ghost pine wind power project nextera energy resources, llc

Ghost Pine Wind Power Project

NextEra Energy Resources, LLC

Verification Report

December 21, 2011

ICF Consulting Canada, Inc.

2600 – 144 Fourth Avenue SW

Calgary, AB T2P 3N4

This page intentionally blank

Statement of Verification

December 21, 2011

Alberta Environment and Water

12th Floor, Baker Centre

10025 – 106 Street

Edmonton, Alberta T5J 1G4

Scope

NextEra Energy Resources, LLC (“Responsible Party”) engaged ICF Consulting Canada, Inc. (“ICF Marbek”)

to review their Notice of Creation of Emission Reduction Credits and supporting evidence, covering the period

January 1 to October 31, 2011 (“GHG Assertion”). The GHG Assertion, dated December 19, 2011

supersedes a previous GHG Assertion dated December 8, 2011, and specifies a claim for 91,856 tonnes CO2e

over the aforementioned period, which resulted from the generation of electricity from wind resources. The

claim consists exclusively of 2011 vintage credits.

The Responsible Party is responsible for the preparation and presentation of the information within the GHG

Assertion. Our responsibility is to express a conclusion as to whether the GHG Assertion is presented fairly in

accordance with Alberta Environment and Water’s approved Quantification Protocol for Wind Powered

Electricity Generation, March 2008, Version 1 (“Protocol”) for this project; the Specified Gas Emitters

Regulation (Alta. Reg.139, 2007) (“Regulation”), and the associated guidance documents.

Methodology

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 reasonable, rather than absolute assurance with respect to the

GHG Assertion. Our review criteria were based on the Protocol; the Regulation, and the associated guidance

documents. We reviewed the Offset Project Plan for Ghost Pine Wind Power Project, December 2011, Version

1.2; the Offset Project Report for Ghost Pine Wind Power Project, December 2011, Version 1.2; the GHG

Assertion; and associated documentation. This Verification Statement supersedes the Verification Statement

contained in the Ghost Pine Wind Power Project Verification Report issued December 12, 2011. We believe

our work provides a reasonable basis for our conclusion.

Conclusion

Based on our review, it is our opinion to a reasonable level of assurance that the GHG emission reduction

contained in the GHG Assertion is presented fairly in accordance with the relevant criteria.

Chris Caners, P.Eng. Duncan Rotherham

Professional Engineer, Ontario (100113719) Vice President, ICF Consulting Canada, Inc.

Lead Verifier, ICF Consulting Canada, Inc.

Toronto, Ontario

Verification Report NextEra Energy Resources, LLC


ICF Marbek Page 1

1 Verification Summary

Lead Verifier: Chris Caners, P.Eng.

Peer Reviewer: Aaron Schroeder, P.Eng.

Verification Timeframe: November – December, 2011

Objective of the verification: Reasonable level of assurance on GHG Assertion for Offset Credits

Assurance being provided to: Alberta Environment and Water

Standard being verified to: ISO 14064-3 (ISO, 2006)

Verification criteria employed: Specified Gas Emitters Regulation, Alta. Reg.139, 2007;

Technical Guidance for Offset Project Developers, v.2, January 2011;

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

Verification scope – Gases: Carbon Dioxide, Methane, Nitrous Oxide

Project: Ghost Pine Wind Power Project

Location(s): Kneehill County, Alberta

Emission Reduction

Temporal period: January 1, 2011 to October 31, 2011

Main Contact Chris Caners, P.Eng.

(Verifier): Manager, ICF Consulting Canada, Inc.

808 – 277 Wellington Street West

Toronto, ON M5V 3E4

[email protected]

Main Contact John Goodwin

(Responsible Party): NextEra Energy Resources LLC

700 Universe Boulevard

Juno Beach, FL 33408

[email protected]



ICF Marbek Page 2

2 Project Information

NextEra Energy Resources LLC (“NextEra”) has developed the necessary documentation detailing project

activities to support their claim for emission reductions to be registered on the Alberta Offset Registry under

Alberta’s Specified Gas Emitters Regulation. NextEra engaged a third-party consultant, SOLAS Energy

Consulting Inc. (“Solas”) to prepare the quantification of the emission reductions from the Ghost Pine Wind

Power Project and the associated documentation. NextEra has engaged ICF Consulting Canada, Inc. (“ICF

Marbek”) to provide a third-party verification of the emission reduction asserted by NextEra related to the

project activities discussed herein.

