Greenhouse Gas Emissions Report Verification. For Cairn Energy PLC. rpsgroup.com/uk

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1 Greenhouse Gas Emissions Report Verification For Cairn Energy PLC

2 Quality Management Prepared by: Tom Dearing Principal Environmental Consultant 22/03/17 Reviewed & checked by: Jennifer Stringer Associate 22/03/17 Authorised by: Tom Dearing Principal Environmental Consultant 22/03/17 Date of issue: 22 March 2017 Revision number: 5 Project number: Document file path: O:\Jobs_ \9419s\Deliverable\_Cairn_verification_report_rev5.docx Revision History Rev. Date Status Reason for revision Additional comments 0 14/02/17 Draft /02/17 Draft For client review /02/17 Draft Internal review JS 3 28/02/17 Draft Client review comments AK 4 20/03/17 Final Client review comments MH 5 22/03/17 Final Client review comments AK Calculations or models filename, location or link: \\BRIG-LW-03\Projects\Jobs_ \9419s\Deliverable\_Cairn_2016_GHG_verification_rev0.xlsx \\BRIG-LW-03\Projects\Jobs_ \9419s\Analysis\_travel_scope3_verification.xls \\BRIG-LW-03\Projects\Jobs_ \9419s\Analysis\_fuel_inputs_scope1_verification.xlsx Checked by: Tom Dearing Principal Environmental Consultant 22/03/17 DISCLAIMER RPS has used reasonable skill and care in completing this work and preparing this report, within the terms of its brief and contract and taking account of the resources devoted to it by agreement with the client. We disclaim any responsibility to the client and others in respect of any matters outside the stated scope. This report is confidential to the client and we accept no responsibility to third parties to whom this report, or any part thereof, is made known. The opinions and interpretations presented in this report represent our reasonable technical interpretation of the data made available to us. RPS accepts no responsibility for data provided by other bodies and no legal liability arising from the use by other persons of data or opinions contained in this report. Except for the provision of professional services on a fee basis, RPS does not have a commercial arrangement with any other person or company involved in the interests that are the subject of this report. COPYRIGHT RPS The material presented in this report is confidential. This report has been prepared for the exclusive use of the client and shall not be distributed or made available to any other company or person without the knowledge and written consent of the client or RPS. 22 March 2017 Rev. 5

3 Contents 1 Verification Statement... 1 Overview... 1 Scope... 1 Assurance Verification Approach... 4 Reporting approach verification... 4 Calculations verification... 5 Data collection and control verification... 7 Verifier qualifications and independence... 8 Assurance March 2017 Rev. 5

4 1 Verification Statement Overview 1.1 This verification statement has been prepared for Cairn Energy PLC, in order to provide voluntary assurance of greenhouse gas (GHG) emissions stated as part of Cairn Energy s Corporate Social Responsibility (CSR) obligation to report on greenhouse gases as a UK listed company. Verification of the assertions made in in the Climate Change, Emissions and Discharges section of Cairn Energy s Annual Report and Accounts 2016 and associated web resource Air Emissions, Direct and indirect air emissions, Total absolute and normalised GHG emissions (scopes 1, 2 and 3) 1 section of the Cairn Energy PLC website (together the GHG Report) has been undertaken, using the principles in BS EN ISO :2012 (the Standard). 1.2 Verification has been undertaken by Tom Dearing, Principal Environmental Consultant, RPS Planning & Development (RPS P&D), part of RPS Group Plc. Activity data pertaining to GHG emissions from Cairn Energy s activities has been collected by Cairn Energy employees, contractors to Cairn Energy, and Cairn Energy commercial partners in the countries in which Cairn Energy operates. Another division of RPS Group, RPS Energy, provides general HSE support to Cairn at the corporate level, which does not include collection or reporting of GHG data. RPS confirms that there is no conflict of interest arising and this assurance has been undertaken independently. 1.3 Chapter 1 of this document and the title/quality management pages provide the minimum verification statement elements set out in A of the Standard. The following sections within this chapter summarise the scope of the verification undertaken, and provide the conclusion (assurance statement with any qualifications). Chapter 2 provides further detail of the verification scope and process, and any limitations or exclusions. Scope 1.4 The GHG Report is intended to serve three purposes for Cairn Energy: i. to meet its commitments to effective Health, Safety, Environment and Social (HSES) management and continued Corporate Social Responsibility (CSR); ii. in partial fulfilment of the requirement for listed companies in the UK to include GHG emissions in annual directors reports, in Part 7 of The Companies Act 2006 (Strategic Report and Directors Report) Regulations 2013 (the Mandatory Carbon Reporting Regulations ); and iii. to provide GHG emissions data and the methodology used to establish it that can potentially be reported to third parties including the Carbon Disclosure Project (CDP). 1 and reporting guidelines at 22 March 2017 Rev. 5 1

