Verification Report for: Carbon Credit Solutions Inc ... · Carbon Credit Solutions Inc. Prepared...

Carbon Credit Solutions Inc. Tillage Project #28, Proj ID: 6092-7125 July 2018

Verification Report for:

Carbon Credit Solutions Inc. Tillage Project #28, Proj ID: 6092-7125

Proponent:

Carbon Credit Solutions Inc.

Prepared by:

Brightspot Climate Inc.

Prepared for:

Alberta Climate Change Office

Version: Final

July 26, 2018


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

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

3.0 Methodology ....................................................................................................... 10 3.1 Procedures ......................................................................................................... 10 3.2 Team ................................................................................................................. 20 3.3 Schedule ............................................................................................................ 22

4.0 Results ............................................................................................................... 22 4.1 Assessment of Internal Data Management and Controls ........................................... 22 4.2 Assessment of GHG Data and Information .............................................................. 23 4.3 Assessment against Criteria .................................................................................. 25 4.4 Evaluation of the GHG Assertion ............................................................................ 30 4.5 Summary of Findings ........................................................................................... 30 4.6 Opportunity for Improvement ............................................................................... 32

5.0 Closure .............................................................................................................. 32 5.1 Verification Statement .......................................................................................... 32 5.2 Limitation of Liability ............................................................................................ 32 5.3 Confirmations ..................................................................................................... 33

6.0 References.......................................................................................................... 34 Appendix A: Final Verification Plan and Sampling Plan ............................................................. 35 Appendix B: Statement of Qualifications ................................................................................ 58 Appendix C: Findings and Issues .......................................................................................... 61 Appendix D: Statement of Verification ................................................................................... 64 Appendix E: Conflict of Interest Checklist .............................................................................. 68 Appendix F: Supplemental Diagrams/Tables/Figures ............................................................... 71

List of Tables Table 1: Risk Assessment .................................................................................................... 14 Table 2: Findings of Data Integrity Verification Procedures....................................................... 23 Table 3: Findings of GHG Data and Information Verification Procedures ..................................... 24 Table 4: Findings of Criteria Verification Procedures ................................................................ 26 Table 5: Offset Criteria Assessment ...................................................................................... 29 Table 6: Summary of Findings .............................................................................................. 31 Table 7: Confirmation Findings ............................................................................................. 33 Table 7: Detailed Findings and Issues Log ............................................................................. 62 There are no additional diagrams, tables or figures appended in this section. ............................. 72

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


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

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


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1.0 Summary – Offset Project

Item Description

Project Title

Enter project title (must match the registry project title)

Carbon Credit Solutions Inc. Tillage Project #28

Project Description

Provide a brief description of the project and baseline conditions.

This project consists of the aggregation of carbon offsets generated from the direct and indirect reductions of greenhouse gas (GHG) emissions through zero tillage management in Alberta. The management of land using zero tillage results in reduced fossil fuel use by farm equipment, reduced fossil fuel use for the production of fertilizer and other amendments, and a decrease in the amount of soil carbon and nitrogen that is released to atmosphere. The project proponent is Carbon Credit Solutions Inc. This Offset Project Plan – Project #28 has been completed in accordance with the Alberta Offset System Conservation Cropping Quantification Protocol v1.0, April 2012 Technical Guidance for Offset Project Developers v4.0 (February 2013).

Project Location

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

Various farms throughout Alberta within the Parkland and Dry-Prairie eco-zones

Project Start Date

Enter the project start date.

January 1, 2015

Offset Start Date

Enter the start date for offset credit generation.

January 1, 2015

Offset Crediting Period

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

January 1, 2015 – December 31, 2020

Reporting Period

Enter the reporting period being verified.



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GHG Assertion (Actual Emission Reductions/Sequestration Achieved)

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

203,213 tCO2e

Protocol

Indicate the relevant protocol (if applicable)

Conservation Cropping Quantification Protocol version 1.0, April 2012

Ownership

Enter offset project owner.

Carbon Credit Solutions (CCSI) has the purchased right to register and sell the emission reduction credits from this project by contractual agreements with the farms involved. Land title records exist to demonstrate land ownership, and Consent Forms signed by all landowners exist to demonstrate ownership of offsets where landowner and farmer are not the same. Master contracts between the farmer CCSI establish CCSI’s right to purchase, register and sell the offsets.

Project Activity

State how the project activity meets the eligibility requirements

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

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

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

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

accurate estimation using replicable techniques.

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

Project Contact

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

Carley Laxdal Credit Development Manager Carbon Credit Solutions Inc. +1 (403)912-9132 [email protected]

Verifier

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

Aaron Schroeder, P.Eng. Brightspot Climate 225 West 8th Avenue, Suite 300 Vancouver BC V5Y 1N3 +1 (604) 353-0264

[email protected]


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Verification Team Members

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

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

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

Rodrigo Cubedo, Eng. Role: Associate Verifier Training: Graduate of Mechanical Engineering, McGill University, June 2016

Nathan Muegge, P.Eng. Role: Peer Reviewer Training: Greenhouse Gas Verification – ISO 14064-3, Canadian Standards Association

Designated Signing Authority

Enter the designated signing authority for this verification.

Aaron Schroeder, P.Eng. Brightspot Climate 225 West 8th Avenue, Suite 300 Vancouver BC V5Y 1N3 +1 (604) 353-0264 [email protected]

Verification Strategy

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

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


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1.1 Summary – Facility

Item Description

Facility Name and Company Name

List company name and facility name.

Not applicable for offset verification reports

Facility Description

Provide a brief description of the facility.


Baseline Emissions Intensity Description

List the approved BEIA and the baseline years.


Reporter Contact

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


GHG Assertion

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


Verifier

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


Verification Team Members

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


Designated Signing Authority

Enter the designated signing authority for this verification.



