Verification Report for the TransAlta Renewables Inc. Ardenville Wind Farm Offset Project

Transcription

1 KPMG Performance Registrar Inc. Box 10426, 777 Dunsmuir Street Vancouver BC V7Y 1K3 Canada Telephone (604) (604) Telefax (604) Matthew Toohey TransAlta Corporation Sustainability Advisor AV SW Calgary, AB T2P 2M1 Dear Mr. Toohey: Re: Verification Report for TransAlta Renewables Inc. Ardenville Wind Farm Offset Project Our Verification Report for the TransAlta Renewables Inc. (TransAlta) Ardenville Wind Farm Offset Project is attached. The verification report documents the results of the verification that took place during the period September 26, We value the ongoing working relationship that we have with TransAlta, and appreciate the assistance provided to the verification team by TransAlta staff during the verification process. If you have any questions regarding the results of the verification please call me at the number listed below. Yours truly, Chris Ridley-Thomas, RP.Bio, CPA, CA, EP(EMSLA) President KPMG Performance Registrar (604) Enc: Verification Report for the TransAlta Renewables Inc. Ardenville Wind Farm Offset Project Wholly owned subsidiary of KPMG LLP, the Canadian member firm of KPMG International, a Swiss nonoperating association.

2 for TransAlta Ardenville Wind Farm Offset Project Verifier: KPMG Performance Registrar Inc. Project Developer: TransAlta Renewables Inc. Date:

3 Table of Contents 1) 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 Appendix A: Verification and Sampling Plan Appendix B: Conflict of Interest Checklist Appendix C: Statement of Qualification... 21

4 Page 1 1) Project Summary Information Project Title: Project Description: Ardenville Wind Farm Offset Project The project generates wind powered electricity that displaces electricity generated from non-renewable energy sources in Alberta. Project Location: Ardenville is located within Alberta, approximately 13 km southwest of the Town of Fort Macleod in the Municipal District of Willow Creek, in sections 2, 3, 10, 11, 14, 15, 22, 23, and 26 of Township 7, Range 26, west of the 4th meridian. Latitude: to Longitude: to Project Start Date: November 1, 2010 Credit Start Date: November 1, 2010 Credit Duration November 1, 2010 to November 1, 2018 Period: Expected Lifetime of the Project: Actual Emissions Reductions / Removals Achieved: According to the Project Report, the expected lifetime of the Project is 15 years. The greenhouse gas (GHG) emission reduction assertion for the Ardenville Wind Farm Offset Project is 36,528 tonnes of CO 2e for the period October 1, 2016 to December 31, Applicable Quantification Protocol(s): Other Environmental Attributes: Project Registration: Ownership: Project Activity: Project Contact Alberta Environment Quantification Protocol for Wind-Powered Electricity Generation (March 2008, Version 1) No other environmental credits or attributes are being requested or created by this Project, including Renewable Energy Certificates (RECs). The Project is registered under the Alberta Emissions Offset Registry. TransAlta Renewables Inc. has full ownership of the Project and the associated environmental attributes. The project generates wind powered electricity that displaces electricity generated from non-renewable energy sources in Alberta. Project conformance with the Alberta offset eligibility criteria is described in Section 6) Program Criteria. Matthew Toohey Sustainability Advisor AV SW

5 Page 2 Calgary, AB T2P 2M1 P (403) E Matthew_Toohey@transalta.com 2) Verification Summary Information Objective Summary Lead Verifier Team Members Peer Reviewer Designated Signing Authority The objective of the verification is to express an opinion as to whether TransAlta Renewables Inc s GHG emission reduction assertion and offset credits for the period October 1 December 31, 2016 are presented fairly in accordance with the relevant criteria, in all material respects. The identified risk factors and associated sampling plan are described in Section B of the Verification Plan. The verification was conducted in accordance with the sampling plan and no adjustment to the methodology was required as a result of the verification findings. The verification objective was met. Chris Ridley-Thomas, RP.Bio, CPA, CA, EP(EMSLA) Sander Jansen, MSc Sylvi Holmsen, RPF, CPA, CA, EP(EMSLA) Chris Ridley-Thomas, RP.Bio, CPA, CA, EP(EMSLA) Verification Dates The verification was conducted during the period September 26, Site Visit Dates September 27, 2016 (TransAlta Renewables Inc. Corporate Office) September 28, 2016 (Ardenville Wind Farm) April 11, 2017 (TransAlta Renewables Inc. Corporate Office) Report Date 3) Introduction The TransAlta Renewables Inc. (TRI) Ardenville Wind Farm Offset Project is a renewable energy project that generates GHG emission reductions through wind-powered electricity production. The Project consists of 23 turbines totaling 69 MW of gross capacity. Since the start of the Project in 2010, no operational changes have been noted. A change in ownership occurred in 2014; the Project previously owned by TransAlta Corporation (TAC) is now owned by Western Sustainable Power Inc., a wholly owned subsidiary of TRI. Emission offsets are registered under TRI. TRI is a subsidiary of TAC and TAC operates the Project. TAC has been authorized to act on behalf of TRI through a Management, Administrative and

