fuel each piece of equipment may use per manufacture specifications.
Based on those assumptions, a formula was developed for the each facility subtype. The CAI will not be triggered unless the reported Fuel Volume is +/- 50% of the calculated fuel usage estimate.
General Audit Awareness