The Ghost Pine Wind Power Project (“Project”) covered by this verification engagement involves the creation

of 2011 vintage emission reductions achieved through the generation of electricity from a facility consisting

of 51 turbines that convert wind energy into electrical energy as the end product. Emission reductions are

quantified based on the generation of an equivalent quantity of electricity from fossil fuel based sources. The

Project is located in Kneehill County, Alberta.

The quantification of the emission reductions associated with the project is defined by Alberta Environment

and Water’s (“AEW”) Quantification Protocol for Wind Powered Electricity Generation, March 2008, Version

1 (“Protocol”). The Notice of Creation of Emission Reductions, dated December 19th, 2011 describes the

emission reduction claim (“GHG Assertion”) made by NextEra related to this project.

The Project is owned by Ghost Pine Windfarm L.P., with the General Partner of Fortuna GP, Inc. Fortuna GP,

Inc. is a wholly owned subsidiary of NextEra Energy Canada, ULC (formerly known as FPLE Canadian Wind,

ULC). NextEra Energy Canada, ULC is an indirect, wholly owned subsidiary of NextEra Energy Resources, LLC.

This is the first year in which ICF Marbek has been engaged by NextEra for verification services resulting from

the Project.

This document describes the terms and scope of this verification. It serves to communicate the findings of the

verification.

3 Verification Execution

The scope of the verification was defined during the verification planning stage and is detailed in the

Verification Plan, which is appended to this document. The verification plan also describes ICF Marbek’s

verification process that was executed through the course of the verification. The specific verification

procedures that were planned and executed are described in the attached Sampling Plan.

3.1 Site Visit

The site visit was conducted by Chris Caners, P.Eng.; he was accompanied on the site visit by Paula

McGarrigle, Managing Director of Solas.

The site visit was a key step in planning and executing the verification. During the course of the site tour, ICF

Marbek interviewed key site operations personnel regarding the operations and data management of the

facility.

NextEra staff interviewed included:

Stephen Young, Associate Wind Site Manager

Solas staff interviewed included:

Paula McGarrigle, Managing Director



ICF Marbek Page 3

The site visit included a review to identify and categorize all greenhouse gas emission sources and sinks in the

Project through a review of electrical systems, mechanical equipment (e.g. trucks and generators)

measurement equipment and diagrams, data management activities, and fuel invoices followed by physical

observation of the wind farm, including meteorological towers and individual turbines.



ICF Marbek Page 4

3.2 Data Management and Control System Review

The verification team developed a thorough knowledge of the data management and control systems utilized in the Project through the review of

the Offset Project Plan, observation during the site visit and interviews with key Project personnel. The data flow diagram shown below outlines the

flow of project data.

B1 Electricity Generation

Diesel

Monthly Natural Gas

Invoices

P1 Facility Operation

AESO Monthly Settlement

Reports

(Generation)

P3 Fuel Extraction and Processing

Natural GasGasoline Electricity

Individual purchase

event (fueling

station)

Individual purchase

event (fueling

station)

Monthly Electricity

Invoices (2 Direct

Energy Meters)

AESO Monthly Settlement

Reports

(Consumption)

Diesel

Monthly Natural Gas

Invoices

Natural GasGasoline

Individual purchase event (fueling station)

receipts

Individual purchase event

(fueling

station)



ICF Marbek Page 5

4 Verification Results

4.1 Discrepancies

No immaterial or material discrepancies were noted in the GHG Assertion.

4.2 Aggregate Materiality

The sum of the immaterial discrepancies in the GHG Assertion does not result in a breach of materiality

(greater than 5% of the total GHG Assertion).

4.3 Other Findings

This Verification Statement and Report supersedes the Ghost Pine Wind Power Project Verification Statement

and Report issued December 12, 2011. During the process of registering the emission reductions detailed in

that report, the Responsible Party determined that Renewable Energy Credits had already been registered on

the Western Renewable Energy Generation Information System for the same activity and overlapping

vintages. As a result, the Responsible Party underwent a process to de-register those Renewable Energy

Credits. Confirmation of de-registration was provided to the Verification Team, and the current report was

updated to reflect the re-issued OPP, OPR and NOC as detailed above.