6 Page 3 Operational service agreement to register and claim all applicable emission reduction credits for this Project. The baseline condition for wind power facilities consists of the generation of an equivalent quantity of electricity from blended generation sources with a defined emissions intensity of 0.65 tonnes of CO2 equivalent (CO2e) per MWh. There have been no changes to the baseline since the project start date. KPMG Performance Registrar Inc. (KPMG PRI) was engaged by TransAlta Renewables Inc. to express an opinion as to whether the Ardenville Wind Farm Offset Project s emission reduction assertion and offset credits for the period October 1 December 31, 2016 are presented fairly in accordance with the relevant criteria, in all material respects. 4) Objective The objective of the verification is to express an opinion as to whether TransAlta Renewable Inc. s GHG emission reduction assertion and offset credits for the period October 1, 2016 December 31, 2016 for the Ardenville Wind Farm Offset Project are presented fairly in accordance with the relevant criteria, in all material respects. 5) Scope The scope of the verification is the net offset credit generated for the Project, as described in TransAlta Renewable s Inc s Ardenville Wind Farm Offset Project Report dated April 6, 2017 for the period October 1 December 31, Level of assurance: Reasonable Materiality threshold: Quantitative materiality is set at 5% of the reported offset credit. 6) Program Criteria This verification was carried out in accordance with the following criteria: Alberta Environment Quantification Protocol for Wind-Powered Electricity Generation (March 2008, Version 1); Technical Guidance for Offset Project Developers (February 2013, Version 4); Climate Change and Emissions Management Act, S.A. 2003, c. C-16.7; and Specified Gas Emitters Regulation (SGER). KPMG assessed the eligibility of the project against the Alberta offset eligibility criteria. Key findings were: Offset Eligibility Criteria Occur in Alberta Findings The Project occurred in Alberta. GHG offsets created are linked directly to activities within the Province.

7 Page 4 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 and occur on or after January 1, 2002 Real and Demonstrable Quantifiable and measureable Have clearly established ownership Counted Once for Compliance Purposes Implemented according to a government approved protocol (for offset projects) Verified by a qualified person meeting the requirements under Section 18 of SGER. Registered on the Alberta Emission Offset Registry Project activities are the result of voluntary actions taken. The Project condition is not required by law. The Project was implemented after January 1, The resulting emission reductions are quantified in the Project Report in accordance with the approved Protocol. The Project Report describes how the quantification of reductions was carried out in accordance with the approved Protocol. TransAlta Renewables Inc. has full ownership of the Project and the associated environmental attributes. The Project Report indicates that the project and the resulting emission offsets are unique, apply to a specific year, and will only be listed once. TransAlta Renewables Inc. used the Quantification Protocol for Wind Powered Electricity Generation (March 2008, Version 1) which is a Government of Alberta-approved quantification protocol. The verifier meets the requirements under Section 18 of SGER. The Ardenville Wind Farm Offset Project is registered on the Alberta Emission Offset Registry (AEOR). 7) Verification Strategy The main elements of our verification were as follows: In relation to project eligibility and ownership: confirm start date described in the Project Plan against commissioning certificate; review eligibility criteria in the approved protocol and compare to disclosures in the Project Plan; and review of contractual agreement regarding offset ownership rights. In relation to quantification of GHG emission reductions: comparison of baseline and project emission calculations to the required methodologies in the protocol;

