Offset Verification Report for Carbon Credit Solutions Inc. Tillage Project #21

Transcription

1 Offset Verification Report for Carbon Credit Solutions Inc. Tillage Project #21 Reporting Period: January 1, 2015 December 1, 2017 Prepared for: Carbon Credit Solutions Inc. For Submission to: Alberta Environment and Sustainable Resource Development 12th Floor Baker Centre Street NW Edmonton, Alberta T5J 1G4 December 4, 2017 Ruby Canyon Engineering 743 Horizon Ct. Suite 385 Grand Junction, Colorado (970)

2 Table of Contents 1.0 Project Summary Information Verification Summary Information Introduction Objective Scope Program Criteria Verification Strategy Verification Plan Sampling Plan Verification Schedule Verification Findings Confirmations Statement of Verification Appendices... A Appendix A: Statement of Verification... 1 Appendix B: Statement of Qualifications... 2 Appendix C: Conflict of Interest Checklist... 3 Appendix D: Subproject Tracking Form... 4 Appendix E: Verification Plan... 5 Appendix F: Sampling Plan... 9 Carbon Credit Solutions Inc. Tillage Project #21 Page i

3 1.0 Project Summary Information Project Title: Carbon Credit Solutions Inc. Tillage Project #21 Project Description Project Location Carbon Credit Solutions Inc. uses the Alberta government approved protocols Specified Gas Emitters Regulation Quantification Protocol for Conservation Cropping Version 1.0 April 2012 which sets out the requirements for quantification of greenhouse gas ( GHG ) emission reductions associated with a change from conventional or full tillage ( FT ) to no-till ( NT ) on the Province of Alberta s agricultural soils. Carbon Credit Solutions Inc. Tillage Project #21 has been completed in accordance with the Technical Guidance for Offset Project Developers (version 4.0 February 2013). This Project consists of the aggregation of greenhouse gas ( GHG ) emission reductions generated through the change in best management practices. The aggregated project activities include farm lands throughout the Province of Alberta. Project Start Date: January 1, 2014 Credit Start Date: January 1, 2015 Credit Duration Period: Expected Lifetime of the Project: Actual Emissions Reductions / Removals Achieved: January 1, 2014 December 31, 2020 This is the verification report for the second reporting period, January 1, 2015 to December 1, The expected lifetime of this project is from January 1, 2014 to December 31, 2020 The project emission reductions as a result of this project since January 1, 2014 (the project credit start date) are: ,391 tonnes CO2e (previous verification) ,964 tonnes CO2e ,331 tonnes CO2e ,043 tonnes CO2e Total quantity 240,729 tonnes CO2e Applicable Quantification Protocol(s): Specified Gas Emitters Regulation Quantification Protocol for Conservation Cropping Version 1.0 April 2012 Carbon Credit Solutions Inc. Tillage Project #21 Page 1

4 Other Environmental Attributes: Project Registration: The Project is not generating any other environmental attributes/credits/benefits. CCSI has signed a Statutory Declaration that includes a statement that the project will not be registered anywhere outside the Alberta Offset System. The Project will only be registered once and in one offset system, the Alberta Offset Registry. Ownership Carbon Credit Solutions Inc. is an aggregator and is acting as an Agent as defined in section Considerations for Aggregated Projects in the Technical Guidance for Offset Project Developers (version 4.0 February 2013). Carbon Credit Solutions Inc. has obtained legal right to transact on the offset credits on behalf of the credit producer. Ownership of the greenhouse gas emission reductions has been established as per land ownership and lease agreements. Contractual agreements for aggregation of the GHG emission reductions exist between the tenant/farmer and Carbon Credit Solutions Inc. or between the landowner and Carbon Credit Solutions Inc. Carbon Credit Solutions Inc. Tillage Project #21 Page 2

5 Project Activity: The Project involves aggregating farms that shift from conventional farming to conservation cropping. RCE confirmed that the project meets all eligibility requirements outlined in the Specified Gas Emitters Regulation: 1) Occurs in Alberta all subprojects are located in Alberta confirmed via land title agreements. 2) Actions not otherwise required by law project activity (conservation cropping) occurs at non-regulated facilities. The responsible parties create offsets through a voluntary action. 3) Actions taken on or after January 1, 2002 the project start date is January 1, 2014 beginning with the 2014 crop year. 4) Real, demonstrable, quantifiable the verification procedures confirmed that the GHG assertion is based on actual measurements of fields using satellite imagery. 5) Clearly established ownership All farmers and land owners sign contracts that clearly transfer any and all rights to carbon credits generated at the field level to CCSI. 6) Counted once for compliance purposes the responsible party provided a declaration that the emission reductions will be registered only in the Alberta Offset System. Project Contact Carbon Credit Solutions Inc. David Marinucci COO East Lake Rd N.E. Airdrie, AB Canada Phone: david@carboncreditsolutions.ca Carley Laxdal Project Manager East Lake Rd N.E. Airdrie, AB Canada Phone: carley@carboncreditsolutions.ca Carbon Credit Solutions Inc. Tillage Project #21 Page 3