5 1.5 Neither the Mandatory Carbon Reporting Regulations nor the CDP is prescriptive concerning the specific GHG accounting methodology that is followed, but both require that a recognised standard has been used. Cairn Energy PLC states in the Reporting page of its website 2 that it follows the content principles of materiality, stakeholder inclusiveness, sustainability context and completeness; and the quality principles of balance, comparability, accuracy, timeliness, clarity and reliability. The resulting approach is set out in its Reporting Guidelines for 2016 Key Performance Indicators 3 page and in its GHG Report. 1.6 This verification has been made against the approach set out in the GHG Report, and conducted using the principles in the Standard, which is accepted for verification by the CDP. The verification process is detailed in Chapter 2. It has encompassed verification of the reporting boundary, verification of methods and metrics for emissions calculations based on activity data, and consideration of potential data collection and control system material risks. It has not included verification of primary activity data collection by sampling or verification of the data collection control system, as the majority of total GHG emissions arose from contractor operations that were completed in June 2016, well before the assurance process began. 1.7 The verification approach was agreed with Cairn Energy by on 20/12/16. Assurance 1.8 Within the scope of the limited assurance engagement, the information made available and findings of the verification process undertaken indicate that the GHG assertions made in the Cairn Energy GHG Report are materially correct, a fair representation of available GHG data and information, and have been prepared in accordance with the methodology defined for reporting in the Cairn Energy PLC Responsibility section web pages entitled Reporting and Reporting Guidelines for 2016 Key Performance Indicators. 1.9 Cross-checking of the GHG emissions calculations has not identified any material gaps, discrepancies or errors in calculations or emission factors. The total calculated GHG emissions in 2016 have been reported accurately in the GHG Report. Limitations 1.10 Primary activity data completeness, accuracy and data collection and control procedures have not been verified. The majority of total GHG emissions arise from activity data in operations under Cairn Energy s contractors primary data collection control. No assurance statement regarding verification of primary data collection and control is therefore made. Chapter 2 suggests possible data collection risks that could be present March 2017 Rev. 5 2

6 1.11 There is inherent variability and uncertainty associated with the available methods for calculation of GHG emissions from activity data; reported emissions and the assurance statement should be understood in that context. 22 March 2017 Rev. 5 3

