verification report for the magrath and chin chute …

VERIFICATION REPORT FOR THE MAGRATH AND CHIN CHUTE WIND POWER PROJECTS (2016)

Prepared for: Suncor Energy Inc. c/o Blue Source Canada ULC Suite 700, 717-7th Ave SW Calgary, AB T2P 0Z3

Prepared by: Stantec Consulting Ltd. 400-655 Tyee Road Victoria BC V9A 6X5

Project Number: 123220447 March 3, 2017


March 3, 2017

E.1

EXECUTIVE SUMMARY

A summary of the verification of the Magrath and Chin Chute Wind Power Projects (the Project) for the period of January 1, 2016 to December 31, 2016 is provided in Table E.1.

Table E.1 Verification Summary Project Name Magrath and Chin Chute Wind Power Projects

Project Start Date • Magrath Project: October, 2004 • Chin Chute Project: November, 2006

Credit Start Date • Magrath Project: January 1, 2005 (start of 5-year extension is January 1, 2013) • Chin Chute Project: May 1, 2007 (start of 5-year extension is May 1, 2015)

Credit Duration Period • Magrath Project: January 1, 2005 – December 31, 2017 • Chin Chute Project: May 1, 2007 – April 30, 2020

Verification Period January 1, 2016 – December 31, 2016

Expected Lifetime of the Project

• Magrath Project: Over 25 years • Chin Chute Project: Over 25 years

Authorized Project Proponent

Kelsey Lank, Carbon Solutions Analyst Blue Source Canada ULC Suite 700, 717-7th Ave SW Calgary, AB T2P 0Z3 Phone: (403) 262-3026 x228 Email:[email protected] Web: http://www.bluesourcecan.com


March 3, 2017

E.2

Table E.1 Verification Summary Applicable Quantification Protocol

Quantification Protocol for Wind-Powered Electricity Generation (version 1.0, March 2008)

Ownership The Project is owned by Enbridge Wind Power General Partnership (Enbridge), Acciona Wind Energy Canada Inc. (Acciona), and Suncor Energy Inc. (Suncor). The Project is operated by Acciona. Suncor has been authorized to act on behalf of the other two partners and will register all applicable emission reduction credits from the Project. On January 1, 2017, Suncor Energy Products Inc. (SEPI) amalgamated with Suncor Energy Inc. The resulting entity is Suncor Energy Inc.

Other Environmental Attributes

This Project is not generating Renewable Energy Certificates (RECs) or other environmental benefits/attributes.

Project Registration The Project is registered under the Canadian Standards Association (CSA) Group Alberta Offset Registry.

GHG Assertion The fundamental assertions to be verified are: • Magrath Project - the creation of 53,127 t CO2e in GHG emission reductions for

the period of January 1 – December 31, 2016 resulting from the production of electricity using wind turbines instead of fossil fuel combustion at the Magrath Power Project, located near Magrath, AB; and

• Chin Chute Project - the creation of 56,576 t CO2e in GHG emission reductions for the period of January 1 – December 31, 2016 resulting from the production of electricity using wind turbines instead of fossil fuel combustion at the Chin Chute Power Project, located near Taber, AB.

Level of Assurance The Specified Gas Emitters Regulation (SGER) and Alberta Environment and Parks (AEP) require the verifier to conduct sufficient procedures to deliver a reasonable level of assurance. The verification was planned and executed accordingly.

Verification Criteria • Climate Change and Emissions Management Act (the Act), SA 2003, c C-16.7; • Specified Gas Emitters Regulation, Alta Reg. 139/200, with amendments up to

and including Alberta Regulation 104/2015 (Regulation); • Technical Guidance for Offset Project Developers (version 4.0, February 2013); • Quantification Protocol for Wind-Powered Electricity Generation (version 1.0,

March 2008); and • The Carbon Offset Emission Handbook (March 2015, V1.0).

Verification Objective The objective of the verification was to assess whether the Project Reports dated February 23, 2017 and the GHG Assertions satisfy the following AEP requirements: • Climate Change and Emissions Management Act; • Specified Gas Emitters Regulation; • Technical Guidance for Offset Project Developers (version 4.0, February 2013); • Quantification Protocol for Wind-Powered Electricity Generation (version 1.0,

March 2008); • The Carbon Offset Emission Handbook (March 2015, V1.0).


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E.3

Table E.1 Verification Summary Verification Standards The verification was conducted in accordance with ISO 14064:3, ISO 14065, and

guidance contained within the Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance, January 2013, version 1.0.

Project Activity For the verification period the Project activities are eligible under the SGER to generate offsets as they meet the following conditions. • Result from actions taken on or after January 1, 2002 – the Project began

operation after this date. • Be real, demonstrable, and quantifiable – the Project has been verified

according to the Verification Criteria above. • Not be required by law – the Project is not required by any current or proposed

law. • Have clearly established ownership – the Project Developer has provided

sufficient and appropriate evidence that Suncor Energy Inc. owns the offset credits generated by the Magrath and Chin Chute Wind Power Projects and that the joint venture partners of the Projects acknowledge that Suncor Energy Inc. is serializing the credits on their behalf.

• Be counted once for compliance purposes – the Project offset credits are serialized on the Alberta Emission Offset Registry (AEOR).

• Be verified by a qualified third party – Stantec is a qualified third party (see Section 1.0, 3.1 and Statement of Qualifications).

• Have occurred in Alberta – the Project is physically located in Alberta.

Verification Summary No unresolved material misstatements were identified in the Project Reports dated February 27, 2017 and the GHG Assertions as submitted. The GHG Assertions for the Projects are deemed to be fairly presented and substantiated by sufficient and appropriate evidence. A reasonable level assurance verification statement for each Project was issued.

Verification Team

Lead Verifier Daniel Hegg, M.Sc., CEM

Designated Signing Authority and Quality Reviewer

Michael Murphy, P.Eng. (formerly Vicki Corning, P.Eng.)

Project Manager Daniel Hegg, M.Sc., CEM

Independent Peer Reviewer

Nicole Flanagan, M.A.Sc., P.Eng.

Verifiers Orasa Webber, M.Eng.; Christina Varner, P.Eng.

Verification Timeframe October 2016 to March 2017

Site Visit Date November 17, 2016

Report Date March 3, 2017


March 3, 2017

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TABLE OF CONTENTS

EXECUTIVE SUMMARY ........................................................................................................................ E.1

1.0 INTRODUCTION ......................................................................................................................... 1 1.1 INTENDED USER .............................................................................................................................. 1 1.2 PROJECT DESCRIPTION ................................................................................................................. 1

1.2.1 Location ....................................................................................................................... 1 1.2.2 Processes and Activities............................................................................................. 2 1.2.3 Summary of Changes ................................................................................................ 3

1.3 GHG ASSERTION ............................................................................................................................ 3

2.0 VERIFICATION METHODOLOGY ............................................................................................... 5 2.1 VERIFICATION OBJECTIVES ........................................................................................................... 5 2.2 LEVEL OF ASSURANCE .................................................................................................................. 5 2.3 VERIFICATION CRITERIA ................................................................................................................ 5 2.4 VERIFICATION STANDARDS .......................................................................................................... 5 2.5 VERIFICATION SCOPE ................................................................................................................... 5 2.6 MATERIALITY ................................................................................................................................... 6 2.7 VERIFICATION PLAN ...................................................................................................................... 6

3.0 VERIFICATION TEAM: QUALIFICATIONS, ROLES AND RESPONSIBILITIES ................................. 7 3.1 STATEMENT OF COMPLIANCE WITH THE SGER ........................................................................... 8

4.0 VERIFICATION STRATEGY .......................................................................................................... 9 4.1 INHERENT RISK ................................................................................................................................ 9 4.2 CONTROL RISK ............................................................................................................................... 9 4.3 DETECTION RISK ........................................................................................................................... 10 4.4 SITE VISIT ........................................................................................................................................ 11 4.5 VERIFICATION PROCEDURES ...................................................................................................... 11 4.6 CONFIRMATIONS ......................................................................................................................... 12

5.0 SUMMARY OF FINDINGS ......................................................................................................... 13

6.0 CONCLUSION ......................................................................................................................... 19 6.1 OPINION ....................................................................................................................................... 19 6.2 SUBMISSION DOCUMENTS .......................................................................................................... 19

7.0 CLOSURE ................................................................................................................................. 20


March 3, 2017

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LIST OF TABLES

Table E.1 Verification Summary ...............................................................................................E.1 Table 1.1 GHG Assertion ............................................................................................................. 4 Table 3.1 Verification Team ....................................................................................................... 7 Table 4.1 Schedule of Verification Activities ......................................................................... 11 Table 5.1 Verification and Sampling Plan .............................................................................. 13 Table 5.2 Identified Misstatements and Resolutions ............................................................. 17 Table 5.3 Unresolved Misstatements ....................................................................................... 18

LIST OF APPENDICES

Appendix A Final Verification Plan Appendix B Submission Documents


Introduction March 3, 2017

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1.0 INTRODUCTION

Stantec Consulting Ltd. (Stantec) was contracted by Blue Source Canada ULC (Blue Source) on behalf of Suncor Energy Products Inc. (now Suncor Energy Inc., herein referred to as Suncor) to conduct an independent third-party verification of the greenhouse gas (GHG) Assertions provided in the Magrath Wind Power Project Report (version 4) dated February 27, 2017 and the Chin Chute Wind Power Project Report (version 5) dated February 27, 2017. The Magrath and Chin Chute Wind Power Projects were verified simultaneously and are referred to as the Projects in this report.

It is understood that the Projects are owned by Enbridge Wind Power General Partnership (Enbridge), Acciona Wind Energy Canada Inc. (Acciona), and Suncor. Suncor has been authorized to act on behalf of the other two partners and will register all applicable emission reduction credits from the Project. The Project is operated by Acciona (Facility Operator). Blue Source was responsible for the completion of the calculations, presentation of the information within the Project Reports, and for the supporting technical documents.

Stantec was responsible for planning and executing the verification to deliver an opinion to a reasonable level of assurance as to whether the Project Reports and GHG Assertions are presented fairly and in accordance with the verification criteria. Stantec is a qualified third party verifier, as defined in Section 18 of the Specified Gas Emitters Regulation SGER. Stantec is accredited with the American National Standards Institute (ANSI), a member of the International Accreditation Forum (IAF), in accordance with ISO 14065 (Accreditation ID #0805 issued to Stantec Consulting Ltd. for greenhouse gas (GHG) verification and validation).