6 2.0 Verification Summary Information Objective Summary Lead Verifier The objective of verification activities was to express an opinion, based on a reasonable level, of assurance about CCSI s GHG assertion including an opinion on the controls in place to limit uncertainty and provide adequate documentation of all required evidence in order to claim GHG emission reductions. RCE reviewed CCSI s controls and also performed substantive testing to ensure that the claimed GHG emission reductions were within scope, real, quantifiable, additional, verifiable, counted once, under clear ownership, and that the Project was in compliance with project additionality, monitoring, and reporting requirements. Ruby Canyon Engineering (RCE) verified Carbon Credit Solutions Inc. (CCSI) s Tillage Project #21 (Project). The greenhouse gas (GHG) assertion of the project is 168,338 tonnes carbon dioxide equivalent (CO2e). RCE verified that the processes used to determine the emissions reductions were reasonable and reproducible and followed the protocol. After determining that the calculation processes and formulas were correct, RCE recalculated the emission reductions. RCE conducted a risk based analysis of the Project according to ISO Part 3 Greenhouse Gases: Specification with Guidance of the Validation and Verification of Greenhouse Gas Assertions, the Quantification Protocol for Conservation Cropping Version 1.0, April 2012 (Protocol), the Technical Guidance for Greenhouse Gas Verification at Reasonable Level of Assurance Version 1.0, January 2013 (Guidance) and the Specified Gas Emitters Regulation (SGER). RCE concludes with reasonable assurance that the Project GHG assertion of 18,964 tonnes CO2e for January 1, 2015 December 31, 2015, 38,331 tonnes CO2e for January 1, 2016 December 31, 2016 and 111,043 tonnes CO2e for January 1, 2017 December 1, 2017 for a total of 168,338 CO2e claimed in the Project Report is materially correct and is a fair representation of the Project activities resulting from the reduction of CO2, CH4, and N2O emissions. Phillip Cunningham, Environmental Scientist Carbon Credit Solutions Inc. Tillage Project #21 Page 4

7 Team Members Subject Matter Experts Peer Reviewer Designated Signing Authority Aaron Schroeder, P. Eng. Michelle Stelmach, P. Ag. Michael Coté, President & Senior Environmental Engineer Zach Eyler, Vice President No Subject Matter Experts needed Samantha Phillips, Environmental Scientist Ronald Collings P.E., Vice President and Professional Engineer Verification Dates October 27 December 1, 2017 Site Visit Dates November 13 17, 2017 Report Date December 4, 2017 Carbon Credit Solutions Inc. Tillage Project #21 Page 5

8 3.0 Introduction Carbon Credit Solutions Inc. (CCSI) contracted Ruby Canyon Engineering (RCE) to perform the third-party greenhouse gas (GHG) verification of the Tillage Project #21 (Project). The project consists of aggregated emission reductions achieved by participants changing farming practices from conventional farming to conservation cropping to sequester carbon in the soil in Alberta. Implementation of the project activity also reduces nitrous oxide emissions from agricultural soils and reduced greenhouse gas emissions due to reduced fuel consumption. CCSI used controls to capture and process relevant data as well as conservative measures to determine eligibility criteria and parameters for calculating emission reductions. The greenhouse gases relevant to the project include carbon dioxide (CO2), methane (CH4) and nitrous oxide (N2O). The reporting period covered during the verification is January 1, 2015 December 1, The Protocol uses a performance standard baseline methodology to quantify emission reductions from conservation cropping management practices. Tillage system management uses a performance standard baseline from Alberta 2006 Census data. Therefore, participants do not need to establish a baseline for each individual farm. CCSI collected sufficient evidence supporting proof of no-till practices for all farms aggregated in the Project. CCSI calculated emission reductions according to the Quantification Protocol for Conservation Cropping Version 1.0, April 2012 (Protocol). 4.0 Objective The objective of verification activities was to ensure that the claimed GHG emission reductions are materially correct and a fair representation of Project activities in accordance with the SGER, Protocol and relevant guidance and determine if the GHG assertion is materially correct to a reasonable level of assurance within a materiality threshold of 5%. RCE s goal was to confirm that the GHG emission reductions were within scope, real, quantifiable, additional, verifiable, counted once, and under clear ownership. 5.0 Scope RCE used the following scope to verify the GHG assertion to a reasonable level of assurance: The organization boundaries and the GHG project and its baseline scenario includes farmlands throughout Alberta who practice conservation cropping as opposed to traditional cultivation The physical infrastructure, activities, technologies and processes of the organization or GHG project include farmers who practice conservation cropping using seeders with shank spacing at intervals that create no more than a 38% soil disturbance each with two passes or no more than 46% soil disturbance with one vehicle pass to apply seed, fertilizer or manure The GHG sources, sinks and/or reservoirs include herbicide production, soil carbon and nitrogen dynamics and field operations The types of GHGs include CO2, CH4 and N2O Carbon Credit Solutions Inc. Tillage Project #21 Page 6

