verification report for: proponent: prepared for: version · chin chute wind power project, project...

Chin Chute Wind Power Project, Project ID: 0766-3464 February 2019

Verification Report for: Chin Chute Wind Power Project, Project ID: 0766-3464

Proponent:

Suncor Energy Inc.

Prepared by:

Brightspot Climate Inc.

Prepared for: Alberta Climate Change Office

Version:

Final

Date:

February 20, 2019


of 63

Table of Contents 1.0 Summary – Offset Project ..................................................................................... 4 1.1 Summary – Facility ........................................................................................................ 7 2.0 Introduction ........................................................................................................ 8

2.1 Objective ............................................................................................................ 8 2.2 Scope ................................................................................................................. 8 2.3 Level of Assurance ............................................................................................... 9 2.4 Criteria ............................................................................................................... 9 2.5 Materiality ......................................................................................................... 10

3.0 Methodology ...................................................................................................... 10 3.1 Procedures ........................................................................................................ 11 3.2 Team ................................................................................................................ 19 3.3 Schedule ........................................................................................................... 21

4.0 Results ............................................................................................................. 21 4.1 Assessment of Internal Data Management and Controls ........................................... 22 4.2 Assessment of GHG Data and Information ............................................................. 23 4.3 Assessment against Criteria ................................................................................. 25 4.4 Evaluation of the GHG Assertion ........................................................................... 27 4.5 Summary of Findings .......................................................................................... 27 4.6 Opportunity for Improvement .............................................................................. 29

5.0 Closure ............................................................................................................. 29 5.1 Verification Statement ........................................................................................ 29 5.2 Limitation of Liability .......................................................................................... 29 5.3 Confirmations .................................................................................................... 30

6.0 References ........................................................................................................ 31 Appendix A: Final Verification Plan and Sampling Plan ............................................................ 32 Appendix B: Statement of Qualifications ............................................................................... 50 Appendix C: Findings and Issues ......................................................................................... 53 Appendix D: Statement of Verification .................................................................................. 55 Appendix E: Conflict of Interest Checklist ............................................................................. 59 Appendix F: Supplemental Diagrams/Tables/Figures .............................................................. 62

List of Tables Table 1: Risk Assessment ................................................................................................... 15 Table 2: Findings of Data Integrity Verification Procedures ...................................................... 22 Table 3: Findings of GHG Data and Information Verification Procedures .................................... 23 Table 4: Findings of Criteria Verification Procedures ............................................................... 25 Table 5: Offset Criteria Assessment ..................................................................................... 26 Table 6: Summary of Findings ............................................................................................ 28 Table 7: Confirmation Findings ............................................................................................ 30 Table 8: Detailed Findings and Issues Log ............................................................................ 54 Table 9: Supporting Documentation Reviewed ....................................................................... 63


of 63

Instructions are in italics throughout and should not be deleted when report is complete. Some instructions are specific to the verification of facilities and for offset projects. The document is not restricted but do not alter the format, the layout, the headings or the overall ‘look and feel’ of the document. If if is more usefule to paste information outside of the text box, use the empty line just below the text box to drop text or tables int. This should not change the headings or the formats. There are several dropdown boxes in the document that must be completed.

• Complete report in Verdana 10pt font (no italics). • After the report is complete, right click the table of contents and ‘update field’ which will

update page numbers in Table of Contents. • If an instruction only applies to facilities or only applies to offsets indicate ‘not applicable’. • Appendix F is available for additional tables, diagrams etc.


of 63

1.0 Summary – Offset Project

Item Description

Project Title

Enter project title (must match the registry project title)

Chin Chute Wind Power Project

Project Description

Provide a brief description of the project and baseline conditions.

The project reduces GHG emissions through the generation of electricity by wind, therefore displacing the electricity generated through use of fossil fuels.

Project Location

Include the latitude and longitude for each unique location or installation. Include legal land location if applicable and other information identifying the unique location.

15km south west of Taber, Alberta

LSD: Sections 25,30,35 and 36 08-17-W4 (3 turbines) and 10- 18-W4 (17 turbines)

Latitude: 49°N Longitude: 112°W

Project Start Date

Enter the project start date.

November 2006

Offset Start Date

Enter the start date for offset credit generation.

The original credit start date was May 1, 2007. A 5-year extension has been granted with the new start date of May 1, 2015 being accepted.

Offset Crediting Period

Enter the offset crediting period, including the offset start date. Include day, month year.

The initial crediting period was from May 1, 2007 to April 30, 2015. The Proponent was granted a 5-year extension allowing credit generation from May 1, 2015 – April 30, 2020.

Reporting Period

Enter the reporting period being verified.

January 1 – December 31, 2018

GHG Assertion (Actual Emission Reductions/Sequestration Achieved)

Enter the actual emissions reductions / sequestration for the reporting period. Enter serial numbers if available.

48,705 tonnes CO2e

Protocol Quantification Protocol for Wind-Powered Electricity Generation (Version 1, March 2008)


of 63

Indicate the relevant protocol (if applicable)

Ownership

Enter offset project owner.

The Project is owned by Enbridge Wind Power General Partnership (Enbridge), Acciona Wind Energy Inc. (Acciona), and Suncor Energy Inc. (Suncor – the ‘Proponent’). The Project is operated by Acciona (Facility Operator). Suncor has been authorized to act on behalf of the other two partners and will register all applicable emission reduction credits from the Project.

Project Activity

State how the project activity meets the eligibility requirements

The project must meet the eligibility criteria stated in Part 3, Section 16 of the Carbon Competitiveness Incentive Regulation (CCIR). In order to qualify, emission reductions must:

• Occur in Alberta; • Result from an action taken that is not otherwise

required by law at the time the action is taken; • Result from actions taken on or after January 1,

2002; • Occur on or after January 1, 2002; • Be real, demonstrable, quantifiable and verifiable; • Be quantifiable and measurable, directly or by

accurate estimation using replicable techniques.

The verification included an evaluation of these criteria as well as the specific applicability criteria described in the Protocol. The results of this analysis are described in Section 4.3 of this report.

Project Contact

Enter contact name, company name, mailing address, phone number and email address.

Justin Friesen, EIT Carbon Solutions Analyst Blue Source Canada ULC +1 (403) 262-3026 (ext 301) [email protected]

Verifier

Verifier name, verifier’s company name, address, phone number email etc.

Aaron Schroeder, P.Eng. Brightspot Climate 401 – 409 Granville Street Vancouver BC V6C 1T2 +1 (604) 353-0264 [email protected]

Verification Team Members

Include verification team members, roles, training, training dates and qualifications.

Aaron Schroeder, P.Eng. Roles: Lead Verifier and Designated Signing Authority Training: Greenhouse Gas Verification – ISO 14064- 3, Canadian Standards Association, 2012; Instructor – Greenhouse Gas Verification – ISO 14064-3, University of Toronto, 2015 – 2018


of 63

Michelle Stelmach, P.Ag. Role: Associate Verifier Training: GHG Validation and Verification, ISO 14064-3, University of Toronto, October 2016

Rodrigo Cubedo, EIT Role: Associate Verifier

Sheldon Fernandes Role: Associate Verifier

Hector Sanchez, P.Eng. Role: Peer Reviewer

Training: Greenhouse Gas Verification – ISO 14064- 3, Canadian Standards Association, 2012

Designated Signing Authority

Enter the designated signing authority for this verification.

Aaron Schroeder, P.Eng. Brightspot Climate 401 409 Granville Street Vancouver BC V6C 1T2 +1 (604) 353-0264 [email protected]

Verification Strategy

Describe the verification strategy used for the verification, including rationale for the approach. Note, if a controls reliance is used, provide justification for how the project is able to support this approach.

The verification strategy applied a largely substantive approach. The verification procedures, which are detailed later in this section, were designed to test the activity data directly, wherever practical. By applying this approach, the verification did not rely heavily on the Responsible Party’s controls, but rather relied on the substantive evidence collected from verification procedures that reviewed metered data, data directly from invoices and independent laboratory reports, for example.


of 63

1.1 Summary – Facility

Item Description

Facility Name and Company Name

List company name and facility name.

Not applicable for offset verification reports

Facility Description

Provide a brief description of the facility.


Baseline Emissions Intensity Description

List the approved BEIA and the baseline years.


Reporter Contact

Enter contact name, company name, mailing address, phone number and email address.


GHG Assertion

Enter the actual emissions, production, emissions intensity and the reduction target being verified.


Verifier

Verifier name, verifier’s company name, address, phone number email etc.


Verification Team Members

Include verification team members, roles, training, training dates and qualifications.


Designated Signing Authority

Enter the designated signing authority for this verification.



of 63

2.0 Introduction Provide an introduction to the facility or project, the verification, and the background.

For Offset Project: summary of offset project baseline, changes to the baseline since project start date and summary of changes at the project since the offset project start date or baseline period.