1.1 INTENDED USER

This report has been prepared for Alberta Environment and Parks (AEP) for the express purpose of facilitating the creation of Emission Reduction Credits (ERCs) under the Climate Change and Emissions Management Act and the SGER.

1.2 PROJECT DESCRIPTION

1.2.1 Location

The Magrath Wind Power Project is located approximately 6 km west of Magrath, Alberta. The Chin Chute Wind Power Project is located approximately 15 km southwest of Taber, Alberta.



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1.2.2 Processes and Activities

The Projects, as defined in their Project Plans, involves the creation of offset credits from the generation of electricity using wind rather than fossil fuels.

• The Magrath Wind Power Project consists of twenty (20) 1.5 MW wind turbines for a total installed capacity of 30 MW. The Project includes a substation and underground transmission lines connecting the turbines to the substation. There is no electricity storage system on-site. The Project is located approximately 6 km west of Magrath, Alberta.

• The Chin Chute Wind Power Project consists of twenty (20) 1.5 MW wind turbines for a total installed capacity of 30 MW. The Project includes a substation and an underground transmission lines connecting the turbines to the substation. There is no electricity storage system on-site. The Project is located approximately 15 km southwest of Taber, Alberta.

Greenhouse gas emissions during Project operation at each site result from electricity use and fossil fuel combustion. The Projects share a fleet of vehicles, office space in Lethbridge, Alberta, and switchyard equipment (Project emissions from those sources are assigned to each Project equally). Electricity consumption and production are metered by third parties. Natural gas and gasoline volumes are metered by third parties. Indirect emissions from the extraction and processing of the fuel used by each Project are included in the Project emissions.

The following GHGs were included within the scope of the verification as required by the SGER:

• carbon dioxide (CO2); • methane (CH4); • nitrous oxide (N2O); • hydrofluorocarbons (HFCs); • perfluorocarbons (PFCs); and • sulphur hexafluoride (SF6).

The total equivalent GHG emissions are reported as tonnes of carbon dioxide equivalents (t CO2e).

Sources of Project GHG emissions for the Projects include:

• Natural Gas Combustion (CO2, CH4, and N2O): for space heating for the two Lethbridge offices; • Mobile Fuel Combustion (CO2, CH4, and N2O): for on-site gasoline vehicles and diesel-fueled cranes

for maintenance. • Fuel Extraction & Processing (CO2, CH4, and N2O, presented as CO2e): indirect emissions associated

with the extraction and processing of fossil fuel resources for gasoline, natural gas, and diesel fuels used in the above sources.

• Electricity Consumption (CO2, CH4, and N2O, presented as CO2e): consumption of electricity from the Alberta grid to run the Projects, including the offices.



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Sources of baseline GHG emissions included:

• Electricity Production (CO2, CH4, and N2O, presented as CO2e): emissions from fossil fuel combustion to produce an equivalent amount of electricity as wind power electricity (during the crediting period) which would have happened in the absence of the Projects.

Emission reductions are calculated as the difference between the baseline emissions and Project emissions.

1.2.3 Summary of Changes

The Magrath Wind Power Project reached the end of its eight year crediting period on December 31, 2012 and received a crediting period extension until December 31, 2017.

The Chin Chute Wind Power Project reached the end of its eight year crediting period on April 30, 2015 and received a crediting period extension until April 30, 2020.

For both Projects, the following changes to the baseline and Project scenarios have been made since the offset project start date:

• GWPs updated to the IPCC 2007 values of 1, 25, and 298 for CO2, CH4, and N2O, respectively. • Reference for the natural gas higher heating value (HHV) has been updated (the value remains

unchanged). • Electricity production and consumption factors have been updated as per AEP’s Carbon Offset

Emissions Factors Handbook. • As of July 1, 2015, the lease of Bay 26 was terminated and Suncor entered into a lease of office

space at 3815 9th Ave N, Lethbridge which is next to and adjoining the current office space at 3825 9th Ave N, Lethbridge. Electricity and natural gas continue to be metered by third parties for these offices.

• The electricity production meter numbers for Chin Chute and for Magrath were noted in the Project Reports to be inconsistent with the meter number in the Offset Project Plans for the 2015 reporting year. This is an administatrative clarification only.

For the Chin Chute Project, Blue Source noted that there was a difference between the wind farm grid electricity consumption retrieved from AESO and the Rodan metered values. Because the Rodan metered electricity consumption was higher than the data retrieved from AESO, Blue Source used the Rodan metered data in the calculation. The difference in the two data sources has an immaterial effect on the emissions reduction.

1.3 GHG ASSERTION

The fundamental assertion being verified is that the Project Reports and GHG Assertions, dated February 27, 2017, meet the verification criteria for the verification period of January 1, 2016 to December 31, 2016.



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The essential information contained within the Project Reports and GHG Assertions to be verified by Stantec is presented in Table 1.1. The units of the emissions are tonnes of carbon dioxide equivalent (t CO2e); further information on these units is provided in Section 2.5.

Table 1.1 GHG Assertion

Facility Year Baseline Emissions (t CO2e)

Project Emissions (t CO2e)

Emission Reductions

(t CO2e) Magrath Wind Power Project January 1 –

December 31, 2016 53,277 149 53,127

Chin Chute Wind Power Project 56,774 198 56,576 Total 110,051 347 109,703 Notes: *Emission Reductions are rounded down as per Guidance.


Verification Methodology March 3, 2017

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2.0 VERIFICATION METHODOLOGY

2.1 VERIFICATION OBJECTIVES

The objective of the verification was to assess whether the Project Reports dated February 27, 2017 and the GHG Assertions (as summarized in Table 2), satisfy the verification criteria identified in Section 2.3.

The verification was conducted in accordance with the verification standards identified in Section 2.4.

2.2 LEVEL OF ASSURANCE

The SGER and AEP require the verifier to conduct sufficient procedures to deliver a reasonable level of assurance. The verification was planned and executed accordingly.

2.3 VERIFICATION CRITERIA

Stantec has conducted sufficient and appropriate procedures in order to express a reasonable level of assurance opinion as to whether the Project Reports (dated February 27, 2017) and the GHG Assertions, satisfies the requirements of the:

• Climate Change and Emissions Management Act (the Act), SA 2003, c C-16.7; • Specified Gas Emitters Regulation, Alta Reg. 139/200, with amendments up to and including Alberta

Regulation 104/2015 (Regulation); • Technical Guidance for Offset Project Developers (version 4.0, February 2013); • Quantification Protocol for Wind-Powered Electricity Generation (V 1.0, March 2008); and • The Carbon Offset Emission Factors Handbook (March 2015, V1.0).

2.4 VERIFICATION STANDARDS

The verification was conducted in accordance with ISO 14064:3, ISO 14065:2013, and the Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance, January 2013, version 1.0 (Verification Guidance).

2.5 VERIFICATION SCOPE

The verification is for the Project period of January 1, 2016 to December 31, 2016.

The verification covers the specified gases under the Act and the SGER. These include carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), sulphur hexafluoride (SF6), hydrofluorocarbons (HFCs) and perfluorocarbons (PFCs). The total GHG emissions and reductions are reported as equivalent tonnes of carbon dioxide (t CO2e) emissions.


Verification Methodology March 3, 2017

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2.6 MATERIALITY

AEP has set the quantitative materiality threshold at 5% of the total reported GHG emission reductions or removals asserted. Materiality of qualitative misstatements are at the discretion of the verification body.

2.7 VERIFICATION PLAN

A copy of the final verification plan is provided in Appendix A. The activities described therein were executed during the course of the verification. The sampling plan, a subset of the verification plan, is outlined along with the final results in Section 5.0 of this report.


Verification Team: Qualifications, Roles and Responsibilities March 3, 2017

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3.0 VERIFICATION TEAM: QUALIFICATIONS, ROLES AND RESPONSIBILITIES

The verification team is identified in Table 3.1.

Table 3.1 Verification Team

Name Role Responsibilities

Daniel Hegg, M.Sc., CEM

Lead Verifier Lead desktop review, sampling plan execution and working paper completion, and prepare verification documentation.

Vicki Corning, P.Eng. Quality Reviewer Review initial verification plan for technical soundness and compliance with Stantec’s internal processes and AEP criteria.

Michael Murphy, PhD, P.Eng.

Quality Reviewer Due to timing constraints, Mike was the Quality Reviewer for the draft and final verification reports. Designated Signing Authority on the verification report.

Nicole Flanagan, P.Eng.


Independent review of verification activities and conclusions. The independent reviewer confirms the verification activities have been completed and that the activities provide the required level of assurance.

Christina Varner, P.Eng. Verifier Complete the desktop review, including sampling plan execution.

Orasa Webber, M.Eng. Verifier Lead site visit to Magrath and Chin Chute Wind Power Projects. Due to timing constraints, Michael Murphy was added to the project team to act as the Quality Reviewer for the Draft and Final verificiation reports. He will also act as the Designated Signing Authority. Dr. Murphy’s cameo is provided below for reference.

Dr. Mike Murphy, P.Eng., is a Senior Principal of Stantec Consulting Ltd. in Environmental Services and leads the company-wide Atmospheric Environment Group out of the Charlottetown, Prince Edward Island office. The Atmospheric Environment Group provides specialized services in Air Quality, Climate and Greenhouse Gases (including carbon footprinting), Acoustics (noise including environmental and building acoustics) and Lighting. Mike graduated from the University of Waterloo in 1987 with a PhD in Chemical Engineering, specializing in energy analyses, fluid modeling and boiling heat transfer. With more than 25 years of experience in Canada, USA and international (France, Italy, United Kingdom, Middle East), he has conducted studies on: emissions inventories of air pollutants, acid gases and greenhouse gases (GHGs), source emissions testing, dispersion modeling, ambient air quality, ambient noise/acoustics, odour, climate analysis, indoor air quality and provided support on several environmental assessments (EAs).

Dr. Murphy has completed the CSA ISO 14064-3 GHG verification training course and has prepared and presented papers on greenhouse gases and significance in environmental assessment. Mike has acted as a Senior Reviewer or Peer Reviewer on several GHG quantification, validation and verification projects. He provides internal training on the different aspects of Atmospheric Environment, and he has mentored senior students and given courses on air pollution, process safety, and mass and energy balances in the Department of Chemical Engineering at the University of New Brunswick.


Verification Team: Qualifications, Roles and Responsibilities March 3, 2017

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3.1 STATEMENT OF COMPLIANCE WITH THE SGER

Dr. Michael Murphy is the signing authority for the report. He is a professional engineer registered by the Association of Professional Engineers of the Province of Prince Edward Island, which satisfies Section 18(a)(ii)(A) of the SGER.