9 The time periods include January 1, 2015 December 31, 2015, January 1, 2016 December 31, 2016 and January 1, 2017 December 1, Program Criteria Criteria Details Alberta Specified Gas Emitters Regulation, Alberta Reg. 139/2007 (With amendments up to and including Alberta Regulation 199/2015) Quantification Protocol for Conservation Cropping Version 1.0 (April 2012) Technical Guidance for Offset Project Developers v4.0 Standards and (February 2013) Protocols for Technical Guidance for Greenhouse Gas Verification at Verification Reasonable Level Assurance v1.0 (January 2013) ISO Specification with guidance for the validation and verification of greenhouse gas assertions Offset Project Plan for Carbon Credit Solutions Inc. Tillage Project #21 (December 2014) Offset Project Report for Carbon Credit Solutions Inc. Tillage Project #21 (November 2017) Reporting Period January 1, 2015 December 1, 2017 Level of Assurance Reasonable Assurance Materiality A +/ 5 percent materiality threshold 7.0 Verification Strategy RCE tailored the verification strategy, included testing CCSI s controls and substantive testing on evidence required for a Conservation Cropping Project, to specific data streams, controls and evidence available for the offset project. The verification strategy drives the verification plan and consequently the sampling plan. The verification team reviewed a mix of control processes functioning within CCSI s database as well as performing substantive tests on original data. CCSI relies on several control steps to ensure that all Protocol required documentation is in place prior to registering offsets. RCE tested the database controls during an office visit and field visits. The verification findings section describes in detail the tests performed on Project data. There were no quantitative material findings, one immaterial finding, and no unresolved material errors or qualitative findings. 8.0 Verification Plan See appendix E for the verification plan. 9.0 Sampling Plan See appendix F for the sampling plan. Carbon Credit Solutions Inc. Tillage Project #21 Page 7

10 10.0 Verification Schedule As the first step in verification activities, RCE developed a verification plan to follow throughout the verification. The verification plan included the following activities listed below. Verification Activity RCE s Internal Auditor completed of a Project Conflict of Interest (COI) form by to identify any potential conflict with the Project or Project developer. The COI assessment revealed no conflicts of interest. RCE held a verification kick off meeting via conference call. During the kick off meeting RCE reviewed the verification objectives and process, the verification schedule, and requested the verification background documents. RCE performed a strategic review and risk assessment of the received data and support documents in order to understand the scope and areas of potential risk in the GHG emissions reductions. RCE developed a risk based desktop sampling plan based upon the strategic review and risk assessment. The sampling plan revolved around assessing the GHG management system in place, information control systems, appropriate application of emissions factors, identifying project boundaries, and the cross checking of GHG calculations and the QA/QC procedures used to assure data quality. The verification plan and sampling plan were used throughout the verification and revised as necessary based upon additional perceived risks. The RCE team conducted a site visit to CCSI s office (during a previous verification) and a representative amount of farms. During the site visit RCE performed key personnel interviews, reviewed CCSI s database management system, observed the on-site GHG management systems, data gathering, monitoring, and handling practices and inspected seeding equipment. RCE performed a risk based desktop review of the submitted verification documents. The desktop review included an assessment of the GHG calculation methods and inputs, completeness of source documentation, evidence of ownership, GHG management and monitoring systems, project qualification relative to start date, evidence of the project activity following the project plan, and company record retention practices. RCE submitted a List of Findings document that included requests for corrective actions, immaterial discrepancies, additional documentation and clarifications. Date 10/25/ /27/ /8/ /8/ /1/ /13/ /17/ /8/ /1/ /30/2017 Carbon Credit Solutions Inc. Tillage Project #21 Page 8

11 RCE s independent peer reviewer conducted a review of the verification sampling, verification report and statement. RCE developed a final Verification Report, Verification Statement, Qualifications Statement, and Conflict of Interest Checklist. 12/1/ /4/2017 RCE held an exit meeting with the client. 12/4/ Verification Findings RCE confirmed that the project meets all eligibility requirements outlined in the Specified Gas Emitters Regulation and Alberta s offset system: Occur in Alberta; Result from actions not otherwise required by law and be beyond business as usual and sector common practices; Result from actions taken on or after January 1, 2002; Occur on or after January 1, 2002; Be real, demonstrable, quantifiable, and verifiable; Have clearly established ownership; and Be counted once for compliance purposes. 1) Ownership of the farm field CCSI purchases land titles from Alberta s SPINII website when new farms are included in a project to confirm who owns each land parcel. Because the government of Alberta does not re-use title numbers, CCSI has developed a computer program to download land title numbers and compare the number to the land title numbers that are currently in their database. If the land titles on the SPINII website and CCSI s database are the same, then CCSI can confirm that for each reporting period, the owner has not changed. If a land title does not exist in the database for any land parcel, CCSI's system will not issue credits. If the land title owner is different from the farm listed in the database, CCSI s system generates a land title consent form that the owner must sign prior to credits being issued to a farmer. RCE tested this control during a previous office site visit by reviewing the database that houses CCSI s documentation of eligibility and confirmed that this control had no errors. During this verification, RCE reviewed an output for each farm selected for sampling and confirmed that if a land title had changed or could not be located, then CCSI did not claim credits for that specific parcel of land. RCE confirmed that this control is operating and that there were no errors. 2) Right to transact on offset credits CCSI requires all land owners to sign a consent form who lease land to any farmers that participate in the Project. The consent form Carbon Credit Solutions Inc. Tillage Project #21 Page 9