7 2 Verification Approach Reporting approach verification Mandatory Carbon Reporting Regulations requirements 2.1 The Mandatory Carbon Reporting Regulations require that reporting companies specify a base year, and provide reporting for scope one (direct emissions) and scope two (indirect emissions from purchased energy flows) in the base year and the current reporting year in total emissions and emissions normalised to the company s activities, insofar as data is practicably available. It is non-specific concerning methodology used, but requires the methodology chosen to be stated. CDP requirements 2.2 The CDP requires that reporting companies specify a base year, and provide reporting for scope one (direct emissions) and scope two (indirect emissions from purchased energy flows) in the base year and the current reporting year. It requires that an emissions reporting boundary is selected (financial control, operational control, equity share or other) and applied consistently to the data reported. Organisation boundary 2.3 The GHG Report applies an operational control approach to boundary-setting, assigning all emissions from activities it controls (including those undertaken by partners and subcontractors) to Cairn Energy. Non-operating ventures in which Cairn Energy may hold equity but does not have operational control are excluded. This is consistent with the approach adopted in the previous year s GHG Report. 2.4 The relevant areas of operational control have been verified against Cairn Energy s 2016 Half- Yearly Report and 2016 Annual Report. Emissions scope and operational boundary 2.5 The operational boundary is set based on categories of GHG-producing activities within the organisational boundary, defined by Cairn Energy. A cross-check against operations listed in Cairn Energy s 2016 Half-Yearly Report and 2016 Annual Report indicates that activities generating material emissions (principally oil exploration and appraisal drilling and supply vessels, and business travel flights) have been included. 2.6 Scope 1 direct emissions included in the GHG Report arise from contractor-operated vehicles/vessels/aircraft and from flaring of oil and gas at offshore exploration facilities. A minor contribution to total emissions is also made by incinerating waste. Emissions factors that include CO 2, CH 4 and N 2 O from the Kyoto basket have been used for the GHG Report. These are relevant to the various forms of fuel combustion reported, and hence consistent with CDP and UK mandatory carbon reporting guidance concerning the relevant GHGs for fuel combustion. 22 March 2017 Rev. 5 4

8 2.7 Fugitive scope 1 emissions are not estimated in the GHG Report as Cairn Energy has no active oil or gas production operations within the GHG Report scope. It is unlikely that any fugitive emissions associated with exploration and flow testing activity would be material to the reported GHG emissions total, based on the default values for fugitive gas emissions from off-shore oil production published by the IPCC for national greenhouse gas reporting. Hydrofluorocarbon emissions (that could arise from fugitive refrigerant releases, for example) are not reported. Given the magnitude of other reported emissions sources, it is unlikely that these fugitive emissions, if occurring, would be material. 2.8 Scope 2 indirect emissions from purchased energy are reported for electricity consumption in the UK headquarters in Edinburgh, and also for Cairn Energy s offices in London, Norway, Senegal and Morocco (until the Rabat office closed in April 2016). The GHG Report indicates that nonelectricity scope 2 emissions are not applicable to Cairn Energy s operations. 2.9 Scope 3 indirect emissions comprise business air and rail travel (excluding London Underground) by Cairn Energy employees and contractors. No other scope 3 emissions (such as upstream supply chain emissions for fuel use or employee/contractor commuting in non-company vehicles) are reported. The extent of scope 3 reporting is stated accurately in the GHG Report. Baseline, reporting year, and previous reporting 2.10 Cairn Energy reports emissions trends from a base year of four years earlier (five years of data reported each year), requiring that emissions are recalculated if there is a material change in calculation methodology, emissions factors, or approach to setting the organisation boundary. This is in line with the CDP s requirements and good-practice GHG reporting guidance, and ensures that genuine emissions trends over time are reported Previous years emissions are outside the scope of this verification engagement. Normalised emissions 2.12 Cairn Energy normalises GHG emissions per 1,000 hours worked for trend comparisons. Summary records of employee and contractor hours have been reviewed and the normalisation of GHG emissions to reported hours verified. Calculations verification 2.13 A materiality threshold of 5% of the total reported GHG emissions has been used in verifying the emissions calculations. 97.8% of total reported GHG emissions arise from the following sources: fuel used in offshore drilling rig and supply vessels (70.7%); oil and gas flaring at exploration well SNE 3 at Sangomar Deep, off Senegal (20.4%); and business air travel (6.7%) None of the other GHG sources (comprising the activities at the Cairn Energy offices, road and rail travel, and aviation fuel used for contractors helicopters) are material individually or 22 March 2017 Rev. 5 5

