Verification Report for Permolex Ltd. Red Deer Ethanol Production Expansion Offset Project ( )

Transcription

1 Verification Report for Permolex Ltd. Red Deer Ethanol Production Expansion Offset Project ( ) Prepared for: Permolex Ltd Edgar Industrial Crescent Red Deer, AB T4P 3R3 Prepared by: Stantec Consulting Ltd Tyee Road Victoria BC V9A 6X5 Project Number: August 31, 2015

2 VERIFICATION REPORT FOR PERMOLEX LTD. RED DEER ETHANOL PRODUCTION EXPANSION OFFSET PROJECT ( ) TABLE OF CONTENTS EXECUTIVE SUMMARY INTRODUCTION PROJECT DESCRIPTION LOCATION PROCESSES AND ACTIVITIES BASELINE EMISSIONS GHG ASSERTION VERIFICATION METHODOLOGY VERIFICATION OBJECTIVES LEVEL OF ASSURANCE VERIFICATION CRITERIA VERIFICATION SCOPE MATERIALITY VERIFICATION PLAN VERIFICATION TEAM: QUALIFICATIONS, ROLES AND RESPONSIBILITIES STATEMENT OF COMPLIANCE WITH THE SGER VERIFICATION STRATEGY INHERENT RISK CONTROL RISK DETECTION RISK SITE VISIT VERIFICATION PROCEDURES CONFIRMATIONS SUMMARY OF FINDINGS CONCLUSION OPINION SUBMISSION DOCUMENTS CLOSURE August 31, 2015 i

3 VERIFICATION REPORT FOR PERMOLEX LTD. RED DEER ETHANOL PRODUCTION EXPANSION OFFSET PROJECT ( ) LIST OF TABLES Table E.1 Verification Summary...E.1 Table 1.1 GHG Assertion... 2 Table 3.1 Verification Team... 5 Table 4.1 Schedule of Verification Activities... 8 Table 5.1 Verification and Sampling Plan Table 5.2 Identified Misstatements and Resolutions LIST OF APPENDICES Appendix A Appendix B Final Verification Plan Submission Documents ii August 31, 2015

4 VERIFICATION REPORT FOR PERMOLEX LTD. RED DEER ETHANOL PRODUCTION EXPANSION OFFSET PROJECT ( ) EXECUTIVE SUMMARY A summary of the verification of the Permolex Ltd. Red Deer Ethanol Production Expansion Offset Project ( ) (the Project) is provided in Table E.1. Table E.1 Verification Summary Verification Summary Project Name Red Deer Ethanol Production Expansion Project Project Start Date March 1, 2004 Credit Start Date March 1, 2004 Credit Duration March 1, 2004 to February 28, 2017 Period Note that the original crediting period was extended by Alberta Environment and Parks (AEP) through February 28, 2017 Reporting Period January 1, 2011 to December 31, 2014 Note that Permolex has received AEP permission to claim 2011 vintage credits under a reasonable level of assurance and the Specified Gas Emitters Quantification Protocol for Biofuel Production and Usage (October 2014, V2.0). Expected Lifetime of the Project Project Contact Applicable Quantification Protocol Other Environmental Attributes Project Registration GHG Assertion 25 years Randy Cook - President Permolex Ltd Edgar Industrial Crescent, Red Deer, AB T4P 3R3 Phone: (403) Fax: (403) rcook@permolex.com The Specified Gas Emitters Quantification Protocol for Biofuel Production and Usage (October 2014, V2.0) No other environmental attributes / credits / benefits have been claimed by the Project as asserted by the Project Developer. The Project is registered under the Alberta Emissions Offset Registry. The fundamental assertion to be verified is the quantification of 81,402 tco2e in GHG reductions for the period of January 1, 2011 to December 31, 2014 resulting from the indirect GHG emission reductions by displacing the use of gasoline with ethanol. The Project is defined as the incremental ethanol produced and sold to Alberta s Renewable Fuels Standard Regulation (RFS) market by the facility due to expansions completed in 2004 and Pre-expansion benchmarks for January 1, 2001 to November 30, 2003 were used to distinguish between pre-expansion and expansion ethanol production and natural gas consumption, i.e., a static pre-expansion benchmark was used to determine the volume of expansion ethanol produced and a dynamic natural gas pre-expansion benchmark was used to August 31, 2015 E.1