12 includes legal wording stipulating that the land owner transfers all rights to the emission reduction credits to the tenant. The tenant subsequently transfers all rights to the emission reduction credits to CCSI. RCE performed a substantive test on a representative number of farms (refer to Appendix A for details). The test included confirming that if the owner listed on the land title agreement does not match the farmer listed in the database for a parcel of land, then a consent form must be in place. RCE confirmed that all agreements were in place for the sample tested and that there were no errors. 3) Field size and location being claimed CCSI uses measurements of aerial images as one source of field size in production data. RCE performed a substantive test on a representative number of fields (refer to Appendix A for details). The test included reviewing Google Earth satellite imagery and determining whether CCSI excluded parts of fields that participants did not seed (bodies of water, roads, dwellings etc.) in the calculation of emission reductions. A team member also performed a site visit to a subset of farms and confirmed that participants reviewed CCSI s data. If the farmers discovered an error for their data, CCSI corrected the data. RCE confirmed that deductions for non-cropped areas were not included in the calculation of emission reductions and that there were no errors. 4) Ecozone protocol area classification CCSI has connected their internal database to the database of ecozones provided by Alberta Agriculture and Forestry. RCE compared all land included in the assertion spreadsheet to the ecozone information for each quarter section in the Alberta Agriculture and Forestry database to the ecozone listed in the CCSI database and confirmed that CCSI had appropriately assigned ecozones. RCE confirmed that this control is operating and that there were no errors. 5) Existence of an annual crop, or first year of seeding of a perennial crop CCSI collects evidence that every field in the project is in production of an annual crop or the first year of a perennial crop. The CCSI project files contain evidence of crop types including crop insurance for each land parcel in a crop year as well as an application that each participant fills out identifying the crop type seed for each crop year. For land where crop insurance records are not available, CCSI requires seed receipts that are reviewed and approved as evidence by a professional agrologist of an annual crop. RCE performed a substantive test on a representative number of fields (refer to Appendix A for details) by reviewing crop insurance data and applications or crop plans Carbon Credit Solutions Inc. Tillage Project #21 Page 10

13 signed by a professional agrologist where applicable. RCE confirmed that the annual crop in CCSI s database matched the records provided for the samples selected. RCE also reviewed CCSI s control in place to check for errors regarding annual crops during a previous site visit. RCE confirmed that this control is operating and that there were no errors. 6) Occurrences of soil disturbance on each farm field being claimed CCSI field agents visit each farm and farmer included in the Project or interview farmers over the phone. The field agents interview each farmer to confirm the number of passes made on fields included in the project as well as whether the farmer performed any discretionary tillage during the crop year. RCE performed a control and substantive test to determine the occurrence of soil disturbance. A verification team member visited 13 farms in both the Dry Prairie and Parkland Eco Zones and across three separate geographic regions. The visits accounted for approximately 6.2% of total offsets claimed. The team member interviewed farmers regarding discretionary tillage, manure injection and number of passes made on fields included in the Project. The team also confirmed that CCSI removed fields from the project that had performed discretionary tillage above the Protocol threshold, had performed more than one pass that did not qualify, or performed manure injection. There was one discrepancy identified during the field interviews. There was one immaterial discrepancy found: Based on the information collected through inquires conducted during farm visits, it was discovered that one farm (Iron Creek Colony) had injected liquid manure on 610 acres (approx. over 4 quarters). Some of this area was reported to CCSI but not all of it. After further inquiry, it was determined that the farmer didn t report the correct LLD to CCSI. CCSI was contacted and all of this land was removed from the pool. 450 acres out of 168,338 (0.27%). The total discrepancy is less than 0.27% of the overall asserted emission reduction In all other instances, RCE confirmed that this control is operating. 7) Seeding/fertilizer specifications used each year CCSI field agents visit each farm and farmer included in the Project or interview farmers over the phone. The field agents photograph the equipment serial numbers and shank spacing. A ruler/tape measure is included in the photograph in order for CCSI office employees to confirm that opener widths and shank spacings meet the requirements of the Protocol. RCE performed a control and substantive test to determine the specifications used each year. A verification team member visited 13 farms in both the Dry Prairie and Parkland Eco Zones and across three separate geographic regions. The visits accounted for Carbon Credit Solutions Inc. Tillage Project #21 Page 11