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

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

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

Summary of Offset Project Baseline

This project consists of the aggregation of carbon offsets generated by individual farmers through conservation cropping management in Alberta. These direct and indirect emission reductions are generated in accordance with the April 2012 Quantification Protocol for Conservation Cropping, v1.0. Conservation Cropping (CCP) management within Alberta is defined based upon the area, Parkland or Dry Prairie, in which the management occurs.

The CCP used a performance standard baseline methodology to quantify GHG emission reductions resulting from conservation cropping management practices. This means that sector level performance based on 2006 Census data was used to establish a sector level baseline for Alberta based on best practices for the sector and known levels of adoption of reduced and no till agriculture within Alberta’s Eco zones. The quantification of the emission reduction for each participating farm is calculated simply as the product of the eligible land area and the appropriate emission reduction factor.

Summary of Changes

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

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

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

The objective of the verification is as follows:

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

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

Standard for Verification, Section 5.1.3.


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2.2 Scope Define the scope in terms of: geographical, organizational, activities and processes, sources, sinks, categories and greenhouse gases included (considering the completeness of the inventory), GHG assertion time period.

For offset verifications: include the serial range (i.e. XXXX-XXXX-XXX-XXX-XXX-XXX to XXXX-XXXX-XXX-XXX-XXX-XXX) if assigned (i.e. in the case of government verification a serial range will be available, otherwise not applicable).

For Facilities: ensure all specified gases and source categories are evaluated. Include list of negligible emission sources and justification for Emission Performance Credits (EPCs). Include listing of end products.

Project Name: Carbon Credit Solutions Inc. Tillage Project #28

Serial Range: To be assigned at registration

Organizational Boundary: Aggregation of farms throughout Alberta

Geographic Boundary: Various farms throughout Alberta within the Parkland and Dry-Prairie eco-zones

Physical Operations: No-till cropping

Emission Sources: Soil Carbon and Nitrogen Dynamics Field Operations

IPCC GHGs Emitted/Removed: Carbon Dioxide (CO2)

Methane (CH4)

Nitrous Oxide (N2O);

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

Reporting Period: January 1, 2015 – December 31, 2017

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

Choose type of verification from the dropdown box above.

Provide explanation on level of assurance.

The Standard for Verification, Version 1.0, December 2017 requires that verifications must be designed and completed to a reasonable level of assurance.

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

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

• Climate Change and Emissions Management Act


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• Carbon Competitiveness Incentive Regulation (255/2017) • Standard for Greenhouse Gas Emission Offset Project Developers, Version 2.0, July 2018 • Standard for Validation, Verification and Audit, Version 2.0, June 2018 • Conservation Cropping Quantification Protocol version 1.0, April 2012

2.5 Materiality Define the materiality of the verification.

The materiality threshold is defined in the Standard for Verification, Version 1.0, December 2017. For this verification, the materiality threshold is 5%.

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

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

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

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

• Observations: the site visit included a tour of the farm sites to observe equipment used and confirm farming practices implemented. A file review at the Responsible Party’s office was also completed including a demonstration of their data management system.

• Review of documentation: Documents reviewed in the office visit included Farmer Contracts, Land Titles, Landlord Agreements, Land Area checks, Irrigation evidence, Equipment Photos, Crop Insurance, Crop Plans and P.Ag Signoffs.

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

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

performed.

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


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

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

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

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

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

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

Agreement (ISO Section 4.3)

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

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

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

Approach (ISO Section 4.4)

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

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

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


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

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

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

Verification Plan

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

The results of the verification risk assessment and the verification procedures (including the sampling plan) has been included in the Verification Plan, but will not be disclosed to the Responsible Party until the final Verification Statement is issued.

Assessment (ISO Sections 4.5 – 4.7)

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

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

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

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

d) The accuracy of the GHG emissions reduction calculations;

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

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

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

Site Visit

As none of the processes have changed since the last site visit in February 2018, a phone interview was conducted by Michelle Stelmach to answer any questions and confirm that there were no changes. A document review (Farmer Contracts, Land Titles, Landlord Agreements, Land Area checks, Irrigation evidence, Equipment Photos, Crop Insurance, Crop Plans and P.Ag Signoffs) was completed using the company’s online record system.

The following Responsible Party staff were interviewed regarding various aspects of the Project.

• Carley Laxdal, Credit Development Manager


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The farm site visits were conducted on June 19-21 2018 by Michelle Stelmach. Sixteen farms representing approximately 8% of the total aggregated assertion were visited. Farmers were interviewed about their farming practices and the tillage equipment was observed and compared to the photos on file with Carbon Credit Solutions Inc.

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

Verification Procedures

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

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

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

Evaluation and Statement (ISO Sections 4.8 – 4.9)

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

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

Peer Review

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

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

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

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

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

Verification Report

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


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

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

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

Inherent Risk × Control Risk × Detection Risk = Verification Risk

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

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

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

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

Table 1: Risk Assessment

Activity Data/ Inventory Component

Inherent Risk

Control Risk Detection Risk Design

Description

Protocol Applicability Requirements

Annual crops See “Field Level Eligibility”

Disturbance levels

See “Field Level Eligibility”


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Inherent Risk


Description

Reversal events Completeness – Low

Farm operators may not report all reversal events.

Control: CCSI interviews farmers to determine if reversal events have occurred.

Control risk: Interviews may not have identified reversal events (low risk).

High Control test – Interview farm operators during farm visits to determine if reversals have occurred over the 2015-2017 crop years.

Ownership See “Field Level Eligibility”

Irrigation, manure incorporation, reseeding


Quantification Data

Cropped area Accuracy – Low

Control: The land area claimed by the farm operator is compared against land titles and aerial images.

Control risk: control may not be applied (low risk).

High Substantive test (sampled) - Compare quantities shown in DMS to aerial images (Google Earth).

GHG reduction factors

Accuracy – High

Control: DMS applies the GHG reduction factor based on the ecozone determined by DMS.

Control risk: There may be an error in the DMS ecozone algorithm (low risk).

Low Substantive test – Recalculate GHG reduction factors using values in the Protocol and compare to factors applied in DMS.