5 VERIFICATION REPORT FOR PERMOLEX LTD. RED DEER ETHANOL PRODUCTION EXPANSION OFFSET PROJECT ( ) Table E.1 Verification Summary determine incremental natural gas combustion due to the expansions. The Baseline condition is the use of conventional gasoline by downstream users if the expansions to the facility had never occurred. Without the Project, incremental quantities of ethanol would not have been produced, and the equivalent amount of conventional gasoline would have been extracted, processed and combusted in place of the Project ethanol. Level of Assurance The SGER and AEP require the verifier to conduct sufficient procedures to deliver a reasonable level of assurance. The verification was planned and executed accordingly. Verification Criteria Climate Change and Emissions Management Act (the Act), SA 2003, c C- 16.7; Specified Gas Emitters Regulation, Alta Reg. 139/200, with amendments up to and including Alberta Regulation 104/2015 (Regulation); Technical Guidance for Offset Project Developers (version 4.0, February 2013); and The Specified Gas Emitters Quantification Protocol for Biofuel Production and Usage (October 2014, V2.0). Verification Objective The objective of the verification was to assess whether the Red Deer Ethanol Production Expansion Project Report and the GHG assertion (as presented in Table 1.1) for January 1, 2011 to December 31, 2014 under the SGER satisfied the following AEP requirements: Climate Change and Emissions Management Act (the Act), SA 2003, c C- 16.7; Specified Gas Emitters Regulation, Alta Reg. 139/200, with amendments up to and including Alberta Regulation 104/2015 (Regulation); Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance (January 2013, V1.0); Technical Guidance for Offset Project Developers (version 4.0, February 2013); and The Specified Gas Emitters Quantification Protocol for Biofuel Production and Usage (October 2014, V2.0). Verification Standards Project Activity The verification was conducted in accordance with ISO 14064:3, ISO 14065, and guidance contained within the Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance, January 2013, version 1.0. The Project Activity is eligible under the SGER to generate offsets as it meets the following conditions. Result from actions taken on or after January 1, 2002 the Project began operation after this date. The Project occurs during the project crediting period the Project has received approval for a 5-year extension, ending on February 28, Be real, demonstrable, quantifiable the Project has been verified according to the Verification Criteria above. E.2 August 31, 2015

6 VERIFICATION REPORT FOR PERMOLEX LTD. RED DEER ETHANOL PRODUCTION EXPANSION OFFSET PROJECT ( ) Table E.1 Verification Summary Verification Summary Not be required by law the Project is not required by any current or proposed law. Have clearly established ownership the Project Developer provided sufficient and appropriate evidence that Permolex Ltd. is the owner and transacting party for the offset credits generated by the Project. Be counted once for compliance purposes the Project s offset credits are serialized on the Alberta Emission Offset Registry (AEOR). Be verified by a qualified third party Stantec is a qualified third party (see Section 1.0, Section 3.1, and Statement of Qualifications). Have occurred in Alberta the Project is physically located in Alberta. Only ethanol sold to Alberta RFS market and feedstock within Alberta are considered for the Project. No unresolved material misstatements were identified for the Project Report (including the Project Offset Plan) as submitted. The GHG assertion for the Project is deemed to be fairly presented and substantiated by sufficient and appropriate evidence. A reasonable level assurance verification statement was issued. Verification Team Lead Verifier/ Project Manager Senior Reviewer and Designated Signing Authority Independent Peer Reviewer Verifier Verification Timeframe Daniel Hegg, M.Sc., EMIT Nicole Flanagan, M.A.Sc., P.Eng. Vicki Corning, P.Eng. Orasa Webber, M.Eng. May 11 August 31, 2015 Site Visit Date May 11, 2015 Report Date August 31, 2015 August 31, 2015 E.3