With respect to the technical knowledge required under Section 18(b)(i-iii), each member of the team has the required technical knowledge of GHG emission quantification methodologies and all have experience in completing third party GHG verifications. Please refer to the team profiles included in the verification plan in Appendix A.


Verification Strategy March 3, 2017

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4.0 VERIFICATION STRATEGY

Details of the verification activities undertaken as part of the verification strategy are set out in Table 4 (Verification Procedures) of the final Verification and Sampling Plan included in Appendix A and summarized in Section 5.0 of this report.

The Verification and Sampling Plan for the Project was developed considering our initial assessment of the verification risk for the engagement. We assessed the initial verification risk as Low1. Using the Verification and Sampling Plan, Stantec assessed the control procedures surrounding the GHG data and information. Important components included: processes for collecting, processing, consolidating and reporting GHG data and information; systems and processes that ensure GHG data accuracy, documenting and monitoring processes; methods to identify errors and methods to identify and report deficiencies in the reporting information and management system. Stantec verified equations used for quantification and monitoring purposes. These procedures included a site visit. Based on the results of the verification procedures undertaken, the final verification risk is deemed to be Low. This final risk assessment is shown based on the assessment of inherent, control and detection risk as follows.

4.1 INHERENT RISK

Inherent risk is the risk of error that occurs as a result of the lack of capacity by staff; the size/complexity of the organization or GHG Project; the industrial sector; and/or, the technologies or processes being applied in the organization or GHG Project. We regard the final risk as Low due to:

• the quantification of offset credits is completed by the third party company, Blue Source Canada, a company that has experience in offset project reduction quantification (low risk);

• this is the fifth verification conducted by Stantec for the Projects and the Project received a positive Statement of Verification for the past reporting periods (low risk); and

• the facility operation is simple and activity data used for quantification of the emission reductions for the Projects are based on third party utility invoices and third party metering reports (low risk).

4.2 CONTROL RISK

Control risk is the risk that the proponent’s control system will not detect and rectify a misstatement. We regard the final risk as Low due to:

• electricity generated by the wind turbines and consumed by wind turbines, substation, and transmission system for each Project is metered by the onsite revenue meters with the third party reports from Rodan Energy Solutions (Rodan) (low risk);

• electricity usage for the Lethbridge offices is metered by a third party (City of Lethbridge) with custody transfer meters (low risk);

1 Possible risk ratings are “high”, “medium” and “low”. These are based on inherent, control, and detection risks as evaluated

by the Project team during the initial desktop review.



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• natural gas usage for the Lethbridge offices is metered by a third party (Gas Alberta Energy) with custody transfer meters (low risk);

• gasoline for onsite fleet vehicles is metered by third parties, including UFA Co-op, at pump stations and volumes are summarized in the UFA report and receipts (low risk);

• crane working hours are tracked by the third party invoices for the work (low risk); and • emission factors are from recognized and appropriate sources (low risk).

4.3 DETECTION RISK

Detection risk is the risk that Stantec will not identify a material misstatement. We regard this risk as Low due to:

• Our Quality Management Procedures. We are committed to providing exceptional service to our clients in accordance with our ISO 9001 and ISO 14065 accreditations. We believe that quality is a basic principle and that quality management is an integral part of our work. We take a systematic approach to quality management to comply with requirements and to strive for continual improvement. The cornerstone of our quality management system is an entrenched process of quality and independent review where by our deliverables are vetted by senior and expert people in our firm (low risk).

• Level of Assurance. The reasonable level of assurance applied in this verification (as required by the Regulation) mandates that Stantec perform increased sampling to meet the assurance requirements, however, the level of assurance still increases the risk to Stantec as the risk-based verification approach means that not all information can be reviewed. Stantec has designed the sampling plan to target potentially material items in the GHG information to minimize detection risk (low risk).

The verification team assessed whether the Project resulted in emission reductions in a manner consistent with the Project Plan. During the verification, the verification team considered the level of audit risk noted above and incorporated necessary procedures to mitigate the audit risk. These procedures included:

• assessing conformance with applicable verification criteria, including the principles and requirements of relevant standards or GHG programs within the scope of verification;

• evaluating the establishment, justification and documentation of the Project Report; • assessing the GHG Project's quality assurance and controls; and • assessing the information for consistency with our knowledge of the operations.

The schedule for the verification activities is presented in Table 4.1.



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Table 4.1 Schedule of Verification Activities

Verification Activity Responsible Party Date of Completion

Kick-Off Meeting With Blue Source Stantec / Blue Source October 26, 2016

Provide Verification Plan to Blue Source Stantec November 15, 2016

Site Visits Stantec/Blue Source November 17, 2016

Receive Documentation for the Projects Blue Source February 13, 2017 – February 23, 2017

Initial Desktop Review Stantec February 13, 2017 – February 17, 2017

Draft Verification Report Stantec March 1, 2017

Address Follow-Up Items Stantec / Blue Source March 3, 2017

Finalize Verification Report and Statement of Verification Stantec March 3, 2017

4.4 SITE VISIT

Stantec Verifier, Orasa Webber, conducted site visits to the Magrath and Chin Chute Wind Power Proejcts on November 17, 2016. During the site visits, the following personnel were interviewed:

• Dave Siggelkow, Turbine Technician, Acciona; and • Larry Bester, Site Manager, Acciona.

The site visit involved a review of data collection, tracking, and retention and transfer procedures. Activities associated with operations, record keeping, data management and emissions sources were also reviewed to better understand the quantification calculations, data treatment and data management. Through interviews, and by attending the site visit, the site boundaries were assessed by the verifier to confirm their veracity. Stantec confirmed emission sources, sinks and reservoirs and assessed the potential for additional sources that were excluded.

4.5 VERIFICATION PROCEDURES

The verification team developed initial verification procedures and sampling plan during the initial desktop review, based on a review of the Project Report, Offset Plan, and available documentation and in consideration of the verification risk. The procedures were designed based on the Verification Guidance (e.g., tracing and recalculation). Over the course of the verification, the verification team considered whether additional verification procedures or samples were required to achieve a reasonable level of assurance.



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Stantec’s final sampling plan included reviewing and sampling the electricity production, electricity consumption, natural gas consumption, and gasoline consumption, as well as recalculating baseline and Project emission factors and emissions. This included recalculating the GHG Assertion and assessing consistency with the Project Plan, Protocol, and AEP guidance. The final verification procedures are provided in the final verification plan (Appendix A) and summarized in Table 5.1.

4.6 CONFIRMATIONS

For this Project, Stantec confirmed that:

• the Project information contained in the Project Plans was consistent with the Project Reports and GHG Assertions;

• the locations as indicated in the Project Reports; • the Project Plans contain the monitoring and quantification procedures applied to these Projects for

the period verified; • the Project proponent, report date, emission reduction numbers and other related information is

accurate for the verification period verified; and • the information systems are consistent with the descriptions contained in the Project Plans.


Summary of Findings March 3, 2017

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5.0 SUMMARY OF FINDINGS

A summary of the key findings from this verification is provided in Table 5.1. Each verification procedure and sample was performed for both Magrath and Chin Chute Wind Power Projects.

Table 5.1 Verification and Sampling Plan

Parameter Procedures Sample Size Result

GHG Assertion Reviewed the Project Report for the following information: • location of the

Projects; • Project start date and

period; • Registration of Offset

Credits; • Project Plan; • GHG Assertion; • protocol followed;

and • eligibility of GHGs

reduction.

All required information. Satisfactory • The Projects take place in Alberta. • The Projects took place after January

1, 2002 and the emission reductions are claimed within the approved 5-year credit extension period.

• The emission reduction credits have been registered on the Alberta registry.

• The Project Plans are available on the Registry.

• Blue Source has appropriately completed the GHG Assertions.

• The Projects are using an appropriate Protocol and the correct version of the Protocol.

• The GHGs reduced are eligible.

Conducted a site tour to compare emissions inventory to on-site sources.

All on-site GHG sources. All sources found on-site are represented in the quantification of emissions. No missing sources of GHG emissions were found.

Ownership Reviewed the Project Report for a statement regarding credit ownership. Reviewed ownership evidence.

Sufficient and appropriate evidence to support that Blue Source is authorized to serialize the offset credits on behalf of Suncor. Sufficient and appropriate evidence to support that Suncor is authorized to serialize the offset credits on behalf of Acciona and Enbridge.

Satisfactory Sufficient and appropriate evidence was provided.



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Project Additionality

Reviewed the Project Report and supporting documentation to assess whether the Project Developer is meeting the additionality criteria in the Protocol and the Project continues to be additional to regulations.

Not applicable. Satisfactory The project remains additional.

Consistency with Project Plan

Reviewed the Project Reports against the respective Project Plans for the following criteria: • deviation of the

Project from the Project Plan;

• same baseline and Project boundaries for the Project and the Project Plan; and

• similar emission reductions claimed.

Not applicable. Satisfactory Blue Source identifed the deviations from the Project Plans in the Project Reports. Blue Source resolved two immaterial qualitative misstatements related to disclosure. For more information, see Table 5.2. The same boundaries are being used for the baseline and project conditions. The emission reductions claimed in 2016 are similar to the estimates in the Offset Project Plans.

Consistency with ISO 14064-2

Assessed the Project Plans for completeness, accuracy, and transparency.

Not applicable. Satisfactory The Project Plans are complete, accurate, and transparent.

Assessed the Project Reports for transparency.

Not applicable. Satisfactory The Project Reports are sufficiently transparent.

Assessed the Project Reports for accuracy.

Not applicable. Satisfactory The Project Reports are materially accurate.

Assessed the Project Reports for relevance.

Not applicable. Satisfactory The Project Reports are sufficiently relevant.

Assessed the Project Reports for consistency.

Not applicable. Satisfactory The Project Reports are consistent with Project operations.



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Quantification and Monitoring

Assessed the Projects for missing electricity, natural gas, and gasoline data and confirmed records were within the crediting period.

Sampled all monthly invoices/records, traced to reports and to GHG emission quantification spreadsheets.

Immaterial qualitative misstatements (2) For both Projects, the electricity consumption data for the Lethbridge offices ends on December 27, 2016 and therefore four days of electricity consumption data have not been included for quantification. For the more information, see Table 5.2. A cutoff error was noted for both Projects where the UFA gasoline purchase report ended on December 16, 2016. These errors were resolved by Blue Source. For more information, see Table 5.2. All electricity production, electricity consumption at the wind farm, and natural gas consumption were within the crediting period.

Trended activity data for the period to identify anomalies.

Natural gas, electricity production, electricity consumption, gasoline.

