KPMG Performance Registrar Inc. Box 10426, 777 Dunsmuir Street Vancouver BC V7Y 1K3 Canada Telephone (604) 691-3000 (604) 691-3401 Telefax (604) 691-3031 www.kpmg.ca Corey Wilson Commercial Manager 141 50 Avenue SE Calgary, AB T2G 4S7 Dear Mr. Wilson: Re: ISO 14064-3 Verification Review Report for Our ISO 14064-3 Verification Review Report for is attached. The report documents the results of the verification that took place during the period February 1, 2010. We value the ongoing working relationship that we have with, and appreciate the assistance provided to the verification team by Company staff and others during the verification process. If you have any questions regarding the results of the verification please call me at the phone number listed below. Yours truly, Tim Clarke Senior Manager KPMG Performance Registrar Inc. (604) 646 6456 Enc: ISO 14064-3 Verification Review Report for Wholly owned subsidiary of KPMG LLP, the Canadian member firm of KPMG International, a Swiss nonoperating association.
ISO 14064 Verification Review Report for Kettles Hill Greenhouse Gas Offset Project
Table of Contents A. Client Information... 1 B. Verification Details... 1 C. Verification Findings... 3 D. Verification Statement... 5
ISO 14064-3 Verification Review Report Page 1 A. Client Information Client Name: Client Representative: Assessment Number: #2573 B. Verification Details Mr. Corey Wilson Verification Standard: ISO 14064 Part 3 Verification Criteria: Alberta Environment quantification Protocol for Wind-Powered Electricity Generation Kettles Hill Greenhouse Gas Offset Project Offset Project Plan Climate Change and Emissions Management Act Specified Gas Emitters Regulation Offset Credit Verification Guidance Document (Version 1, September 2007) General Offset Credit Methodology Protocol (Version 1, January 2010) Level of Assurance: Verification scope: Limited assurance (defined in Alberta Environment s Offset Credit Verification Guidance Document as negative assurance). The scope of the verification is the net offset credit generated by the Kettles Hill Greenhouse Gas Offset Project for the January 1, 2009 to December 31,2009 Verification date(s): Verification planning and document review: February 1 and 5, 2010 On-site Verification : February 8, 2010 February 11, 2010 Verification Completion and Reporting: February 22 February 23, 2010 Materiality Alberta Environment has set a quantitative materiality of 5%
Verification procedures: ISO 14064-3 Verification Review Report Page 2 The procedures used to conduct the verification involved a combination of: (1) documentation and records review, and (2) staff interviews. The review procedures included: Review of the 2009 Offset Project - Inventory tracking spreadsheet and cross-checking of selected energy generation and sales data to source records; Test-checking the accuracy of source records for power generation and DTS loads against AESO data for the windfarm; Test-checking of contracts for green energy sales to confirm sales and delivery commitments; Review of the tracking spreadsheet and underlying calculations to confirm the formula references and accumulation of data and re-performance of a sample of the calculations; Test-checking the accuracy of the allocation of green energy sales against Kettles Hill generation; Reviewing ownership of emission reduction rights associated with the windfarm; and Site visit to the Kettles Hill windfarm to verify the location, existence and onsite sources, sinks and reservoirs of GHG emissions. Multi-site sampling N/A - Single site. Verification team: Lead auditor: Tim Clarke Audit team member: Sylvi Holmsen Audit team member: Terence Wells Technical Reviewer Chris Ridley-Thomas Report distribution: Confidentiality requirements: Use of the Verification Mark: KPMG verification files Alberta Environment Any further distribution of the verification statement by ENMAX Energy Corporation must include the complete verification statement and associated assertion. Except as required by law, a legal or judicial process, a professional duty and the requirements of our accreditation, KPMG, will treat as strictly confidential any information which comes into the possession of its officers, directors, employees or agents in the course of conducting the verification of ENMAX Energy Corporation s Greenhouse Gas assertion. Not Applicable
ISO 14064-3 Verification Review Report Page 3 C. Verification Findings Control Environment A limited assurance engagement does not contemplate certain verification procedures such as performing tests of internal control over reporting to evaluate design and implementation or testing operating effectiveness. Hence, no opinion is provided on the effectiveness of internal controls. Controls in place include: a) Electricity generation is metered by the Alberta Electric System Operator (AESO) at the point of supply (POS) into the Alberta Interconnected Electric System at the respective substations through Measurement Canada certified meters. b) Demand transmission service is the net from grid electrical energy consumed by the facilities. DTS is metered at the facilities substations by AESO through Measurement Canada certified meters. c) Vehicle mileage related to plant operations is captured using estimates supplied by plant operators. d) Emissions from fuel extraction are also derived from estimated vehicle mileage. e) On-site batteries and