7 VERIFICATION REPORT FOR PERMOLEX LTD. RED DEER ETHANOL PRODUCTION EXPANSION OFFSET PROJECT ( ) 1.0 INTRODUCTION Permolex Ltd. (Permolex) retained Stantec Consulting Ltd. (Stantec) to conduct a verification of the Red Deer Ethanol Production Expansion Project for the reporting period of January 1, 2011 to December 31, 2014 (the Project) located in Red Deer, Alberta. Permolex is the Project Proponent and Project Developer. In this work, Permolex was responsible for collection of data used in the calculations and data management. Permolex retained Viresco Solutions Ltd. (Viresco) to complete the calculations and present the information within the Project Report, and supporting technical documents. Stantec is a qualified third party verifier, as defined in Section 18 of the SGER. Stantec is accredited with the American National Standards Institute (ANSI), a member of the International Accreditation Forum (IAF), in accordance with ISO (Accreditation ID #0805 issued to Stantec Consulting Ltd. Atmospheric Environment Group for greenhouse gas (GHG) verification). Stantec was responsible for planning and executing the verification in order to deliver an opinion as to whether the Project Report is presented fairly and in accordance with the verification criteria. 1.1 PROJECT DESCRIPTION LOCATION The Permolex Red Deer Ethanol Production facility is located in Red Deer, Alberta. The coordinates of the facility are latitude N and longitude W. 1.2 PROCESSES AND ACTIVITIES The Red Deer Ethanol Production facility began operation in 1997 under the operation of API grain Process Limited Partnership. In 2003, the facility was acquired by Permolex. In 2004, Permolex completed their first stage expansion increasing their ethanol production by 3.5 million liters per year (increased from 21.5 to 25 million liters per year). In March 2007, a second phase of expansion was completed to increase the ethanol production volume to 42 million liters per year. The facility integrates three processes, the flour mill, a gluten plant and an ethanol plant. The three processes run in series, using by-products from one process as feedstock for the next process. There is also a cogeneration facility that produces electricity from waste heat and provides electricity for the facility s use only. Permolex confirmed that electricity generated from its cogeneration facility is not sent to the grid. Grid electricity was also purchased for use at the facility in addition to generated electricity. The offset credits to be verified arise from the incremental production of ethanol beyond the preexpansion period (January 1, 2001 to November 30, 2003), which is considered to displace the combustion and associated GHGs from an equivalent amount of fossil fuel (gasoline) when consumed. Two pre-expansion benchmarks were developed for use in the Baseline scenario, i.e., a static preexpansion benchmark was developed to determine the incremental volume of expansion ethanol August 31,

8 VERIFICATION REPORT FOR PERMOLEX LTD. RED DEER ETHANOL PRODUCTION EXPANSION OFFSET PROJECT ( ) produced and a dynamic natural gas pre-expansion benchmark was developed to determine incremental natural gas combustion due to the expansions. A static pre-expansion benchmark of ethanol production volume (liter per month) was calculated based on the average of monthly ethanol production volumes from January 2001 to November A dynamic pre-expansion natural gas benchmark (GJ) was determined using a multiple regression model developed based on plant operational data (ethanol and gluten production data) and temperature records from Environment Canada climate data for January 2001 to November 2003 (from the Red Deer weather station station id ). The Baseline condition applicable to this Project is the use of fossil fuel by downstream users had the expansions to the Red Deer facility never occurred, incremental quantities of ethanol would not have been produced, and an energy equivalent amount of conventional gasoline would have been extracted, processed and combusted in its place. The Project condition is the incremental production of ethanol from the facility, as a result of two expansion projects, completed in 2004 and 2007 that almost doubled the pre-expansion ethanol production capacity of the facility. The Project period to which offset credits have been generated is: January 1, 2011 to December 31, Emission reductions are calculated as the difference between the Baseline emissions and Project emissions. 1.3 BASELINE EMISSIONS The Baseline scenario is the production, processing, distribution, and usage of an equivalent amount of gasoline from expansion of ethanol production. Baseline emissions are estimated using the Project expansion ethanol volume, lifecycle emissions factor for conventional fuel (gasoline), RFS Intensity, and emissions factor for co-product displacement (ethanol) as outlined in the quantification protocol. 1.4 GHG ASSERTION The fundamental assertion verified was the quantification of 81,402 tco2e in GHG reductions for the period of January 1, 2011 to December 31, 2014 resulting from the indirect GHG emission reductions by displacing the use of gasoline with ethanol (see Section 2.3). The essential information contained within the GHG assertion verified by Stantec is presented in Table 1.1 below. Table 1.1 GHG Assertion Vintage Year Baseline Emissions (t CO2e) Project Emissions (t CO2e) ,835 14,721 8, ,457 24,714 26, ,724 24,904 20, ,663 26,388 25,275 Notes: Emission Reductions are rounded down as per Guidance. Emission Reductions (t CO2e) 2 August 31, 2015