8 Page 5 agreement of emission factors to supporting documentation in the approved protocol and/or required sources of emission factors; verifying data disclosed in the Project Report against the associated source records; review of meter calibration records; and re-performance of a sample of calculations to ensure conformance with the relevant methodology. The selected approach was primarily a substantive approach given the ready availability of third party data to support the project assertions. For a full description of the procedures performed, the sampling plan and identified risk factors, refer to Appendix A Verification and Sampling Plan. 8) Verification Plan Refer to Appendix A Verification and Sampling Plan. 9) Sampling Plan Refer to Appendix A Verification and Sampling Plan. 10) Verification Schedule The verification schedule is summarized as follows: Verification planning and document review: September 26 October 14, 2016 On-site Verification: September 27, 2016 (TransAlta Corporate Office), September 28, 2016 (Ardenville Wind Farm), April 11, 2017 (TransAlta Corporate Office) Verification Completion and Reporting: March 27 11) Verification Findings Internal data management and controls A reasonable assurance engagement considers the control environment in place when designing and conducting tests to evaluate the GHG assertion. These tests support our opinion on the GHG assertion and are not designed to support a separate opinion on the effectiveness of internal controls over GHG assertions. Based on the procedures performed, the following process for collecting and consolidating GHG data was noted: Each turbine is metered and monitored through a dedicated system: Supervisory Control and Data Acquisition (SCADA). SCADA is managed and operated 24/7 by TransAlta staff at the Pincher Creek control centre. Additionally, there is an electronic meter located at the Ardenville wind farm substation to capture the electricity consumption and generation for the entire wind farm. Rodan Energy

9 Page 6 Solutions is contracted by TransAlta to inspect and test (in-situ) the substation meter per the Alberta Electric System Operator (AESO) testing intervals. A separate revenue meter is positioned outside TransAlta s control and measures the amount of electricity entering the grid. This meter is operated by AESO (third party) and captures electricity generation. TransAlta corporate staff upload the electricity generation and consumption data from Rodan Energy Solutions and AESO into the GHG assertion spreadsheet for preparation of the Project Report. Project emissions associated with maintenance vehicles and cranes are calculated based on surrogate parameters entered manually into GHG assertion spreadsheet. Project emissions associated with SF6 leaks at switch gear, are identified through monthly inspections of pressure gauges for SF6 at the Ardenville substation, and subsequently entered manually into the GHG assertion spreadsheet. At year end, the GHG assertion spreadsheet is reviewed by TransAlta representatives, by reconciling AESO generation data against Rodan Energy Solution generation data, and performing sense checks. No deficiencies that would compromise the GHG assertion were noted in the process for collecting and consolidating GHG data. Summary of GHG Calculation methods and assumptions Per the Quantification Protocol for Wind-Powered Electricity Generation (March 2008, Version 1), the following quantification approach for GHG emission reductions is required: Emissions reduction = Emissions(baseline) Emissions(project) Emissions(baseline) = Emissions(electricity generation) Emissions(project) = Emissions(fuel extraction and processing) + Emissions(facility operation) + Emissions(on-site electricity storage system) Additionally, the Protocol requires that the quantification of emission reductions achieved by the Project is based on actual measurement and monitoring. Based on the procedures performed, it is noted that: The quantification of fuel use in maintenance vehicles and cranes is based on surrogate parameters, whereas the Protocol prescribes direct metering or reconciliation of fuel volumes. Direct fuel consumption data (volume) was not available for TransAlta Renewables Inc. to calculate emissions from vehicles and crane use in accordance with the Protocol methodology. KPMG assessed the parameters and assumptions used in the calculation of emissions associated with maintenance vehicles and cranes use and found them to be consistent with the principles of accuracy and reasonableness. The quantification methodology employed by TransAlta Renewables Inc. for all other emission sources is consistent with the Protocol. The quantification methodology employed by TransAlta Renewables Inc. is described in greater detail in the following document: Ardenville Wind Farm Offset Project Report, dated April 6, 2017.