Satisfactory Trending was performed for the samples identified. No anomalies were identified from the trending.

Assessed the Projects for quantification methodologies that are inconsistent with the Offset Plans.

All methodologies (including baseline emissions, Project emissions, and emission reductions).

Satisfactory The quantification methodologies used are consistent with the Offset Plans. Blue Source resolved an immaterial quantitative misstatement related to the natural gas energy conversion. For more information, see Table 5.2.

Traced electricity production records to the quantification spreadsheet.

Sampled all monthly invoices, traced to reports and to GHG emission quantification spreadsheets.

Satisfactory The electricity production records for the Alberta Electric System Operator (AESO) were compared to the electricity production used to quantify baseline emissions. An identified immaterial quantitative misstatement was resolved by Blue Source. For more information, see Table 5.2.

Traced electricity consumption records to the quantification spreadsheets.

All monthly electricity consumption statements (two offices).

Satisfactory The electricity consumption records from City of Lethbridge were compared to the electricity consumption used to quantify project emissions. No misstatements were detected.



16



Traced gasoline records to the quantification spreadsheets.

Sampled all records for the period, traced to reports and to GHG emission quantification spreadsheets.

Satisfactory Gasoline volumes from the UFA report and eight additional receipts were compared to the volume used to quantify project emissions. No misstatements were found in the quantification spreadsheets.

Traced crane operation hours to the quantification spreadsheets.

Sampled all crane invoice records (3), traced to reports and to GHG emission quantification spreadsheets.

Satisfactory The crane records support the hours used to calculate diesel consumption.

Traced natural gas records to the quantification spreadsheet.

All monthly natural gas statements.

Immaterial quantitative misstatements (2) The natural gas invoices do not support the value of the natural gas energy used to quantify project emissions. For more information on these misstatements, see Table 5.2.

Recalculated baseline emissions.

12 months Satisfactory The baseline emissions were successfully recalculated.

Recalculated Project emissions.

12 months Satisfactory The project emissions were successfully recalculated, in consideration of the misstatements detected above.

Assessed whether emission factors were appropriate and agree with the source.

Sampled the following factors: • electricity

displacement factor (CO2e);

• electricity use factor (CO2e);

• natural gas combustion factors (CO2, CH4, N2O);

• gasoline combustion factors (CO2, CH4, N2O);

• diesel combustion factors (CO2, CH4, N2O); and

• natural gas, gasoline, and diesel extraction

Satisfactory The emission factors were appropriate and supported by the source document.



17


Parameter Procedures Sample Size Result and processing factors (CO2, CH4, N2O).

GHG Data Management and Quality Control

Assessed whether the Project’s GHG data management systems, including quality control, are adequate.

Overall system for completeness, accuracy, validity, and restricted access, through interviews, Project documentation, and site visits.

Satisfactory The data management system at the Projects, operated by Acciona, were found to be adequate. Data are maintained securely.

Inspect calibration records for revenue electricity meter.

Chin Chute and Magrath

Satisfactory Both the Chin Chute and Magrath revenue electricity meters are within the 6 year calibration period.

GHG Data Retention

Assessed whether there is sufficient document storage and retention.

Not applicable. Satisfactory Project data are retained by Suncor indefinitely.

Misstatements identified during the verification are provided in Table 5.2.

Table 5.2 Identified Misstatements and Resolutions

Identified Misstatement Type Resolution

Consistency with Project Plan • The gasoline and diesel combustion emission factors used to

quantify project emissions in 2016 were updated from the Offset Project Plans. This update was not disclosed in the Offset Project Reports.

Immaterial qualitative misstatements (2).

Resolved.

Quantification and Monitoring • For both Projects, the electricity consumption data for the

Lethbridge offices ends on December 27, 2016 and therefore four days of electricity consumption data have not been included for quantification. The quantitative effect this error has on the emission reductions is immaterial to the assertion in comparison to the baseline emissions. This misstatement has not been resolved.

• A cutoff error was noted for both Projects where the UFA gasoline purchase report ended on December 16, 2016. The magnitude of the misstatement is 0.66 t CO2e per project (over-reported emission reductions), which is less than 0.01% of the reported assertions. Upon inquiry to Blue Source, an additional 576 L of diesel (288 L per project) was added for quantification. These misstatements were resolved.

• A summation error in the data supporting the Chin Chute electricity production caused a misstatement of -939 t CO2e (under-reported emission reductions). This represented 1.69% of

Immaterial qualitative misstatements (2). Immaterial quantitative misstatements (7)

Not resolved (4). Resolved (5).



18

Table 5.2 Identified Misstatements and Resolutions

Identified Misstatement Type Resolution the assertion. The Chin Chute calculator was subsequently updated to resolve this misstatement.

• The natural gas invoices provided do not match the data used to quantify project emissions for all months of 2016. The magnitude of the misstatement is 4.52 t CO2e per project (over-reported emission reductions), which is less than 0.01% of the assertions. These misstatements have not been resolved.

• The conversion from natural gas energy to natural gas volume was not correct in the Magrath or Chin Chute calculators. The magnitude of the misstatement is -4.44 t CO2e per project (under-repored emission reductions). Blue Source corrected the calculators to resolve these misstatements.

The summary of unresolved misstatements is provided in Table 5.3.

Table 5.3 Unresolved Misstatements

Identified Misstatement Type

Quantification and Monitoring • For both Projects, the electricity consumption data for the

Lethbridge offices ends on December 27, 2016 and therefore four days of electricity consumption data have not been included for quantification. The quantitative effect this error has on the emission reductions is immaterial to the assertion in comparison to baseline emissions. This misstatement has not been resolved.

Immaterial qualitative misstatements (2)

• The natural gas invoices provided do not support the data used to quantify project emissions for all months of 2016. The magnitude of the misstatement is 4.52 t CO2e per project (over-reported emission reductions), which is less than 0.01% of the assertions. These misstatements have not been resolved.

Immaterial quantitative misstatements (2) Net: 4.52 t CO2e (over-reported emission reductions) Absolute: 4.52 t CO2e (over-reported emission reductions)


Conclusion March 3, 2017

19

6.0 CONCLUSION

6.1 OPINION

Based on the procedures undertaken and described in this report, the Project Reports and GHG Assertions for the Magrath and Chin Chute Wind Power Projects, dated February 27, 2017, satisfy the requirements of the:

• Climate Change and Emissions Management Act (the Act), SA 2003, c C-16.7; • Specified Gas Emitters Regulation, Alta Reg. 139/200, with amendments up to and including Alberta

Regulation 104/2015 (Regulation); • Technical Guidance for Offset Project Developers (version 4.0, February 2013); • Quantification Protocol for Wind-Powered Electricity Generation (V 1.0, March 2008); and • The Carbon Offset Emission Factors Handbook (March 2015, V1.0).

6.2 SUBMISSION DOCUMENTS

The verification documents for submission are in Appendix B and include: Statements of Qualifications, a Statements of Verification, and Conflict of Interest Checklists.


Closure March 3, 2017

20

7.0 CLOSURE

Stantec has undertaken all assignments in its role as an environmental engineering consulting firm using professional effort consistent with the Technical Guidance for Offset Project Developers, February 2013, version 4.0, and the Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance, January 2013, version 1.0. Stantec has assessed the Project Reports submitted by Blue Source for the Magrath and Chin Chute Wind Power Projects using reasonably ascertainable information, as defined by ISO 14064-3, obtained from a review of operational records and available literature and documents. The assessment represents the conditions in the subject area at the time of the assessment. Stantec did not conduct direct monitoring or measurement or other physical sampling and analysis in conjunction with this verification report. Stantec disclaims liability for use by any other party and for any other purpose.

Stantec will retain all Project documents for a minimum of seven (7) years.

This report entitled, “Verification Report For the Magrath and Chin Chute Wind Power Projects (2016)” was produced by Daniel Hegg (Lead Verifier) and Christina Varner (Verifier). This report was peer reviewed by Nicole Flanagan and quality reviewed by Michael Murphy.

Respectfully Submitted,

STANTEC CONSULTING LTD.

Daniel Hegg, M.Sc., CEM Lead Verifier Environmental Services Tel: (250) 217-9729

Nicole Flanagan, M.A.Sc., P.Eng. Independent Peer Reviewer Environmental Services Tel: (613) 738-6086

Michael Murphy, PhD, P.Eng. Quality Review/Designated Signing Authority Environmental Services Tel: (902) 620-0253


March 3, 2017

Appendix A Final Verification Plan


March 3, 2017

Stantec Consulting Ltd. 400 - 655 Tyee Road Victoria BC V9A 6X5 Tel: (250) 388-9161 Fax: (250) 382-0514

Template version 2.0 July 2016

VIA EMAIL <[email protected] March 3, 2017 File: 123220447

Attention: Kelsey Lank, Carbon Solutions Analyst Blue Source Canada ULC 700, 717-7th Ave. SW, Calgary, AB T2P 0Z3

Dear Ms. Lank,

RE: FINAL VERIFICATION PLAN - SPECIFIED GAS EMITTERS REGULATION VERIFICATION OF THE 2016 MAGRATH AND CHIN CHUTE WIND POWER PROJECTS

INTRODUCTION

Stantec Consulting Ltd. (Stantec) provides this Verification Plan for the Magrath and Chin Chute Wind Power Projects (the Projects or referred to as individual Project described below). The Project title for each Project is:

• Magrath Wind Power Project; and • Chin Chute Wind Power Project.

The verification is being completed under the Alberta Environment and Parks (AEP) Specified Gas Emitters Regulation (SGER). The verification plan outlines the terms of the engagement and the planned verification procedures. The verification plan also contains a list of data and documentation required to complete the planned procedures.

It is understood that the Projects are owned by Enbridge Wind Power General Partnership (Enbridge), Acciona Wind Energy Canada Inc. (Acciona), and Suncor Energy Products Inc (Suncor, “the Proponent”), a wholly owned subsidiary of Suncor Energy Inc. Suncor has been authorized to act on behalf of the other two partners and will register all applicable emission reduction credits from the Project. The Project is operated by Acciona (Facility Operator).

In this work, Acconia was responsible for the collection of data used in the calculations and data management. Blue Source Canada ULC (Blue Source) was retained by Suncor and was responsible for the completion of the calculations, presentation of the information within the Project Reports and GHG Assertions, and for the supporting technical documents. Blue Source was also responsible for the facilitation of the third party verification.

The Magrath and Chin Chute wind power sites, while separate, share an office and storage space in Lethbridge, Alberta and a fleet of on-site vehicles. Stantec has issued this verification plan for both sites combined and assessed each Project assertion separately

This is Stantec’s fifth consecutive verification of the Projects.