9 collectively. Verification of GHG emissions calculations has therefore focused mainly on the sources listed in paragraph Fuel combustion 2.15 Monthly fuel consumption records and fuel density are provided by drilling rig, marine vessel and helicopter operators to Cairn Energy, which are converted from litres to tonnes using the reported density, and also from tonnes to GJ on a gross calorific value (CV) basis. Records are also provided for onshore vehicle diesel and petrol consumption. The fuel density, CV and emission factors used are reasonable, with reference to those provided for company reporting in the UK by Defra and BEIS (formerly DECC) Activity data used in the GHG emission calculations has been verified against the monthly fuel records provided by the contractors and operational partners in Senegal. Minor discrepancies in one month s fuel data for one marine vessel and one month s fuel data for helicopter operations due to input errors have been identified and corrected for the final GHG Report. Oil and gas flaring 2.17 The volume of oil flared from SNE 3 is recorded, and from this the associated gas is estimated using a ratio of typical gas to oil based on measurements taken at the drilling site, which have not been verified. Oil and gas are converted to tonnes and emission factors for typical flaring, assuming 95% flare efficiency, applied An error in the calculated gas density was identified affecting flaring emissions from SNE 3 in 2016; this has now been updated using data from gas samples which indicated a gas density approximately 30-50% higher than the typical range from literature sources but consistent with Cairn s measured gas properties Use of GWPs from the IPCC Second Assessment Report (AR2) for calculating CO 2 e emissions from flaring was identified and this has been updated to use of GWPs from the Fifth Assessment Report (AR5) in the final GHG Report, for consistency with the rest of Cairn Energy s reporting Oil and gas composition analyses are understood to be available and if used, could allow a more precise estimate of GHG emissions than use of the generic activity factor. Any change is unlikely to be material to the total reported 2016 GHG emissions, but may become material should flaring associated with exploration and production activities increase in future years. Business travel 2.21 Air and rail travel activity data is collected by Cairn Energy s travel agents in the UK and Norway, and estimated from staff expense claims. Air travel booked by the UK travel agents accounts for 94% of total scope 3 emissions. For air travel, passenger km are recorded in trip categories consistent with those in the Defra and BEIS reporting guidance, allowing appropriate emission factors per category including uplift for additional non-ghg radiative forcing to be applied. Some uncertainties are noted where routes are only available as multiple legs, but are unlikely to cause systematic bias or be material to the total emissions reported. 22 March 2017 Rev. 5 6

10 2.22 Minor errors (data gaps) in flights data were identified and corrected for the final GHG report The Defra/BEIS air travel emission factors used incorporate AR4 GWPs as opposed to AR5. However, this does not make a material difference to the total emissions reported. Hours worked 2.24 Records of hours worked are used to calculate the GHG intensity figure. The majority of employee hours (worldwide) and long-term, UK and Norway-based contractor hours are recorded by Cairn s time-writing system, part of its HR/financial procedures. That system has not been separately audited for this verification. Other short-term contractors hours are estimated from lists of contractors and days worked. Records of hours worked by contractors in field operations are provided by rig, vessel and shore base operators No errors in data entry for hours worked or evident gaps or discrepancies in contractors hours have been identified. Electricity consumption 2.26 Electricity consumption in Cairn s Edinburgh, London, Stavanger and Dakar offices is recorded in kwh based on meter readings and suppliers invoices. Electricity consumption in Morocco is estimated based on cost, and is a very minor proportion of the total. Due to data not yet being available, electricity consumption for the London office in Q has been estimated from 2015 records and for the Dakar office in December 2016 has been estimated based on the previous month s consumption Location-based scope 2 electricity consumption emissions are calculated using grid mix factors for each country published by IEA in 2013 (2011 data), the latest IEA factor set that is readily available, for each country concerned, excluding transmission and distribution losses. These emission factors have not been updated in the calculations for 2016, but this is not material to Cairn s GHG emissions Market-based emissions for the Edinburgh and London offices are reported as zero, based on suppliers certification of providing 100% renewable energy Scope 2 district heating and cooling energy consumption emissions for the Stavanger office are calculated using an emission factor published by Defra/BEIS for the UK. This may not be fully representative of district heating/cooling emissions intensity in Norway, but this is not material to Cairn s GHG emissions No material errors or discrepancies in electricity data input or calculations have been identified. Data collection and control verification 2.31 Data collection is by Cairn Energy employees, contractors and operational partners in the UK, Norway and Africa, overseen by the HSE team in Cairn Energy s head office. 22 March 2017 Rev. 5 7