9 VERIFICATION REPORT FOR PERMOLEX LTD. RED DEER ETHANOL PRODUCTION EXPANSION OFFSET PROJECT ( ) 2.0 VERIFICATION METHODOLOGY 2.1 VERIFICATION OBJECTIVES The objective of the verification was to assess whether the Project Report and the GHG assertion (as presented in Table 1.1) identified within the Project Report under the SGER satisfied the AEP requirements in the verification criteria in accordance with the verification standards identified in Section LEVEL OF ASSURANCE The SGER and AEP require the verifier to conduct sufficient procedures to deliver a reasonable level of assurance. The verification was planned and executed accordingly. 2.3 VERIFICATION CRITERIA Stantec has conducted sufficient and appropriate procedures in order to express a reasonable level of assurance opinion as to whether the Project (the GHG assertion) satisfies the requirements of the: Climate Change and Emissions Management Act (the Act), SA 2003, c C-16.7; Specified Gas Emitters Regulation, Alta Reg. 139/200, with amendments up to and including Alberta Regulation 104/2015 (Regulation); Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance (January 2013, V1.0); Technical Guidance for Offset Project Developers (version 4.0, February 2013); and The Specified Gas Emitters Quantification Protocol for Biofuel Production and Usage (October 2014, V2.0). The verification was conducted in accordance with ISO 14064:3, ISO 14065:2013, and the Technical Guidance for Greenhouse Gas Verification at Reasonable Level Assurance, January 2013, version 1.0 (Verification Guidance). 2.4 VERIFICATION SCOPE The verification is for the Project period of January 1, 2011 to December 31, Permolex received AEP permission to claim 2011 vintage credits under a reasonable level of assurance and the Specified Gas Emitters Quantification Protocol for Biofuel Production and Usage (October 2014, V2.0). The verification covers the specified gases under the Act and the SGER. These include carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), sulphur hexafluoride (SF6), hydrofluorocarbons (HFCs) and August 31,

10 VERIFICATION REPORT FOR PERMOLEX LTD. RED DEER ETHANOL PRODUCTION EXPANSION OFFSET PROJECT ( ) perfluorocarbons (PFCs). The total GHG emissions are reported as equivalent tonnes of carbon dioxide (t CO2e) emissions. Sources of Project GHG emissions include: Fertilizer/Pesticide Production and Transportation (CO2e): related to feedstock (wheat, corn, and rye/barley) used in ethanol production; Crop-based Feedstock Production, Feedstock Processing, and Direct Land Use Change (CO2e): related to feedstock (wheat, corn, and rye/barley) used in ethanol production; Feedstock Processing and Processed Feedstock Transportation (CO2e): related to feedstock (wheat, corn, and rye/barley) used in ethanol production; Chemicals Production and Transportation (CO2e): related to feedstock (wheat, corn, and rye/barley) used in ethanol production; Fossil Fuel Consumption (CO2, CH4, and N2O): natural gas and other fuels used to run the ethanol production facility; Grid Electricity Usage (CO2e): grid electricity used for the ethanol production facility; Biofuel (ethanol) distribution and dispensing (CO2e): related to ethanol distribution and dispensing; Use of biofuel (ethanol) (CH4 and N2O): related to blended ethanol combustion. Produced CO2 is excluded as it is biogenic. Sources of Baseline GHG emissions at the Project are: Conventional Fuel (gasoline) Extraction and Processing, Distribution and Dispensing, and Usage (CO2e): related to additional production and use of fossil fuel by downstream users if the Project had never occurred. 2.5 MATERIALITY AEP has set the quantitative materiality threshold at 5% of the total reported GHG emission reductions or removals asserted. Qualitative misstatements are at the discretion of the verification body. 2.6 VERIFICATION PLAN A copy of the final verification plan is provided in Appendix A. The activities described therein were executed during the course of the verification. The sampling plan, a subset of the verification plan, is outlined along with the final results in Section 5.0 of this report. 4 August 31, 2015