Through the course of the verification, the data management systems and controls employed in the

quantification of emissions at the facility were reviewed, as detailed in the Sampling Plan procedures. These

systems were found to be effective in the calculation of the GHG Assertion.



ICF Marbek Page 6

5 Verification Team

Since 1969, ICF International has been serving major corporations, all levels of government, and multilateral

institutions. Globally, approximately 400 of our 4,000 employees are dedicated climate change specialists,

with experience advising public and private-sector clients. ICF International has earned an international

reputation in the field of climate change consulting for its analytical rigour, in-depth expertise, and technical

integrity through scores of GHG emissions-related assignments over the past two decades.

Within Canada over the past 10 years, ICF Consulting Canada, Inc. (“ICF Marbek”), a fully owned subsidiary

of ICF International, has carried out numerous facility-level GHG verifications and verifications of emission

reduction projects. ICF Marbek has developed the necessary internal controls to ensure qualified and

competent staffing uphold the principles of the relevant standard while quality control processes are utilized

to assure data integrity is maintained and safeguarded. ICF Marbek’s clients choose ICF Marbek for its strong

brand, technical expertise, and rigorous methodological approach.

ICF Marbek has assembled a Verification Team consisting of experienced greenhouse gas verifiers and

relevant technical experts.

Lead Verifier

Chris Caners is a Professional Engineer in the Provinces of Ontario and Saskatchewan, and holds a Master of

Science in Engineering from Queen’s University, as well as a Bachelor of Applied Science from the University

of Toronto. He has completed supplementary verification training, receiving a certificate of training for ISO

14064. Chris has acted as the lead verifier for numerous facilities under Alberta’s Specified Gas Emitters

Regulation, including natural gas compressor stations, cogeneration plants, and SAGD facilities. Chris has also

lead third party assurance and reassurance engagements for several offset projects under the Alberta Offset

System, including wastewater treatment, aerobic composting, acid gas injection, and energy efficiency.

Internal Peer Reviewer

Aaron Schroeder is a Professional Engineer in the Province of Alberta and holds a B.Sc. in Engineering from

the University of Saskatchewan. He has completed supplementary training in ISO 14064 as well as Auditing

and Assurance Engagements through the University of Toronto, School of Continuing Studies. Aaron has

acted as lead verifier on third-party assurance assignments for multiple compliance periods under Alberta’s

Specified Gas Emitters Regulation. These projects included work at SAGD facilities in Alberta’s oil sands, a

complex sour gas processing facility, two of Alberta’s largest natural gas pipelines and combined-cycle electric

generating facilities. Additionally, Aaron has completed numerous verifications as lead verifier for emission

reduction (offset) projects in agricultural tillage management, wind electricity generation, and acid gas

injection projects.



ICF Marbek Page 7

Statement of Qualifications

As the Lead Verifier and a Professional Engineer registered in the province of Ontario, I, Chris Caners, meet or

exceed the required qualifications described in Section 18 of the Specified Gas Emitters Regulation, including

the training requirements under ISO 14064.

The information contained within this document and this statement of qualifications, is complete and

correctly represents the qualifications of ICF Marbek and the members of the Verification Team described

herein. Dated this twenty-first day of December, two-thousand eleven.

Chris Caners, P.Eng. Duncan Rotherham

Professional Engineer, Ontario (100113719) Vice President, ICF Consulting Canada, Inc.

Lead Verifier, ICF Consulting Canada, Inc.

Toronto, Ontario



ICF Marbek Page 8

Appendices

Verification Plan

Sampling Plan

Conflict of Interest Statement

ICF Marbek Page 1

Verification Plan NextEra Energy Resources LLC – Ghost Pine Wind Power Project













Emission Reduction





Toronto, ON M5V 3E4

[email protected]





[email protected]

Verification Plan

ICF Marbek Page 2

1. Introduction

NextEra Energy Resources LLC (“NextEra”) has developed the necessary documentation detailing project activities to

support their claim for emission reductions to be registered on the Alberta Offset Registry under Alberta’s Specified

Gas Emitters Regulation. NextEra engaged a third-party consultant, Solas Energy Consulting (“Solas”) to prepare

the quantification of the emission reductions from the Ghost Pine Wind Power Project and the associated

documentation. NextEra has engaged ICF Consulting Canada, Inc. (“ICF Marbek”) to provide a third-party

verification of the emission reduction asserted by NextEra related to the project activities discussed herein.