14 approximately 6.2% of total offsets claimed. The team member recorded serial numbers of equipment and measured the shank spacing. RCE confirmed that this control is operating and that there were no errors. 8) Reseeding events, if applicable CCSI field agents visit each farm and farmer included in the Project or contact farmers over the phone each crop year. The field agents record whether any re-seeding events take place. This information is entered into CCSI s database and recorded on the application form. RCE performed a control test to determine whether this information is accurate. A verification team member visited 13 farms in both the Dry Prairie and Parkland Eco Zones and across three separate geographic regions. The visits accounted for approximately 6.2% of total offsets claimed. The team member interviewed the farmers about any re-seeding events that occurred in the applicable crop year. RCE confirmed that this control is operating and that there were no errors. 9) Use of irrigation in Dry Prairie Ecozone, if applicable CCSI tracks all fields in their database and records information on whether a field is irrigated. For fields irrigated in the Dry Prairie Ecozone, CCSI collects evidence of irrigation practices including crop insurance and satellite imagery of pivots. If crop insurance did not exist for a farm, CCSI requested the crop management plan. RCE performed a substantive test to confirm at least two types of evidence are on file for each irrigated field in the sample (refer to Appendix A for details). RCE confirmed that this control is operating and that there were no errors Confirmations Confirmations are beyond the scope of a greenhouse gas verification, but are activities AESRD requires verifiers to perform during the verification. Confirmations determine whether the information reported in the greenhouse gas assertion are accurate (e.g., responsible party, address, dates, title, consistency across documents, etc.). AESRD requires the following information to be confirmed: Confirmation Item Consistency of offset project information across offset project documentation Offset project location and any applicable approvals information Methodology documents or procedures manual exist Statement of Confirmation Confirmed Not Confirmed Confirmed Not Confirmed Confirmed Not Confirmed Carbon Credit Solutions Inc. Tillage Project #21 Page 12

15 Offset project contact, report dates, emission reduction numbers, etc. (part of one above) Completeness and accuracy of process and data flow diagrams Confirmed Not Confirmed Confirmed Not Confirmed 13.0 Statement of Verification The Statement of Verification is listed in Appendix A. Carbon Credit Solutions Inc. Tillage Project #21 Page 13

16 Appendices Carbon Credit Solutions Inc. Tillage Project #21 Page A-A

17 Appendix A: Statement of Verification Carbon Credit Solutions Inc. Tillage Project #21 Page A-1

18 Statement of Verification Carbon Credit Solutions Inc. Tillage Project #21 December 4, 2017 Director, Climate Change Secretariat Alberta Environment and Sustainable Resource Development 12th Floor, Baker Centre Street Edmonton, Alberta T5J 1G4 Ruby Canyon Engineering (RCE) submits this statement of verification to Alberta Environment and Sustainable Resource Development for the Carbon Credit Solutions Inc. Tillage Project #21 located at various farm locations throughout Alberta. The aggregated project includes conservation cropping activities at 556 farms throughout Alberta, Canada that practice conservation cropping. RCE conducted a risk based analysis of the Carbon Credit Inc. Tillage Project #21 GHG assertion including a strategic review of the Project data and supporting documentation. During the verification processes, RCE reviewed the evidence collected and provided in the following documents: Offset Project Plan for Carbon Credit Solutions Inc. Tillage Project #21 (December 2014) Offset Project Report for Carbon Credit Solutions Inc. Tillage Project #21 (November 2017) Verification Data Package Project 21 for January 1, 2015 December 1, 2017 Land title agreements, satellite imagery files, crop insurance, photo documentation of equipment, and other documents to confirm conformance with the Protocol RCE concludes that the GHG assertion in the Project Report is materially correct and is a fair representation of the Project activities resulting from the reduction of CO2, CH4, and N2O emissions. The reporting period covers January 1, 2015 through December 1, The Project can be considered in conformance with: Alberta Specified Gas Emitters Regulation, Alberta Reg. 139/2007 (With amendments up to and including Alberta Regulation 199/2015) Technical guidance for Offset Project Developers (February, 2013), Quantification Protocol for Conservation Cropping Version 1.0 (April 2012), Technical Guidance for Greenhouse Gas Verification at a Reasonable Level of Assurance, Version 1.0 (January 2013) ISO Greenhouse gases Part 3: Specification with guidance for the validation and verification of greenhouse gas assertions

19 RCE concludes to a reasonable level of assurance that the GHG assertion is without material discrepancy or material changes in how the project was carried out compared to the offset project plan. The verified emission reductions are listed below in Table 1. Emissions Verified Table 1: Emission Reductions Verified for January 1, 2015 December 1, CO 2 e CO 2 e CO 2 e (metric tons) (metric tons) (metric tons) Total CO 2 e (metric tons) Baseline Emissions 18,964 38, , ,338 Project Emissions Emission Reductions 18,964 38, , ,338 Lead Verifier Independent Peer Reviewer Signature Phillip Cunningham Ruby Canyon Engineering, Inc. 743 Horizon Ct. Suite 385 Grand Junction, Colorado (970) pcunningham@rubycanyoneng.com Samantha Phillips Ruby Canyon Engineering, Inc. 743 Horizon Ct. Suite 385 Grand Junction, Colorado (970) mcote@rubycanyoneng.com Designated Signing Authority Signature Ronald C. Collings, PE Ruby Canyon Engineering, Inc. 743 Horizon Ct. Suite 385 Grand Junction, Colorado (970) rcollings@rubycanyoneng.com