For Facilities: Description of compliance or baseline report, facility/project boundary, facility identification information, GHG historical performance, summary of changes since the baseline or since the last compliance report.

Summary of Offset Project Baseline

The baseline for the project is the production of electricity from generators connected to the Alberta Interconnected Electric System.

Summary of Changes

The Responsible Party’s Offset Project Report (OPR) indicates that there have been no changes to the project boundaries and no equipment changes during the reporting period.

The OPR states that the project’s boundaries, operations and major sources of greenhouse gas emissions have not changed from those previously reported.

This was confirmed through the course of the verification.

2.1 Objective Describe the objective of the verification (should include expressing an opinion).

The objective of the verification is as follows:

• to issue an verification statement on whether the GHG assertion is without material discrepancy;

• to issue an verification report that provides details of the verification activities; and • to complete the “confirmations” activities defined in the Alberta Climate Change Office

Standard for Validation, Verification and Audit, Section 5.1.3.

2.2 Scope Project Name: Chin Chute Wind Power Project

Serial Range: To be assigned at registration.

Organizational Boundary: Chin Chute Wind Farm

Geographic Boundary: 15km south west of Taber, Alberta


of 63

LSD: Sections 25,30,35 and 36 08-17-W4 (3 turbines) and 10- 18-W4 (17 turbines)


Physical Operations: Electricity generation by wind power by 20 General Electric 1.5 MW wind turbines at each project site Transmission and Distribution lines: a network of 25 kV underground distribution lines and a 138kV overhead transmission line at each project site

Emission Sources Identified: Operations and maintenance facilities

Operations and maintenance fleet

Heavy equipment (crane operations)

Natural gas consumption for heating

Gasoline consumption for maintenance vehicle

operations

Diesel consumption for crane operations

Electricity consumption for lighting and power

Fugitives from switchgear

IPCC GHGs Emitted/Removed: Carbon Dioxide (CO2) Methane (CH4) Nitrous Oxide (N2O);

remaining IPCC GHGs were not emitted in the baseline or project condition.

Reporting Period: January 1 – December 31, 2018

2.3 Level of Assurance The verification was conducted to a reasonable level of assurance.

Choose type of verification from the dropdown box above.

Provide explanation on level of assurance.

The Standard for Validation, Verification and Audit, Version 3.0, December 2018 requires that verifications must be designed and completed to a reasonable level of assurance.

2.4 Criteria Outline the program criteria used and relevant supporting documentation (acts, regulations, protocols, standards, guidance documents, project documentation etc).


of 63

The program criteria used and relevant supporting documentation is as follows:

• Climate Change and Emissions Management Act • Carbon Competitiveness Incentive Regulation 255/2017, with amendments up to and

including Alberta Regulation 96/2018 • Standard for Validation, Verification and Audit, Version 3.0, December 2018. Alberta

Climate Change Office • Standard for Greenhouse Gas Emission Offset Project Developers, Version 2.0, July 2018 • Technical Guidance for the Assessment of Additionality, Version 1.0, May 2018 • Quantification Protocol for Wind-Powered Electricity Generation, Version 1.0, March 2008

2.5 Materiality Define the materiality of the verification.

The materiality threshold is defined in The Standard for Validation, Verification and Audit, Version 3.0, December 2018. For this verification, the materiality threshold is 5%.

3.0 Methodology Statement that the verification is performed according to ISO 14064-3.

Summary of the assessments/tests/reviews/evaluations that were conducted during the verification.

This verification was designed and completed according to the requirements of the ISO 14064-3 Standard.

The following verification activities (assessments/tests/reviews/evaluations) were conducted through the course of this verification. The specific verification activities that were conducted are detailed in the Verification Plan, which is appended to this report. They are also listed with the verification findings throughout section 4 of this report.

• Observations: the site visit included a tour of the project sites to observe emission sources, observation of the centralized meter data collection, and observation of the meter normalization for standard temperature and pressure;

• Review of documentation: the site visit included a review of the site metering diagram and process flow diagram, documentation supporting the activity data was reviewed, including review of any manual transcription that was applied between documents and the emission quantification software, meter calibration reports were reviewed for completeness and to identify any metering issues;

• Recalculation: the emissions quantities were recalculated using metered data and original data sources and by applying the quantification methodologies stated in the Responsible Party’s Offset Project Report; the methods for calculating any averages used in the emission quantification were recalculated and evaluated for accuracy and appropriateness;

• Inquiry: the site visit included an interview of the site operator. • Analytical procedures: a year-over-year comparison of overall emissions offsets was

performed.


of 63

3.1 Procedures Description of how the verification was conducted including: description of the nature, scale and complexity of the verification activity, confidence and completeness of the responsible party’s GHG information and assertion, assessment of GHG information system and its controls, assessment of GHG data and information, assessment of GHG information system and controls, assessment against criteria, evaluation of the GHG assertion.

The verification strategy applied a largely substantive approach. The verification procedures, which are detailed later in this section, were designed to test the activity data directly, wherever practical. By applying this approach, the verification did not rely heavily on the Responsible Party’s controls, but rather relied on the substantive evidence collected from verification procedures that reviewed metered data, data directly from invoices and independent laboratory reports, for example.

Regarding the scale and complexity of the verification procedures, the verification risk assessment was leveraged to design verification activities appropriate to address the inherent, controls and detection risk evaluated in relation to each activity data and boundary condition. In most cases, these verifications involved review of documentation, recalculation or analytical procedures designed to produce verification evidence to support the accuracy, completeness and consistency of the information. All activity data and boundary conditions were evaluated through the verification risk assessment and verification activities were designed and completed commensurate with the verification risk assessed.

In a similar way, the data integrity, quantification methodologies and quantification itself were assessed through the verification risk assessment. Verification procedures were designed and completed to address each of these key areas.

Verification evidence was developed from each of these verification activities, which was used to establish a verification conclusion regarding the GHG information systems, the Responsible Party’s controls and ultimately, the GHG Assertion.

Describe steps of the verification including planning, assessment, site visit, off-site verification, and report preparation.

The verification was conducted according to the ISO 14064-3 standard, which establishes four primary phases of a greenhouse gas verification as described in this section. The relevant sections from the ISO standard are noted below.

Agreement (ISO Section 4.3)

The verification level of assurance, objectives, criteria, scope and materiality was affirmed in the contract for services and re-affirmed during a verification kickoff meeting.

A conflict of interest review was conducted prior to beginning work and monitored throughout the verification. A conflict of interest statement is appended to this report.

Internally, Brightspot Climate began documenting the verification upon contract signing. All documentation related to the verification will be maintained for a period of seven years following the date of the verification statement.


of 63

Approach (ISO Section 4.4)

Brightspot Climate conducted an initial review of the Project’s greenhouse gas information, primarily by reviewing the reports and the Offset Project Plan. Brightspot Climate prepared a verification risk assessment based on this information, evaluating:

a) the inherent risks of discrepancies for each variable used to calculate each emission source and the general greenhouse gas reporting system;

b) the risk that the Responsible Party’s controls are insufficient to detect and prevent each inherent risk from causing a discrepancy in the GHG assertion; and

c) the potential magnitude of each inherent and control risk described above resulting from the contribution of the associated emission source.

This information was used to develop an appropriate verification procedure for each identified risk. Each procedure was designed to reduce the probability that the verification would not detect a discrepancy that has not been corrected by the Responsible Party’s controls. The tolerable error for each emission source is stated in the verification risk assessment.

Generally, a substantive approach was applied to the verification. Therefore, the verification procedures relied more heavily on data analysis than on controls testing.

Verification Plan

Brightspot Climate developed a Verification Plan that documents the level of assurance, verification objective, verification criteria, verification scope, and materiality. Additionally, the Verification Plan provides general description of the Project, documents operational and organizational changes that have occurred since the previous verification, explains the Project’s control environment, and describes the safety requirements of the site visit.

Assessment (ISO Sections 4.5 – 4.7)

The verification procedures consist primarily of tests, analysis and review focused on the following six critical areas:

a) The completeness and relevance of emission sources included in the GHG Assertion;

b) The consistency of the emission sources and quantification methodologies between the Protocol, the Offset Project Plan, Offset Project Report and the tools used to quantify the emission reduction;

c) The accuracy and level of transparency of measured and estimated data sources, data integrity of electronic and manual data transfers and transcription between data systems and the GHG calculation;

d) The accuracy of the GHG emissions reduction calculations;

e) The completeness, accuracy and transparency of information presented in the Offset Project Plan and Offset Project Report documents, including the implementation of stated methodologies and emission factors in the quantification of emissions reductions; and

f) The accuracy of transcription of final calculated values into the GHG Assertion, including the “confirmations” required by ACCO as described in the ACCO Standard for Validation, Verification and Audit.

The principles defined in the preceding six areas are defined in ISO 14064-1 (accuracy, completeness, consistency, relevance and transparency).