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Inherent Risk


Description

Ecozone Accuracy – Medium

Control: DMS applies the ecozone.


Low Substantive test – Compare all legal land descriptions in the aggregated Project to the Alberta Agriculture and Forestry ecozone database.

Farm Level Eligibility and Documentation

Aggregator / Farm Operator contract

Completeness – Medium

Missing contracts

Control: The Credit Development Manager reviews each farm file for completeness.

Control risk: The Credit Development Manager may not complete the file review (medium risk).

Low Substantive test (sampled) – Confirm that aggregator/farm operator contracts have been executed and uploaded on DMS/DocSys.

Field Level Eligibility and Documentation

Land title certificate

Accuracy - Medium


Land title certificates may be missing or outdated



Medium Substantive test (sampled) – Confirm that land title certificates are uploaded on DMS/DocSys.

Farm Operator / Landowner contract


Contracts may be missing



Medium Substantive test (sampled) – Confirm that farm operator/landlord contracts have been executed and the acres are within the limits of the land title certificates.


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Inherent Risk


Description

Annual crops – farm records

Accuracy – Low


Potential errors in automated data management processes or manual entries



Medium Substantive test (sampled) – Confirm that farm records indicate an annual crop was grown on land in sample of aggregated assertion.

Annual crops – supporting records approved by a Professional Agrologist


Approval of supporting records by a Professional Agrologist may be missing

Control: The Quality Manager reviews each farm file for completeness.

Control risk: The Quality Manager may not complete the file review (medium risk).


Disturbance – farm records (including manure incorporation and reseeding events)

Completeness – High

Farm records may not completely represent the disturbance events.

Control: CCSI Sales Agents interview farmers to confirm information provided by farmers is accurate and complete.

Control risk: Interview may fail to identify or record disturbance events, (medium risk)

Medium Controls test – Interview farm operators with a series of questions during farm visits to determine if all disturbances that occur on the farm have been recorded in DMS. These questions include both typical and atypical farm activities that may constitute a disturbance event.


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Inherent Risk


Description

Discretionary tillage –disclosure

Completeness – Low

Farm records may not completely represent discretionary tillage events.

Control: CCSI interview farmers to confirm information provided by farmers is accurate and complete.

Control risk: Interview may fail to identify or record discretionary tillage. (medium risk)

High Substantive test (sampled) – Interview farm operators regarding discretionary tillage during farm visits.

Seeding equipment – record and photographs of equipment used

Accuracy – Medium Completeness – Medium

Photographs may not be on file or may not clearly illustrate opener width and spacing



Low Substantive test (sampled) – Compare equipment photos in the DMS/DocSys to observations made during farm visits. Also compare the measurements of opener width and shank spacing made during farm visits to the values recorded in the DMS.

Irrigation – aerial images and additional farm records approved by a Professional Agrologist

Accuracy – Low

Completeness – Low

Aerial images may not clearly indicate that irrigation occurred on land. Secondary documentation may not be on file.


Control risk: The Credit Development Manager may not complete the file review (low risk).

High Substantive test (sampled) – review aerial images to confirm that fields appear to have been irrigated. Review secondary documentation to confirm irrigation.

Emission Quantification and Reporting


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Inherent Risk


Description

Application of the approved quantification protocol

Accuracy (high)

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

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

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

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

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

Quantification of emission reduction

Accuracy (high)

Emission reduction calculation may contain arithmetic errors.

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

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

Data Integrity


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Inherent Risk


Description

Activity data and emission factor data integrity

Accuracy (high)

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

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

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

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

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

Transcription of final emission reduction into Offset Project Report

Accuracy (high)

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


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

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

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

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

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


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

Lead Verifier: Aaron Schroeder, P.Eng.

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

Biography: Aaron Schroeder has eleven years of professional experience analyzing, quantifying and verifying greenhouse gas emissions in North America. Prior to forming Brightspot Climate Inc. in 2015, Aaron worked for several years leading a team of fifteen greenhouse gas verification and policy analysts across Canada with ICF International. He provided leadership for this team and led the development of ICF’s standardized verification process, conformant with ISO 14064-3. In 2012, ICF’s verification process was accredited by the American National Standards Institute (ANSI).

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

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

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

Technical Specialist: Michelle Stelmach, P.Ag.

Biography:

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

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

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

Associate Verifier: Rodrigo Cubedo, B.Eng.

Biography: Rodrigo Cubedo has a background in mechanical engineering, specializing in aerospace projects. Rodrigo has leveraged his engineering experience to understand and systematically improve the processes used to work with international clients. He is fluent in Spanish, English, French and basic Mandarin. His experience working with a large accounting


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firm through an in-house deployment of analytical software exposed him to a systematic research framework, which he has recently used to complete GHG verifications.

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

Peer Reviewer: Nathan Muegge, P.Eng.

Biography: With over a decade of experience in the fields of energy and environment, Nathan has a broad background in the application and evaluation of conventional and emerging energy technologies. More recently service offerings are expanding into the fields of Health and Safety, Emergency Response and Preparedness, and Risk Assessments Services.

Training: Greenhouse Gas Verification – ISO 14064-3, Canadian Standards Association, 2009; Environmental Auditing, Legislation, Regulations and other Canadian Requirements, 2008

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

Verification Kickoff Meeting June 5, 2018

Draft Verification Plan June 5, 2018

Site Visit June 19-21, 2018

Supplementary Information Request July 3, 2018

Draft Verification Report July 20, 2018

Final Verification Report July 26, 2018

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

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

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

The Project’s GHG quantification is primarily performed in the Carbon Credit Solutions Inc. “Data Management System” database (“DMS”). All data required to quantify emissions reductions for the Project is either manually transcribed into this database or electronically transferred from other spreadsheets. The final calculated quantities from this database are transferred into the Offset Project Report. Carbon Credit Solutions Inc. utilizes a paperless filing


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system, so all documentation, equipment photos, maps, etc. are scanned or uploaded to their “DocSys” filing system.