March 3, 2017 Blue Source Canada ULC Page 2 of 17


VERIFICATION CRITERIA & SCOPE

The verification is being undertaken to form an opinion as to whether, materially, the GHG Assertion and information in the Project Reports are presented fairly and are in accordance with the requirements of:

• the Climate Change and Emissions Management Act, S.A. 2003, c. C-16.7; • the Alberta Specified Gas Emitters Regulation, Alta Reg. 139/200, with amendments up to and

including Alberta Regulation 104/2015 (Regulation); • the Technical Guidance for Offset Project Developers (February 2013, V4.0); • the Specified Gas Emitters Quantification Protocol for Wind-Powered Electricity Generation

(V 1.0, March 2008); and • the Emission Factors Handbook (March 2015, V1.0).

VERIFICATION STANDARDS

The verification is being conducted in accordance with:

• ISO 14064 Part 3 – Greenhouse Gases: Specification with guidance for the validation and verification of greenhouse gas assertions;

• ISO 14065 – Greenhouse Gases: Requirements for greenhouse gas validation and verification bodies for use in accreditation and other forms of recognition; and

• Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance (January 2013, version 1.0).

VERIFICATION SCOPE

Stantec understands the Project is described in the following manner. The reasonableness of this Project description is subject to verification by Stantec.

• The Magrath Wind Power Project consists of twenty (20) 1.5 MW wind turbines for a total installed capacity of 30 MW. The Project includes a substation and an underground transmission lines. There is no electricity storage system on-site. The Project is located approximately 6 km west of Magrath, Alberta.

• The Chin Chute Wind Power Project consists of twenty (20) 1.5 MW wind turbines for a total installed capacity of 30 MW. The Project includes a substation and an underground transmission lines. There is no electricity storage system on-site. The Project is located approximately 15 km southwest of Taber, Alberta.

Project operation emissions at each site result from electricity use and fossil fuel combustion. The Projects share a fleet of vehicles, office space in Lethbridge, Alberta, and switchyard equipment (Project emissions from those sources are assigned to each Project equally). Electricity consumption and production is metered by third parties. Natural gas and gasoline volumes are metered by third parties. Indirect emissions from the extraction and processing of the fuel used by each Project are included in the Project emissions.



The following GHGs were included within the scope of the verification as required by the SGER:

• carbon dioxide (CO2); • methane (CH4); • nitrous oxide (N2O); • hydrofluorocarbons (HFCs); • perfluorocarbons (PFCs); and • sulphur hexafluoride (SF6). The total equivalent GHG emissions are reported as tonnes of carbon dioxide equivalents (t CO2e).

Sources of Project GHG emissions for the Projects include:

• Natural Gas Combustion (CO2, CH4, and N2O): for space heating for the Lethbridge office and bay;

• Mobile Fuel Combustion (CO2, CH4, and N2O): for on-site gasoline vehicles and diesel-fueled cranes for maintenance (if applicable).

• Fuel Extraction & Processing (CO2, CH4, and N2O, presented as CO2e): indirect emissions associated with the extraction and processing of fossil fuel resources for gasoline, natural gas, and diesel fuels used in the above sources.

• Electricity Consumption (CO2, CH4, and N2O, presented as CO2e): consumption of electricity from the Alberta grid to run the Projects.

Sources of baseline GHG emissions included:

• Electricity Production (CO2, CH4, and N2O, presented as CO2e): emissions from fossil fuel combustion to produce an equivalent amount of electricity as wind power electricity (during the crediting period) which would have happened in the absence of the Projects.

ASSERTION

The fundamental GHG Assertion to be verified for the Project is that it meets the verification criteria for the Project reporting period January 1, 2016 to December 31, 2016. The initial GHG Assertion (i.e., reductions being claimed) for the Projects to be verified is to be provided by Blue Source.

LEVEL OF ASSURANCE

Sufficient procedures are being conducted in order to express a reasonable level of assurance opinion as required by AEP.

MATERIALITY

AEP has set the quantitative materiality threshold to 5% of the asserted emission reductions and removals for offset Projects. The materiality will be assessed on the net and absolute values of discrepancies. The identification of material qualitative discrepancies is at the discretion of the verification body. Stantec will execute the verification accordingly.



VERIFICATION SCHEDULE

Table 1 presents the verification schedule.

Table 1 Planned Verification Schedule

Verification Activity Responsible Party

Date of Completion

Kick-Off Meeting with Blue Source Stantec / Blue Source October 26, 2016

Provide Verification Plan to Blue Source Stantec November 15, 2016

Site Visits Stantec / Blue Source November 17, 2016

Receive Documentation for the Projects Blue Source Week of January 9, 2017

Initial Desktop Review Stantec Week of January 16, 2017

Draft Verification Report Stantec Week of January 23, 2017

Address Follow-up Items Stantec / Blue Source Week of January 30, 2017

Finalize Verification Report and Statement of Verification Stantec Week of January 30, 2017

* Dates in italics are proposed.

VERIFICATION TEAM: QUALIFICATIONS, ROLES AND RESPONSIBILITIES

As part of Stantec’s GHG Standard Operating Procedures (SOP), the competence and selection of the team is completed following ISO 14066 - Greenhouse Gases – Competence requirements for greenhouse gas validation teams and verification teams.

Table 2 presents the verification team.

Table 2 Verification Team


Daniel Hegg, M.Sc., CEM Lead Verifier Lead desktop review, sampling plan execution and working paper completion, and prepare verification documentation.

Vicki Corning, P.Eng. Quality Reviewer Review verification plan for technical soundness and compliance with Stantec’s internal processes and AEP criteria.

Michael Murphy, PhD, P.Eng.

Quality Reviewer Due to timing constraints, Mike quality reviewed the draft and final verification reports. Designated Signing Authority on the verification report and final verification plan.

Nicole Flanagan, M.A.Sc., P.Eng.


Independent review of verification activities and conclusions. The independent reviewer confirms the verification activities have been completed and that the activities provide the required level of assurance.



Table 2 Verification Team


Orasa Webber, M.Eng. Verifier Complete the desktop review of the Project and conduct the site visits.

TEAM PROFILE

Lead Verifier – Daniel Hegg, M.Sc., CEM.

Daniel Hegg is a Senior Sustainability Specialist and Regional (Western Canada/US) GHG & Climate Technical Leader for Stantec Consulting Ltd.

Living on Canada’s west coast has deepened Dan’s passion for the development and implementation of sustainable practices. His unique perspectives and insights cross many important areas such as integrated carbon, strategic energy and water management, sustainable ROI business case development, full value accounting, climate change risk assessment and planning for the private and public sectors. In addition to providing strategy and policy advice, Dan has prepared multiple climate-resilience strategies across a variety of sectors including buildings/real-estate, forestry, oil & gas, renewable energy and mining. Much of his work has directly helped guide various private and public sector organizations in sustainability and climate decision-making. In fact, Dan was recently seconded to the BC Ministry of Environment, Climate Investment Branch to assist with due diligence in the Province’s carbon offset portfolio. Daniel has also developed and validated over 80 organizational and facility GHG inventories and offset projects across a wide range of industry sectors.

Quality Reviewer – Vicki Corning, P.Eng.

Vicki has a degree in chemical engineering and 12 years of technical and management expertise in many environmental services in the field of atmospheric emissions. Vicki is a GHG & Climate Services Discipline Leader at Stantec with the responsibility for growth and continuous improvement of the service line. She has been involved in over 120 verifications for organizational inventories and GHG offset projects in western Canada, Ontario, Quebec, Atlantic Canada and the United States. She also regularly leads air, noise and climate components of environmental assessments for a wide range of industrial clients. These involve monitoring existing conditions using analytical techniques, establishing emissions inventories for new facilities and evaluating expected environmental effects using modeling techniques.

Vicki has worked with clients in a variety of different industries in Canada and the US including: upstream and downstream oil and gas (gas processing plants, oil refineries, SAGD facilities, pipeline operations), electrical generating stations (coal, gas, co-generation, biomass), manufacturing plants, chemical processing facilities, mining, construction projects and pulp and paper. Vicki has managed the preparation of several policy reports on renewable energy for the New Brunswick Department of Energy, and authored technical content on carbon capture systems for coal facilities as part of an environmental report for Carbon Capture Nova Scotia. Vicki developed Stantec’s internal GHG program competency training process and has also delivered course material on GHG verification, inventory and data management techniques through a contract with the Canadian Standards Association.



Quality Reviewer and Signing Authority – Dr. Mike Murphy, P.Eng.

Dr. Mike Murphy, P.Eng., is a Senior Principal of Stantec Consulting Ltd. in Environmental Services and leads the company-wide Atmospheric Environment Group out of the Charlottetown, Prince Edward Island office. The Atmospheric Environment Group provides specialized services in Air Quality, Climate and Greenhouse Gases (including carbon footprinting), Acoustics (noise including environmental and building acoustics) and Lighting. Mike graduated from the University of Waterloo in 1987 with a PhD in Chemical Engineering, specializing in energy analyses, fluid modeling and boiling heat transfer. With more than 25 years of experience in Canada, USA and international (France, Italy, United Kingdom, Middle East), he has conducted studies on: emissions inventories of air pollutants, acid gases and greenhouse gases (GHGs), source emissions testing, dispersion modeling, ambient air quality, ambient noise/acoustics, odour, climate analysis, indoor air quality and provided support on several environmental assessments (EAs).


Independent Peer Reviewer – Nicole Flanagan, M.A.Sc., P.Eng

Nicole Flanagan, M.A.Sc., P.Eng. has 13 years of environmental engineering, nine of which are with Stantec. Nicole’s experience is specialized in air emissions under a variety of industrial, government and corporate settings. She is currently a senior practitioner and technical reviewer for greenhouse emission quantification, reporting and verification. Nicole was the lead verifier of some of the first regulatory greenhouse gas offsets sold in North America, has completed Environmental Compliance Approvals (ECAs), and National Pollutant Release Inventory reporting for clients facilitating regulatory compliance. In addition, she has completed projects for various facilities developing voluntary greenhouse gas inventories, and emission/energy performance key metrics and identification of reduction opportunities. Her clients include major electric utilities, energy companies, petrochemical production facilities as well as oil & gas companies.

She also spent four years with Environment Canada working on program development and program delivery of greenhouse gas inventory and reduction programs, which included meeting with stakeholders and administering procedural processes. During this time, she developed a strong understanding of the workings of government from program administration (Greenhouse Gas, NPRI Reporting Division and Canada’s Offset System) as well as regulatory and instrument development (development of regulations and Pollution Prevention Planning requirements)

Verifier – Orasa Webber, M.Eng.