20 Appendix B: Statement of Qualifications Carbon Credit Solutions Inc. Tillage Project #21 Page A-2

21 December 4, 2017 Director, Climate Change Secretariat Alberta Environment and Sustainable Resource Development 12th Floor, Baker Centre Street Edmonton, Alberta T5J 1G4 Designated Signing Authority: Ronald Collings P.E., Vice President and Senior Engineer Mr. Mr. Collings is a Registered Professional Engineer in Colorado, U.S.A., with specialized knowledge in petroleum engineering and coal bed and coal mine methane recovery. Mr. Collings has worked in various aspects of hydrocarbon exploration and production since He was a Petroleum Engineer with Chevron Corporation for 18 years from 1981 to 1999, primarily in the capacity of reservoir engineer, where he was responsible for oil and gas reservoir characterization, modeling and simulation, improved oil recovery processes, reservoir management, project economic risk assessment and petroleum reserves determination. Since 1999, Mr. Collings has become a leading authority in coal mine methane resource and reserves determination. His extensive background in the oil and gas and coal mining sectors provides a unique understanding of how methane emissions can be economically reduced through the appropriate implementation of technology in these two sectors. Mr. Collings is a designated RCE lead verifier and has performed validations and verifications in the oil and gas, transportation, power generation, and coal mine methane sectors. Peer Reviewer: Samantha Phillips, Environmental Scientist Sam Phillips began working at Ruby Canyon Engineering in June Since then, Sam s enthusiasm for being part of the global climate change solution has grown and she has worked towards becoming a valuable member of Ruby Canyon s verification team. Sam s current activities include up-to-date research, assistance with the preparation of verification documents, and sampling and data analysis for voluntary and mandatory GHG inventories. In addition, Sam has participated as a verification team member on several voluntary carbon offset projects that reduce methane emissions and is an accredited Lead Verifier under the CAR for landfill projects. Sam graduated from Colorado Mesa University with a B.S. in Environmental Science & Technology in May Lead Verifier: Phillip Cunningham, Environmental Scientist Phillip Cunningham is an environmental scientist at Ruby Canyon Engineering. His involvement at the company includes auditing a variety of carbon offset project types as well as greenhouse gas (GHG) inventories under voluntary and mandatory reporting programs, assessing spreadsheet functionality, and consulting. His recent activities include assisting with the development of the U.S. EPA GHG national inventory for underground and surface coal mine methane and abandoned mine methane emissions, evaluating the carbon neutrality of refuse derived-waste-to-energy projects and consulting for a large fertilizer company.

22 He is an approved Lead Verifier for Landfill, Livestock, Ozone Depleting Substances, Coal Mine Methane and Nitric Acid Production project protocols under the Climate Action Reserve; an Air Resources Board (ARB) accredited Lead Verifier for Livestock, Ozone Depleting Substances and Coal Mine Methane project verifications; has worked as Lead Verifier under The Climate Registry verifying greenhouse gas emission inventories for local governments, universities, a transportation company and a variety of other industrial sectors; and a Lead Verifier for carbon offset projects and emissions inventories under the British Columbia offset regulation and British Columbia Reporting Regulation. Phillip Cunningham graduated from Colorado Mesa University with a B.S. in Environmental Science & Technology in Prior to joining Ruby Canyon, Phillip worked for the Colorado Department of Agriculture at the Palisade Insectary and as a research assistant for the City of Grand Junction. Team Member: Michael Coté, President and Senior Environmental Engineer Michael Coté is an experienced environmental engineer in the climate change industry with skills in inventory analysis, baseline methodology development, project evaluation and feasibility, emission reductions calculations, and validation/verification of greenhouse gas (GHG) offset projects and corporate inventories. He has worked in various aspects of the environmental and green energy industry for the past 23 years, from project identification, feasibility and development, to verification and registration in various GHG programs. For the past 10 years, Mr. Coté has specialized in voluntary and compliance carbon markets including the development and qualification of greenhouse gas (GHG) emission reduction projects and corporate GHG inventories. Beginning in 2005, Mr. Coté and partner Ronald Collings founded Ruby Canyon Engineering Inc. (RCE), an organization dedicated to facilitating and qualifying GHG emission reduction projects (primarily targeting methane-to-energy projects from vented and fugitive methane emission sources) as well as providing corporate GHG inventory services. In addition, Mr. Coté led RCE s effort to receive its ANSI-accreditation as an ISO verification body in October 2009, and has since managed RCE s GHG validation and verification activities. Since receiving its accreditation, RCE has completed over 200 GHG validation/verifications. Mr. Coté has authored numerous GHG emissions baseline methodologies and project documents related to coal mine methane projects that have been submitted to U.S. EPA, the United Nations Framework Convention on Climate Change (UNFCCC), California Air Resources Board, Voluntary Carbon Standard, and the American Carbon Registry. He earned his Bachelor of Science degree (magma cum laude) in Environmental Science and Waste Management from Mesa State College in Aaron Schroeder P. Eng. Verification Subcontractor Aaron Schroeder has eleven years of professional experience analyzing, quantifying and auditing 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