11 2.32 Verification of primary data collection accuracy, by sampling or audit of primary data collection records and methods, is outside the scope of this brief save in respect of the data cross-checks detailed in the calculation section. Most of Cairn Energy s 2016 GHG data arose from contractor operations that were completed in June 2016, well before the assurance process began, so it was not possible to sample primary data collection records. No assurance statement regarding verification of primary data collection and control is therefore made Potential primary data collection and control risks, summarised in the Standard, could include: incompleteness of data collection (e.g. sources not recorded); inaccuracy in data collection or handling (e.g. errors in manual transfers of data); inconsistency in data collection (e.g. in approaches used in different parts of Cairn Energy operations); or data control weaknesses (e.g. non-calibration of metering instruments or lack of internal audit) Cairn Energy s HSE data manager describes a thorough data collection and control process, with records retained for data entry, queries and primary data sources, which mitigates these risks. Verifier qualifications and independence 2.35 Verification has been managed by Tom Dearing, Principal Environmental Consultant. Tom has six years experience in producing and verifying GHG emissions assessments for development projects and corporate reporting. Tom is a Chartered Environmentalist and Member of the Institute of Environmental Management and Assessment (IEMA) The Standard requires that a verifier is independent, noting that assistance with compilation of the responsible party s GHG assertion on GHG information is considered to be a breach of independence (page 15) The CDP requires that verification is undertaken by an independent external organisation accredited and competent to perform GHG verification. This organisation must be independent of the organisations that have gathered and/or provided the data and those that will use the data. (CDP, Frequently asked questions: Verification, page 1.) 2.38 The British Standards Institution (BSI), responsible for the Standard, does not offer certification/accreditation to the Standard. Competency to undertake the verification is summarised in paragraph Another division of RPS Group, RPS Energy, provides general HSE support to Cairn at the corporate level, which does not include collection or reporting of GHG data. RPS confirms that there is no conflict of interest arising and this assurance has been undertaken independently. Verifier independence has been assured using RPS s approach to conflict management, in which conflict checks are undertaken at the outset of a commission, and the verifier reports to a divisional management structure that is independent of the division assisting Cairn with other 22 March 2017 Rev. 5 8

12 work. RPS is independent of Cairn Energy, the organisation that has gathered and will use the data. Assurance 2.40 Within the scope of the limited assurance engagement, the information made available and findings of the verification process undertaken indicate that the GHG assertions made in the Cairn Energy GHG Report are materially correct, a fair representation of available GHG data and information, and have been prepared in accordance with the methodology defined for reporting in the Cairn Energy PLC Responsibility section web pages entitled Reporting and Reporting Guidelines for 2016 Key Performance Indicators Cross-checking of the GHG emissions calculations has not identified any material gaps, discrepancies or errors in calculations or emission factors. The total calculated GHG emissions in 2016 have been reported accurately in the GHG Report. Limitations 2.42 Primary activity data completeness, accuracy and data collection and control procedures have not been verified. The majority of total GHG emissions arise from activity in operations under Cairn Energy s contractors primary data collection control. No assurance statement regarding verification of primary data collection and control is therefore made There is inherent variability and uncertainty associated with the available methods for calculation of GHG emissions from activity data; reported emissions and the assurance statement should be understood in that context. 22 March 2017 Rev. 5 9

13 Contact Tom Dearing Principal Environmental Consultant RPS Planning & Development 6-7 Lovers Walk Brighton East Sussex BN1 6AH T: +44 (0) rpsgroup.com