DMS includes data controls to prohibit double entries of legal land descriptions. It also automatically assigns the Ecozone. It validates the equipment specification against the applicability criteria of the protocol.

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

Results of Verification Procedures

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

Table 2: Findings of Data Integrity Verification Procedures

GHG Report Element

Verification Procedures Verification Findings


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

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

No discrepancies detected.


The complete emission reduction was recalculated using the original data.



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

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


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

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


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

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

Table 3: Findings of GHG Data and Information Verification Procedures

GHG Report Element


Verification Findings

Quantification Data

Cropped area Substantive test - Compare quantities shown in DMS to aerial images (Google Earth).

The Responsible Party uses aerial images from Google Earth to substantiate the land areas claimed.



Substantive test – Recalculate GHG reduction factors using values in the Protocol.

GHG reduction factors were correctly calculated and applied.


Ecozone Substantive test (sampled) – Compare all legal land descriptions in the aggregated Project to the Alberta Agriculture and Forestry ecozone database.

The Protocol notes the Ecozone is determined using the map in Figure 5 of the Protocol or online at http://www1.agric.gov.ab.ca/$department/deptdocs.nsf/all/cl11708.

The Responsible Party’s online database, DMS, has a control set up to determine the Ecozone based on this map compared to the LLD of each field.


Emission Quantification and Reporting


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

The recalculation of the emission reduction matched Carbon Credit Solution Inc.’s calculation.



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GHG Report Element


Verification Findings

Application of approved quantification protocol

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

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

The Responsible Party’s Offset Project Plan follows the methodologies described in the quantification protocol.

The recalculation matched the quantity reported by Carbon Credit Solutions. Therefore, the methods applied by the Responsible Party are proven to match the methods described in the quantification protocol.



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

The Responsible Party’s Offset Project Plan follows the methodologies described in the quantification protocol.

The recalculation matched the quantity reported by Carbon Credit Solutions Inc. Therefore, the methods applied by the Responsible Party are proven to match the methods described in the quantification protocol.


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

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

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


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Table 4: Findings of Criteria Verification Procedures

GHG Report Element


Protocol Applicability Requirements


Disturbance levels


Reversal events Control test – Interview farm operators during farm visits to determine if reversals have occurred over the 2015, 2016 or 2017 crop years.

Undisclosed reseeding was detected on one farm during the farm visits.

An immaterial qualitative discrepancy is discrepancy is detailed in Appendix C as Item 17-01.




Farm Level Eligibility and Documentation

Aggregator / Farm Operator contract

Substantive test (sampled) – Confirm that aggregator/farm operator contracts have been signed and filed.

A sample of aggregator/farm operator contracts were viewed and determined to be complete and on file.


FIELD LEVEL ELIGIBILITY AND DOCUMENTATION

Land title certificate

Substantive test (sampled) – Confirm that current land title certificates correspond with lands included in Project #28.

All land titles in the selected sample were confirmed to be current and match with the lands included in Project #28.



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GHG Report Element



Substantive test (sampled) – Confirm that farm operator/landlord contracts have been executed and the acres are within the limits of the land title certificates.

After review of the sample, the farmer operator/landlord contracts were signed, filed and the acres were checked and found to be within the limits of the land title certificates.



Substantive test (sampled) – Confirm that farm records indicate an annual crop was grown on land in sample of aggregated assertion.

The farm records that were reviewed in the sample specified that only annual crops were grown.



Substantive test (sampled) – Confirm that farm records indicate an annual crop was grown on land in sample of aggregated assertion.

The data management system was observed and sampled, and it denoted that a Professional Agrologist had reviewed and approved that annual crops were grown.



Controls test – Interview farm operators with a series of questions during farm visits to determine if all disturbances that occur on the farm have been recorded in DMS. These questions include both typical and atypical farm activities that may constitute a disturbance event.

Undisclosed reseeding was detected on one farm during the farm visits.

An immaterial qualitative discrepancy is detailed in Appendix C as Item 17-01.

Discretionary tillage was identified on one farm during the farm visits.



Substantive test (sampled) – Interview farm operators regarding discretionary tillage during farm visits.

Discretionary tillage exceeding the threshold defined in the Protocol was detected on one field during the farm visits.



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GHG Report Element



Substantive test (sampled) – Compare equipment photos in the Carbon Credit Solutions Inc. data management system to observations made during farm visits. Also compare the measurements of opener width and shank spacing made during farm visits to the values recorded in the Carbon Credit Solutions Inc. data management system.

After reviewing a sample of the photos on file the documentation appeared to be consistent with the equipment observed on the farm visits.



Substantive test (sampled) – review aerial images to confirm that fields appear to have been irrigated.

Substantive test (sampled) – confirm that additional farm records, beyond aerial images, have been filed.

After comparing a sample of the irrigated quarter sections in the Responsible Party’s database, the irrigation was clearly viewed on the Google Earth images and AFSC (crop insurance) documentation.



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Table 5: Offset Criteria Assessment

Offset Eligibility Criteria

Assessment

Reduction or sequestration occurs in Alberta

The aggregated project includes sub-projects in locations throughout Alberta. The Spatial Locator was reviewed to confirm all locations are within the Province of Alberta.

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

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

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

January 1, 2015.

Reduction or sequestrations is real and demonstrable

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

Quantifiable and measurable

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

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

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


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4.4 Evaluation of the GHG Assertion The verification assessment is that the GHG Assertion meets the requirements of the Carbon Competitiveness Incentive Regulation

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

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

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

There were two discrepancies detected through the course of the verification that have not been corrected in the final GHG Assertion. These discrepancies are described in the following section. The aggregated of these discrepancies were within the materiality threshold established at the outset of the verification.

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

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


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Table 6: Summary of Findings

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

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

Understatement / Overstatement

Tonnes CO2e % net

Tonnes CO2e % absolute

17-01 Immaterial Qualitative

Reversal Event: One field identified during farm visits consisting of 65 acres exceeded the discretionary tillage threshold and is therefore ineligible.