Site Visit

Rodrigo Cubedo attended a full day site visit to the Project, where completeness of data sources, accuracy of measurement and data system integrity was tested through observation


of 63

and interviews with site operations and production accounting personnel. The site visit included a closing meeting to review outstanding action items and to provide site operations personnel with an overview of the verifier’s observations.

The following Responsible Party personnel were interviewed regarding various aspects of the

Further details of the verification activities that were conducted on site, including observations and inquiries, are provided in Section 4 of this report.

Verification Procedures

The remainder of the verification procedures was conducted through a desk review following receipt of the draft GHG Assertion.

Through the course of the assessment phase of the verification, Brightspot Climate issued questions and requests for additional documentation and data. These requests were consolidated in a simple electronic tracking document to maintain a common record of communication.

The Responsible Party had the opportunity to address any issues that were raised through the course of the verification before they were documented as discrepancies in the Verification Report.

Evaluation and Statement (ISO Sections 4.8 – 4.9)

Following the completion of all verification procedures and consideration of all information received from the Responsible Party, the verifier was tasked with concluding whether the GHG assertion is without material discrepancy and whether the verification reviewed sufficient and appropriate evidence to support a reasonable level of assurance.

If any outstanding discrepancies remained, their materiality would have been calculated according to ACCO guidance such that both the aggregate net quantitative error and the absolute quantitative error could be reported. In such circumstances, qualitative discrepancies would be evaluated based on the potential impact on the GHG assertion and the potential impact on the Intended User’s ability to use the reported information.

Peer Review

The independent Peer Reviewer conducted a complete review of the verification. The peer review process examined:

a) The completeness of the verification risk assessment; b) The appropriateness of the verification procedures considering the inherent and control

risks identified in the verification risk assessment; c) The appropriateness of any sampling conducted in each of the verification procedures; d) The completeness of each verification procedure, including the verifiers documentation

of work completed; e) Closure of any issues raised by the verifier through the course of the verification; f) The sufficiency and appropriateness of all evidence reviewed through the verification to

support a reasonable level of assurance; and g) A review of the final Verification Statement and Conflict of Interest Statement.

Verification Report

The Verification Report includes a Verification Statement, Statement of Qualifications, Conflict of Interest Statement and a report on the findings of the verification. The final Verification and Sampling Plan has been appended to the Verification Report, including the results of the verification risk assessment.


of 63

Describe how the risk based approach was implemented in the sampling plan. Identify categories of risk including inherent risk, and detection risk (organization and verifier). Include the Verification Plan with the Sampling Plan in Appendix A. Paste the risk assessment table in this section.

Verification risk is defined as the risk of an incorrect verification conclusion. It can be calculated as the product of

• The Project’s inherent risks; • The Responsible Party’s control risks; and • The detection risks associated with the verifier’s verification procedures.

Inherent Risk × Control Risk × Detection Risk = Verification Risk

The verifier cannot affect the inherent risk or the control risk. Therefore, to reduce the overall verification risk and reach the agreed level of assurance (defined in the verification scope), the verifier must design verification procedures that reduce the detection risk.

Each inherent and control risk was provided with the risk score (high/medium/low). The risk analysis of inherent and control risks considers both the magnitude of the activity data or inventory component on the overall GHG assertion as well as the probability that the risk will result in a discrepancy, as assessed by the verifier.

The Verification Risk Assessment Summary on the following pages describes the following information: • Activity Data / Inventory Component: The boundary, eligibility requirement, data

component or reporting activity being evaluated. • Inherent Risk: The verifier’s evaluation of inherent risk. Inherent risks have been

categorized according to the ISO 14064-1 principles (accuracy, completeness, consistency, relevance, transparency).

• Control Risk: A description of the Responsible Party’s controls (if any controls are applicable) and the verifier’s evaluation of control risks.

• Max Detection Risk: The maximum detection risk that can be applied and still result in an overall verification risk that meets the agreed level of assurance.

• Designed Detection Risk: The detection risk of the verification procedure that the verifier intends to complete. Note that the designed detection risk must always be equal to or lower than the maximum detection risk.

• Verification risk: the product of the inherent, control and (designed) detection risk, as defined in the equation above.

Important note: The verification strategy for this verification applies both substantive tests and control tests. Substantive tests are designed to focus on directly testing activity data or inventory components and their associated inherent risks. Control tests are designed to focus on testing the Responsible Party’s controls and if the test is successful, relying on the Responsible Party’s control. Therefore, control tests indirectly test activity data or inventory components.

Each verification procedure listed in the following table denotes if the procedure is a substantive or control test.


of 63

Table 1: Risk Assessment

Activity Data/ Inventory Component

Inherent Risk Control Risk Max Detection Risk

Detection Risk Design

Description Verification Risk

Protocol Applicability Requirements

Metering of net electricity must be made at a point downstream of both generation and any storage system.

Completeness (low)

Electricity consumption downstream of the meter may not be included.

The Responsible Party does not have a control specifically designed to address this inherent risk.

High Low Substantive test: Review electrical single line diagram and observe electricity consumption sources during site visit.

Low

The quantification of the emission reduction is based on actual metering and monitoring.

Relevance (high)

GHG activity data may be estimated rather than measured.


Low Low Substantive test: Review substantiating documentation for all GHG activity data.

Low

Quantification Data

Volume of natural gas, gasoline and diesel for facility and maintenance operations

Accuracy (low)

Completeness (low)

Reported natural gas volumes may be missing some periods or may be inaccurate.


High Low Substantive test: Review fuel invoices for completeness and accuracy against reported volumes.

Low


of 63





Net electricity generated

Accuracy (high)

The quantity of electricity generated may be inaccurately reported.

Control: Compare metered electricity with AESO reported electricity.

Control risk: Comparison to AESO reported generation may not have been completed.

High Low Substantive test: Compare reported electricity consumption to quantity reported by the Alberta Electricity System Operator (AESO).

Low

Fuel emission factors and grid displacement factors

Accuracy (high)

The emission factors used to quantify the emission reduction may have been inaccurately transcribed.

N/A (controls not considered for verification)

Low Low Substantive test: Review the transcription of the emission factors into the Responsible Party’s quantification spreadsheet.

Low


of 63





Emission Quantification and Reporting

Application of the approved quantification protocol

Accuracy (high)

The project developer may not have implemented approved quantification methodologies or applied additional methodologies.

Control: Responsible Party has developed an Offset Project Plan that is intended to conform to the requirements of the approved quantification protocol.

Control Risk: The protocol requirements may not have been implemented correctly (medium)

Low Low Controls test: compare the methodologies described in the Responsible Party’s Offset Project Plan to the methodologies described in the approved quantification protocol.

Low

Substantive test: Recalculate the emission reduction using original metered data and methods described in the approved quantification protocol.

Low

Quantification of emission reduction

Accuracy (high)

Emission reduction calculation may contain arithmetic errors.


Low Low Substantive test: Recalculate the emission reduction using original metered data.

Low


of 63





Data Integrity

Activity data and emission factor data integrity

Accuracy (high)

Data may not have been accurately transferred between electronic systems and calculation sheets.

Control: The Responsible Party uses electronic data transfers whenever possible to maintain data integrity.

Control Risk: Electronic data transfers may result in errors or may not be available for all data (medium).

Low Low Controls test: Analyze all metered data for abnormal data (zeros, missing data, values outside range).

Low

Substantive test: Recalculate the complete emission reduction using original data.

Low


of 63





Transcription of final emission reduction into Offset Project Report

Accuracy (high)

Final emission reduction may not have been transcribed accurately from calculation spreadsheets into the Offset Project Report.


Low Low Substantive test: compare the final emission reduction quantity reported by the Responsible Party to the quantity reported in the Offset Project Report. Also, compare these quantities to the recalculated quantity in previous verification procedures.

Low

3.2 Team List verification team members including peer reviewer(s).

Describe the qualifications and training of the team members and peer reviewer(s) including dates of training and certifications.

For Offsets: fill in the sample Statement of Qualification provided and included in Appendix B.

For Facilities: include the Statement of Qualifications from the facility compliance form in Appendix B.

ISO 14064-3 defines sixteen subject matter areas in which the verifier should demonstrate familiarity (see ISO 14064-3, Section A.2.2.3). The verification team has competencies in each of these sixteen subject matter areas.

Lead Verifier: Aaron Schroeder, P.Eng.

Aaron Schroeder will be the Lead Validator and Designated Signing Authority. His extensive experience quantifying and verifying greenhouse gas emissions satisfies all sixteen subject matter areas defined in the standard.

Biography: Aaron Schroeder has eleven years of professional experience analyzing, quantifying and verifying greenhouse gas emissions in North America. Prior to forming Brightspot Climate Inc. in 2015, Aaron worked for several years leading a team of fifteen greenhouse gas verification and policy analysts across Canada with ICF International. He


of 63

provided leadership for this team and led the development of ICF’s standardized verification process, conformant with ISO 14064-3. In 2012, ICF’s verification process was accredited by the American National Standards Institute (ANSI).