Ms. Orasa Webber has conducted over 80 greenhouse gas (GHG) verifications in Canada and the United States under many jurisdictions and programs including British Columbia Reporting Regulation, Alberta’s Specified Gas Emitters Regulation (SGER), Ontario Regulation, The Climate Registry, The Massachusetts Department of Environmental Protection Regulation. The GHG verification projects have included the following sectors: oil and gas extraction, production and



refining; power generation; chemical and petrochemical production; natural gas distribution systems; metal production; mining and mineral production.

Orasa has also conducted over 15 offset credit verifications under Alberta’s Offset Credit System. Orasa completed her Master’s Degree in chemical engineering from McGill University and brings over ten years of experience. For the past five years, she has focused on climate change and environmental work including National Pollutant Release Inventory (NPRI) reporting, ambient air quality and noise monitoring, environmental impact assessment, GHG inventory, GHG verification and validation, and petroleum contaminated water/soil testing under Atlantic Risk-Based Corrective Action (RBCA) guidelines. She also has industrial experience in quality control of oil refinery products and processing and design of plastic products.

RISK ASSESSMENT

Stantec has done a preliminary assessment of the potential risk associated with this verification assignment for the Projects. The risk assessment is an internal procedure used to assess inherent, control, and detection risk which uses the following equation:

Audit Risk = Inherent Risk x Control Risk x Detection Risk

Detection risk is the risk that Stantec will not uncover a material discrepancy (e.g., the misstatement was present in the assertion and was not identified during the verification). The assessment of detection risk impacts the nature, timing and extent of the verification procedures that are to be performed by Stantec. Inherent Risk is the risk of a material misstatement that arises due to error or omission as a result of factors that are outside of the failure of controls. Inherent risk is generally considered to be higher where a high degree of judgment and estimation is involved or where GHG emissions data collection and processing are highly complex and involved processes. Organizations must have adequate internal controls in place to prevent and detect instances of error, misstatements, and omissions. Control Risk is the risk of a material misstatement arising due to absence or failure in the operation of relevant GHG system controls. Control risk is considered to be high where the Project does not have adequate internal controls to prevent and detect misstatements in the assertion.

There is an inverse relationship between the inherent and control risks, and the detection risk. If the inherent and control risks are high, Stantec will perform verification and sampling procedures that reduce detection risk so that the final verification risk is maintained at a low level. Higher control and inherent risk equates to more rigorous investigation and sampling. It typically results in additional detailed on and off-site sampling, additional information requests and staff interviews. Detection risk is lowered by more rigorous sampling; however, sampling is always done as per the verification criteria and standards.

Based on the risk assessment in each of these categories, the Stantec team assigns an overall risk to the verification of the Projects. The preliminary overall risk for this verification has been assessed as Low. A summary of the risk assessment is provided in Table 3.



Table 3 Risk Summary for Verification of the Projects

Risk Area Preliminary Assessment Final Assessment

Inherent Risk Low To be determined.

Control Risk Low To be determined.

Detection Risk Low To be determined.

Overall Risk Low To be determined.

We consider the initial inherent risk to be Low based on the following:

• The quantification of offset credits is completed by the third party company, Blue Source Canada, a company that has experience in offset project reduction quantification (low risk);

• This is the fifth verification conducted by Stantec for the Projects and the Project received a positive Statement of Verification for the past reporting periods (low risk); and

• The facility operation is simple and activity data used for quantification of the emission reductions for the Projects are based on third party utility invoices and third party metering reports (low risk).

We consider the initial control risk to be Low based on the following:

• electricity generated by the wind turbines and consumed by wind turbines, substation, and transmission system for each Project is metered by the onsite revenue meters with the third party reports from MIDAS (Metering Services Ltd.) (low risk);

• electricity usage for the Lethbridge office and bay is metered by a third party (City of Lethbridge) with custody transfer meters (low risk);

• natural gas usage for the Lethbridge office and bay is metered by a third party (Garden City) with custody transfer meters (low risk);

• gasoline for onsite fleet vehicles is metered by third party (UFA) at pump stations and volume are summarized in the UFA reports (low risk);

• diesel volume for crane activities is tracked by the site maintenance reports (low risk); and • emission factors are from recognized and appropriate sources (low risk).

Detection risk is the risk that Stantec will not identify a material discrepancy. We regard this risk as Low due to:

• Our Quality Management Procedures. We are committed to providing exceptional service to our clients in accordance with our ISO 9001 and ISO 14065 accreditations. We believe that quality is a basic principle and that quality management is an integral part of our work. We take a systematic approach to quality management to comply with requirements and to strive for continual improvement. The cornerstone of our quality management system is an entrenched process of quality and independent review where by our deliverables are vetted by senior and expert people in our firm (low risk).



• Level of Assurance. The reasonable level of assurance applied in this verification (as required by the Regulation) mandates that Stantec perform increased sampling to meet the assurance requirements, however, the level of assurance still increases the risk to Stantec as the risk-based verification approach means that not all information can be reviewed. Stantec has designed the sampling plan to target potentially material items in the GHG information to minimize detection risk (low risk).

VERIFICATION PLAN

The verification and sampling plan is intended to facilitate the assessment of completeness, conservativeness, consistency, accuracy, and transparency of the responsible party’s GHG information and confirm the GHG Assertion as identified in the Project Report. The verification team has established and will modify the sampling plan to verify that sufficient and appropriate evidence is available to support the Project Reports and GHG Assertions presented. Further, any discrepancies that contribute to the GHG Assertion will be assessed and documented in the verification report.

With regards to the magnitude of potential errors, omissions and misrepresentations, electricity generation represent the greatest risk of material error to the GHG Assertion (e.g., tracking of electricity production). Thus, verification procedures focused on the evidence and controls related to these parameters.

Table 4 shows the planned verification procedures for each Project.



Table 4 Verification Procedures for Each Project

Line Item Verification Objective Risk Identified Type of Procedure Description of Procedure

Greenhouse Gas Assertion

Completeness Incompleteness of inventory.

Test of detail – inspection, inquiry

Conduct a site tour of the Project location to determine sources and compare with inventory. Inquire on SF6 use and whether there were discharges at the Project location.


Completeness Incompleteness of Project Report.

Test of detail – inspection. Inspect Project Report for missing information.


Occurrence Document storage and retention practices may not be sufficient.

Test of detail – inquiry. Inquire of Proponent the location and retention period of data used for GHG Assertion.


Accuracy

Information not appropriately disclosed.

Test of detail – inspection. Inspect Project Report for correct reporting of emissions and related information.


Accuracy

GHG Assertion is incorrect

Test of detail – inspection, tracing, recalculation

Check emission factors, quantification methodology and recalculate GHG Assertion.

Electricity Production / Consumption

Completeness Incorrect recording of data resulting in an incorrect GHG Assertion.

Test of detail – inspection, reconciliation, tracing.

Compare raw data records, invoices against data in GHG calculator for consistency and completeness.


Consistency Inconsistent quantification methodologies.

Test of detail – inspection. Assess whether quantification methodologies (including offset emission factors) are consistent with previous periods.


Accuracy Anomaly in production of electricity

Test of detail – inquiry. Analytical test – profile.

Inquire with operators regarding any production anomalies during the assertion period. Run profile tests for monthly data.






Accuracy Inaccurate measurement of electricity.

Test of control – inspection, inquiry.

Inspect calibration records performed by MiDAS. Inquire on data aggregation and quality assurance and control procedures.


Accuracy Inaccurate calculation of emissions.

Test of detail – recalculation.

Recalculate baseline emissions.


Cut-off Improper dates of recording electricity production/ consumption.

Test of detail – inspection. Inspect the dates of electricity generation and consumption records.

Natural Gas Combustion

Completeness Accuracy

Missing fuel receipts. Inaccurate natural gas consumption.

Test of detail – tracing. Trace fuel volumes from receipts to emission reduction calculations.



Test of detail – inspection. Assess whether quantification methodologies (including emission factors) are consistent with previous periods.


Accuracy Anomaly in emissions trend.

Analytical test – profile. Test of detail – inquiry

Run profile tests for monthly data. Inquire with operators on anomalies in natural gas use.


Cut-off Improper dates of fuel receipts.

Test of detail – inspection. Inspect the dates of natural gas invoices.





Gasoline and diesel Combustion

Completeness Accuracy

Missing fuel receipts. Inaccurate fuel consumption.

Test of detail – tracing. Trace fuel volumes from receipts to calculations.





Cut-off Improper dates of fuel receipts.

Test of detail – inspection. Inspect the dates of fuel invoices.

Diesel Combustion Completeness Missing diesel fuel use. Test of detail – inquiry, inspection.

Inquire with operators whether there was crane operation during the reporting period. Inspect maintenance records to assess if the numbers of maintenance events involving diesel usage for cranes.

Fuel Extraction and Processing



Fuel Extraction and Processing

Accuracy Inaccurate emission quantification.

Test of detail – recalculation.

Recalculate emissions from fuel extraction and processing.



SITE VISIT

Stantec Verifier, Orasa Webber will conduct a site visit to the Magrath and Chin-Chute Wind Farms, and the Lethbridge office on November 17, 2016.

The site visits involve a review of data collection, tracking, and retention and transfer procedures. Activities associated with operations, record keeping, data management and emissions sources were also reviewed to better understand the quantification calculations, data treatment and data management. Through interviews, and by attending the site visit, the site boundaries will be evaluated by the verifier to confirm their veracity. The verifier will perform procedures to identify Project boundaries, confirm GHG sources, look for additional sources, visually confirm the presence of the wind turbines and electrical meters. Emission sources, sinks and reservoirs will be evaluated and the potential for additional sources (omitted) will be reviewed

The proposed site visit agenda is provided in Table 5. The agenda was structured to include a general site tour where the verification team will look at sources, meters, and calibration tags.

Table 5 Site Visit Agenda

Date Facility Item Responsible Party Time

November 17, 2016

Magrath Wind Farm

Magrath wind farm tour. Stantec / Blue Source /

Acciona

9:30 am – 10:00 am

Lethbridge Office

Overview of facility GHG reporting boundaries.

Acciona 10:45 am – 12:00 pm

Overview of centralized data management and storage procedures for GHG data on-site.

Acciona

On-site data sampling. Stantec / Acciona

Follow-up questions and close-out.

Stantec

Chin Chute Wind Farm

Chin Chute wind farm tour. Stantec / Blue Source /

Acciona

12:30 pm – 1:00 pm

INFORMATION REQUEST

Table 6 contains a list of documentation and data requested by Stantec to complete the proposed procedures and the outcome of the requests. This table was updated as needed through the verification process to track requests.