Overstatement N/A N/A


Reseeding Event: One farm reseeded five quarters of land due to poor germination of the first crop seeded. The total disturbance between the original seeding and the reseeding event exceeded the disturbance eligibility threshold.

Overstatement

N/A N/A


Tillage Event: One farm uses vertical tillage on some land. Although this practice is not specifically excluded by the Protocol, the Responsible Party has declared a conservative policy of excluding vertical tillage lands.

Overstatement N/A N/A

Total Error N/A N/A


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

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

Overall, the GHG information was orderly and thoroughly presented.

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

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

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

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

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

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

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

Provide the verification conclusion in the drop down box below.

The verification conclusion is:

Positive

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

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

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

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


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

Section 5.1.3 of the Standard for Verification document lists seven activities that are beyond the scope of a typical greenhouse gas verification.

Table 7: Confirmation Findings

Confirmation Confirmation Finding

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

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

Quantification Methodology document is provided and consists of the required components

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

Simplified process flow diagrams and energy diagrams

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

Fuel usage This requirement is not applicable to Offset Projects.

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

The Statutory Declaration was reviewed and found to be complete.

The Spatial Locator was reviewed.

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

This requirement is not applicable to Offset Projects.

Project report information details as required The Responsible Party has prepared an Offset Project Report that meets all the requirements specified in the Standard for Greenhouse Gas Emission Offset Project Developers, Version 1.0, December 2017


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

The documents reviewed through the course of the verification include:

• Carbon Credit Solutions. 2018. Offset Project Plan for Carbon Credit Solutions Inc. Tillage Project #28.

• Carbon Credit Solutions Inc. 2018. Tillage Project #28 Offset Project Report

• Carbon Credit Solutions Inc. 2018. Tillage Project #28 workbook.xlsx

• Carbon Creidt Solutions Inc. 2018. Processes and procedures documents:

• DMS database and DocSys (Application, Contract, Equipment Photos, Equipment Declaration, Rented Land Report, Satellite Review, Farmer Crop Insurance, Professional Agrologist Approvals of documentation)

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Appendix A: Final Verification Plan and Sampling Plan


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

Revisions to the sampling plan

Date originally sent to Facility/project

Level of assurance agreed with the facility/project developer

Verification scope

Verification criteria

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

Methodologies for determining representative samples

Sampling Plan and Procedures

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

- Details of site visit

-offset/facility boundaries

- Methodologies, emissions factors and conversions used

- Comparability with the approved baseline

- Conformance to the program criteria

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

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

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

- Other relevant information

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

Carbon Credit Solutions Inc.

Tillage Project #28 Verification Plan

June 5, 2018

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Brightspot Climate Inc. – Verification Plan Carbon Credit Solutions Inc. – Tillage Project #28

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

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

The Alberta Climate Change Office Standard for Verification1 extends this definition to include the document that identifies the greenhouse gas emission reduction and/or removals and emissions offsets being claimed by the offset project over a defined period of time.

Project: activity or activities that alter the conditions identified in the baseline scenario which cause greenhouse gas emission reductions or greenhouse gas removal enhancements.

The GHG Assertion subject of this verification is for Carbon Credit Solutions Inc. Tillage Project #28, which will be referred to throughout this document as “the Project”.

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

Responsible Party: person or persons responsible for the provision of the greenhouse gas assertion and supporting GHG information.

The Responsible Party for this verification is Carbon Credit Solutions Inc. (Carbon Credit Solutions).

Intended User: individual or organization identified by those reporting GHG-related information as being the one who relies on that information to make decisions.

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

Verifier: competent and independent person, or persons, with the responsibility of performing and reporting on the verification process.

The Verifier for this verification is Brightspot Climate Inc. (Brightspot Climate). The members of the verification team are provided in section 2 of this document.

1 Standard for Verification, Version 1.0, December 2017, Alberta Climate Change Office.


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Introduction This document serves to communicate information between the parties associated with the independent verification of the Offset Project Report for the Carbon Credit Solutions Inc. Tillage Project #28.

This document contains six sections:

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

2. The Verification, which defines the verification parameters and the GHG inventory principles that will be tested by the verification. This section also provides information regarding the verification team and site visit;

3. The Responsible Party Data Management and Controls, which describes the data management system and control environment implemented by the Responsible Party;

4. The Verification Risk Assessment and Verification Procedures, which describes the risks of potential errors, omissions or misrepresentations to the overall GHG assertion and the verification procedures that have been developed to reduce the overall verification risk; and

5. The Sampling Plan, which lists the verification procedures that could apply sampling of the project data, along with the sampling size, the sampling methodology and justification.

The Responsible Party developed the Project in accordance with the requirements of the Conservation Cropping Quantification Protocol version 1.0, April 2012 (the Protocol).

GHG Quantification Principles ISO 14064-2 defines six principles that are fundamental to the fair accounting and reporting of GHG information. The verification procedures will test that these principles have been upheld through the Responsible Party’s inventory, accounting and reporting processes.

Section 3.2 – 3.6 of ISO 14064-1 defines these principles as follows:

Accuracy: reduce bias and uncertainty as far as practical

Completeness: include all relevant emission sources

Conservativeness: use conservative assumptions, values and procedures to ensure that GHG emission reductions or removal enhancements are not over-estimated

Consistency: enable meaningful comparisons of reported emissions (from year to year or between facilities or between companies)

Relevance: select GHG sources, sinks and reservoirs, data and quantification methodologies appropriate to the needs of the intended user

Transparency: disclose sufficient and appropriate GHG information to facilitate verification and to allow intended users to make decisions with relative confidence


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Verification Verification Principles ISO 14064-3 defines four fundamental principles to conducting a greenhouse gas verification, namely independence, ethical conduct, fair presentation and due professional care.

Brightspot Climate has implemented processes, including mandatory training for all verification team members, to ensure the application of these principles for this verification.