The Ghost Pine Wind Power Project (“Project”) covered by this verification engagement involves the creation of

2011 vintage emission reductions achieved through the generation of electricity from a facility consisting of 51

turbines that convert wind energy into electrical energy as the end product. Emission reductions are quantified based

on the generation of an equivalent quantity of electricity from fossil fuel based sources. The Project is located in

Kneehill County, Alberta.

The quantification of the emission reductions associated with the project is defined by Alberta Environment and

Water’s (“AEW”) Quantification Protocol for Wind Powered Electricity Generation, March 2008, Version 1

(“Protocol”). The Notice of Creation of Emission Reductions, dated December 19th, 2011 describes the emission

reduction claim (“GHG Assertion”) made by NextEra related to this project.

The Project is owned by Ghost Pine Windfarm L.P., with the General Partner of Fortuna GP, Inc. Fortuna GP, Inc. is a

wholly owned subsidiary of NextEra Energy Canada, ULC (formerly known as FPLE Canadian Wind, ULC). NextEra

Energy Canada, ULC is an indirect, wholly owned subsidiary of NextEra Energy Resources, LLC.

This is the first year in which ICF Marbek has been engaged by NextEra for verification services resulting from the

Project.

This document describes the terms and scope of this verification. It serves to guide the verification team,

communicate the parameters of the verification to the indented users and inform the development of the

verification procedures described in the Sampling Plan.

2. Objective

The primary objective of this verification is to determine if the Project resulted in the greenhouse gas (“GHG”)

emission reduction reported in the Notice of Creation of Emission Reduction Credits and supporting information

(“GHG Assertion”). This assessment will be based on the verification criteria defined by the scope of the project.

3. Parties and Users

As defined in Section 2.15 of ISO 14064-3:2006, the individual or organization that has overall control and

responsibility for the GHG project is the “Project Proponent”. For this verification, NextEra is the Project Proponent.

ICF Marbek, the “Verifier,” has been engaged by NextEra to provide a third party verification of the emission

reduction.

The “Intended User,” is defined in Section 2.26 of ISO 14064-3:2006 as the individual or organization identified by

those reporting GHG-related information that relies on that information to make decisions. Alberta Environment

and Water is the primary intended user of the information contained within this verification.

Verification Plan

ICF Marbek Page 3

4. Scope

Boundaries

During the initial verification planning, the organizational boundaries and the sources, sinks and reservoirs (“SSRs”)

defined in the OPP were reviewed for conformity with the approved Protocol. The procedures utilized to review the

emission reductions reported in the GHG Assertion were designed to support a reasonable level of assurance. These

procedures systematically review:

the relevant power purchase, ownership and subsidy agreements entered into by NextEra;

the lease agreements between the land owners where the turbines (and peripheral equipment) are

situated;

the project activity covered by the quantification including electrical generation records;

the facility and related equipment (e.g. maintenance vehicles) covered by the quantification;

the systems utilized for recording, tracking and safeguarding the data associated with the

quantification;

the Offset Project Plan, the Offset Project Report and the Protocol; and,

the GHG Assertion.

Verification Criteria

The verification criteria employed in the development of the review procedures documented in the verification plan

include:

Climate Change and Emissions Management Act, S.A. 2003, c. C-16.7;

Alberta Specified Gas Emitters Regulation, Alta. Reg.139, 2007;


Quantification Protocol for Wind-Powered Electricity Generation v.1, March 2008;

Offset Project Report for Ghost Pine Wind Power Project, December 2011, Version 1.2

Offset Project Plan for Ghost Pine Wind Power Project, December 2011, Version 1.2

Notice of Creation of Emission Reduction Credits, December 19, 2011

Gases

The emission reduction accounts for three greenhouse gases: Carbon Dioxide, Methane and Nitrous Oxide.

Reporting Period

The GHG Assertion includes emission reductions occurring between January 1, 2011 and October 31, 2011.