10 Baseline condition Verification Report Page 7 The baseline condition for wind power facilities consists of the generation of an equivalent quantity of electricity from blended generation sources with a defined emissions intensity of 0.65 tonnes of CO 2 equivalent (CO 2e) per MWh. No changes to the baseline or project have been identified since the project start date. Project condition The project condition consists of the generation of electricity using wind turbines and includes emissions associated with power consumed for the operation of the wind farm, and associated use of diesel and gasoline during operations. GHG Emission Reductions Emission reductions are created as a result of lower CO 2e emissions from wind powered electricity generation as compared to non-renewable energy sources in Alberta. GHG Assertion We agree with management s assessment that the observations listed in the table below are not material to the GHG assertion. Observations The following non-material observations were noted as a result of the verification activities: Result # Type Description Effect on GHG Emission Reduction Assertion #16-01 Quantitative Accuracy: Total Absolute Quantitative Error KPMG noted that the vehicle mileage of 4 trucks was incorrectly recognized in the determination of reported emissions. Tonnes CO 2 eq %net, % absolute, understatement or overstatement Effect on GHG assertion (abs): 0.55 tco2e Effect on GHG assertion (%): % Overstatement UNCORRECTED UNCORRECTED: Overstatement of 0.55 tco2e (0.0015%)

11 Page 8 12) Confirmations Per the Technical Guidance for Greenhouse Gas Verifications at Reasonable Level of Assurance confirmation requirements: We assessed the consistency of offset project information across offset project documentation and did not identify material discrepancies; We confirmed the project location and assessed any applicable approval information and did not identify material discrepancies; We confirmed the existence of methodology documents or procedures and did not identify material discrepancies; We assessed the offset project contract, report dates and emission reduction numbers and did not identify material discrepancies; We assessed the completeness and accuracy of process and data flow diagrams and did not identify material discrepancies.

12 Page 9 13) Statement of Verification To TransAlta Renewables Inc. and Alberta Environment and Parks We have been engaged by TransAlta Renewables Inc. (the Company) to examine the greenhouse gas (GHG) emission reduction assertion for the period October 1, 2016 to December 31, 2016 presented below in Table 1 and described in the Company s Project Report for the Ardenville Wind Farm Offset Project, dated April 6, 2017 (the Report). Table 1. Emission reduction credits claimed by vintage year Period Emission Reduction Claimed (tonnes CO 2e) October 1 December 31, ,528 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 the GHG emission reduction assertion is presented fairly in accordance with the approved quantification methodology for the project (Quantification Protocol for Wind Powered Electricity Generation, (March 2008, Version 1)) and the Specified Gas Emitters Regulation. Our duties in relation to this report are owed solely to the Company. Accordingly we do not accept any responsibility for any loss occasioned to any third party acting or refraining from action as a result of this report. We completed our examination in accordance with ISO 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 reasonable, rather than absolute assurance with respect to the GHG emission reduction assertion. Our examination criteria were based on the Specified Gas Emitters Regulation and the Quantification Protocol for Wind Powered Electricity Generation (March 2008, Version 1) (together the Criteria). We believe our work provides a reasonable basis for our conclusion. Based on our examination, in our opinion the GHG emission reduction assertion presented in the Report is presented fairly in accordance with the criteria, in all material respects. GHG and energy use data are subject to inherent limitations. Differing measurement techniques, assumptions and emission factors can result in materially different emission reduction estimates. The Quantification Protocol for Wind Powered Electricity Generation (March 2008, Version 1) provides prescribed methods for calculating emissions based on assumptions and available emission factors. Our verification was designed to assess the Report against the requirements of the protocol and any inherent uncertainty in the protocol assumptions remains outside the scope of the verification. Chris Ridley-Thomas, RP.Bio, CPA, CA, EP(EMSLA) Lead Verifier and Designated Signing Authority KPMG Performance Registrar Inc. Issued in Vancouver, British Columbia

13 14) Appendices Verification Report Page 10

14 Appendix A: Verification and Sampling Plan Verification Report Page 11

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22 Appendix B: Conflict of Interest Checklist Verification Report Page 19 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: X 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. X 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: X 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.

