1. What’s Up with Saskatchewan Measurement?
Corvelle Consulting
2/5/2019
What’s Up with Saskatchewan Measurement?
Good morning! My name is Yogi Schulz; smile
Thank you to CAPPA for inviting me and my partner Clay Long to present today
Our topic is: What’s Up with Saskatchewan Measurement?
How are you doing, today?
Our goal today is to improve your understanding of recent measurement and EPAP developments in Saskatchewan
March 2016
What’s Up with Saskatchewan Measurement?

2. Yogi Schulz Biography Partner in Corvelle Consulting
2/5/2019
Yogi Schulz Biography
Partner in Corvelle Consulting
Information technology consulting
EPAP implementation and operation
Relevant development work:
Led EPAP at AER
Led PSAP at AER
Led measurement at ECON
Leading EPAP at ECON
Proposed presenter: Yogi
Title: Yogi Schulz - Biography
Who am I?
I’m a Partner of Corvelle Consulting
We offer information technology related management consulting
We have executed many project management and systems development assignments for our clients in the upstream oil & gas industry
With my partner Clay Long, our associates and I also work to help operators implement and operate EPAP
I want to highlight a few assignments that are relevant to the Petrinex opportunities I want to describe today:
From 2007 until early 2010, I led the project team that developed EPAP for the AER and the oil & gas industry
In 2013, I worked with AER pipeline engineers to develop an improved pipeline compliance assurance methodology named PSAP
In 2014 and 2015, Clay Long and I worked with the Government of Saskatchewan on the development of the first ever harmonized Directive; Directive 017 for measurement; we hope this directive will be an example that encourages further inter-provincial regulatory collaboration
Since early 2015 Clay Long and I have been working with the Government of Saskatchewan on the development and implementation of EPAP for Saskatchewan operators
What’s Up with Saskatchewan Measurement?

3. Clay Long Biography Partner in Corvelle Consulting
2/5/2019
Clay Long Biography
Partner in Corvelle Consulting
Senior IT Management Consultant and Project Manager
Focus on the oil and gas industry
Specializes in:
program management
project management
facilitation
Led initiatives in:
strategic planning
software development & implementation
major RFP creation & execution
Clay Long Biography
Partner in Corvelle Consulting
Senior IT Management Consultant and Project Manager
Focus on the oil and gas industry
Specializes in:
program management
project management
facilitation
Led initiatives in:
strategic planning
software development & implementation
major RFP creation & execution
What’s Up with Saskatchewan Measurement?

4. Presentation Outline Introduction Background Directive PNG017:
Corvelle Consulting
2/5/2019
Presentation Outline
Introduction
Background
Directive PNG017:
Measurement Requirements for Oil and Gas Operations
Directive PNG076:
Enhanced Production Audit Program (EPAP)
Guideline PNG028:
Initiating and Operating the Enhanced Production Audit Program (EPAP)
Discussion
Presentation Outline
Introduction
Safety moment
Individual introductions
Background
First I’ll provide a quick summary of what led Saskatchewan to pursue improved measurement requirements and EPAP
Directive PNG017:
Measurement Requirements for Oil and Gas Operations
Directive PNG076:
Enhanced Production Audit Program (EPAP)
Guideline PNG028:
Initiating and Operating the Enhanced Production Audit Program (EPAP)
Discussion
What’s Up with Saskatchewan Measurement?

5. Corvelle Consulting Profile
2/5/2019
Corvelle Consulting Profile
Consulting firm focused on the oil & gas industry
Experienced with oil & gas spanning more than 20 years
Implemented systems for field data capture, production accounting, financial accounting, public data management
Led development of EPAP for the then ERCB
Leading EPAP implementation projects
Management consulting, data management & IT
Project leadership
Process review & redesign
Data quality & integration
Facilitation
Corvelle Consulting Profile
We are a Calgary consulting firm focused on the Canadian oil & gas industry
Corvelle has been consulting in this industry for over 20 years
Experienced with oil & gas spanning more than 20 years
Implemented systems for field data capture, production accounting, financial accounting
Led development of EPAP for the then ERCB; currently leading development of measurement requirements and EPAP for ECON in Saskatchewan
Leading EPAP implementation projects and EPAP operation for operators
Management consulting, data management & IT
Project leadership
Process review & redesign
Data quality & integration
Facilitation
What’s Up with Saskatchewan Measurement?