5. Materiality

During the course of the verification procedures, individual errors, omissions or misrepresentations or the aggregate

of these discrepancies will be evaluated qualitatively and quantitatively. Materiality defines the level at which

discrepancies in the GHG Assertion or any underlying supporting information precludes the issuance of a limited

level of assurance.

The Lead Verifier, Lead Reviewer and Associate Verifiers (“Verification Team”) is responsible for determining if

qualitative discrepancies could adversely affect the GHG Assertion and subsequently influence the decisions of the

Intended User, in which case the discrepancy(ies) are deemed to be material.

Quantitative discrepancies will be calculated for each project within the aggregated project and in aggregate to

determine the percentage of the GHG Assertion that is affected. Alberta Environment and Water has defined

quantitative discrepancies as material if they represent error of greater than or equal to 5% of the GHG Assertion.

Verification Plan

ICF Marbek Page 4

All discrepancies that are outstanding at the conclusion of the verification are documented in the Verification Report

and classified on an individual basis as either material or immaterial.

Materiality Threshold

The materiality threshold is defined as 5% of the total reported reduction in the GHG Assertion. Note that the

materiality threshold may be breached by individual errors, or the sum of multiple errors.

6. Principles

ISO 14064-3:2006 defines six principles that should be upheld in the development of the GHG Assertion. These

principles “are intended to ensure a fair representation and a credible and balanced account of GHG emission

reductions and removal enhancements from projects” (ISO 14064-3:2006). The verification procedures developed

and executed during the course of this verification present evidence such that each of these principles is satisfied.

a. Relevance

Appropriate data sources are used to quantify, monitor or estimate emission sources. Appropriate minimum

thresholds are used to justify the exclusion or the aggregation of minor GHG sources or the number of data

points monitored.

b. Completeness

All emission sources identified in the Protocol are established in the OPP and all emissions in the Project are

included within the quantification.

c. Consistency

Uniform calculations are employed between the baseline and project condition and through the entire

crediting period. Emission calculations for each emission source are calculated uniformly. If more accurate

procedures and methodologies become available, documentation should be provided to justify the changes

and show that all other principles are upheld.

d. Accuracy

Measurements and estimates are presented, without bias as far as is practical. Where sufficient accuracy is

not possible or practical, measurements and estimates should be used while maintaining the principle of

conservativeness.

e. Transparency

Information is presented in an open, clear, factual, neutral and coherent matter that facilitates independent

review. All assumptions are stated clearly and explicitly and all calculation methodologies and background

material are clearly referenced.

f. Conservativeness

Appropriate parameters affecting the project’s emission sources are utilized in the calculation of the GHG

Assertion. When parameters or data sources are highly uncertain, the choice of parameter or data source to

be utilized results in an underestimation in the GHG Assertion (i.e. baseline emissions are under-estimated,

project emissions are overestimated).

7. Risk Assessment

There are three types of risk associated with the GHG Assertion defined in ISO 14064-3:

Inherent Risk

Control Risk

Detection Risk

Verification Plan

ICF Marbek Page 5

The assessed level of risk for this verification dictates the degree of rigour planned for the verification procedures

described in the accompanying Sampling Plan. A risk assessment was completed based on observations made

following an initial review of the OPP and OPR and interviews with key individuals responsible for the project.

The inherent risk relates to the likelihood that a material misstatement in the GHG Assertion will occur in the

absence of NextEra’s project controls. Because the project employs standard metering and monitoring approaches,

the inherent risk is minimized. Control risk relates to the likelihood that a material misstatement in the GHG

Assertion will not be prevented or detected by NextEra’s internal control systems. This is the first verification under

the Alberta Offset System for NextEra, which increases control risk; however, NextEra has engaged a third-party

consultant with experience in the Alberta Offset System. In addition, there are checks and balances imposed on the

project via external agencies, such as the Alberta Electricity System Operator, which helps to minimize this risk.

The detection risk is a measure of the risk that the verification evidence collected and reviewed will fail to detect

material misstatements, should such misstatements exists. Unlike inherent and control risk, which are typically

attributes of the project type and technologies employed therein, detection risk is variable and defined as being

inversely proportional to the inherent and control risk. Therefore the detection risk is maintained at a low level by

designing appropriate verification procedures. Given availability of electronic project data and the reasonable level

of assurance required, ICF Marbek will review all project calculations and the vast majority of original source

information.