Mr. Schroeder’s hands on experience conducting greenhouse gas verifications includes numerous engagements for oil and gas extraction and processing, refining, pipeline, electricity generation and petrochemical facilities. Additionally, he has conducted verifications of emission reduction projects in industrial facilities, renewable energy, waste management and agriculture. He is sought after for his expertise devising strategies to bridge the gap between theoretical and practical implementation of methodologies for quantifying, reporting and verifying.

In 2014, the University of Toronto engaged Mr. Schroeder to instruct professional development courses on greenhouse gas inventory and project quantification, reporting and verification. Since 2014, Mr. Schroeder has instructed several of these courses in live, two-day sessions and on-line instruction as a sessional lecturer through the university’s School of Environment. Additionally, Mr. Schroeder has worked with the School of Environment to re-write and update the courses.

Training: Greenhouse Gas Verification – ISO 14064-3, Canadian Standards Association, 2012; Instructor – Greenhouse Gas Verification – ISO 14064-3, University of Toronto, 2015 - 2017

Technical Specialist: Michelle Stelmach, P.Ag.

Biography:

Michelle Stelmach has worked as a Technical Specialist for verification and protocol development initiatives under Alberta’s Specified Gas Emitters Regulation. This work has included performing site visits and assisting with the verification planning and procedures for Wind-Powered Electricity Generation, Solar Electricity Generation, Conservation Cropping, Agricultural Nitrous Oxide Emission Reduction (NERP) and Fed Cattle (Beef Days on Feed) projects.

Michelle has worked with the Hazard Analysis Critical Control Point (HACCP) to design and conduct internal system audits and to meet Canadian Food Inspection Agency standards at the producer level, in feed manufacturing plants and poultry processing plants. She has extensive experience working with agricultural producers across Alberta through her work as Program Advisor and Coordinator with Maple Leaf Foods and Landmark Feeds.

Training: Michelle received GHG Validation and Verification, ISO 14064-3, training through the University of Toronto in October 2016.

Associate Verifier: Rodrigo Cubedo, B.Eng.

Biography: Rodrigo Cubedo has a background in mechanical engineering, specializing in aerospace projects. Rodrigo has leveraged his engineering experience to understand and systematically improve the processes used to work with international clients. He is fluent in Spanish, English, French and basic Mandarin. His experience working with a large accounting firm through an in-house deployment of analytical software exposed him to a systematic research framework, which he has recently used to complete GHG verifications.

Training: Rodrigo Cubedo graduated as a mechanical engineer from McGill University in June of 2016.

Associate Verifier: Sheldon Fernandes, B.ASc., MBA

Biography: Sheldon Fernandes has over five years of experience working on energy, climate change and sustainability issues in Canada and abroad. He has strong experience in carbon market analysis, regulatory analysis, sustainability reporting, greenhouse gas (GHG) quantification and verification and energy efficiency program design and delivery in provinces,


of 63

territories, and states across North America as well as in the European Union. He has worked as a Lead Verifier and Associate Verifier on a wide range of compliance and offset projects.

Training: Sheldon graduated as a systems design engineer from the University of Waterloo in 2014, and completed an MBA at the University of British Columbia in 2018.

Peer Reviewer: Hector Sanchez, P.Eng.

Biography: Hector Sanchez is a Professional Engineer with over 10 years of experience. He holds a Bachelor of Engineering Science in Chemical and Environmental Engineering from the University of Western Ontario and is registered as a Professional Engineer in the Province of Ontario. Hector has completed supplementary verification training, receiving a GHG verification certificate of training for ISO 14064. Hector has acted as a Lead Verifier in over 50 GHG verifications in in a range of projects under Alberta, British Columbia, Ontario and Quebec’s Greenhouse Gas Reporting Regulations. These projects included work at sour gas processing facilities, oil sands SAGD facilities, natural gas pipelines, mining refining, as well as several coal and natural gas combined-cycle electric generating facilities. Additionally, Hector has helped upstream oil and gas producers to comply with the different flaring regulations in the Province of Alberta and Saskatchewan (Directive S10) which provides enforceable regulatory requirements for reducing flaring and venting of associated gas. Hector’s previous work experience as an engineer in a sour natural gas processing facility provides important technical knowledge for these projects.

Training: Greenhouse Gas Verification – ISO 14064-3, Canadian Standards Association, 2012Association

3.3 Schedule Provide a list or table of verification activities and dates. Indicate when the verification was completed.

Verification Kickoff Meeting November 27, 2018

Draft Verification Plan November 27, 2018

Site Visit November 29, 2018

Supplementary Information Request February 11, 2019

Draft Verification Report February 15, 2019

Final Verification Report February 20, 2019

4.0 Results Add introduction to results section here, if desired.

The verification results are presented in the following five subsections. Subsections 4.1 – 4.3 present the results of the verification procedures for the data integrity (4.1), Quantification Methodologies and Quantification (4.2), and Boundary Conditions and Activity Data (4.3).


of 63

4.1 Assessment of Internal Data Management and Controls Provide a summary the information system(s) and its controls for sources of potential errors. Include information on the selection and management of data, process for collecting and consolidating data, data accuracy systems, design and maintenance of the GHG system, the systems and processes that support the GHG information system and results from previous assessments if applicable.

The Project’s GHG quantification is primarily performed in an Excel spreadsheet: Chin Chute GHG calculator_v2.0_2019-1-31.xlsx. All data required to quantify emissions reductions for the Project is either manually transcribed into these spreadsheets or electronically transferred from other spreadsheets. The final calculated quantities from these spreadsheets are transferred into the Offset Project Report. Data validation is completed before information is transferred; therefore, there are no active data controls in this document.

All activity data are either metered or referenced from supplier invoices. Meters are maintained on a preventative maintenance program, including periodic calibration. Calibration records are filed on-site.

The Responsible Party maintains an Offset Project Plan (OPP) and produces an Offset Project Report (OPR), which document the emission sources, processes for collecting GHG activity data, equations applied to quantify emissions reduction, calculation assumptions, meter calibration procedure and schedule, the averaging method applied to quantification, and a discussion of GHG data management.

Findings from Previous Verification

There were no findings from previous verifications.

Results of Verification Procedures

There were two verification procedures completed to test data integrity. The results of these procedures are provided in the following table.

Table 2: Findings of Data Integrity Verification Procedures

GHG Report Element

Verification Procedures Verification Findings

Activity data and emission factor data integrity

Controls test: Analyze all metered data for abnormal data (zeros, missing data, values outside range).

The activity data and emission factor data was analyzed for any abnormal data.

No discrepancies detected.

Substantive test: Recalculate the complete emission reduction using original data.

The complete emission reduction was recalculated using the original data.



of 63

GHG Report Element


Transcription of final emission reduction into Offset Project Report

Substantive test: compare the final emission reduction quantity reported by the Responsible Party to the quantity reported in the Offset Project Report. Also, compare these quantities to the recalculated quantity in previous verification procedures.

The emission reduction quantity was accurately transcribed into the Offset Project Report.


4.2 Assessment of GHG Data and Information Provide a summary of the information found during the verification of the GHG data and a summary of the GHG Assertion that was assessed.

For Facilities: Confirm that the quantification methodologies that were used in the compliance report are the same as those reported in the BEIA.

For Offset Projects: Confirm that the quantification methodologies that were used by the project proponent are the same as those described in the project plan. Indicate which quantification methodologies were used by the project proponent.

The GHG information consists of the activity data applied to quantify emissions reductions, the source documentation for the activity data, the information in the Offset Project Plan, as described in the previous section of this report, and the documentation supporting the boundary, methodologies, meter calibration, and emission factors.

Table 3: Findings of GHG Data and Information Verification Procedures

GHG Report Element


Verification Findings

Quantification Data

Volume of natural gas, gasoline and diesel for facility and maintenance operations

Substantive test: Review fuel invoices for completeness and accuracy against reported volumes.

All fuel invoices were reviewed and a recalculation was completed to verify the accuracy of the reported volumes.



of 63

GHG Report Element



Net electricity generated

Substantive test: Compare reported electricity consumption to quantity reported by the Alberta Electricity System Operator (AESO).

The quantity of net electricity generation reported by the Responsible Party matches the quantity reported publicly by the AESO.


Fuel emission factors and grid displacement factors

Substantive test: Review the transcription of the emission factors into the Responsible Party’s quantification spreadsheet.

The emission factors applied by the Responsible Party match the emission factors listed in the Alberta Emission Factors handbook.


Emission Quantification and Reporting

Application of the approved quantification protocol

Controls test: compare the methodologies described in the Responsible Party’s Offset Project Plan to the methodologies described in the approved quantification protocol.

The verification team compared the methods described in the Offset Project Plan to the methods described in the approved Quantification Protocol.

The quantification methods described in the Responsible Party’s Offset Project Plan adhere to the methods described in the approved Quantification Protocol.


Substantive test: Recalculate the emission reduction using original metered data and methods described in the approved quantification protocol.