11 VERIFICATION REPORT FOR PERMOLEX LTD. RED DEER ETHANOL PRODUCTION EXPANSION OFFSET PROJECT ( ) 3.0 VERIFICATION TEAM: QUALIFICATIONS, ROLES AND RESPONSIBILITIES The verification team is identified in Table 3.1. Table 3.1 Verification Team Name Role Responsibilities Daniel Hegg, M.Sc., EMIT Lead Verifier Lead and delegate verification duties. Conduct the site visit. Nicole Flanagan, M.A.Sc., P.Eng Vicki Corning, P.Eng. Senior Reviewer and Designated Signing Authority Independent Peer Reviewer Review verification deliverables technical soundness and compliance with Stantec s internal processes and AEP criteria. Designated Signing Authority on verification documents. Independent review of verification activities and conclusions. The independent reviewer confirms the verification activities have been completed and that the activities provide the required level of assurance. Orasa Webber, M.Eng. Verifier Assist in sampling plan execution and report preparation. Full details of the qualifications of the project team are included in the final verification plan located in Appendix A. 3.1 STATEMENT OF COMPLIANCE WITH THE SGER Ms. Nicole Flanagan is the signing authority for the report. She is a professional engineer registered by the Professional Engineers of Ontario which satisfies Section 18(a)(ii)(A) of the SGER. With respect to the technical knowledge required under Section 18(b)(i-iii), each member of the team has the required technical knowledge of GHG emission quantification methodologies and all have experience in completing third party GHG verifications. Please refer to the team profiles included in the verification plan in Appendix A. August 31,

12 VERIFICATION REPORT FOR PERMOLEX LTD. RED DEER ETHANOL PRODUCTION EXPANSION OFFSET PROJECT ( ) 4.0 VERIFICATION STRATEGY Details of the verification activities undertaken as part of the verification strategy are set out in Table 4: Verification Procedures of the final Verification and Sampling Plan included in Appendix A and summarized in Section 5.0 of this report. The Verification and Sampling Plan for the Project was developed considering our initial assessment of the verification risk for the engagement. We assessed the initial verification risk as Medium 1. Using the Verification and Sampling Plan, Stantec assessed the control procedures surrounding the GHG data and information. Important components included: processes for collecting, processing, consolidating and reporting GHG data and information; systems and processes that ensure GHG data accuracy, documenting and monitoring processes; methods to identify errors and methods to identify and report deficiencies in the reporting information and management system. Stantec verified equations used for quantification and monitoring purposes. These procedures included a site visit. Based on the results of the verification procedures undertaken, the final verification risk is deemed to be Medium. This final risk assessment is shown based on the assessment of inherent, control and detection risk as follows. 4.1 INHERENT RISK Inherent risk is the risk of error that occurs as a result of the lack of capacity by staff; the size/complexity of the Project; the industrial sector; and/or, the technologies or processes being applied in the Project. We regard this risk as Medium due to: There are many sources, sinks and reservoirs (SSRs) included in the Project which may increase the risk for emission calculation errors (medium risk); A recently updated and approved Biofuel Production and Usage Protocol for the quantification of offsets generated from biofuel production and usage has been applied to the Project and this is the first Project Report for Permolex after the quantification protocol has been updated. There is a risk that the Protocol has been misinterpreted leading to a material misstatement (medium risk); and Permolex received a separate letter from Alberta Environment and Parks (AEP) that allows Permolex to bring forward the tonnage from January 1 to March 31, 2011 under the Protocol without having to provide the Renewable Fuels Standard compliance reports (as required by the Protocol). Although there is verifiable evidence for the ethanol produced by Permolex, other than a self-assertion by Permolex, there is no independent data to support the amount of eligible ethanol. Although immaterial to the GHG assertion (i.e. the error would not be more than 933 tco2e), there is a risk that the amount of eligible ethanol is not correct (medium risk). 4.2 CONTROL RISK Control risk is the risk that the proponent s control system will not detect and rectify a misstatement. We regard this risk as Medium due to: 1 Possible risk ratings are high, medium and low. These are based on inherent, control, and detection risks as evaluated by the project team prior to engaging in verification activities. 6 August 31, 2015