8. Verification Schedule

The verification activities for this GHG assertion will be carried out over November and December, 2011. A site visit

to the project operations occurred on November 23, 2011. This visit included interviews with key personnel

(Stephen Young, NextEra and Paula McGarrigle, Solas), and included a review of the on-site electrical systems,

mechanical equipment (e.g. trucks, generators and other fossil-fuel consuming equipment) measurement equipment

(e.g. electrical utility meters, power conditioning equipment, MIDAS metering), measurement diagrams (single-line

electricity diagrams, data flow diagrams), data management activities (storage and safekeeping of Project data and

information). The site visit also included physical observation of the wind farm, including meteorological towers and

individual turbines.

9. Verification Procedures

The specific procedures utilized to gather evidence supporting the principles underlying the GHG Assertion are

described in the Sampling Plan.

ICF Marbek Page 1

Sampling Plan NextEra Energy Resources LLC – Ghost Pine Wind Power Project













Emission Reduction





Toronto, ON M5V 3E4

[email protected]





[email protected]

Sampling Plan

ICF Marbek Page 2

Objective:

The primary objective of completing verification procedures is to collect evidence in support of the principles and

quantification methodology underlying the emission reduction assertion made by NextEra Energy Resources LLC

(“Responsible Party”) and to reveal any material discrepancies in their Notice of Creation of Emission Reduction

Credits and supporting evidence (“GHG Assertion”), should they exist.

Testing Procedures:

This plan describes the testing procedures that will be utilized. The specific procedures are summarised in separate

tables for each process or activity involved in the quantification and reporting of the GHG emission reduction

assertion. Materiality is specified for each specific procedure. Aggregate materiality is determined separately.

The table on the following page provides information on the details that are included for each verification

procedure.

Summary of Procedures:

Project Boundaries

B1: Documentation of Boundaries

Ownership

O1: Confirmation of Ownership

Calculation

C1: Emission Reduction Calculation – Appropriate Methodology

C2: Emission Reduction Calculation – Calculation

Data Sources and Supporting Data

D1: Data Handling

Assertion:

A1: Greenhouse Gas Emission Reduction Assertion

A2: Offset Project Plan and Offset Project Report

Sampling Plan

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Procedure Definition Table Explained

Z1: Procedure Title

Introduction: This introduction serves to explain the reason the verification team has interest in the procedure described below. For instance the inclusion of all emission sources ensures that that quantification of the total direct emission satisfies the principle of completeness.

Type of Evidence The Type of Evidence can usually be grouped as: Physical Examination, Confirmation, Documentation, Observation, Inquiries of the Client, Reperformance, or Analytical Procedures.

Data Sources The Data Sources describes the form in which the evidence is presumed to be available to the verification team. Specific Documents or Assigned Positions, for example.

Objective (specific principles) The objective serves to focus the procedure as pursuant to one of the audit

principles of: Relevance, Completeness, Consistency, Accuracy, Transparency, or Conservativeness.

Specific Activities .1 The Specific Activities are outlined here.

Potential Error Conditions The anticipated Potential Error Conditions are listed here to aid the verification team;

As the sampling plan is a living document until the end of the verification process additional error conditions may be identified during the execution of the procedures.

Sample Unit The Sample Unit describes the individual record unit required to define the

Sample Size.

ie. one parcel of land

Sample Size The Sample Size represents the original planned depth of the sampling, as a percent.

ie. 15% of the monthly project data

Materiality Threshold Two options exist for the definition of the Materiality Threshold;

A Quantitative description describing the threshold in tonnes, .eg. 5% of the emission reduction assertion;

A Qualitative statement where the nature of the error not a quantitative one. eg. Qualitative errors will be reviewed on a case by case basis for materiality.

Sampling Plan

ICF Marbek Page 4

Project Boundaries

B1: Documentation of Boundaries

Type of Evidence Documentation, Observation, Inquiries of the Client

Data Sources Offset Project Plan for Ghost Pine Wind Power Project, December 2011,

Version 1.2 (“OPP”); Offset Project Report for Ghost Pine Wind Power

Project, December 2011, Version 1.2 (“OPR”), Quantification Protocol for

Wind-Powered Electricity Generation v.1 (“Protocol”)

Objective (specific principles) Completeness, Relevance

Specific Activities .1 Compare each emission source listed in the OPP to those listed in the Protocol, identify and evaluate any discrepancies against ISO 14064, and consider applicability of each to the project.