The independent recalculation of the emission reduction resulted in the same emission reduction quantity asserted by the Responsible Party. Therefore, the approved Protocol quantification methods were applied in the Responsible Party’s emission reduction quantification.



of 63

GHG Report Element



Quantification of emission reduction

Substantive test: Recalculate the emission reduction using original metered data.

The independent recalculation of the emission reduction resulted in the same emission reduction quantity asserted by the Responsible Party. Therefore, the verification team concluded that no arithmetic or calculation errors were made by the Responsible Party in the emission reduction quantification.


4.3 Assessment against Criteria Provide a description of how eligibility criteria is met or not met.

For Offset Project: Complete Table 1 to indicate if the GHG Assertion conforms to the Regulation and Standard for Greenhouse Gas Emission Offset Project Developers eligibility criteria.

For Facilities: Delete Table 1 and Indicate if verification criteria are met or not met and explain.

Table 4: Findings of Criteria Verification Procedures

GHG Report Element


Protocol Applicability Requirements

Metering of net electricity must be made at a point downstream of both generation and any storage system.

Substantive test: Review electrical single line diagram and observe electricity consumption sources during site visit.

Electricity consumption sources were observed and reviewed with the Operator during the site visit.


The quantification of the emission reduction is based on actual metering and monitoring.

Substantive test: Review substantiating documentation for all GHG activity data.

All documentation was reviewed and metering was observed during the site visit.



of 63

Table 5: Offset Criteria Assessment

Offset Eligibility Criteria

Assessment

Reduction or sequestration occurs in Alberta

The project is located in Chin Chute, Alberta.

Result from actions not required by Law at the time the action is taken

The project activity is not required by municipal, provincial or federal regulations or directives.

Result from Actions taken on or after January 1, 2002 and occur on or after January 1, 2002

The project start date is November, 2006.

Reduction or sequestrations is real and demonstrable

The emission reduction was demonstrated through measurement and estimation of data required for the quantification. The GHG information presented to the verification team included sufficient and appropriate evidence to substantiate conformance with the Protocol Applicability Requirements and to substantiate the quantification data.

Quantifiable and measurable

The emission reduction was demonstrated through measurement and estimation of data required for the quantification. This data was substantiated by sufficient and appropriate evidence. Table 3 of this report presents the findings of the evaluation of each variable required for the emission reduction quantification.

Verified by a third party verifier that meets the requirements in Part 1 for the Standard for Validation, Verification and Audit.

Brightspot Climate Inc. is an independent third-party verifier that meets the requirements outlined in Section 1 of the Standard for Validation, Verification and Audit. The Lead Verifier and Designated Signing Authority, Aaron Schroeder, is a Professional Engineer and has extensive experience quantifying and verifying greenhouse gas emissions, satisfying all sixteen subject matter areas defined in the ISO 14064-3 Standard.


of 63

4.4 Evaluation of the GHG Assertion The verification assessment is that the GHG Assertion Choose an item.

Provide an assessment of the evidence collected during the verification. Determine if the data and information available support the GHG assertion. Provide a conclusion on whether the assertion meets the materiality requirements and the level of assurance agreed to at the beginning of the verification process.

The results of each verification procedure are provided in the preceding three subsections (4.1 – 4.3). Sufficient and appropriate evidence was collected through the verification procedures to reach the verification conclusion at a reasonable level of assurance, which is provided in the Verification Statement.

The data and GHG information provided by the Responsible Party is sufficient to support the GHG assertion.

There were no material or immaterial discrepancies detected in the final GHG assertion.

4.5 Summary of Findings Provide a summary of material and immaterial discrepancies expressed in tonnes and as net and absolute error in Table 2. Include whether the discrepancy was an understatement or an overstatement.

Include a more detailed description and log of results in Appendix C the “Issues Log”. This log will include both resolved and unresolved issues from the verification. Unresolved issues should be brought forward to Table 2.


of 63

Table 6: Summary of Findings

Number the finding with the year and provide a unique # for each finding. Note: A detailed description of all material and immaterial findings should be provided in Table 3 of Appendix C. Provide only a summary statement (1-4 sentences) for each unresolved immaterial finding and each material finding (resolved or unresolved). If the finding is a resolved material finding, then put the tonnes net and absolute in the summary description column and indicate n/a in the net and absolute columns. Do not include the tonnes in the total error calculation. Indicate the type of error (qualitative or quantitative). Indicate the Source Category (for facilities) or the Source/Sink (for offsets). Indicate if the finding is an understatement or overstatement. Provide both net and absolute error in tonnes of CO2 eq and as a % of the assertion. Provide the total net error and the total absolute error in tonnes of CO2 eq and as a % of the assertion.

Result Type Summary Description of Finding Source Category or Source/Sink

Understatement / Overstatement

Tonnes CO2e % net

Tonnes CO2e % absolute

No material or immaterial discrepancies detected in the final GHG assertion.

Total Error


of 63

4.6 Opportunity for Improvement Provide feedback on the data management system and controls, transparency, completeness of the inventory, additions to the quantification methodology document or diagrams, etc. Include positive considerations and observations also.

Identify strengths and weaknesses that may help to improve the report/s for the current facility, sector, and compliance program. Identify ways in which the project/facility could be more easily verified.

Overall, the GHG information was orderly and thoroughly presented.

The quantification spreadsheets were satisfactorily organized and sufficiently transparent to conduct the verification procedures.

Sufficient and appropriate evidence was provided by the Responsible Party to conduct each of the verification procedures.

The Offset Project Plan and Offset Project Report thoroughly document the emission sources, quantification approach, equations, data collection and information controls.

5.0 Closure 5.1 Verification Statement Include the signed verification statement in Appendix D.

Instructions to insert a pdf: 1. Click Insert>Object 2. In the Object dialog box click Create from File and then click Browse. 3. Find the pdf you want to insert then click Insert. 4.Click OK.

For Offset Projects: fill in the sample Verification Statement provided, sign, scan and paste.

For Facilities: paste a signed version of the Verification Statement from the facility compliance form. Include the conclusion on the GHG assertion and any qualification or limitations and the level of assurance.

Provide the verification conclusion in the drop down box below.

The verification conclusion is:

Positive

5.2 Limitation of Liability Include signed Conflict of Interest Checklist in Appendix E.

For Offset Projects: fill in the sample Conflict of Interest Checklist provided, sign, scan and paste.

For Facilities: paste the signed Conflict of Interest Checklist from the facility compliance form.

Insert limitation of liability statement and include information in an Appendix F if applicable.


of 63

5.3 Confirmations Document information confirmed, including any discrepancies or inconsistencies, as per the Confirmations section in the Standard for Greenhouse Gas Verification.

Section 5.1.3 of the Standard for Validation, Verification and Audit document lists nine activities that are beyond the scope of a typical greenhouse gas verification.

Table 7: Confirmation Findings

Confirmation Confirmation Finding

Correct entry of administrative fields such as facility codes and legal locations

The Offset Project Report was reviewed for completeness and accuracy. All project and legal location information is complete and accurate.

Quantification Methodology document is provided and consists of the required components

The Responsible Party has documented all relevant methodologies, procedures and controls in the Offset Project Plan and the Offset Project Report.

Simplified process flow diagrams and energy diagrams

The Responsible Party’s Offset Project Plan and Offset Project report provide process flow diagrams, which were reviewed and found to accurately represent the Project.

Fuel usage This requirement is not applicable to Offset Projects.

Additional request items/forms are complete and reasonable justification provided where needed

The Statutory Declaration was reviewed and found to be complete.

N/A is checked on pages in the reporting form that do not apply

This requirement is not applicable to Offset Projects.

For forecasting facilities, the fund to credit ratio was met for all four reporting periods


For oil sands facilities, the area fugitive calculations are accounted for, as required


Project report information details as required The Responsible Party has prepared an Offset Project Report that meets all the requirements specified in the Standard for Greenhouse Gas Emission Offset Project Developers, Version 2.0, July 2018


of 63

6.0 References Author. Year. Title. (no hyperlinks)

The documents reviewed through the course of the verification include:

See Appendix F.

of 63

Appendix A: Final Verification Plan and Sampling Plan


of 63

Information to be included in the Verification Plan and Sampling Plan:

Revisions to the sampling plan

Date originally sent to Facility/project

Level of assurance agreed with the facility/project developer

Verification scope

Verification criteria

Amount and type of evidence (qualitative and quantitative) necessary to achieve the agreed level of assurance

Methodologies for determining representative samples

Sampling Plan and Procedures

Risk Assessment: Risks of potential errors, omissions or misrepresentations that are identified throughout the verification process including:

- Details of site visit

-offset/facility boundaries

- Methodologies, emissions factors and conversions used

- Comparability with the approved baseline

- Conformance to the program criteria

- Integrity for the responsible party’s data management system and control (organization chart, GHGH management plan, personnel/consultant training, protocols used, control system documentation, software/program documentation/certifications)

- Greenhouse gas data and information, including the type of evidence collected, verification testing and crosschecking, inventory of emission sources

- Discussion of data management, (measurement, fuel sampling, calibration, consistent use of standard conditions, data storage, procedures to fill missing data; procedures to repair inconsistent data, adjustment of variables and factors)

- Other relevant information

+1 (604) 353-0264 • www.brightspot.co • [email protected]

Suncor Energy Inc.