13 VERIFICATION REPORT FOR PERMOLEX LTD. RED DEER ETHANOL PRODUCTION EXPANSION OFFSET PROJECT ( ) Several data inputs to calculation of emission reduction (e.g., natural gas consumption, electricity consumption, ethanol production) were manually transcribed from third party invoices or plant production reports to calculators. There is a risk for transcription errors with this manual data entry (medium risk); and There was an issue with quality control and assurance for quantification calculators as some errors leading to material discrepancies were detected. However, the errors were resolved during the course of verification (medium risk). 4.3 DETECTION RISK Detection risk is the risk that Stantec will not identify a material misstatement. We regard this risk as Low due to: Our quality management procedures. We are committed to providing exceptional service to our clients in accordance with our ISO 9001 and ISO accreditations. We believe that quality is a basic principle and have made quality management an integral part of our work. We take a systematic approach to quality management in compliance with ISO requirements and strive to achieve continual improvement. The cornerstone of our quality management system is an entrenched process of technical and independent peer review where our deliverables are objectively vetted by senior and expert people in our firm. Level of assurance. The reasonable level of assurance applied in this verification (as required by the SGER) mandates that Stantec perform increased sampling to meet the assurance requirements, however, the level of assurance still increases the risk to Stantec as the risk-based verification approach means that not all information can be reviewed. Stantec has designed the sampling plan to target all potentially material items in the GHG information to minimize detection risk. The verification team assessed whether the Project resulted in emission reductions in a manner consistent with the Project Offset Plan. During the verification, the verification team considered the level of audit risk noted above and incorporated necessary tasks to mitigate the audit risk. These tasks included: assessing conformance with applicable verification criteria (as per Section 2.3) within the scope of verification; evaluating the establishment, justification and documentation of the Project Report; assessing the GHG project's quality assurance and controls; and assessing the information for consistency with our knowledge of Permolex s operations. The schedule for the verification activities is presented in Table 4.1. August 31,

14 VERIFICATION REPORT FOR PERMOLEX LTD. RED DEER ETHANOL PRODUCTION EXPANSION OFFSET PROJECT ( ) Table 4.1 Schedule of Verification Activities Responsible Verification Activity Party Date of Completion Kick-Off Meeting With Permolex Stantec / Permolex May 11, 2015 Site & Office Visit Stantec / Permolex May 11, 2015 Receive Permolex Documentation Permolex / Viresco Solutions May 19, 2015 Desktop Review Stantec May 19 June 10, 2015 Provide Verification Plan To Permolex Stantec June 11, 2015 Receive Additional Documentation Permolex / Viresco Solutions June 15 August 28, 2015 Draft Verification Report Stantec August 28, 2015 Address Follow-Up Items Stantec / Permolex August 28, 2015 Finalize Verification Report And Statement Of Verification Stantec August 31, SITE VISIT Stantec Lead Verifier and Project Manager, Daniel Hegg, conducted a site visit to the Red Deer Ethanol Production facility, located in Red Deer, Alberta (8010 Edgar Industrial Crescent) on May 11, The following Permolex personnel were interviewed: Bridgette Duniece (HSE & HR Manager); and Erin McKay (Process Coordinator). Stantec conducted a tour, led by Permolex representatives with in-depth knowledge of the facilities and the Project. During the tour, Stantec performed procedures to identify Project boundaries, confirmed GHG sources, looked for additional sources, visually confirmed the presence of ethanol production and cogeneration activities, natural gas and electrical meters, gluten, flour, grain scales, activities related to diesel and propane consumption as well as inquired about Project operations and Project specific GHG data management systems. 4.5 VERIFICATION PROCEDURES The process of developing the sampling plan included a review of Permolex s records and comparisons of raw data to calculation spreadsheets provided by Permolex for the verification program. Interviews with the staff members listed above were conducted to assess various aspects of Project operations, data management, data storage, and transfer. Activities associated with operations, record keeping, meter data management, and emissions sources were reviewed to better understand the calculations, data treatment, and data management for the Project. 8 August 31, 2015