Regarding the principle of independence, Brightspot Climate conducted an assessment of threats to independence prior to initiating this verification. No real or perceived threats to independence were identified. Brightspot Climate will continue to monitor for threats to independence throughout the course of this verification. A final “Conflict of Interests Checklist” will be appended to the Verification Statement.

Verification Parameters The verification will be conducted according to the parameters defined in the following table: Table 1: Verification Parameters

Level of Assurance Reasonable assurance

Objectives

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

• issue a verification report that provides details of the verification activities; and

• complete the “confirmations” activities defined in the Standard for Verification2, Section 5.1.3.

Criteria

• Climate Change and Emissions Management Act

• Carbon Competitiveness Incentive Regulation (96/2018)

• Standard for Greenhouse Gas Emission Offset Project Developers, Version 2.0, July 2018

• Standard for Validation, Verification and Audit, Version 2.0, June 2018

• Conservation Cropping Quantification Protocol version 1.0, April 2012

2 Standard for Verification, Version 1.0, December 2017, Alberta Climate Change Office.


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Scope

Project Name: Carbon Credit Solutions Inc. Tillage Project #28

Geographic Boundary: Various farms throughout Alberta within the Parkland and Dry-Prairie eco-zones

Physical Operations: No-till cropping

Emission Sources: Soil Carbon and Nitrogen Dynamics Field Operations

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

Reporting Period: January 1, 2015 – December 31, 2017

Materiality Quantitative materiality threshold is 5% of asserted greenhouse gas emission reduction.

Preliminary Verification Schedule

Verification Kickoff Meeting June 5, 2018

Draft Verification Plan June 5, 2018

Site Visit June 18-22, 2018

Draft Verification Report July 20, 2018

Final Verification Report July 26, 2018

Verification Team Aaron Schroeder, P.Eng., will be the Lead Verifier and Designated Signing Authority for this verification. His extensive experience quantifying and verifying greenhouse gas emissions satisfies all sixteen subject matter areas defined in the ISO 14064-3.

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

Rodrigo Cubedo, Eng. will provide analytical support to the verification team through the completion of the verification procedures and the development of the Verification Report.

Nathan Muegge, P.Eng., will conduct an independent peer review of the verification.

Additional information regarding the qualifications of the verification team will be provided in a Statement of Qualifications, which will be appended to the Statement of Verification.

Site Visit Safety Requirements Personnel conducting farm visits are required to wear steel-toed boots and exercise caution when driving on rural roads.


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Responsible Party Data Management and Controls Data Management Systems The Credit Development Manager has the primary responsibility for collecting GHG information, quantifying the emission reduction and completing required documentation. The Sales Support Team assists with the collection of the information and the QA/QC Team is responsible for reviewing the files for completeness and correctness.

The Responsible Party uses the Carbon Credit Solutions Inc. Data Management System (‘DMS”) to manage GHG information and quantify the emission reduction. This database contains all farm and field level data, applies data controls and quantifies the emission reduction. Carbon Credit Solutions Inc. utilizes a paperless filing system, so all documentation, equipment photos, maps, etc. are scanned or uploaded to their “DocSys” filing system. Table 2, below, describes the data measurement, estimation and data storage locations for all GHG information used by the Responsible Party to produce the GHG inventory. The final column in this table describes the data storage location and the path (intermediate data transfer) prior to use in the GHG inventory.” Table 2: GHG Information Data Management

Activity Data Description Measurement Type Data Storage Location / Path

Cropped Area

Crop insurance records, land title certificates, landlord agreements

>> Original records >> DocSys >>DMS

GHG Reduction Factors Calculated from Protocol values

>>Quantification Protocol >> DMS

Ecozone Logical value defined by legal land description

>> Alberta Agriculture and Forestry Dataset >> DMS

Irrigation Logical value declared by project developer

>> DocSys >>DMS


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

that have been designed and implemented within their quality assurance/quality control framework. The accuracy and completeness of the documentation of the Responsible Party’s controls will be reviewed through the course of the verification.

The following processes, procedures and systems have been employed by the Responsible Party and are divided into 3 Stages: Data Collection, Data Entry and QA/QC Processes. Within each of these 3 stages are automatic and manual controls to ensure the credits generated are sound.

• Data Collection – Farmers submit their information along with their Sales Agents in the application. When all of the information is collected, including equipment photographs, crop insurance/crop plans, etc. it is passed on to Data Entry.

• Data Entry – The information package is reviewed by Data Entry to determine if it is eligible, and to confirm ownership of the lands. All farm lands must meet the CCSI internal standards as well as those of the protocol to be eligible to generate credits. After they are deemed eligible and entered into DMS and documents loaded into DocSys, a “Project Data Check” report is generated which highlights any errors in the data entry. After these issues are addressed, the file moves into QA/QC.

• QA/QC – The file and all supporting documents are now reviewed by QA/QC for correctness and completeness as well as Google Earth Pro images are used to ensure correct crop areas are being used. After this process is complete, the file is “locked down” and the farmer must review and sign off that it is correct and complete. If there are any changes, they go through the QA/QC process again. Only after it is signed off by the farmer and approved by a CCSI manager will the credits be available for verification and sale.

• A new Offset Project Plan is developed for each Project. The Credit Development Manager reviews the document for accuracy, completeness, consistency, relevance and transparency. The OPP documents:

o Farm and field eligibility requirements o Farm-level data collection o Field-level data collection o GHG emission reduction quantification methodology o Documentation requirements and document sources o Data management o Data quality controls and procedures, including data collection, data entry into DMS,

data maintenance and validation, emission reduction calculation and reporting.


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Previous GHG Assertions Changes to Operations and Boundaries There have not been any modifications to the original project since the original Offset Project Plan was developed.

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

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

Inherent Risk × Control Risk × Detection Risk = Verification Risk

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

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

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

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


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Table 3: Verification Risk Assessment Summary

Activity Data / Inventory Component

Inherent Risk Control Risk Detection Risk Design

Description of Verification Procedure

PROTOCOL APPLICABILITY REQUIREMENTS


Disturbance levels See “Field Level Eligibility”

Reversal events Completeness – Low Farm operators may not report all reversal events.