Magrath and Chin Chute Wind Power Projects

Verification Plan

November 27, 2018

This page intentionally blank

Brightspot Climate Inc. – Verification Plan Suncor Energy Inc. – Magrath and Chin Chute Wind Power Projects 2018

i

Terminology

ISO 14064-2 defines the following terms used in the context of a GHG verification:

GHG Assertion: a declaration or factual and objective statement made by the Responsible

Party.

The Alberta Climate Change Office Standard for Verification1 extends this definition to include

the document that identifies the greenhouse gas emission reduction and/or removals and

emissions offsets being claimed by the offset project over a defined period of time.

Project: activity or activities that alter the conditions identified in the baseline scenario which

cause greenhouse gas emission reductions or greenhouse gas removal enhancements.

The GHG Assertion subject of this verification is for Magrath and Chin Chute Wind Power

Projects, which will be referred to throughout this document as “the Project”.

ISO 14064-2 defines the following parties associated with the verification:

Responsible Party: person or persons responsible for the provision of the greenhouse gas

assertion and supporting GHG information.

The Responsible Party for this verification is Suncor Energy Inc. (Suncor).

Intended User: individual or organization identified by those reporting GHG-related information

as being the one who relies on that information to make decisions.

The Intended User for this verification is the Alberta Climate Change Office (ACCO).

Verifier: competent and independent person, or persons, with the responsibility of performing

and reporting on the verification process.

The Verifier for this verification is Brightspot Climate Inc. (Brightspot Climate). The members of

the verification team are provided in section 2 of this document.

1 Standard for Validation, Verification and Audit, Version 2.0, June 2018, Alberta Climate Change Office.


1

Introduction

This document serves to communicate information between the parties associated with the

independent verification of the Offset Project Report for the <Project>.

This document contains six sections:

1. The Introduction, which defines the principles by which this verification will be conducted;

2. The Verification, which defines the verification parameters and the GHG inventory principles that

will be tested by the verification. This section also provides information regarding the verification

team and site visit;

3. The Responsible Party Data Management and Controls, which describes the data management

system and control environment implemented by the Responsible Party;

4. Previous GHG Assertions, which describes any modifications to the original project that have

been made since the original Offset Project Plan was developed and any findings from previous

verifications for this Project;

5. The Verification Risk Assessment and Verification Procedures, which describes the risks of

potential errors, omissions or misrepresentations to the overall GHG assertion and the

verification procedures that have been developed to reduce the overall verification risk; and

6. The Sampling Plan, which lists the verification procedures that could apply sampling of the

project data, along with the sampling size, the sampling methodology and justification.

The Responsible Party developed the Project in accordance with the requirements of the Quantification

Protocol for Wind-Powered Electricity Generation, Version 1, March 2008 (the Protocol).

GHG Quantification Principles

ISO 14064-2 defines six principles that are fundamental to the fair accounting and reporting of GHG

information. The verification procedures will test that these principles have been upheld through the

Responsible Party’s inventory, accounting and reporting processes.

Section 3.2 – 3.6 of ISO 14064-2 defines these principles as follows:

Accuracy: reduce bias and uncertainty as far as practical

Completeness: include all relevant emission sources

Conservativeness: use conservative assumptions, values and procedures to ensure that GHG

emission reductions or removal enhancements are not over-estimated

Consistency: enable meaningful comparisons of reported emissions (from year to year or

between facilities or between companies)

Relevance: select GHG sources, sinks and reservoirs, data and quantification methodologies

appropriate to the needs of the intended user

Transparency: disclose sufficient and appropriate GHG information to facilitate verification and

to allow intended users to make decisions with relative confidence


2

Verification

Verification Principles

ISO 14064-3 defines four fundamental principles to conducting a greenhouse gas verification, namely

independence, ethical conduct, fair presentation and due professional care.

Brightspot Climate has implemented processes, including mandatory training for all verification team

members, to ensure the application of these principles for this verification.

Regarding the principle of independence, Brightspot Climate conducted an assessment of threats to

independence prior to initiating this verification. No real or perceived threats to independence were

identified. Brightspot Climate will continue to monitor for threats to independence throughout the

course of this verification. A final “Conflict of Interests Checklist” will be appended to the Verification

Statement.

Verification Parameters

The verification will be conducted according to the parameters defined in the following table:

Table 1: Verification Parameters

Level of Assurance Reasonable assurance

Objectives

• issue a verification statement on whether the GHG assertion is

without material discrepancy;

• issue a verification report that provides details of the verification

activities; and

• complete the “confirmations” activities defined in the Alberta

Climate Change Office Guidance Document2, Section 5.1.3

2 Standard for Validation, Verification and Audit, Version 2.0, June 2018. Alberta Climate Change Office.


3

Criteria

• Climate Change and Emissions Management Act

• Carbon Competitiveness Incentive Regulation 255/2017 with

amendments up to and including Regulation 96/2018

• Standard for Validation, Verification and Audit, Version 2.0, June

2018

• Standard for Greenhouse Gas Emission Offset Project Developers,

Version 2.0, July 2018

• Standard for Completing Greenhouse Gas Compliance and

Forecasting Reports, Version 2.0, June 2018

• Technical Guidance for the Assessment of Additionality, Version

1.0, May 2018

• Quantification Protocol for Wind-Powered Electricity Generation,

Version 1, March 2008


4

Scope

Project Name: Magrath Wind Power Project


Geographic Boundary: Chin Chute: 15km south west of Taber, Alberta

LSD: Sections 25,30,35 and 36 08-17-W4 (3

turbines) and 10- 18-W4 (17 turbines)

Latitude: 49°N Longitude: 112°W Magrath: 6km west of Magrath, Alberta

LSD: Sections 7,8,18,19 and 24 05-23-W4 (6

turbines) and 05-22-W4 (14 turbines)


Physical Operations: Electricity generation by wind power by 20

General Electric 1.5 MW wind turbines at each

project site

Transmission and Distribution lines: a network of

25 kV underground distribution lines and a 138kV

overhead transmission line at each project site

Operations and maintenance facilities

Operations and maintenance fleet

Heavy equipment (crane operations)

Emission Sources: Natural gas consumption for heating

Gasoline consumption for maintenance vehicle

operations

Diesel consumption for crane operations

Electricity consumption for lighting and power

Fugitives from switchgear

IPCC GHGs Emitted: Carbon Dioxide (CO2)

Methane (CH4)

Nitrous Oxide (N2O)

Reporting Period: January 1 – December 31, 2018

Materiality Quantitative materiality threshold is 5% of asserted greenhouse gas

emission reduction.


5

Preliminary Verification

Schedule

Verification Kickoff Meeting November 27, 2018

Draft Verification Plan November 27, 2018

Site Visit November 29, 2018

Draft Verification Report February 15, 2019

Final Verification Report February 19, 2019

Verification Team

Aaron Schroeder, P.Eng., will be the Lead Verifier and Designated Signing Authority for this verification.

His extensive experience quantifying and verifying greenhouse gas emissions satisfies all sixteen subject

matter areas defined in the ISO 14064-3.

Michelle Stelmach, P.Ag., will conduct site visits and complete verification procedures under the

supervision of the Lead Verifier.

Rodrigo Cubedo, EIT will provide analytical support to the verification team through the completion of

the verification procedures and the development of the Verification Report.

Sheldon Fernandes will provide analytical support to the verification team through the completion of the

verification procedures and the development of the Verification Report.

Hector Sanchez, P.Eng., will conduct an independent peer review of the verification.

Additional information regarding the qualifications of the verification team will be provided in a

Statement of Qualifications, which will be appended to the Statement of Verification.

Site Visit Safety Requirements

Personnel conducting site visits are required to wear personal protective equipment including steel-toed

boots, Nomex coveralls, hard hat, safety glasses with side shields and gloves. A site orientation must

be completed before entering the site.


6

Responsible Party Data Management and Controls

Data Management Systems

Bluesource Canada, as Suncor’s consultant, has the primary responsibility for collecting GHG

information, quantifying the emission reduction and completing required documentation.

The Responsible Party uses Suncor’s Renewable Energy group’s monthly master production tracking

spreadsheet to manage GHG information and quantify the emission reduction. Table 2, below,

describes the data measurement, estimation and data storage locations for all GHG information used

by the Responsible Party to produce the GHG inventory. The final column in this table describes the

data storage location and the path (intermediate data transfer) prior to use in the GHG inventory.