23 development of ICF s standardized verification process, conformant with ISO In 2012, ICF s verification process was accredited by the American National Standards Institute (ANSI). Mr. Schroeder s hands on experience conducting over 100 greenhouse gas verifications includes numerous engagements for emission reduction projects in beef and dairy management, conservation cropping (zero-tillage) and nitrogen fertilizer management in addition to renewable energy, waste management and industrial energy facilities. 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. Mr. Schroeder is originally from rural Saskatchewan where he grew up on his family s mixed dairy and grain farm. His experience in agriculture is apparent in his work ethic and his knowledge of conventional farming practices. Michelle Stelmach, P. Eng. Verification Subcontractor 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 verification planning and procedures for Conservation Cropping, Agricultural Nitrous Oxide Emission Reduction (NERP) and Fed Cattle (Beef Days on Feed) projects. Ms. Stelmach 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. Michelle has supported several greenhouse gas verification teams over the past few years providing technical support, specifically for agricultural and biological emission reduction (offset) project verifications. For these assignments, Michelle provides technical input into the development of the verification plans, conducts field visits to interview farmers and make observations of their operations, assists with the execution of verification procedures and provides input for the verification report. Team Member: Zach Eyler, Vice President Zach serves as a Vice President for Ruby Canyon, utilizing his broad experience with greenhouse gas (GHG) programs and renewable energy to assist on a variety of work including GHG verifications, technical research and other client projects. In addition, he assists the company in understanding GHG regulations and policies across North America and internationally, using this knowledge to analyze potential new areas of growth. Specifically, Zach is helping lead Ruby Canyon s expansion into California s AB 32 cap-and-trade program, as well as new programs in Canada and Latin America. Zach also serves as Ruby Canyon s representative on a variety of GHG registry stakeholder groups that assist in the development of high level protocol and verification standards for new GHG programs. Zach has completed a

24 wide range of verification work for projects across registries (ARB, PCT, CAR, TCR, ACR, VCS) including coal mine methane, landfills, livestock, oil/gas, fuel switching, ODS, nitric acid production, and GHG entity inventories. Zach is currently an accredited Lead Verifier for the CAR, PCT and ACR programs. Zach is also an ARB accredited Lead Verifier and Project Specialist for livestock, mine methane and ODS projects. Prior to joining Ruby Canyon, Zach worked at Element Markets for four years where he managed over 15 carbon offset projects, as well as conducting all GHG policy and regulatory analysis to support the company s trading activities and client relationships in the U.S. and Canada. He also served as a company representative on carbon offset working groups including the Coalition for Emission Reduction Policy (CERP) and the Canadian Industry Provincial Offsets Group (IPOG). He earned a Bachelor s degree in Environmental Technology from NC State University in 2005 and a Master s of Environmental Management from Duke University s Nicholas School of the Environment in Summary As the Designated Signing Authority and a Professional Engineer registered in the State of Colorado, U.S.A., I, Ronald Collings meet or exceed the required qualifications described in Section 18 of the Specified Gas Emitters Regulation, including the training requirements under ISO The information contained within this document and this statement of qualifications, is complete and correctly represents the qualifications of Ruby Canyon Engineering Inc and the members of the Verification Team described herein. Dated on this fourth day of December Ronald C. Collings, PE Ruby Canyon Engineering, Inc. 743 Horizon Ct. Suite 385 Grand Junction, Colorado rcollings@rubycanyoneng.com

25 Appendix C: Conflict of Interest Checklist Carbon Credit Solutions Inc. Tillage Project #21 Page A-3

26 Conflict of Interest Checklist Carbon Credit Solutions Inc. Tillage Project #21 A conflict of interest checklist must be completed and signed before the verification is undertaken. It affirms that the verification team is independent and free from conflict of interest. This document is part of the required project documentation needed to register a project on the registry. 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 X 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? X For example: Provided greenhouse gas consultation services to the project; Provided validation for the project If providing non-greenhouse gas work for the company, consideration needs to be given as to how potential and perceived conflict of interests can be managed. A member of the verification team was previously employed with the company 3. Does the verifying organization or a member of the verification team, or a person in the chain of command for the verification, promote or be perceived to promote, a project developer's position or opinion to the point that objectivity X may, or may be perceived to be, compromised? For example: Dealing in, or being a promoter of, greenhouse gas credits on behalf of a project developer; or Acting as an advocate on behalf of the project developer in litigation or in resolving disputes with third parties. 4. Is one or more of the verification team too sympathetic to the project developer's interests by virtue of a close relationship with a project developer, its directors, officer or employees? For example: A person on the verification team has a close personal relationship with a person who is in a senior greenhouse gas compilation role at the project developer; or The verification team or a person of influence on the verification team has accepted significant gifts or hospitality from the project developer. X

27 Question Yes No 5. Is a member of the verification team or a person in the chain of command deterred from acting objectively and exercising professional skepticism by threats, actual or perceived, from the directors, officers or employees of the X Project Developer. For example: The threat of being replaced as a third party verifier due to a disagreement with the application of an greenhouse gas quantification protocol; Fees from the project developer represent a large percentage of the overall revenues of the verifying organization. The application of pressure to inappropriately reduce the extent of work performed in order to reduce or limit fees; or Threats of litigation from the project developer. Eilleen Kerby, December 4, 2017 Senior Accountant and Auditor Grand Junction, Colorado, USA