Control: Carbon Credit Solutions interviews farmers to determine if reversal events have occurred.

Control risk: Interviews may not have identified reversal events (low risk).

High Control test – Interview farm operators during farm visits to determine if reversals have occurred over the 2015-2017 crop year.





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QUANTIFICATION DATA

Cropped area Accuracy – Low Control: The land area claimed by the farm operator is compared against land titles and aerial images.

Control risk: control may not be applied (low risk).

High Substantive test (sampled) - Compare quantities shown in DMS to aerial images (Google Earth).

GHG reduction factors Accuracy – High Control: DMS applies the GHG reduction factor based on the ecozone determined by DMS.


Low Substantive test – Recalculate GHG reduction factors using values in the Protocol and compare to factors applied in DMS.

Ecozone Accuracy – Medium Control: DMS applies the ecozone.


Low Substantive test – Compare all legal land descriptions in the aggregated Project to the Alberta Agriculture and Forestry ecozone database.


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FARM LEVEL ELIGIBILITY AND DOCUMENTATION Aggregator / Farm Operator contract

Completeness – Medium Missing contracts



Low Substantive test (sampled) – Confirm that aggregator/farm operator contracts have been executed and uploaded on DMS/DocSys.

FIELD LEVEL ELIGIBILITY AND DOCUMENTATION Land title certificate Accuracy - Medium

Completeness – Medium Land title certificates may be missing or outdated



Medium Substantive test (sampled) – Confirm that land title certificates are uploaded on DMS/DocSys.


10





Completeness – Medium Contracts may be missing



Medium Substantive test (sampled) – Confirm that farm operator/landlord contracts have been executed and the acres are within the limits of the land title certificates.


Accuracy – Low Completeness – Medium Potential errors in automated data management processes or manual entries





Completeness – Medium Approval of supporting records by a Professional Agrologist may be missing





11





Completeness – High Farm records may not completely represent the disturbance events.


Control risk: Interview may fail to identify or record disturbance events, (medium risk)

Medium Controls test – Interview farm operators with a series of questions during farm visits to determine if all disturbances that occur on the farm have been recorded in DMS. These questions include both typical and atypical farm activities that may constitute a disturbance event.


Completeness – Low Farm records may not completely represent discretionary tillage events.


Control risk: Interview may fail to identify or record discretionary tillage. (medium risk)



Accuracy – Medium Completeness – Medium Photographs may not be on file or may not clearly illustrate opener width and spacing



Low Substantive test (sampled) – Compare equipment photos in the DMS/DocSys to observations made during farm visits. Also compare the measurements of opener width and shank spacing made during farm visits to the values recorded in the DMS.


12





Accuracy – Low Completeness – Low Aerial images may not clearly indicate that irrigation occurred on land. Secondary documentation may not be on file.


Control risk: The Credit Development Manager may not complete the file review (low risk).

High Substantive test (sampled) – review aerial images to confirm that fields appear to have been irrigated. Review secondary documentation to confirm irrigation.

EMISSION REDUCTION QUANTIFICATION

Application of the approved quantification protocol

Accuracy (high)

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

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

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

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


13




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


Accuracy (high)

Emission reduction calculation may contain arithmetic errors.


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

DATA INTEGRITY


Accuracy (high)

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

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

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

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



14





Accuracy (high)

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


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


15

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

The sampling size, the sampling methodology and their respective justifications are also described in the following table. Table 4: Sampling Plan


Detection Risk Design


Sample Size Sampling Methodology and Justification

Land title certificate Medium Substantive test (sampled) – Confirm that land title certificates are uploaded on the Carbon Credit Solutions data management system.

121 fields in aggregated assertion (90% confidence level, 7.5% confidence interval); appropriate for the defined Detection Risk.

Random sampling; discrepancies are normally distributed.


Medium Substantive test (sampled) – Confirm that farm operator/landlord contracts have been executed and uploaded on the Carbon Credits Solution data management system.









16 farms in the aggregated assertion, representing 8% of the aggregated assertion; appropriate for the defined Detection Risk.



16






Low Substantive test (sampled) – Compare equipment photos in the Carbon Credit Solutions data management system to observations made during farm visits. Also compare the measurements of opener width and shank spacing made during farm visits to the values recorded in the Carbon Credit Solutions data management system.




High Substantive test (sampled) – review aerial images to confirm that fields appear to have been irrigated. Substantive test (sampled) – confirm that additional farm records, beyond aerial images, have been filed and approved by a Professional Agrologist.

39 of 752 fields in aggregated assertion (80% confidence level, 10% confidence interval): appropriate for the defined Detection Risk

Random sampling; discrepancies are normally distributed. The emission reduction from fields with irrigation comprises only approximately 3% of the aggregated emission reduction.

Cropped area High Substantive test (sampled) - Compare quantities shown in ADS to aerial images (Google Earth).




17






Low Substantive test – Recalculate GHG reduction factors using values in the Protocol and compare to factors applied in ADS.

All Only 3 factors to review.

Ecozone Low Substantive test – Compare all legal land descriptions in the aggregated Project to the Alberta Agriculture and Forestry ecozone database.

All Reviewing all records requires the same level of effort as reviewing a sample of records.

Page 58 of 72

Appendix B: Statement of Qualifications

Page 59 of 72

Statement of Qualifications

Offset Report Project Name Offset Project ID

Carbon Credit Solutions Inc. Tillage Project 6092-7125

Reporting Company Legal Name Report Type Reporting Period

Carbon Credit Solutions, Inc. Offset Report from


to

Signature of Third Party Verifier

I, Aaron Schroeder

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

Verifying Company Name

Brightspot Climate Inc. Per: Aaron Schroeder

Signature of Third Party Verifier Date:

Training Received Under ISO 14064 Part 3

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

First Name Last Name

Aaron Schroeder

Professional Designation E-mail Address Phone Number

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

Lead Verifier

� Same as third party verifier??