6. Background Background
Corvelle Consulting
2/5/2019
Background
Background
In this section, I’ll provide some background on the reasons that caused the Ministry of the Economy in Saskatchewan to make significant measurement improvements and to introduce EPAP
I’ll refer to the Ministry of the Economy in Saskatchewan simply as ECON in this presentation
What’s Up with Saskatchewan Measurement?

7. Measurement Issues OGCR requirements outdated and lack detail
Corvelle Consulting
2/5/2019
Measurement Issues
OGCR requirements outdated and lack detail
Some companies operate as if there are no requirements
Increasing pressures for environmental, health and safety improvements
Recent audit results confirm operator noncompliance
Improper measurement and reporting created gaps in production data
OGCR measurement requirements outdated and lack detail
OGCR - Saskatchewan Oil and Gas Conservation Regulations
Some companies operate as if there are no measurement requirements because of a lack of regulatory enforcement
Increasing pressures for environmental, health and safety improvements
The EHS track record of the industry is actually excellent and continues to improve but society’s expectations are increasing more quickly
Recent audit results confirm a serious lack of operator compliance with various regulator requirements including measurement
Lack of compliance is cause for concern with respect to environment, safety, health , resource conservation and reservoir management
Inaccurate and incomplete measurement and reporting has created significant gaps in production data on Petrinex
Accurate and complete measurement data is required to:
ensure accurate crown royalty invoicing
promote the development of adequate natural gas collection and processing facilities
What’s Up with Saskatchewan Measurement?

8. This audit was conducted for a small random sample of facilities
Corvelle Consulting
2/5/2019
2013 ECON Audit Results
This graph illustrates some of the results from the 2013 field audits that ECON staff conducted
The worst noncompliance was around metering, where 16 out of the 20 facilities, or 80% were noncompliant
This audit was conducted for a small random sample of facilities
Unfortunately, the sample size is not large enough that we can confidently extrapolate the results to all Saskatchewan facilities
However, this audit raised the level of concern with respect to noncompliance at ECON significantly
ECON expects to improve the state of measurement through Directive PNG017: Measurement Requirements for Oil and Gas Operations
What’s Up with Saskatchewan Measurement?

9. 2014 Single Well Battery Field Audit
Corvelle Consulting
2/5/2019
2014 Single Well Battery Field Audit
This graph illustrates some of the 2014 audit results for the field audit conducted at 60 high-risk sour gas Single Well Batteries
This audit shows that only 12% failed with respect to metering
However, this field audit was focused on sour gas emissions and only the most obvious metering noncompliances were recorded
36 of the 60 single well batteries audited or 60% were shut-in due to significant noncompliances for venting and emissions of sour gas
What’s Up with Saskatchewan Measurement?

10. Estimated Reporting Discrepancy for Fuel, Flare and Vent
Corvelle Consulting
2/5/2019
Estimated Reporting Discrepancy for Fuel, Flare and Vent
Estimated Reporting Discrepancy for Fuel, Flare and Vent
This graph illustrates the gap between what Environment Canada has estimated based on their detailed research of other available data and the reported volume of gas contributing to GHG emissions from oil and gas operations in Saskatchewan
The red bars are the Environment Canada Estimates and the blue bars are the volumes reported by operators to Petrinex
This is based on 2012 data and suggests that only a third of the total volume of Fuel, Flare and Vent gas in Saskatchewan is being reported to Petrinex
We’re not sure how accurate the Environment Canada estimate is, but the significant gap does highlight that we may have a serious reporting problem
ECON expects to improve its understanding of the level of measurement and reporting compliance by introducing Directive PNG076: Enhanced Production Audit Program (EPAP)
What’s Up with Saskatchewan Measurement?