.2 Review evidence supporting Protocol Applicability criteria to Project

.3 Confirm that all relevant sources are included in the project document

Error Conditions Source defined in Protocol was wrongfully excluded in OPP

Insufficient evidence to prove applicability of Protocol to Project

Divergence from Protocol without appropriate justification or non-conformance with the principles of ISO 14064.

Sample Unit Emission sources in Protocol and OPP

Sample Size All sources.

Materiality 5% of the total GHG Assertion. Qualitative discrepancies will be evaluated on a case by case basis for materiality.

Sampling Plan

ICF Marbek Page 5

Ownership

O1: Confirmation of Ownership

Type of Evidence Documentation, Inquiries of the Client

Data Sources Land Title Documents; Wind Farm Lease Agreements; Contractual Sales, Subsidy and Ownership Agreements; Environmental Permits; De-listing and De-Registration information from Western Renewable Energy Generation Information System

Objective (specific principles) Transparency, Completeness

Specific Activities .1 Review ownership documents proving Responsible Party has full ownership in wind turbine equipment

.2 Ensure temporal coverage of ownership documents

.3 Confirm that environmental attributes have not been otherwise sold or transferred

Error Conditions Missing or unclear documentation

Incorrect identification of legal entities covered by contract

Expired documentation

Environmental attributes previously sold

Sample Unit Individual agreements/contracts

Sample Size All relevant agreements/contracts.

Materiality Any errors in ownership information could result in material errors. Case by case evaluation required.

Sampling Plan

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Calculation

C1: Emission Reduction Calculation – Appropriate Methodology

Type of Evidence Documentation

Data Sources Protocol, OPP, OPR, Emissions Reductions Calculator (spreadsheets)

Objective (specific principles) Completeness, Consistency, Conservativeness, Accuracy

Specific Activities .1 Review of conformance to quantification guidance in Protocol

.2 Review use of any contingent data collection procedures

.3 Review use and application of any Flexibility Mechanisms

.4 Review and confirm applicability and sources of emission factors applied.

Error Conditions Undocumented deviations from prescribed methodology

Incorrect use of contingent data collection procedures prescribed methodology

Use of a Flexibility Mechanism without justification or incorrect use.

Sample Unit Equations and data sources used to quantify emission sources

Sample Size All emission sources


C2: Emission Reduction Calculation – Recalculation

Type of Evidence Re-performance, Analytical procedures, Documentation

Data Sources OPP, OPR, Emissions Reductions Calculators, Alberta Electric System Operator (AESO) Settlement Reports and Database, Natural Gas Utility Invoices, Fuel Receipts (Diesel and Gasoline), Electricity Utility Invoices

Objective (specific principles) Accuracy, Conservativeness

Specific Activities .1 Review and compare data supporting calculated emission reductions with original/independent data

.2 Re-performance of emission reductions from original/independent data

Error Conditions Missing or incomplete data sets

Non-conservative use of available data sources

Inaccurate or out-dated estimation data/techniques

Sample Unit Hourly energy delivered to grid (AESO database), AESO Monthly Settlement Reports, monthly natural gas invoices, all electricity invoices, two months of diesel and gasoline invoices.

Sample Size All AESO data, all natural gas invoices, all electricity invoices, two months of diesel and gasoline invoices.


Sampling Plan

ICF Marbek Page 7

Data Sources and Supporting Data

D1: Data Handling

Type of Evidence Documentation, Observation, Inquiries of the Client, Reperformance, Analytical Procedures

Data Sources Interviews, OPP, OPR, Emissions Reductions Calculator

Objective (specific principles) Accuracy, Transparency, Conservativeness

Specific Activities .1 Interview parties responsible for quantifying associated emission reductions

.2 Confirm appropriate meter calibration/verification

.3 Assess availability and safekeeping of original data

Error Conditions Transcription errors

Missing or incomplete data sets

Uncontrolled access to project data

Sample Unit Hourly energy delivered to grid (AESO database), AESO Monthly Settlement Reports, monthly natural gas invoices, all electricity invoices, two months of diesel and gasoline invoices.