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

July 26, 2018

Page 60 of 72

Peer Reviewer First Name Last Name Nathan Muegge E-mail Address Phone Number

[email protected]> Nathan: (647) 280-0410

Training Received Under ISO 14064 Part 3

• Greenhouse Gas Verification – ISO 14064-3, Canadian Standards Association, 2009 • Environmental Auditing, Legislation, Regulations and other Canadian Requirements, 2008

Page 61 of 72

Appendix C: Findings and Issues

Page 62 of 72

Table 7: Detailed Findings and Issues Log

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

Item (YR-##)

Description of the Issues Investigated During the Verification

Summary of information exchanged between Verifier and Responsible Party

Resolution Conclusion

17-01 Reversal Event: The Protocol defines a reversal event as tillage or other types of soil disturbance that can cause previously sequestered soil carbon to be re-released into the atmosphere. It also states that a reversal event that affects more than 10% of a given field is not considered business as usual for normal farm activities. These events over 10% of a field must be documented in the Offset Project Report and removed from the project condition for that project vintage year.

One farm operator indicated that he did have a reversal event (tillage) on 65 acres (100% of the field) in 2017 and did not report it on his application. The Responsible Party was, therefore, not aware of this until after it was discovered on the farm visit. This 65 acre field was removed from the project condition.

Since the farm operator did not openly admit to this reversal event when filling out his application, there was no way for the Responsible Party to have caught this through their control process.

The Responsible Party investigated this issue and determined that the subproject farmer did not appropriately disclose the reseeding event.

The affected field was removed from the aggregated project.

Further testing of the Responsible Party’s controls for discretionary tillage revealed no issues

Despite the discovery of one instance where the control failed, the control testing found that the control is effective at identifying and preventing ineligible fields from entering the project.

The qualitative discrepancy is deemed to be immaterial.

Page 63 of 72

17-02 Reseeding Event: The Protocol states that up to two passes are allowed with low disturbance openers (up to 38% each) to apply seed, fertilizer or manure.

The Responsible Party’s process is to interview the farmer and record the type and specification of seeding equipment used and record the number of disturbances made. The Responsible Party then inputs the equipment and number of disturbances into their database.

After conducting the on-farm site visits, one farm was found to have reseeded some of its land in 2015 and this was not recorded on the Responsible Party’s application.

The Responsible Party investigated this issue and found that the seeding equipment being used did not meet the eligible specifications in the Protocol that would permit a second disturbance.

The Responsible Party removed the affected land from the project.

The root cause analysis of this issue concluded that this was a one-off scenario.

The qualitative discrepancy is deemed to be immaterial.

17-03 Tillage Event: One farm was identified during the farm visits uses a vertical tillage practices on some land. The vertical tillage was not reported to the Responsible Party.

Vertical tillage is not specifically disallowed in the protocol; however, the Responsible Party has chosen a conservative policy with vertical tillage and does not allow land in their projects under this practice.

The Responsible Party’s controls that should identify vertical tillage failed to identify this instance.

The root cause analysis determined this issue to be a breakdown in the Responsible Party’s control.

The Responsible Party removed the affected land from the project.

Since the affected land meets the eligibility requirements of the Protocol, the qualitative discrepancy is deemed to be immaterial.

Page 64 of 72

Appendix D: Statement of Verification


Page 65 of 72

Statement of Verification Associated SGER Submission

Offset Project Protocol Project ID #

Carbon Credit Solutions Inc. Tillage Project #28,

Conservation Cropping Quantification Protocol version 1.0, April 2012 6092-7125

Project Developer Serial Range Start Report Period

Carbon Credit Solutions, Inc. N.A.


Serial Range End

N.A.

Statement of Verification

GHG Assertion

Value Units

Total Baseline Emissions 203,213 tonnes CO2e

Total Project Emissions 0 tonnes CO2e

Other N.A. tonnes CO2e

Net Reductions 203,213 tonnes CO2e


Page 66 of 72

Statement of Assertion

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

The GHG Assertion covers the reporting period January 1, 2015 – December 31, 2017 and states an emission reduction and removal claim of 203,213 tonnes CO2e over this period.

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

Responsibilities of Project Developer and Third Party Verifier

Our responsibility as the Verifier is to express an opinion as to whether the GHG Assertion is materially correct, in accordance with approved Protocol, the Carbon Competitiveness Incentive Regulation (the “Regulation”), and the Alberta Climate Change Office – Standard for Greenhouse Gas Emission Offset Project Developers, Version 1.0, December 2017.

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

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

Conclusion

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

There were three immaterial qualitative misstatements in the final GHG Assertion.

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





Date:

July 26, 2018


Page 67 of 72

First Name Last Name

Aaron S Schroeder

Professional Designation E-mail Address

Phone Number

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

Page 68 of 72

Appendix E: Conflict of Interest Checklist

Page 69 of 72

Conflict of Interest Checklist

Associated SGER

Submission Offset Project Protocol

Carbon Credit Solutions Inc. Tillage Project #28

Conservation Cropping Quantification Protocol version 1.0, April 2012

Project Developer Report Type Report Period

Carbon Credit Solutions, Inc. Offset Report


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

1.

The relationship between my firm and this reporting company poses unacceptable threat to or compromises the impartiality of my firm.

False

2.

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

False

3.

The personnel my firm has scheduled to participate in the verification may have an actual or potential conflict of interest.

False

4.

My firm participated in some manner in the development or completion of the associated offset submission for this reporting company.

False

5.

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

False

6.

My firm will use personnel that have, are, or will be engaged or previously employed by the reporting company.

False

7.

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

False

8.

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

False

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


Page 70 of 72


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

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



Signature of Third Party Verifier Date:

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

July 26, 2018

Page 71 of 72

Appendix F: Supplemental Diagrams/Tables/Figures

Page 72 of 72

There are no additional diagrams, tables or figures appended in this section.

Limitation of Liability

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

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

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