11. If you think compliance is expensive, try noncompliance . . . UGH!
Corvelle Consulting
2/5/2019
If you think compliance is expensive, try noncompliance . . .
UGH!
If you think compliance is expensive, try noncompliance . . .
UGH!
Some of you may be thinking these new measurement and EPAP requirements are regulatory overkill or border on excess
The PNG017 measurement requirements are more about explaining more prescriptively what the measurement requirements are in Saskatchewan than about introducing a lot of new or onerous measurement requirements
EPAP is specifically designed to be the most cost-effective way possible to achieve a reasonable level of assurance with respect to the state of compliance
What’s Up with Saskatchewan Measurement?

12. Directive PNG017: Measurement Requirements for Oil and Gas Operations
Corvelle Consulting
2/5/2019
Directive PNG017: Measurement Requirements for Oil and Gas Operations
Directive PNG017: Measurement Requirements for Oil and Gas Operations
In this section, we’ll discuss a summary of Directive PNG017: Measurement Requirements for Oil and Gas Operations
Directive PNG017 is the first ever harmonized directive between Alberta and Saskatchewan
If you read Directive PNG017 you can be absolutely assured that everything you read also applies in Alberta
In the few places where the two provinces differ, Directive PNG017 highlights the difference through a prominent box
What’s Up with Saskatchewan Measurement?

13. New Requirements for Saskatchewan
Corvelle Consulting
2/5/2019
New Requirements for Saskatchewan
Replace provisions in The Oil and Gas Conservation Regulations, 2012
Petrinex functionality has been expanded
Explicit sampling and analysis requirements throughout Directive PNG017
Measurement points identified
Measurement schematics
New Requirements for Saskatchewan
So what major measurement and reporting changes have been made?
The new requirements in Saskatchewan are largely harmonized with Alberta Directive 017 and replace the existing provisions in The Oil and Gas Conservation Regulations
The changes are quite significant for Saskatchewan operators, primarily because the existing rules are unclear or, in some cases, non-existent
I can’t go through all of the changes but will discuss a few of the more significant ones
In preparation of the Directive coming into force, Petrinex functionality was expanded for Saskatchewan operators:
Adopted proration battery subtypes
Defined criteria for paper battery facility subtype
Defined Crude Oil Type based on actual density
Light, Medium or Heavy designation will be based on its actual oil density, rather than its geographic area, which had been the case in some instances
As a result, some heavy oil is now being produced in the Swift Current area, rather than being designated as medium oil. For clarity, this change will not impact the way Crown royalties are currently determined.
Explicit sampling and analysis requirements throughout Directive PNG017
Sediment and Water determination in Section 14 and Appendix 3
Truck sampling in Section 10
Gas and liquid sampling and analysis methodology and standards in Section 8
Measurement points identified
Delivery point measurement identified with uncertainty requirements
Metered vs estimated measurement; if the volume at a facility exceeds 500 cubic meters of gas per day, it must be metered
Measurement schematics
Comes into force effective April 1, 2018
operators are required to maintain a measurement schematic of each facility, which shows the current physical layout of the facility
schematics will not have to be submitted to the regulator, unless requested
This requirement will not come into effect until April 1, 2018, to provide sufficient time for operators to prepare
What’s Up with Saskatchewan Measurement?

14. Major Differences Between SK and AB
Corvelle Consulting
2/5/2019
Major Differences Between SK and AB
Saskatchewan has facility subtypes specific to Heavy Oil
Condensate produced at a gas well
Royalty triggers
Sulphur requirements do not apply
Major Differences Between SK and AB
Saskatchewan has facility subtypes specific to Heavy Oil
313 - Heavy Crude Oil Paper Battery
325 - Heavy Crude Oil Single-Well Battery
326 - Heavy Crude Oil Multiwell Group Battery
327 - Heavy Crude Oil Multiwell Proration Battery
These facility subtypes make it easier to link specific measurement requirements with a particular facility
Condensate produced and separated at a gas well
If recombined with gas, reported as GAS Production
If delivered in liquid form, reported as COND Production
Royalty Triggers:
SK does not charge royalties on natural gas liquids
SK Gas royalties payable at the wellhead
Sulphur measurement requirements in section 11 do not apply in Saskatchewan
Saskatchewan does not have the equivalent of the S-30 Monthly Gas Processing Plant Sulphur Balance Report
What’s Up with Saskatchewan Measurement?