23 Page 20 Question Yes No 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: X A person on the verification team has a close personal relationship with a person who is in a senior GHG compilation role at the Project Developer; or The verification team or a person of influence on the verification team has accepted significant gifts or hospitality from the Project Developer. 5. Is a member of the verification team or a person in the chain of command is deterred from acting objectively and exercising professional scepticism by threats, actual or perceived, from the directors, officers or employees of the Project Developer. For example: X 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. Chris Ridley-Thomas, RP.Bio, CPA, CA, EP(EMSLA) President KPMG Performance Registrar Inc. Vancouver, BC

24 Page 21 Appendix C: Statement of Qualification The below Statement of Qualification demonstrates that the Lead Verifier meets the requirements established in section 18 of the Specified Gas Emitters Regulation (SGER). Per the regulation, only the Lead Verifier must meet all the qualification requirements. For the relevant experience of the other team members, refer to the information below the Statement of Qualification. SGER requirements for Third Party Verifiers 18 (1) A person is eligible to be a third party auditor under this Regulation if the person (a) is (i) registered as (A) a professional engineer under the Engineering, Geological and Geophysical Professions Act, or (B) a chartered accountant under the Regulated Accounting Profession Act, (ii) a member of a profession that has substantially similar competence and practice requirements as a profession referred to in subclause (i) (A) in a province or territory of Canada, or (B) approved by the director, in a jurisdiction outside of Canada, (b) has technical knowledge of (i) specified gas emission quantification methodologies, (ii) audit practices, and (iii) any other matters considered relevant by the director, and (c) has any other qualifications that the director considers necessary. Lead Verifier Qualifications The Lead Verifier, Chris Ridley-Thomas, CPA, CA is a chartered accountant under the Regulated Accounting Profession Act, with technical expertise related to the Project sector. (i) Specified gas emission quantification methodologies: The Lead Verifier, Chris Ridley-Thomas, RP.Bio, CPA, CA, EP(EMSLA) has detailed technical knowledge of GHG emission quantification methodologies, the Alberta Carbon Offset requirements and verification experience related to wind-powered electricity generation. Chris has been engaged in more than 140 GHG verifications, including over 10 Windfarm Projects. (ii) Audit and assurance practices: As a CPA the Lead Verifier, Chris Ridley-Thomas has extensive technical knowledge of audit and assurance practices including GHG verifications, financial statement audits and assurance over non-financial reporting. (C) Any other qualifications: The Lead Verifier, Chris Ridley-Thomas, RP.Bio, aside from being a CPA, is a registered professional

25 Page 22 (2) A person is not eligible to be a third party auditor for a facility if (a) that person is the person responsible for the facility or is a director, officer or employee of the person responsible for the facility or of an affiliate, within the meaning of section 2 of the Business Corporations Act, of the person responsible, or (b) the person is an employee or agent of the Government. biologist (Association of Professional Biologists of British Columbia), and an Environmental Management Systems Lead auditor (Eco Canada). He is president of KPMG Performance Registrar Inc., a wholly owned subsidiary of KPMG LLP that delivers accredited assurance services to clients across North America under the ISO (environmental), ISO 9001 (quality), OHSAS (health and safety) and ISO (greenhouse gas) standards as well as delivering sustainability assurance under the GRI assurance standards. The Lead Verifier is eligible to conduct a GHG verification for the offset project as defined by the regulation and can demonstrate absence of any conflict of interest related to TransAlta Renewables Inc. as documented in the Conflict of Interest Checklist, Appendix B. Chris Ridley-Thomas, RP.Bio, CPA, CA, EP(EMSLA) President KPMG Performance Registrar Inc. Vancouver, BC

26 Page 23 Relevant experience of other team members: Team member Education Experience and knowledge assessment Sylvi Holmsen RPF, CPA, CA Competent for role of peer reviewer 1,2,3,4,5,6,7,8 Sander Jansen MSc. Competent for role of team member 1,3,4,5 Experience and knowledge assessment notations: 1. Team member has conducted research with respect to the Alberta greenhouse gas offset system as part of the preparation for the engagement. 2. Team member has successfully completed the ISO Part 3 GHG Validation and Verification of GHG Assertions lead auditor course. 3. Team member has prior audit experience directly related to GHGs. 4. Team member has prior experience specific to Windfarm Offset Projects. 5. Team member has sufficient knowledge with respect to the sinks and sources associated with windfarms. 6. Team member is a Chartered Professional Accountant in Canada. 7. Team member is an ISO Environmental Management Systems Lead Auditor. 8. Team member has prior experience in financial auditing.