switchgear containing SF 6 are inspected monthly. f) REC Sales & Billing To ensure that no double counting of greenhouse gas emission reductions that are eligible as offsets under the SGER, the electricity generation associated with Renewable Energy Certificates that have been sold or otherwise transferred to another owner are not included in the quantification of GHG offsets from the projects. Sales of Renewable Energy Certificates are tracked in the 2009 Inventory & Allocation spreadsheet based on allocations against each contract. g) Record Retention ENMAX Corporation has specific document retention policies addressing the management of records from creation to final disposition and in the case of GHG Offsets the records are kept for a period of seven years as specified by the SGER protocol. GHG Calculation methods and assumptions The baseline condition for wind-powered electricity generation is the net energy production of the wind farm multiplied by 0.65 tonnes per MWh as specified by Alberta Environment. The project condition is the sum of the emissions from facility operation, emissions associated with on-site electricity storage systems and the indirect emissions associated with extraction and processing of the fuel used on-site. For the project condition, the Company estimated vehicle mileage for plant operation based on NRCan annual average fuel consumption data. The Company assumed that there were no emissions from on-site electricity storage systems (limited to sealed lead acid batteries) and SF 6 switch gear based on automated monitoring of equipment for low SF 6 levels. Total emissions associated with the project condition were determined to be immaterial and related primarily to fuel consumption. The green attributes of wind power production may also be sold to residential and commercial customers in the form of Renewable Energy Certificates (RECs) and similar products. As a result,
ISO 14064-3 Verification Review Report Page 4 sales of such products that were attributable to the energy produced by the windfarm were deducted from net generation in MWh prior to calculating the number of offsets available. GHG Assertion Our assessment of the GHG assertion did not identify any nonconformities. No material discrepancies were identified during the review. The immaterial discrepancies identified were negligible in size and the GHG assertion was adjusted except as described under opportunities for improvement. Opportunities for improvement Without qualifying our verification statement the following opportunities for improvement were identified during the audit: 1. Emissions Associated with facility operation were calculated at approximately 11 tonnes of CO2e per year. These were not deducted in the calculation of offset credits on the basis that they are negligible consistent with direction provided in Section 5.1.1 of the Technical Guidance For Completing Baseline Emissions Intensity Applications, Version 2.0 January 2009. However, this direction applies to compliance reports and is not provided in the applicable offset credit project guidance documents produced by Alberta Environment. As a result, there is an opportunity to improve the accuracy of the quantification approach in the offset project plan by deducting negligible facility emissions from the offset credit claimed.
ISO 14064-3 Verification Review Report Page 5 D. Verification Statement To Alberta Environment: We have been engaged by (the Company) to examine the greenhouse gas (GHG) emission reduction of 90,360 tonnes of CO 2 equivalent presented in the Company s Kettles Hill Greenhouse Gas Offset Project Report (the Report) for the period January 1, 2009 to December 31, 2009. The Company is responsible for the preparation and presentation of the information within the Report. Our responsibility is to express a conclusion as to whether anything has come to our attention to suggest that the greenhouse gas emission reduction is not presented fairly in accordance with Alberta Environment s approved quantification methodology (Quantification Protocol for Wind-Powered Electricity Generation Version 1, March 2008) for this project; the Specified Gas Emitters Regulation, and the associated guidance documents. We completed our review in accordance with ISO 14064-Part 3 Specification with Guidance for the validation and verification of greenhouse gas assertions. As such, we planned and performed our work in order to provide limited, rather than absolute assurance with respect to the greenhouse gas emission reduction. Our review criteria were based on Alberta Environment s approved quantification methodology (Quantification Protocol for Wind-Powered Electricity Generation Version 1, March 2008); the Specified Gas Emitters Regulation and associated guidance documents. We believe our work provides a reasonable basis for our conclusion. A review does not constitute an audit and, consequently, we do not express an audit opinion on the greenhouse gas reduction. Based on our review, nothing has come to our attention that causes us to believe that the greenhouse gas emission reduction presented in the Report is not, in all material respects, presented fairly in accordance with the relevant criteria. Chris Ridley-Thomas President