15. Implementation of New Requirements
Corvelle Consulting
2/5/2019
Implementation of New Requirements
Directive PNG017 effective April 1, 2016
Measurement exemptions rescinded
Existing facilities must become fully compliant
New facilities must be fully compliant
Implementation of New Requirements
ECON recognizes that the changes being introduced are significant and that some operators may be under pressure to learn and implement the new requirements.
As a result, ECON has attempted to alleviate that pressure as much as possible through its implementation plan for Directive PNG17.
Directive PNG017 comes into force effective April 1, 2016
Operators were notified about ECON’s plan to introduce PNG17 in May 2015 with posting of Directive PNG017
Operators have been provided an opportunity to familiarize themselves with the new measurement and reporting requirements prior to it coming into force effective April 1, 2016
Measurement exemptions rescinded
All existing measurement exemptions will be rescinded
Many current exemptions may not be necessary under the new requirements
If an exemption is required, an operator must apply and receive approval from ECON through the Integrated Resource Information System (IRIS)
Facilities that currently exist:
Must be fully compliant with current measurement requirements
Necessary improvements to meet Directive PNG017 requirements can be phased in over a four-year period
Operators expected to make significant progress each year; with approximately 25 percent of necessary remediation is to be implemented each year
ECON does not prescribe how the annual implementation percentage is determined
Not mandatory for operators to submit supporting documentation regarding the progress they are making each year
However, ECON will audit progress and documentation must be provided on request
Operators must also declare that they are making progress during the phase-in period, through their annual EPAP declaration
All operators must fully implement Directive PNG017 requirements by March 31, 2020
New facilities must be designed, constructed and operated in compliance with Directive PNG017 requirements
New facilities are those licensed after April 1, 2016
What’s Up with Saskatchewan Measurement?

16. Available Measurement Information and Resources
Corvelle Consulting
2/5/2019
Available Measurement Information and Resources
Directive PNG017
FAQs about Directive PNG017
Compliance Reporting Tool
Ministry of the Economy Website
ECON Measurement Committee
Petroleum and Natural Gas (PNG) Support Desk
Available Measurement Information and Resources
Directive PNG017
Updated version will be posted prior to April 1, 2016
FAQs about Directive PNG017
Answers to some common questions
Compliance Reporting Tool
Spreadsheet to plan and measure an operator’s implementation progress during the four-year phase-in period
This tool, in the form of an Excel spreadsheet, is simply an aid developed by ECON to assist industry, and is not mandatory or prescribed
Other methodologies and documentation to measure an operator’s progress are also acceptable
However, some form of documentation will be required to demonstrate that an operator is making progress
Ministry of the Economy Website
ECON Measurement Committee
Petroleum and Natural Gas (PNG) Support Desk
What’s Up with Saskatchewan Measurement?

17. Corvelle Consulting
2/5/2019
Any chance I could get shorter, easier to understand measurement instead?
What do you say when a Leprechaun offers you a pot of gold?
Any chance I could get a shorter, easier to understand measurement requirements instead?
Some people groan or a overwhelmed when they first flip through Directive PNG017
However, the contents are seen as providing not just measurement requirements but also useful guidance for measurement operation
What’s Up with Saskatchewan Measurement?

18. Directive PNG076: Enhanced Production Audit Program (EPAP)
Corvelle Consulting
2/5/2019
Directive PNG076: Enhanced Production Audit Program (EPAP)
Directive PNG076: Enhanced Production Audit Program (EPAP)
In this section, we’ll discuss a summary of Directive PNG076: Enhanced Production Audit Program (EPAP)
When you read Directive PNG076, you will see that the requirements are identical to Alberta
There are phrasing and formatting differences between the Saskatchewan and Alberta directive versions
We have tried to apply the results of five years of EPAP experience in Alberta to the writing of the Saskatchewan directive
We hope you will find the Saskatchewan directive clearer
What’s Up with Saskatchewan Measurement?