Table 2: GHG Information Data Management

Activity Data Description Measurement Type Data Storage Location / Path

Volume of natural gas and

gasoline for facility and

maintenance operations

Natural Gas – Monthly

Invoices

Gasoline – purchase

receipts and Fuel

Usage Report

Monthly Invoices/purchase receipts

>>Bluesource GHG Calculator

Volume of diesel used for the

crane during maintenance (Chin

Chute only)

Invoice for Crane

Usage and

documented

methodology for

calculation of fuel

consumption

Invoice >>Bluesource GHG Calculator

Net electricity generated Continuously Metered

Recorded electronically by the on-site

revenue meters and monitored by a third-

party, MIDAS Metering Services Ltd >>

Bluesource GHG Calculator


7

Control Environment

The Responsible Party’s Offset Project Plan (OPP) describes the processes, procedures and systems

that have been designed and implemented within their quality assurance/quality control framework. The

accuracy and completeness of the documentation of the Responsible Party’s controls will be reviewed

through the course of the verification.

The following processes, procedures and systems have been employed by the Responsible Party:

• Quantification is based on direct metering and measurement.

• Meter calibration is performed in accordance with measurement Canada on the electricity

production meters.

• Data is transferred electronically between systems to reduce transcription errors where

possible. Invoices are also used and transcribed into the Blue Source GHG Calculator.

• The Responsible Party has implemented a QA/QC and senior review process to validate data,

transcription, calculations, references and methodologies.

• All quantification data is stored on the Responsible Party’s corporate server in a unique project

folder under the date it was downloaded. Electronic data is backed up by a third-party service

provider.

• The Responsible Party has implemented a record retention system that meets the requirements

of the Regulation.

• The Offset Project Plan (OPP) is reviewed annually for accuracy, completeness, consistency,

relevance and transparency. The OPP documents:

• Project boundary

• Project processes

• Emission sources, including negligible emission sources

• Changes made to the project since the baseline condition was established

• Activity data used to quantify emissions

• Emission quantification equations and other methods for deriving values required for the

quantification of emissions and production

• Emission factors and references

• Meter maintenance processes

• Data management

• Data quality controls and procedures


8

Previous GHG Assertions

Changes to Operations and Boundaries

This is the second year that Brightspot Climate has provided verification services for the Project.

The Offset Project Plan was revised in 2015 to meet the new requirements of the Alberta Offset

System. There were no changes made to the quantification methodology at that time.

There were no changed made to the Projects since the previous verification.

Findings from Previous Verifications

There were no findings reported in the previous verification reports for the Projects.


9

Verification Risk Assessment and Verification Procedures

Verification risk is defined as the risk of an incorrect verification conclusion. It can be calculated as the

product of

• The Facility’s inherent risks;

• The Responsible Party’s control risks; and

• The detection risks associated with the verifier’s verification procedures.

Inherent Risk × Control Risk × Detection Risk = Verification Risk

The verifier cannot affect the inherent risk or the control risk. Therefore, to reduce the overall verification

risk and reach the agreed level of assurance (defined in the verification scope), the verifier must design

verification procedures that reduce the detection risk.

Each inherent and control risk was provided with the risk score (high/medium/low). The risk analysis of

inherent and control risks considers both the magnitude of the activity data or inventory component on

the overall GHG assertion as well as the probability that the risk will result in a discrepancy, as assessed

by the auditor.

The Verification Risk Assessment Summary on the following pages describes the following information:

Activity Data / Inventory Component: The boundary, eligibility requirement, data component or

reporting activity being evaluated.

Inherent Risk: The verifier’s evaluation of inherent risk. Inherent risks have been categorized

according to the ISO 14064-1 principles (accuracy, completeness, consistency, relevance,

transparency)

Control Risk: A description of the Responsible Party’s controls (if any controls are applicable)

and the verifier’s evaluation of control risks.

Max Detection Risk: The maximum detection risk that can be applied and still result in an overall

verification risk that meets the agreed level of assurance.

Designed Detection Risk: The detection risk of the verification procedure that the verifier intends

to complete. Note that the designed detection risk must always be equal to or lower than the

maximum detection risk.

Verification risk: the product of the inherent, control and (designed) detection risk, as defined in

the equation above.

Important note: The verification strategy for this verification is to use substantive tests instead of control

tests wherever possible. Substantive tests are designed to focus on directly testing activity data or

inventory components and their associated inherent risks. Control tests are designed to focus on

testing the Responsible Party’s controls and if the test is successful, relying on the Responsible Party’s

control. Therefore, control tests indirectly test activity data or inventory components.

Each verification procedure listed in the following table denotes if the procedure is a substantive or

control test.


10

Table 3: Verification Risk Assessment Summary

Activity Data /

Inventory

Component

Inherent Risk Control Risk Max

Detection

Risk

Designed

Detection

Risk

Description of Verification

Procedure

Verification

Risk

PROTOCOL APPLICABILITY REQUIREMENTS

Metering of net

electricity must be

made at a point

downstream of both

generation and any

storage system.

Completeness (low)

Electricity

consumption

downstream of the

meter may not be

included.

The Responsible

Party does not

have a control

specifically

designed to

address this

inherent risk.

High Low Substantive test: Review

electrical single line diagram and

observe electricity consumption

sources during site visit.

Low

The quantification of

the emission

reduction is based

on actual metering

and monitoring.

Relevance (high)

GHG activity data

may be estimated

rather than

measured.

The Responsible

Party does not

have a control

specifically

designed to

address this

inherent risk.

Low Low Substantive test: Review

substantiating documentation for

all GHG activity data.

Low

QUANTIFICATION DATA

Volume of natural

gas, gasoline and

diesel for facility and

maintenance

operations

Accuracy (low)

Completeness (low)

Reported natural

gas volumes may be

missing some

periods or may be

inaccurate.

The Responsible

Party does not

have a control

specifically

designed to

address this

inherent risk.

High Low Substantive test: Review fuel

invoices for completeness and

accuracy against reported

volumes.

Low


11

Activity Data /

Inventory

Component


Detection

Risk

Designed

Detection

Risk


Procedure

Verification

Risk

Net electricity

generated

Accuracy (high)

The quantity of

electricity generated

may be inaccurately

reported.

Control: Compare

metered electricity

with AESO

reported electricity.

Control risk:

Comparison to

AESO reported

generation may

not have been

completed.

High Low Substantive test: Compare

reported electricity consumption

to quantity reported by the

Alberta Electricity System

Operator (AESO).

Low

Fuel emission

factors and grid

displacement

factors

Accuracy (high)

The emission factors

used to quantify the

emission reduction

may have been

inaccurately

transcribed.

N/A (controls not

considered for

verification)

Low Low Substantive test: Review the

transcription of the emission

factors into the Responsible

Party’s quantification

spreadsheet.

Low


12

Activity Data /

Inventory

Component


Detection

Risk

Designed

Detection

Risk


Procedure

Verification

Risk

EMISSION REDUCTION QUANTIFICATION

Application of the

approved

quantification

protocol

Accuracy (high)

The project

developer may not

have implemented

approved

quantification

methodologies or

applied additional

methodologies.

Control:

Responsible Party

has developed an

Offset Project Plan

that is intended to

conform to the

requirements of

the approved

quantification

protocol.

Control Risk: The

protocol

requirements may

not have been

implemented

correctly (medium)

Low Low Controls test: compare the

methodologies described in the

Responsible Party’s Offset

Project Plan to the

methodologies described in the

approved quantification protocol.

Low

Substantive test: Recalculate the

emission reduction using original

metered data and methods

described in the approved

quantification protocol.

Low


13

Activity Data /

Inventory

Component


Detection

Risk

Designed

Detection

Risk


Procedure

Verification

Risk

Quantification of

emission reduction

Accuracy (high)

Emission reduction

calculation may

contain arithmetic

errors.

The Responsible

Party does not

have a control

specifically

designed to

address this

inherent risk.

Low Low Substantive test: Recalculate the

emission reduction using original

metered data.

Low

DATA INTEGRITY

Activity data and

emission factor data

integrity

Accuracy (high)

Data may not have

been accurately

transferred between

electronic systems

and calculation

sheets.

Control: The

Responsible Party

uses electronic

data transfers

whenever possible

to maintain data

integrity.

Control Risk:

Electronic data

transfers may

result in errors or

may not be

available for all

data (medium).

Low Low Controls test: Analyze all

metered data for abnormal data

(zeros, missing data, values

outside range).

Low


14

Activity Data /

Inventory

Component


Detection

Risk

Designed

Detection

Risk


Procedure

Verification

Risk

Substantive test: Recalculate the

complete emission reduction

using original data.

Low

Transcription of final

emission reduction

into Offset Project

Report

Accuracy (high)

Final emission

reduction may not

have been

transcribed

accurately from

calculation

spreadsheets into

the Offset Project

Report.

The Responsible

Party does not

have a control

specifically

designed to

address this

inherent risk.

Low Low Substantive test: compare the

final emission reduction quantity

reported by the Responsible

Party to the quantity reported in

the Offset Project Report. Also,

compare these quantities to the

recalculated quantity in previous

verification procedures.