KPMG PRI Box 10426, 777 Dunsmuir Street Vancouver BC V7Y 1K3 Canada Telephone (604) 691-3000 (604) 691-3401 Telefax (604) 691-3031 www.kpmg.ca Introduction KPMG PRI STATEMENT OF QUALIFICATION KPMG PRI has conducted a verification of the greenhouse gas offset credit assertions prepared by ENMAX Energy Corporation in relation to offsets associated with the McBride Lake and Kettles Hill Wind farms. Statement of Qualification KPMG PRI meets the qualifications for third party auditors as stated in Section 18 of the Specified Gas Emitters Regulation Review Team Qualifications The review team comprised 3 auditors and a technical reviewer. The team had: Knowledge and experience of the greenhouse gas offset system all members of the team have conducted research with respect to the Alberta greenhouse gas offset system as part of the preparation for the review. This included the Offset Credit Project Guidance Document, the Offset Credit Verification Guidance Document and the Quantification Protocol for Wind-Powered Electricity Generation. Three members of the team have previously conducted verification under the Offset Credit Verification Guidance Document and the Quantification Protocol for Wind-Powered Electricity Generation. Knowledge and experience of greenhouse gas science All members of the team have successfully completed the ISO 14064 lead auditor course. Three members of the team have prior audit experience directly related to green power audits requiring the determination/use of emission reductions based on the generation of an equivalent quantity of electricity from fossil fuel based sources. All members of the team have sufficient knowledge with respect to the sinks and sources associated with wind-powered electricity generation as defined by Alberta Environment. Knowledge and experience of data assurance methodologies one of the team is a chartered accountant in Canada, one is a Professional Engineer (P. Eng. Alberta). All of the team members are ISO 14001 Environmental Management Systems Lead Auditors and two are also ISO 9001 Quality Management Systems Lead Auditors. Science related and/or industry expertise All members of the team have prior experience in auditing green power programs, green power contracts, green energy tracking and trading in green power certificates. Chris Ridley-Thomas President February 22, 2010
Appendix C: Conflict of Interest Checklist Question Yes No 1. Can the verifying organization or the verification team members directly benefit from a financial interest in the Project Developer or the Project Developer s Project? For example: Owning shares of the Project Developer; Having a close business relationship with the Project Developer; Contingent fees relating to the results of the engagement; Potential employment with the Project Developer; or Undue concern about the possibility of losing the verification or other fees from the Project Developer. 2. Can the verifying organization or verification team members be in a position of assessing their own work? For example: Involvement of the verification organization in the compilation of the data contained in the GHG assertion. Involvement of the verification organization in the development of a quantification protocol other than protocol recognized or recommended by the regulatory authority. A verification organization member performing non-verification services that directly impinge on the client s GHG assertion, such as implementing the GHG data management system, or having performed validation services on the project being reviewed; A member of the verification engagement team having previously been a GHG data compiler of the Project Developer or who was employed by the Project Developer in a position to exert direct and significant influence over the Project Developer's GHG assertion being verified. 3. Does the verifying organization or a member of the verification team, or a person in the chain of command for the verification, promote or be perceived to promote, a Project Developer's position or opinion to the point that objectivity may, or may be perceived to be, compromised? For example: Dealing in, or being a promoter of, GHG credits on behalf of a Project Developer; or Acting as an advocate on behalf of the Project Developer in litigation or in resolving disputes with third parties. 4. Is one or more of the verification team too sympathetic to the Project Developer's interests by virtue of a close relationship with a Project Developer, its directors, officer or employees? For example: A person on the verification team has a close personal relationship with a person who is in a senior GHG compilation role at the Project Developer; or The verification team or a person of influence on the verification team has accepted significant gifts or hospitality from the Project Developer. X X X X
Question Yes No 5. Is a member of the verification team or a person in the chain of command is deterred from acting objectively and exercising professional scepticism by threats, actual or perceived, from the directors, officers or employees of the Project Developer. For example: The threat of being replaced as a third party verifier due to a disagreement with the application of an GHG quantification protocol; Fees from the Project Developer represent a large percentage of the overall revenues of the verifying organization. The application of pressure to inappropriately reduce the extent of work performed in order to reduce or limit fees; or Threats of litigation from the Project Developer. X Chris Ridley-Thomas, President