19. EPAP Goals Shift how operators demonstrate compliance
Corvelle Consulting
2/5/2019
EPAP Goals
Shift how operators demonstrate compliance
Raise level of assurance over Directive PNG017 compliance
Encourage continuous improvement
EPAP Goals
The goals of EPAP remain identical between the provinces
Shift how operators demonstrate measurement & reporting compliance with the requirements described in Directive PNG017 and R01
Shifting from onus being on the Regulator to demonstrate noncompliance to operator demonstrating that infrastructure to maintain compliance exists and is functioning
Raise level of assurance over Directive PNG017 compliance
Level of assurance is how well we understand something
Encourage continuous improvement in measurement & reporting business processes, controls and compliance
What’s Up with Saskatchewan Measurement?

20. EPAP Components Controls Declarations Evaluation of Controls
Corvelle Consulting
2/5/2019
EPAP Components
Controls
Declarations
What does EPAP consist of?
EPAP consists of these 6 Major Components
Controls
Controls are what the operator uses to minimize the risk of noncompliance
Our guidance to operators is to strengthen controls where necessary
Evaluation of Controls
Evaluation of Controls are what the operator conducts throughout the year to evaluate the effectiveness of controls
Our guidance to operators is to conduct a few evaluations of controls each year to achieve a reasonable level of assurance over the state of compliance
Declarations
These are the operator declarations that are submitted annually to the Regulator, through the EPAP system on Petrinex, about the state of compliance at the operator’s facilities
Our guidance to operators is to submit an EPAP Declaration to the Regulator on time every year
Compliance Assessment – This EPAP component is where we’ll spend our time today
Compliance Assessment is the process that both operators and the Regulator use every month to identify indicators of potential noncompliance
The Regulator produces a Compliance Assessment Report for every operator based on anomalies detected in the data that operators submit to Petrinex
Operators are encouraged to investigate and resolve items listed on the Compliance Assessment Report
Our guidance to operators is to investigate and resolve a few items each month and thus avoid further Regulator scrutiny
We recommend avoiding the next two components:
Workflow - Regulator initiated
Workflows are formal Regulator direction to operators to investigate indicators of potential noncompliance including CAI Report items we’re here to discuss today
Workflows can be initiated and responded to at any time
Our guidance to operators is to perform enough EPAP-related work to minimize the risk of the Regulator issuing a Workflow and thus receive further Regulator scrutiny
Compliance Assurance
Compliance Assurance is the process that the Regulator uses when operators fail to respond to Workflows
The Regulator will direct the operator to provide more information if an investigation and subsequent mitigation fail to correct an indicator of potential noncompliance
Compliance Assurance can occur at any point in the year
Our guidance to operators is to submit a credible declaration, respond to Regulator-initiated Workflows promptly and thus avoid Compliance Assurance altogether
AER has rescinded D019 and has not yet defined a replacement approach
Any comments about these EPAP components?
Are any of them creating difficulties for you?
Evaluation of Controls
Compliance Assessment
Workflow Regulator initiated
Compliance Assurance
What’s Up with Saskatchewan Measurement?