Table 6 Information Requested

Information Requested Request Date

Obt

aine

d on

for

Mag

rath

Win

d Pr

ojec

t

Obt

aine

d on

for

Chi

n C

hute

Win

d Pr

ojec

t

1. The current version of Offset Project Plan for each Project.

November 15, 2016

Obtained from Registry

Obtained from Registry

2. Offset Project Report (signed version) when available for each Project.

November 15, 2016 March 3, 2017 March 3, 2017

3. The signed GHG Assertion form for each Project when available.

November 15, 2016 March 3, 2017 March 3, 2017

4. Confirm whether there has been change to Projects ownership (i.e., The Projects are owned by Enbridge Wind Power General Partnership (Enbridge), Acciona Wind Energy Canada Inc. (Acciona), and Suncor Energy Products Inc (Suncor, “the Proponent”), a wholly owned subsidiary of Suncor Energy Inc. Suncor has been authorized to act on behalf of the other two partners and will register all applicable emission reduction credits from the Project).

November 15, 2016

February 13, 2017

February 13, 2017

5. Offset calculation spreadsheet for each Project with final assertion.

November 15, 2016

February 24, 2017

February 24, 2017

6. The 2016 MIDAS reports for electricity generation and consumption by wind turbines, substation and transmission system for each Project.

November 15, 2016

February 13, 2017

February 13, 2017

7. Meter calibration or check records in 2016 for the revenue meter for each Project.

November 15, 2016

February 13, 2017

February 13, 2017

8. The 2016 electricity utility invoices from third party suppliers.

November 15, 2016

February 13, 2017

February 13, 2017

9. The 2016 natural gas utility invoices from third party suppliers.

November 15, 2016

February 23, 2017

February 23, 2017

10. The 2016 UFA reports for gasoline and diesel consumption for the onsite trucks.

November 15, 2016

February 22, 2017

February 22, 2017

11. Access to the revenue meter for Magrath Wind Farm to confirm meter ID during the site visit.

November 15, 2016

November 17, 2016

November 17, 2016



Table 6 Information Requested

Information Requested Request Date

Obt

aine

d on

for

Mag

rath

Win

d Pr

ojec

t

Obt

aine

d on

for

Chi

n C

hute

Win

d Pr

ojec

t

12. Access to the revenue meter for Chin Chute Wind Farm to confirm meter ID during the site visit.

November 15, 2016

November 17, 2016

November 17, 2016

13. Access to the utility meters (natural gas and electricity) for the Lethbridge office to confirm meter IDs during the site visit (if applicable).

November 15, 2016

November 17, 2016

November 17, 2016

14. Site verifier would like to observe January and June 2016 wind turbine electricity generation data in SCADA (supervisory control and data acquisition) if available.

November 15, 2016

November 17, 2016

November 17, 2016

15. Discussion during the site visit about data management system regarding wind turbine electricity generation, utility, and consumption data.

November 15, 2016

November 17, 2016

November 17, 2016

16. Evidence of crane hours. 17. Clarify what the “Stampede Crane CH-

15t.pdf” is for. It appears to be blank.

November 15, 2016

February 13, 2017

February 22, 2017

Not Applicable

18. Explain why the electricity production in the file “Chin2016_Q1-Q4_GenerationData.xlsx” does not match the production in the calculator for months July, September, October, November, and December.

February 20, 2017

Not Applicable

February 22, 2017

19. Provide an attestation from Suncor on Project ownership.

February 22, 2017 March 3, 2017 March 3, 2017

FINALIZING THE VERIFICATION PLAN

The initial verification procedures may be adjusted to reflect changes to the risk identified during the verification and any additional verification procedures deemed necessary to provide a reasonable level of assurance. This Section captures any changes to risk, the verification procedures or the GHG Assertion since the issuance of the initial verification plan.



RISK ASSESSMENT

Stantec has done a final assessment of the potential risk associated with this verification assignment. As stated in the initial verification plan, the risk assessment is an internal procedure used to assess inherent, control, and detection risk. Based on the risk assessment in each of these categories, the Stantec team assigns an overall risk to the verification and continues to monitor the risk throughout the verification process. The final overall risk for this verification has been assessed to remain as Low.

ADDITIONAL VERIFICATION PROCEDURES

The planned verification procedures for this assignment are outlined in Table 4, above. The following additional procedures were performed.

Table 7 Additional Verification Procedures

Line Item Verification Objective Risk Identified Type of

Procedure Description of Procedure


Completeness Ownership information may have changed.

Test of detail – inspection

Inspect evidence that Suncor still owns the Magrath and Chin Chute Wind Power Projects. Inspect evidence that Suncor has been authorized by the other joint venture partners to serialize offset credits on their behalf. Inspect evidence that Blue Source has been authorized to assist Suncor with serializing offsets from these Projects.

ASSERTION

The initial GHG assertions for this assignment were not provided in the initial verification plan. The final GHG assertions for the Chin Chute and Magrath Wind Power Projects are:

• Chin Chute: 56,576 t CO2e; and • Magrath: 53,127 t CO2e.



CLOSURE

Should you have any questions or require additional information, please contact me directly. Sincerely,


Daniel Hegg, M.Sc., CEM Lead Verifier Tel: (250) 217-9729 [email protected]

This report was reviewed and approved for transmittal by:

Mike Murphy, PhD, P.Eng. Quality Reviewer and Signing Authority Tel: (902) 620-0253 [email protected]

Nicole Flanagan, M.A.Sc., P.Eng. Independent Peer Reviewer Tel: (613) 738-6086 [email protected]

\\cd1002-f04\ghg\suncor_mag_chin_123220447_2016\6_ver_statement (report)\rpt_final\blu_mag_chin_sger_offset_vplan_20170303.docx

mailto:[email protected]




March 3, 2017

Appendix B Submission Documents


March 3, 2017

CONFLICT OF INTEREST CHECKLIST – CHIN CHUTE WIND POWER PROJECT (JANUARY 1 – DECEMBER 31, 2016)

Page 1 of 1

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? 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? For example: • provided greenhouse gas consultation services to the project; • provided validation for the project; • if providing non-greenhouse gas work for the company, consideration needs to be given as to how

potential and perceived conflict of interests can be managed; or • a member of the verification team was previously employed with the company.

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? For example: • dealing in, or being a promoter of, greenhouse gas 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? For example: • a person on the verification team has a close personal relationship with a person who is in a senior

greenhouse gas 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. For example: • the threat of being replaced as a third party verifier due to a disagreement with the

application of a greenhouse gas 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.


Daniel Hegg, M.Sc., CEM Lead Verifier, Environmental Services Tel: (250) 217-9729

Nicole Flanagan, M.A.Sc., P.Eng. Peer Reviewer, Environmental Services Tel: (613) 738-6086

Mike Murphy, PhD, P.Eng. Designated Signing Authority, Quality Reviewer Environmental Services Tel: (902) 620-0253

March 3, 2017 Issued in Victoria, British Columbia

STATEMENT OF QUALIFICATIONS – CHIN CHUTE WIND POWER PROJECT (JANUARY 1 – DECEMBER 31, 2016)

Page 1 of 3

STATEMENT OF QUALIFICATIONS

Dr. Michael Murphy is the signing authority for the report. He is a professional engineer registered by the Association of Professional Engineers and Geoscientists of New Brunswick, which satisfies Section 18(a)(ii)(A) of the SGER. With respect to the technical knowledge required under Section 18(b)(i-iii), each member of the team has the required technical knowledge of GHG emission quantification methodologies and all have experience in completing third party GHG verifications. Please refer to the team cameos below for details.

TEAM QUALIFICATIONS AND EXPERIENCE

Lead Verifier – Daniel Hegg, M.Sc., CEM

Daniel Hegg is a Senior Sustainability Specialist and the Western Regional Technical Leader (climate and greenhouse gas (GHG)) for Stantec Consulting Ltd. Daniel offers unique perspectives and insights on integrated carbon, energy and water management and strategy, sustainable return on investment business case development and climate change risk assessment and planning for private and public sector clients. He has provided strategy, policy advice, and has prepared a number of climate-related strategic guidance documents and plans across a variety of sectors including buildings/real-estate, forestry, oil and gas, renewable energy, mining, local, regional and provincial governments. He was recently on secondment with the BC Ministry of Environment, Climate Investment Branch assisting with the due diligence of the Province’s $25 million dollar carbon offset portfolio. Daniel has also developed, validated and verified over 70 organizational and facility GHG inventories and offset projects for clients in a wide range of sectors.

Quality Review (verification plan) – Vicki Corning, P.Eng.

Ms. Corning has a degree in chemical engineering and 10 years of technical and management expertise in many environmental services in the field of atmospheric emissions. Ms. Corning is a GHG & Climate Services Discipline Leader with the responsibility for growth and continuous improvement of the service line. She has been involved in over 100 verifications for organizational inventories and GHG offset projects in western Canada, Ontario, and the United States. Ms. Corning has worked with clients in a variety of different industries in Canada and the US including: gas processing plants, oil refineries, SAGD facilities, pipeline operations, electrical generating stations (coal, gas, co-generation), manufacturing plants, chemical processing facilities, construction projects and pulp mills. Ms. Corning has managed the preparation of several policy reports on renewable energy for the New Brunswick Department of Energy, and authored technical content on carbon capture systems for coal facilities as part of an environmental report for Carbon Capture Nova Scotia.

Quality Review (verification report) and Signing Authority – Michael Murphy, PhD, P.Eng.

Dr. Mike Murphy, PhD, P.Eng., is a Senior Principal of Stantec Consulting Ltd. in Environmental Services and leads the company-wide Atmospheric Environment Group out of the Charlottetown, Prince Edward Island office. The Atmospheric Environment Group provides specialized services in Air Quality, Climate and Greenhouse Gases (including carbon foot-


Page 2 of 3

printing), Acoustics (noise including environmental and building acoustics) and Lighting. Mike graduated from the University of Waterloo in 1987 with a PhD in Chemical Engineering, specializing in energy analyses, fluid modeling and boiling heat transfer. With more than 25 years of experience in Canada, USA and international (France, Italy, United Kingdom, Middle East), he has conducted studies on: emissions inventories of air pollutants, acid gases and greenhouse gases (GHGs), source emissions testing, dispersion modeling, ambient air quality, ambient noise/acoustics, odour, climate analysis, indoor air quality and provided support on several environmental assessments (EAs).


Independent Peer Reviewer – Nicole Flanagan, M.A.Sc., P.Eng.

