For many upstream oil and gas operators, EPAP can be viewed primarily as an annual compliance exercise. But strong Enhanced Production Audit Program (EPAP) performance is built long before the annual declaration is completed.

It is built into the everyday connection between measurement, reporting, documentation, accountability, and issue resolution.

That is why Alberta Energy Regulator (AER) Directives 007 and 017 should not be considered separate from EPAP. The AER specifically identifies both directives as part of the measurement and reporting requirements included within EPAP.

From Field Measurement to Regulatory Reporting

Directive 017 establishes requirements around how oil and gas volumes are measured, estimated, accounted for, documented, and ultimately reported. It also addresses what information must be retained for audit purposes.

Directive 007 focuses on the reporting of volumetric and infrastructure information for wells, facilities, and pipelines through Petrinex.

EPAP brings these requirements together by asking operators to evaluate whether the controls they have in place provide reasonable assurance that measurement and reporting requirements are being met.

The important question, therefore, is not simply: Are we meeting each individual requirement?

It is: How reliably does information move from the field through our internal processes and into our regulatory reporting?

Look at the Handoffs

Many compliance challenges do not originate with a single measurement device, report, or employee. They develop at the points where responsibility or information changes hands.

A field measurement may need to move through operations, measurement specialists, production accounting, and regulatory reporting. Equipment changes need to be communicated. Exceptions need to be identified and resolved. Corrections must make their way into the appropriate systems. Supporting records need to be retained and easily retrieved.

When these connections are unclear, even well-designed individual processes can leave gaps.

A stronger approach is to evaluate the entire workflow:

  • Are measurement requirements clearly understood and consistently applied?
  • Does field information reach the people responsible for reporting?
  • Are exceptions and potential noncompliances identified early?
  • Is responsibility for resolving issues clearly assigned?
  • Can the organization demonstrate what was done, when it was done, and why?

This is where EPAP becomes more than an annual declaration. It becomes a useful framework for evaluating whether day-to-day controls are actually working.

Better Controls Do Not Have to Mean More Process

Strengthening EPAP performance should not mean adding unnecessary administrative steps.

The goal is to create a clearer connection between regulatory requirements, field practices, reporting, issue resolution, and retained evidence. In many cases, improving that connection can reduce duplication, clarify accountability, and make compliance easier to manage.

Intricate can help operators evaluate these connections across their measurement and reporting processes, identify control or handoff gaps, and determine where practical improvements can strengthen alignment with Directives 007, 017, and EPAP requirements.

The result is not simply better preparation for the annual declaration. It is a measurement and reporting program that is easier to manage, easier to demonstrate, and better equipped to identify issues before they become larger compliance problems.

Strengthen Your EPAP Program

Whether you are preparing for your annual Directive 076 operator declaration, addressing compliance assessment indicators, reviewing measurement and reporting controls, or looking to improve documentation and accountability, Intricate can help.

Our team brings extensive EPAP, measurement, reporting, and regulatory experience to help operators identify practical improvements and build stronger, more consistent compliance processes.

Ready to strengthen your EPAP program? Contact Intricate to discuss your audit, declaration, measurement, reporting, or software needs.

 

Jesse Elcombe headshot

Jesse Elcombe

Director of Consulting

Jesse Elcombe is the Director of Consulting at Intricate, where he brings nearly a decade of regulatory, environmental, and emissions management experience within the Canadian energy sector. His leadership emphasizes operational clarity, accountability, and strategic foresight, ensuring Intricate’s clients receive practical, measurable outcomes in complex regulatory environments. With a background in environmental science and compliance auditing, Jesse has worked across upstream operations and consulting, partnering with clients to design and implement regulatory strategies that drive efficiency, mitigate risk, and unlock long-term value.