21. EPAP Declaration Timeline
Corvelle Consulting
2/5/2019
EPAP Declaration Timeline
Submission Deadline
Submission Period
Declaration Period - 12 months
EPAP Declaration Timeline
There are a number of components in the EPAP Declaration Timeline
This visual representation helps to describe all the pieces and how they relate to each other
Every EPAP Declaration timeline is a 14 month period
Declaration Month
The entire timeline is anchored by the Declaration Month that has been assigned to every Saskatchewan operator
The Declaration Month is the twelfth month of the twelve-month Declaration Period
Declaration Period - 12 months
The Declaration Period is the 12 month period that the assertions of the Declaration text and the data reported in the attachments apply to
The Declaration Months assigned to Saskatchewan operators have been distributed across the Declaration Period to equalize the workload of ECON staff
Submission Period
The Submission Period is the second month after the Declaration Month or the 14th month of this timeline
The EPAP Declaration functionality on Petrinex is available to accept data from the operator during the Submission Period
The 13th and 14th months exist to provide ample time for the operator staff to consolidate the results of the evaluations of controls in preparation for entering the data in Petrinex
Submission Deadline
The Submission Deadline is the last day of the Submission Period or the 14th month
This timeline suggests that the operator staff should meet with the senior executives either late in the 13th month or early in the 14th month to review the results of the year’s work and have the declaration signed 1 2 3 10 11 12 13 14 1 2 3
Declaration Month
Declaration Period 12 months
What’s Up with Saskatchewan Measurement?

22. SK EPAP Declaration Differences
Corvelle Consulting
2/5/2019
SK EPAP Declaration Differences
SK & AB declarations are almost identical. The major differences are assertions 5 & 7
Assertion #5 is about the CAI Report
CAIs are part of EPAP and this assertion is intended to acknowledge the existence of CAIs
Assertion #7 is the assertion for measurement and reporting remediation progress, not EPAP progress
For assertion #7, unlike AB’s declaration, measurement remediation progress must be asserted during the first 4 years of the program
Operators have the flexibility to measure measurement remediation implementation in any way they see fit, so long as it’s defensible
Operators may choose to use the Compliance Reporting Tool that ECON has provided
The assertions you’ve all seen before are for EPAP level of assurance and remediation of controls that were concluded as not effective
What’s Up with Saskatchewan Measurement?

23. Implementation of New Requirements
Corvelle Consulting
2/5/2019
Implementation of New Requirements
Directive PNG076 effective April 1, 2016
Trial declaration period from April 1, 2016 to November 30, 2016
Your Declaration month has been ed to your EPAP Change Leader from PNG Support
Implementation of New EPAP Requirements
Directive PNG076 is effective April 1, 2016
Trial declaration period from April 1, 2016 to November 30, 2016
Likely a good period to initiate EPAP for Saskatchewan within your organization
Your Declaration month has been ed to your EPAP Change Leader from PNG Support
What’s Up with Saskatchewan Measurement?

24. Available EPAP Information and Resources
Corvelle Consulting
2/5/2019
Available EPAP Information and Resources
Directive PNG076
FAQs about Directive PNG076
Ministry of the Economy Website
Petroleum and Natural Gas (PNG) Support Desk
Available EPAP Information and Resources
Directive PNG076
Updated version will be posted prior to April 1, 2016
FAQs about Directive PNG076
Answers to some common questions
Ministry of the Economy Website
Petroleum and Natural Gas (PNG) Support Desk
What’s Up with Saskatchewan Measurement?

25. Sask ECON Roadshow
2/5/2019
“We’re going to parachute in and conduct a surprise evaluation of controls, but I want to keep the whole event low key.”
When we descend on a facility to conduct an evaluation of controls with the operations and PA staff, it’s often far from low key
There’s often a lot of apprehension about being evaluated or blamed for issues that the operations and PA staff can’t control
It’s up to us to defuse the apprehension and to set a collaborative tone that encourages continuous improvement
What have you found helpful to defuse apprehension and encourage collaboration?
“We’re going to parachute in and conduct a surprise evaluation of controls, but I want to keep the whole event low key.”
What’s Up with Saskatchewan Measurement?

26. Corvelle Consulting
2/5/2019
Guideline PNG028: Initiating and Operating the Enhanced Production Audit Program (EPAP)
Guideline PNG028: Initiating and Operating the Enhanced Production Audit Program (EPAP)
In this section, we’ll discuss Guideline PNG028: Initiating and Operating the Enhanced Production Audit Program (EPAP)
When you read Guideline PNG028, you will see huge differences compared to the EPAP Operators’ Handbook for Alberta
Despite these differences be assured that the goals of EPAP remain identical between the provinces
We have tried to apply the results of five years of EPAP operation experience in Alberta to the writing of the Saskatchewan guideline
We hope you will find the Saskatchewan guideline clearer, more tactical, easier to understand and easier to implement
If you follow the steps described in each section of the guideline you will be assured that you are operating EPAP in a manner that is compliant, comprehensive and still cost-effective
What’s Up with Saskatchewan Measurement?