28 Appendix D: Subproject Tracking Form Carbon Credit Solutions Inc. Tillage Project #21 Page A-4

29 Appendix E: Verification Plan Carbon Credit Solutions Tillage Project #21 Page A-5

30 The verification objective, scope and level of assurance being provided; The objective of verification activities is to ensure that the claimed GHG emission reductions are materially correct and a fair representation of Project activities in accordance with the SGER, the Protocol and relevant guidance. The preliminary greenhouse gas assertion, baseline assertion, and previous assertions, if applicable; The preliminary greenhouse gas assertion was 168,368 tco2e. The final greenhouse gas assertion is 168,388 tco2e. The program criteria highlighting any specific requirements that are reviewed; 1. Ownership of the farm field 2. Right to transact on offset credits 3. Field Size and location being claimed 4. Ecozone protocol area classification 5. Existence of an annual crop, or first year of seeding of a perennial crop (only first year of planting is eligible) 6. Occurrences of soil disturbance on each farm field being claimed 7. Seeding / fertilizer specifications used each year 8. Reseeding events, if applicable 9. Use of Irrigation in Dry Prairie Ecozone, if applicable The assurance standard being used by the verification team; The verification team used ISO as the assurance standard. Documents any changes to operations, and organizational or operational boundaries since the prior verification: There are no changes to operations, organizational or operational boundaries for this verification. The greenhouse gas subject matter or a reference to the greenhouse gas subject matter associated with the assertion; The greenhouse gas subject matter is carbon sequestration through conservation cropping. A description of the responsible party s data management systems(s); CCSI s data management system is a robust set of eligibility documents and QA/QC procedures ensuring accurate and conservative emission offset calculation. The table below lists specific parameters CCSI uses in determining emission reductions. Carbon Credit Solutions Tillage Project #21 Page A-6

31 A description of the control environment; There are several checks in place to ensure that no offsets are generated if any required documentation is missing from CCSI s database. RCE reviewed CCSI s database during a previous site visit and confirmed that controls are in place to reduce the risk of an error in reporting offsets. During the site visit, RCE tested CCSI s control environment including reviewing several projects in CCSI s database. In all situations, CCSI demonstrated that controls were in place in order to flag incomplete data items. If any Protocol required documents were missing from CCSI s database, errors were noted and emission reductions were not calculated for the specified locations. Materiality and tolerable error threshold being used; RCE used a 5 percent materiality threshold for the calculation of emission reductions. RCE used a 5 acre materiality threshold for each quarter section of land for determining whether CCSI made an error in measurement for a particular field. Reference to prior verification reports and findings; Tetra Tech EBA previously verified the 2014 crop year for this project. Members of the verification team including the peer reviewer and designated signing authority; The verification team is described above in Appendix B: Statement of Qualifications. Language(s) that the site visit and verification are to be conducted in; Site visits and verification were conducted in English; there were no safety requirements needed for completing the site visit. Safety requirements needed to complete the site visit; There were no safety requirements need for the site visits. Carbon Credit Solutions Tillage Project #21 Page A-7

32 A description of the verification procedures (nature, timing, and extent) that will be applied to address risks identified at the assertion level for each material line item in the inventory/offset project. Identified areas of risk: Reason that risk exists Inherent Control Detection Risk Ownership of the farm field Ownership of credits must be clear and unambiguous. Medium Low Higher Right to transact on offset credits Ownership of credits must be clear and unambiguous. Medium Low Higher Field size Ecozone protocol area classification Existence of an annual crop, or first year of seeding of a perennial crop (only first year of planting is eligible) Occurrences of soil disturbance on each farm field being claimed Seeding / fertilizer specifications used each year Main parameter in determining amount of credits. Must exclude any non-crop areas including woods, leases, low spots that were not seeded etc. Must use ecozone parameters that are applicable to the geographic location of each field. Only annual crops are eligible (or first year perennials); must confirm that only annual crops are included. Fields with discretionary tillage over 10% or ineligible to be credited in each crop year. Shank space and evidence of type of equipment must be reviewed to determine eligibility. Medium Medium Medium Low Low Highest Medium Low Higher Medium Medium Medium Medium Medium Medium Re-seeding events Re-seeding events must be documented Low Low Highest Use of Irrigation in Dry Prairie Ecozone, if applicable (any two records from list) Delayed harvest Must use ecozone parameters that are applicable to the geographic location of each field. Some farmers were unable to harvest due to weather conditions. Need to confirm how CCSI is handling this and what effects it may have on the Project. Medium Medium Medium How Risk is addressed and alleviated Control test: review CCSI s database on-site and confirm that if documents are missing or requirements are not met, then emission reductions are not calculated Substantive test: review records to determine that signed contracts are in place between land owners and tenants to transfer ownership and between farmers to CCSI Substantive test: review records and re-calculate eligible cropping area for each quarter section. Substantive test: review records and confirm that correct emission factors were used based on field locations. Substantive test: review records and confirm that only eligible crop types are included. Substantive test: select a random sample of farms, visit the locations and interview the farmer regarding amount of discretionary tillage. Substantive test: select a random sample of farms, visit the locations and record equipment serial numbers and measure shank spacing to confirm data is entered correctly. Substantive test: select a random sample of farms, visit the locations and interview the farmer regarding whether a reseeding event took place. Substantive test: review records and confirm that evidence exists for irrigation in Dry Prairie zone. High Medium Lower N/A for the current reporting period. Carbon Credit Solutions Tillage Project #21 Page A-8