Sample Size All AESO data, all natural gas invoices, all electricity invoices, two months of diesel and gasoline invoices.


Sampling Plan

ICF Marbek Page 8

Assertion

A1: Greenhouse Gas Emission Reduction Assertion

Type of Evidence Documentation

Data Sources Notice of Creation dated December 19, 2011, Emission Reductions Calculator, AEW Guidance

Objective (specific principles) Accuracy, Conservativeness

Specific Activities .1 Review emission reductions asserted in Notice of Creation as compared to quantified reductions

.2 Compare language in notice of creation to requirements of AEW

Error Conditions Disagreement with calculated and asserted values

Language inconsistent with requirements of AEW

Non-conservative rounding of final asserted quantity

Sample Unit Notice of Creation

Sample Size Entire Notice of Creation.

Materiality Any discrepancies

A2: Offset Project Plan and Offset Project Report

Type of Evidence Physical Examination, Confirmation, Documentation, Observation, Inquiries of the Client

Data Sources OPP, OPR, Facility Operators, Consultants (SOLAS Energy Consulting Inc.), Protocol, AEW Guidance

Objective (specific principles) Completeness, Consistency, Accuracy, Transparency

Specific Activities .1 Review OPP and OPR for completeness (conformance with documentation requirements)

.2 Review OPP and OPR for transparency, accuracy and consistency with other documentation

Error Conditions Document is not in conformance with requirements of AEW

Document is inconsistent with other available information

Inaccurate or unclear information

Sample Unit OPP, OPR

Sample Size All contents of reports.

Materiality Any discrepancies will be evaluated on a case-by-case basis.

Conflict of Interest Checklist

Question Yes No

1. Can the verifying organization or the verification team members directly benefit from a financial

interest in the Project Developer or the Project Developer’s Project?

X

For example: • Owning shares of the Project Developer; • Having a close business relationship with the Project Developer; • Contingent fees relating to the results of the engagement; • Potential employment with the Project Developer; or • Undue concern about the possibility of losing the verification or other fees from the Project Developer.

2. Can the verifying organization or verification team members be in a position of assessing their own

work?

X

For example: • Involvement of the verification organization in the compilation of the data contained in the GHG assertion. • Involvement of the verification organization in the development of a quantification protocol other than protocol recognized or recommended by the regulatory authority.

• A verification organization member performing non-verification services that directly impinge on the client’s GHG assertion, such as implementing the GHG data management system, or having performed validation services on the project being reviewed; • A member of the verification engagement team having previously been a GHG data compiler of the Project Developer or who was employed by the Project Developer in a position to exert direct and significant influence over the Project Developer's GHG assertion being verified.

3. Does the verifying organization or a member of the verification team, or a person in the chain of

command for the verification, promote or be perceived to promote, a Project Developer's position or

opinion to the point that objectivity may, or may be perceived to be, compromised?

X

For example: • Dealing in, or being a promoter of, GHG credits on behalf of a Project Developer; or • Acting as an advocate on behalf of the Project Developer in litigation or in resolving disputes with third parties.

4. Is one or more of the verification team too sympathetic to the Project Developer's interests by virtue of

a close relationship with a Project Developer, its directors, officer or employees?

X

For example: • A person on the verification team has a close personal relationship with a person who is in a senior GHG compilation role at the Project Developer; or • The verification team or a person of influence on the verification team has accepted significant gifts or hospitality from the Project Developer.

5. Is a member of the verification team or a person in the chain of command is deterred from acting

objectively and exercising professional skepticism by threats, actual or perceived, from the directors,

officers or employees of the Project Developer.

X

For example: • The threat of being replaced as a third party verifier due to a disagreement with the application of a GHG quantification protocol;

• Fees from the Project Developer represent a large percentage of the overall revenues of the verifying organization. • The application of pressure to inappropriately reduce the extent of work performed in order to reduce or limit fees; or • Threats of litigation from the Project Developer.

The declaration made in this statement is correct and truly represents ICF Consulting Canada Inc. and the members of the verification team. Dated this twenty-first day of December, 2011.

Chris Caners, P.Eng. Duncan Rotherham Professional Engineer, Ontario (100113719) Vice President, ICF Consulting Canada, Inc. Lead Verifier, ICF Consulting Canada, Inc. Toronto, Ontario