27. Major EPAP Operation Processes
Corvelle Consulting
2/5/2019
Major EPAP Operation Processes
Design Choices for Operating EPAP
Annual EPAP Declaration
Ongoing Remediation Arising from Evaluations of Controls
Monthly CAI Report
Ongoing Regulator-initiated Workflows
Major EPAP Operation Processes
Design Choices for Operating EPAP
operators apply their professional judgment to making these Design Choices
The goal is to operate EPAP with compliance and with minimum effort while ensuring that a reasonable level of assurance is being achieved
Operators must be confident that the assertions stated in the declaration text are true
Annual EPAP Declaration
These are the processes that an operator performs to complete the Annual EPAP Declaration
The goal is to complete the Annual EPAP Declaration on time and with minimum effort while ensuring that an reasonable level of assurance has been achieved
If the number of Acceptable Reporting Themes is increasing year over year, that is an excellent indicator of continuous improvement
Ongoing Remediation Arising from Evaluations of Controls
These are the processes that an operator performs to remediate controls that were concluded as not effective
The goal is to remediate controls with minimum effort while ensuring that continuous improvement is occurring
If the number of controls requiring remediation is decreasing year over year, that is an excellent indicator of continuous improvement
Monthly CAI Report
These are the processes that an operator performs to investigate and perhaps remediate the contents of the Monthly CAI Report
The goal is to gradually reduce the number of lines on the Monthly CAI Report as remediation is completed
A decreasing number of lines on the Monthly CAI Report is an excellent indicator of continuous improvement
Ongoing Regulator-initiated Workflows
These are the processes that an operator performs to address Regulator-initiated Workflows
The goal is to avoid receiving these Workflows by submitting the annual EPAP Declaration and by investigating and remediating the Monthly CAI Report
What’s Up with Saskatchewan Measurement?

28. EPAP Initiation Project Tasks
Corvelle Consulting
2/5/2019
EPAP Initiation Project Tasks
Assign project manager and project resources
Conduct an initial EPAP assessment
Brief managers and senior executives
Build awareness of operator staff
Develop project plan
Execute project plan
Estimate of annual EPAP operation effort
EPAP Initiation Project Tasks
This is a list of acceptable practice, high-level task associated with initiating EPAP at an operator
The goal is to initiate EPAP in a reasonably comprehensive way that prepares the operator for EPAP operation without spending excessively
Assign project manager and project resources
Assign someone to lead initiating EPAP
Asking someone to run the initiation from the corner of their desk will work only at the smallest operators
Conduct an initial EPAP assessment
The initial EPAP assessment provides a sense of the state of compliance with measurement and reporting requirements and the state of controls
Brief managers and senior executives
Report on the findings of the initial EPAP assessment
Make recommendations about how to initiate EPAP
Build awareness of operator staff
Develop and deliver an EPAP overview for operator staff
Develop project plan to initiate EPAP
Have a manager or senior executives approve the project plan
Approval typically includes approval of approach, project resourcing, budget and timeline
Approach typically encompasses roles & responsibilities of various internal operating areas and the extent to which EPAP operation will be outsourced
Execute project plan
Perform the tasks in the approved project plan
Estimate of annual EPAP operation effort
Produce an estimate of annual EPAP operation effort and cost
What’s Up with Saskatchewan Measurement?

