This page describes the major EPAP impacts on operators.
Evaluate sufficient controls
Operators must evaluate sufficient controls so that senior executives can declare their company’s state of compliance with a level of assurance.
The meaning of sufficient is left to individual operator judgment. Similarly, the meaning of reasonable level of assurance is left to individual operator judgment. The AER will only challenge operator judgment when it finds evidence that calls operator judgment into question. The sources of such evidence will typically be:
- Increasing number of items listed on the AER-produced Compliance Assurance Report.
- Fines based on items listed on the Registry-produced AER Noncompliance Report.
- Increasing number of noncompliance events on the Field Surveillance Inspection Report.
Many operators have determined that they can achieve a reasonable level of assurance by evaluating the controls at properties associated with at least 25% of their Alberta operated production each year.
To invite a Corvelle consultant to your office to describe best practise approaches to creating a sample of properties to evaluate, please contact us.
Investigate Compliance Assurance Indicator (CAI) Report items
Operators must investigate some items listed on the monthly CAI Report that the AER produces from data that operators submit to Petrinex.
How many CAI items each operator must investigate is left to individual operator judgment.
Some operators have set a goal to resolve at least 25% of their CAI items each year.
A best practice approach to investigating and resolving CAI items is summarized in this table:
|
Priority
|
Resolution Effort
|
Volume Impact
|
|---|---|---|
|
1 |
Low |
High |
|
2 |
Low |
Low |
|
3 |
High |
High |
|
4 |
High |
Low |
To invite a Corvelle consultant to your office to describe how to investigate specific CAI items, please contact us.
Submit annual EPAP Declaration
Operators must submit an annual EPAP Declaration to the Regulator. This requirement applies to all operators who submit data to Petrinex..
The EPAP Declaration consists of:
- Title page that describes nine assertions that the senior executives who sign the declaration on behalf of each operator assert to accurate.
- Attachment A – Summary of Evaluations of Controls
- Attachment B – Measurement and Reporting Requirements Not Addressed by Controls
- Attachment C – Number of Facilities Operated by Facility Sub-Type
The EPAP Declaration is shown in Appendix 1 of Directive 76: Operator Declaration Regarding Measurement and Reporting Requirements.
Download a copy of AER Directive 076. The EPAP Declaration can also be printed or saved as a PDF on the EPAP system in Petrinex.
Download a copy of the ECON Directive PNG076.
To invite a Corvelle consultant to your office to complete the EPAP Declaration, please contact us.
Remediate Not Effective Controls
Where operators conclude that a control is not effective, they must remediate the deficiency.
What constitutes not effective is left to individual operator judgment. Similarly, what constitutes sufficient remediation is left to individual operator judgment.
Sufficient is defined to mean sufficient to enable the senior executives to confidently sign the EPAP Declaration.
The Regulator expectation is that operators will perform some remediation each year. There is no expectation that remediation must be completed before the EPAP Declaration is signed.
The Regulator will only challenge operator judgment when it finds evidence that calls operator judgment into question.
To invite a Corvelle consultant to your office to lead building a remediation plan, please contact us.