Low


15

Sampling Plan

The verification procedures that could apply sampling of the project data are listed in the following table.

The sampling size, the sampling methodology and their respective justifications are also described in the following table.

Table 4: Sampling Plan

Activity Data /

Inventory

Component

Detection

Risk

Design


Procedure

Sampling Methodology and

Justification

Sample Size

Volume of natural

gas, gasoline and

diesel for facility

and maintenance

operations

Low Substantive test: Review fuel

invoices for completeness and

accuracy against reported

volumes.

Review of full dataset has lower

detection risk than sampling.

All values.

Net electricity

generated

Low Substantive test: Compare

reported electricity consumption to

quantity reported by the Alberta

Electricity System Operator

(AESO).



All values.

Fuel emission

factors and grid

displacement

factors

Low Substantive test: Review the

transcription of the emission

factors into the Responsible Party’s

quantification spreadsheet.



All values.

of 63

Appendix B: Statement of Qualifications

of 63

Statement of Qualifications

Offset Report Project Name Offset Project ID


0766-3464

Reporting Company Legal Name Report Type Reporting Period

Suncor Energy Inc.

Offset Report

from


to

Signature of Third Party Verifier

I, Aaron Schroeder

(Third Party Verifier), meet or exceed the qualifications of third-party verifiers described in Section 29 of the Carbon Competitiveness Incentive Regulation.

Verifying Company Name

Brightspot Climate Inc. Per: Aaron Schroeder

Signature of Third Party Verifier Date:

Training Received Under ISO 14064 Part 3

• Greenhouse Gas Verification – ISO 14064-3, Canadian Standards Association, 2012 • Instructor – Greenhouse Gas Verification – ISO 14064-3, University of Toronto, 2015 – 2018

First Name Last Name

Aaron Schroeder

Professional Designation E-mail Address Phone Number

Professional Engineer [email protected] (604) 353-0264

Lead Verifier

� Same as third party verifier??

First Name Last Name Professional Designation E-mail Address Phone Number Training Received Under ISO 14064 Part 3

February 20, 2019

of 63

Peer Reviewer First Name Last Name Hector Sanchez E-mail Address Phone Number [email protected] (416) 300-2661 Training Received Under ISO 14064 Part 3

• Greenhouse Gas Verification – ISO 14064- 3, Canadian Standards Association, 2012

of 63

Appendix C: Findings and Issues

of 63

Table 8: Detailed Findings and Issues Log

Number the issue with the year and provide a unique # for the issue. If the issue resolved during the verification, indicate that in the resolution column. If the issue is not resolved during the verification, or if the issue was material (whether resolved or not) record it as a finding in Table 2 and provide a cross reference to the finding # in the resolution column. Describe the issues investigated. State the verification criteria that are not met. Provide a description of how it is not met and provide the evidence. Indicate the Source Category (for facilities) or the Source/Sink (for offsets). Indicate if the finding is an understatement or overstatement. Summarize information between verifier and client. Provide a conclusion including % discrepancy, if applicable.

Item (YR-##)

Description of the Issues Investigated During the Verification

Summary of information exchanged between Verifier and Responsible Party

Resolution Conclusion

There were no issues raised during the verification that required investigation beyond the verification activities described herein.

of 63

Appendix D: Statement of Verification


Page 56 of 63

Statement of Verification Associated SGER Submission

Offset Project Protocol Project ID #


Quantification Protocol for Wind-Powered Electricity Generation, Version 1, March 2008

0766-3464

Project Developer Serial Range Start Report Period

Suncor Energy Inc.

TBD


Serial Range End

TBD

Statement of Verification

GHG Assertion Value Units

Total Baseline Emissions 48,974 tonnes CO2e

Total Project Emissions 269 tonnes CO2e

Other 0 tonnes CO2e

Net Reductions 48,705 tonnes CO2e

Statement of Assertion

The Responsible Party’s GHG Assertion is comprised of the Offset Project Plan, Offset Project Report and supporting documentation.


Page 57 of 63

The GHG Assertion covers the reporting period January 1 – December 31, 2018 and states an emission reduction and removal claim of 48,705 tonnes CO2e over this period.

The emission reduction and removal claim consists of 2018 vintage credits.

Responsibilities of Project Developer and Third Party Verifier

Our responsibility as the Verifier is to express an opinion as to whether the GHG Assertion is materially correct, in accordance with approved Protocol, the Carbon Competitiveness Incentive Regulation (the “Regulation”), and the Alberta Climate Change Office – Standard for Greenhouse Gas Emission Offset Project Developers, Version 2.0, July 2018.

We completed our review in accordance with the ISO 14064 Part 3: Greenhouse Gases: Specification with Guidance for the Validation and Verification of Greenhouse Gas Assertions (ISO, 2006). As such, we planned and performed our work in order to provide positive, but not absolute assurance with respect to the GHG Assertion.

The verification procedures that were performed through the course of the verification were developed based on the results of a risk assessment that was completed during the verification planning stage. These verification procedures are described in the Verification Plan. Certain verification procedures included data sampling. The sampling type, sample size and the justification for the planned sampling type and size are detailed in a Sampling Plan, which is included in the Verification Plan.

Conclusion

I believe our work provides a reasonable basis for my conclusion.

There were no unresolved misstatements in the final GHG Assertion.

Based on our review, it is my opinion at a reasonable level of assurance that the GHG Assertion is materially correct and presented fairly in accordance with the relevant criteria.





Date:

First Name Last Name

Aaron S Schroeder

Professional Designation E-mail Address

Phone Number

February 20, 2019


Page 58 of 63

Professional Engineer [email protected] (604) 353-0264

of 63

Appendix E: Conflict of Interest Checklist


Page 60 of 63

Conflict of Interest Checklist

Associated SGER Submission

Offset Project Protocol


Quantification Protocol for Wind-Powered Electricity Generation, Version 1.0 March, 2008

Project Developer Report Type Report Period

Suncor Energy Inc. Offset Report


Checklist Respond either "True" or "False" to each of the following statements:

1. The relationship between my firm and this reporting company poses

unacceptable threat to or compromises the impartiality of my firm.

False

2. The finances and sources of income of my firm compromise the impartiality of

my firm.

False

3. The personnel my firm has scheduled to participate in the verification may have

an actual or potential conflict of interest.

False

4. My firm participated in some manner in the development or completion of the

associated offset submission for this reporting company.

False

5. My firm provided greenhouse gas consultancy services to this reporting

company.

False

6. My firm will use personnel that have, are, or will be engaged or previously

employed by the reporting company.

False

7. My firm will outsource the Statement of Verification for the associated offset

submission.

False

8. My firm offers products or services that pose an unacceptable risk to

impartiality.

False

Important: If you have checked "True" to any of the above, you may not fulfill the "independence" requirement for third party verifiers. Please contact Alberta Environment and Parks for further instruction. If the potential conflict of interest is a sufficient threat to impartiality (perceived or actual), or cannot be effectively managed, you Third Party Verification Report will not be acceptable to Alberta Environment and Parks.


Page 61 of 63


I , Aaron Schroeder (Third Party Verifier), have personally examined and am familiar

with the information contained in this Conflict-of Interest Checklist, and can demonstrate freedom from any conflict of interest related to the reporting company for which the verification was performed. I hereby warrant that the information submitted in this Conflict-of Interest Checklist is true, accurate and complete to the best of my knowledge, and that all matters affecting the validity of this Conflict-of-Interest Checklist have been fully disclosed. Impartiality shall be monitored over the duration of the verification and any identified actual or potential conflict-of-interest situations will be communicated to AEP directly.



Signature of Third Party Verifier Date:

First Name Last Name Aaron Schroeder Professional Designation E-mail Address Phone Number Professional Engineer [email protected] (604) 353-0264

February 20, 2019

of 63

Appendix F: Supplemental Diagrams/Tables/Figures

of 63

Table 9: Supporting Documentation Reviewed

File Name Description

Chin Chute_GHG calculator_v2.0_2019_1_31.xlsx Calculator

Chin Chute_OPR_v2.0_01-31_2019.pdf Offset Project Report

0766_3464_AEOR_OffsetProjectPlan_20150501_20200430.pdf Offset Project Plan

Chin Load Facility Report 2018.pdf Facility Power Summary

Chin Production Report 2018.pdf Production Summary

Multiple Invoices Natural Gas Invoices

Multiple Invoices Crane Work Orders

Multiple Invoices Electricity Invoices

Limitation of Liability

This report is intended for the responsible party and the intended user as defined in the attached verification report. The sole intention of the report is to verify the GHG assertion made by the responsible party named in the report and is not intended to provide assurance of any kind for any purpose other than for reporting under the GHG program as defined in the scope of the attached report.

Brightspot Climate disclaims liability for use by any other party and for any other purpose.

verification report for: proponent: prepared for: version · chin chute wind power project, project...

Documents