29. Corvelle Consulting
2/5/2019
Acceptable Practices
PNG028 describes examples of acceptable practice that achieves EPAP compliance
PNG076 provides significant latitude for operator professional judgment
Operators may adopt other acceptable practices in the operation of EPAP
Acceptable Practices
Guideline PNG028 describes examples of acceptable practice that achieves EPAP compliance
The guideline is full of “Operators may”, “Operators are encouraged to”, “Operators should”
The intent is for operators to give serious consideration to adopting these examples of acceptable practice
All the “must” statements in the guideline make reference to requirements in Directive PNG076
There are no new or additional “must” statements in the guideline
Readers of Directive PNG076 will be aware that EPAP requirements provide significant latitude for operator professional judgment
The judgment exists because ECON recognizes that operators vary a lot in terms of size, type and age of facilities, business processes and culture
These differences greatly influence what constitutes acceptable practice that achieves EPAP compliance
Operators may adopt other acceptable practices in the operation of EPAP, than those described in the Guideline, provided that these other acceptable practices achieve a reasonable level of assurance with respect to measurement and reporting requirements
We believe the example acceptable practices described in PNG028 are excellent; that’s why they’re in the document
However, we are aware of other practices that are acceptable
Often these practices are specifically mandated by senior executives to ensure they can confidently sign the EPAP Declaration
That’s not only acceptable, it’s desirable because it indicates that operators are being thoughtful about their approach to operating EPAP
What’s Up with Saskatchewan Measurement?

30. Reasonable Understanding
Corvelle Consulting
2/5/2019
Reasonable Understanding
That’s plenty. By the time we add an introduction, a few illustrations and a conclusion, it will look like a management report.
I think we have enough information now, don’t you?
Reasonable Understanding
I think we have enough information now, don’t you?
All we have is one supposed “fact” you made up.
That’s plenty. By the time we add an introduction, a few illustrations and a conclusion, it will look like a management report.
The EPAP requirements state that operators must make a reasonable effort to understand their state of compliance
We don’t need to let this work take over our life
We don’t need to become perfect in our measurement and reporting
We do need to demonstrate that we’re making a reasonable effort and that continuous improvement is occurring
What might be some indicators that we have a Reasonable Understanding?
Number of Reporting Themes concluded as Deficient is going down
Number of CAI Report items on CAI Report is going down
All we have is one “fact” you made up.
What’s Up with Saskatchewan Measurement?

31. Thinking Creatively Stuck on escalator video
Corvelle Consulting
2/5/2019
Thinking Creatively
Stuck on escalator video
File: People stuck on escalator.wmv
Think outside the box
Don’t just throw up your hands and ignore real problems
Involve other disciplines in the investigation
No one is expecting you to be Superman or Superwoman
What’s Up with Saskatchewan Measurement?

32. Conclusion Conclusion
Corvelle Consulting
2/5/2019
Conclusion
Conclusion
We’ve reached the wrap-up of the luncheon presentation for today
What’s Up with Saskatchewan Measurement?

33. Corvelle Consulting
2/5/2019
Conclusion
Saskatchewan has improved definition of measurement requirements
Saskatchewan is implementing EPAP
Many resources available to help
Conclusion
Saskatchewan has improved definition of measurement requirements by publishing Directive PNG017
Remediate facilities to improve measurement compliance
Saskatchewan is implementing EPAP through Directive PNG076
Raise your level of assurance with respect to measurement and reporting compliance
Evaluate your controls, submit your declaration in 2017, investigate items on CAI Report
Many resources available to help you improve your measurement and reporting
ECON website
Guideline PNG028
Attached section of resources that we can send you; please request copy of presentation by
What’s Up with Saskatchewan Measurement?

34. Discussion Have you found our time together helpful? Any Questions?
Corvelle Consulting
2/5/2019
Discussion
Have you found our time together helpful?
Any Questions?
What’s Up with Saskatchewan Measurement?

35. What’s Up with Saskatchewan Measurement?
Corvelle Consulting
2/5/2019
What’s Up with Saskatchewan Measurement?
Yogi Schulz
(403)  
Mark Perrin
(403)
Clay Long
(403)
Mel Miners
(403)
What’s Up with Saskatchewan Measurement?
Corvelle Consulting
300, Ave. S.W.
Calgary, Alberta T2P 0L6
What’s Up with Saskatchewan Measurement?