Nicole Flanagan has 13 years of environmental engineering, nine of which are with Stantec. Nicole’s experience is specialized in air emissions under a variety of industrial, government and corporate settings. She is currently a senior practitioner and technical reviewer for greenhouse emission quantification, reporting and verification. Nicole was the lead verifier of some of the first regulatory greenhouse gas offsets sold in North America, has completed Environmental Compliance Approvals (ECAs), and National Pollutant Release Inventory reporting for clients facilitating regulatory compliance. In addition, she has completed projects for various facilities developing voluntary greenhouse gas inventories, and emission/energy performance key metrics and identification of reduction opportunities. Her clients include major electric utilities, energy companies, petrochemical production facilities as well as oil & gas companies.

She also spent four years with Environment Canada working on program development and program delivery of greenhouse gas inventory and reduction programs, which included meeting with stakeholders and administering procedural processes. During this time, she developed a strong understanding of the workings of government from program administration (Greenhouse Gas, NPRI Reporting Division, and Canada’s Offset System) as well as regulatory and instrument development (development of regulations and Pollution Prevention Planning requirements).

Verifier – Orasa Webber, M.Eng.

Ms. Webber has a Master’s Degree in chemical engineering from McGill University and has experience in a variety of environmental fields including National Pollutant Release Inventory (NPRI) reporting, ambient air quality and noise monitoring, environmental impact assessment, greenhouse gas (GHG) inventory, GHG verification and validation, and petroleum contaminated water/soil testing under Atlantic Risk-Based Corrective Action (RBCA) guidelines. She also has industrial experience in quality control of oil refinery products, polymer characterization, and processing and design of plastic products.


Page 3 of 3

Ms. Webber successfully completed the ISO-14064-3 (GHG Verification) training. She has experience on GHG verification projects under Alberta’s Specified Gas Emitters Regulation (SGER), Alberta’s Offset Credit, British Columbia Reporting Regulation, Ontario Regulation, The Massachusetts Department of Environmental Protection Regulation, and The Climate Registry. The GHG validation/verification projects have included the following sectors: Oil and gas extraction, production and refining, Power generation, Chemical and petrochemical production, Natural gas distribution systems, Metal, mining and mineral production, and Carbon capture and storage. Ms. Webber has also completed an introductory training for CALPUFF (air dispersion modelling) and is continuing development in air dispersion modelling as an area of interest.

Verifier – Christina Varner, P.Eng.

Christina has practiced environmental engineering, specializing in atmospheric environment, for seven years. She is a lead GHG verifier at Stantec, having completed over 70 GHG validation and verification projects for clients in oil and gas, chemical manufacture, electricity generation, commercial operations, and municipal governments. Christina has completed desktop reviews, reporting, and site visits for facility and project GHG inventories under Alberta’s SGER, British Columbia’s Emissions Offset Regulation and Reporting Regulation, The Climate Registry, Verified Carbon Standard, Ontario’s Environmental Protection Act 452/09, and Massachusetts’ Mandatory Greenhouse Gas Reporting Regulation.

Christina has been involved in air quality studies such as dispersion modelling, noise monitoring, source emissions testing, and ambient air quality monitoring. Her clients include pulp and paper mills, petroleum refineries, electricity generating stations, and asphalt plants. She has performed data collection and analysis for environmental assessments. Christina has created emissions inventories to address regulatory requirements and permitting, including National Pollutant Release Inventory (NPRI) and Environment Canada Greenhouse Gas program reporting.




Mike Murphy, PhD, P.Eng. Designated Signing Authority Quality Reviewer Environmental Services Tel: (902) 620-0253


STATEMENT OF VERIFICATION – CHIN CHUTE WIND POWER PROJECT (JANUARY 1 – DECEMBER 31, 2016)

Page 1 of 4

1.0 STATEMENT OF VERIFICATION

Blue Source Canada ULC (Blue Source) retained Stantec Consulting Ltd. (Stantec) on behalf of Suncor Energy Inc. (Suncor) to conduct a 3rd party verification of the Project Report and GHG Assertion, dated February 27, 2017 (version 5), for the Chin Chute Wind Power Project (Chin Chute Project).

The Chin Chute Project is owned by Enbridge Wind Power General Partnership (Enbridge), Acciona Wind Energy Canada Inc. (Acciona), and Suncor Energy Inc. (Suncor). Suncor has been authorized to act on behalf of the other two partners (e.g., they are authorized to serialize the offset credits generated by the Project).

In this work, Suncor Energy Inc. (Suncor) is responsible for the collection of data used in the greenhouse gas (GHG) emission calculations. Blue Source Canada ULC (Blue Source), a GHG emissions quantifier contracted by Suncor, is responsible for data management, completion of the calculations, presentation of the information within the Offset Project Report, and for the supporting technical documents. Acciona is responsible for the daily operations and management of the Chin Chute facility.

Stantec was responsible for planning and executing a 3rd party verification in order to deliver an opinion as to whether the Project Report is presented fairly and in accordance with the verification criteria. Stantec is a qualified third party verifier, as defined in Section 18 of the Specified Gas Emitters Regulation (SGER). Stantec is accredited with the American National Standards Institute (ANSI), a member of the International Accreditation Forum (IAF), in accordance with ISO 14065 (Accreditation ID #0805 issued to Stantec Consulting Ltd. for greenhouse gas (GHG) verification and validation).

1.1 INTENDED USER

This report has been prepared for Alberta Environment and Parks (AEP) for the express purpose of facilitating the creation of Emission Reduction Credits (ERCs) under the Climate Change and Emissions Management Act and the SGER.

1.2 VERIFICATION OBJECTIVE

The objective of the verification was to conclude as to whether the Project Report and GHG Assertion (as presented in Table 1.1), satisfied the AEP Verification Criteria in accordance with the Verification Standards (Sections 1.5 and 1.6).

1.3 PROJECT DETAILS

1.3.1 Location

The Chin Chute Project is located approximately 15 km southwest of Taber, Alberta.


Page 2 of 4

1.3.2 Description

The Chin Chute Project consists of twenty (20) 1.5 MW wind turbines for a total installed capacity of 30 MW. The Project generates emission reductions by displacing grid electricity with renewable, wind-powered electricity generation. The project includes a substation and an underground collection system. There is no electricity storage system on-site.

The baseline scenario for the Chin Chute Project is based on the combustion of fossil fuels to generate the equivalent amount of wind energy (30 MW). The project scenario includes quantification of GHGs associated with natural gas combustion in one office and storage unit in Lethbridge, electricity use in the office and storage unit, gasoline combustion in fleet vehicles, SF6 leakage from the switchgear, and the use of large diesel powered cranes if maintenance was performed during the year. Emission reductions are calculated as the difference between the Baseline emissions and the Project emissions.

1.3.3 Baseline and Project Conditions

The Baseline scenario is the production of an equivalent amount of electricity by a conventional fossil fuel power plant. Baseline emissions are estimated using the Project electricity production and a grid electricity emission factor developed by the Alberta Environment and Parks (AEP).

1.3.4 Emission Reduction Credit Period

Emission reductions have been verified for the period of January 1 – December 31, 2016.

1.4 GHG ASSERTION

The fundamental GHG Assertion verified is presented in Table 1.1 below.

Table 1.1 GHG Assertion

Year Baseline Emissions (t CO2e)

Project Emissions (t CO2e)

Emission Reductions (t CO2e)

January 1 – December 31, 2016 56,774 198 56,576

Notes: Emission Reductions are rounded down as per the Guidance. Totals may not sum due to rounding.

1.5 VERIFICATION CRITERIA

Stantec has conducted sufficient and appropriate procedures in order to express a reasonable level of assurance opinion as to whether the Project Report and the GHG Assertion satisfies the requirements of the:

• Climate Change and Emissions Management Act (the Act), SA 2003, c C-16.7; • Specified Gas Emitters Regulation, Alta Reg. 139/200, with amendments up to and including

Alberta Regulation 104/2015 (Regulation);


Page 3 of 4

• Technical Guidance for Offset Project Developers (version 4.0, February 2013); • Quantification Protocol for Wind-Powered Electricity Generation (version 1.0, March 2008);

and • The Carbon Offset Emission Factors Handbook (version 1.0, March 2015).

1.6 VERIFICATION STANDARDS

The verification was conducted in accordance with ISO 14064:3, ISO 14065, and the verification guidance contained within the Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance, January 2013, version 1.0 (the Verification Guidance).

1.7 UNRESOLVED DISCREPANCIES

AEP has set the materiality threshold for offset projects to 5% of the total reported GHG emission reductions or removals asserted. Qualitative discrepancies were at the discretion of the Lead Verifier. The following immaterial misstatements remain in the assertion; see the verification report for further details.

• The electricity consumption data for the Lethbridge offices ends on December 27, 2016 and therefore four days of electricity consumption data have not been included for quantification. The quantitative effect this error has on the emission reductions is immaterial to the assertion.

• The natural gas invoices provided do not support the data used to quantify project emissions. The magnitude of the misstatement is 4.52 t CO2e (over-reported emission reductions), which is less than 0.01% of the assertion.

1.8 OPINION

Based on the procedures undertaken and described in this report, the Project Report and GHG Assertion, dated February 27, 2017 (version 5), for the Chin Chute Wind Power Project satisfies the requirements of the:

• Climate Change and Emissions Management Act (the Act), SA 2003, c C-16.7; • Specified Gas Emitters Regulation, Alta Reg. 139/200, with amendments up to and including

Alberta Regulation 104/2015 (Regulation); • Technical Guidance for Offset Project Developers (version 4.0, February 2013); • Quantification Protocol for Wind-Powered Electricity Generation (version 1.0, March 2008);

and • The Carbon Offset Emission Factors Handbook (version 1.0, March 2015).

1.9 VERIFICATION CLOSURE

The findings presented herein were used to make a reasonable level of assurance opinion as required by AEP.

Stantec did not conduct direct GHG emissions monitoring or other environmental sampling and analysis in conjunction with this verification.


Page 4 of 4

Because of the inherent limitations in any internal control structure it is possible that fraud, error or non-compliance with other laws and regulations may occur and not be detected. Further, the verification was not designed to detect all weaknesses or errors in internal controls as the verification has not been performed continuously throughout the period and the procedures performed on the relevant internal controls were on a test basis. Any projection of the evaluation of control procedures to future periods is subject to the risk that the procedures may become inadequate because of changes in conditions, or that the degree of compliance with them may deteriorate.




Mike Murphy, PhD, P.Eng. Designated Signing Authority Quality Reviewer Environmental Services Tel: (902) 620-0253