15 VERIFICATION REPORT FOR PERMOLEX LTD. RED DEER ETHANOL PRODUCTION EXPANSION OFFSET PROJECT ( ) The site boundaries were evaluated to confirm that no additional GHG sources, sinks, or reservoirs were present. During the site visit, Stantec observed the third party (ATCO) natural gas meter, electricity meter, direct grind feed stock receipts and truck scales, equipment for direct grind s quality assessment, ethanol production flow meter, and co-generation facility. Activities associated with feedstock, processing units, measurements and emissions sources and reductions were reviewed to confirm consistency with the Project Report. Stantec s final sampling plan included sampling records for feedstock receipts, natural gas, diesel and propane consumption (immaterial volumes consumed), electricity consumption, ethanol production, percent of ethanol sold to Alberta RFS market, moisture content of ethanol, higher heating value (HHV) of ethanol, emission factors and conversion factors as well as recalculating Baseline and Project emissions and assessing consistency with the Protocol and AEP guidance. The final verification procedures are provided in the final verification plan (Appendix A) and summarized in Table CONFIRMATIONS For this Project, Stantec confirmed that: The Project information was consistent across the Project documentation; The Project location is as indicated in the Project Offset Report; The Project Plan contains the monitoring and quantification procedures applied to this Project; The Project contact, report date, emission reduction numbers and other related information is accurate; and The Project GHG Information System is consistent with the data flow diagram shown in the Project Plan. August 31,

16 VERIFICATION REPORT FOR PERMOLEX LTD. RED DEER ETHANOL PRODUCTION EXPANSION OFFSET PROJECT ( ) 5.0 SUMMARY OF FINDINGS A summary of the key findings from this verification is provided in Table 5.1. Table 5.1 Verification and Sampling Plan Parameter Procedures Sampling Plan Result GHG Assertion Reviewed the Project Report for the following information: Location of the Project; Project start date and period; All required information. Satisfactory The Project takes place in Alberta. The Project took place after January 1, A 5- year credit extension to February 28, 2017 has been granted by AEP for the Project. Registration of Offset Credits; The credits have been registered on the Alberta registry. Project Plan; The Project Offset Plan is available on the Registry. Notice of Creation; Protocol followed; and Eligibility of GHGs reduction. Permolex has appropriately completed the Notice of Creation. The Project is using the correct version of the Alberta Biofuel Production Protocol. The GHGs emission reductions are eligible. The following material misstatements were noted and resolved by Permolex. Details on the misstatement and resolution can be found in Table 5.2: No RFSR reports supporting the 6,043 L of ethanol being claimed for the period January March 2011 was provided. No RFSR reports supporting the 832,016 L of ethanol being claimed for the period January March 2011 was provided. 10 August 31, 2015

17 VERIFICATION REPORT FOR PERMOLEX LTD. RED DEER ETHANOL PRODUCTION EXPANSION OFFSET PROJECT ( ) Table 5.1 Verification and Sampling Plan Parameter Procedures Sampling Plan Result Ethanol volumes from Alberta (origin) to Saskatoon, Saskatchewan (destination) were included in the 2011 GHG assertion. Satisfactory Stantec conducted a site visit and onsite interviews to assess procedures for various aspects of Project operations, data management, production accounting, QA/QC and data storage and transfer. Activities associated with feedstock, processing units, measurements and emissions sources and reductions were reviewed to confirm consistency with the Project Report. The site boundaries were also evaluated by the Verifier to confirm that there have been no physical changes that would affect the boundary for the Project Plan. Stantec confirmed the facility emissions sources were considered in the emission reductions included in the report and looked for additional sources that were not included in the Project Plan. Conducted a site tour to compare emissions inventory to on-site sources. All on-site GHG sources. Ownership Reviewed the Project Report for a statement regarding credit ownership. Reviewed ownership evidence. Sufficient and appropriate evidence to support that Permolex is authorized to serialize the offset credits. Sufficient and appropriate evidence to support that Permolex has ownership over the emissions reductions. Satisfactory The Project Report indicates that Permolex owns the Project. This was confirmed from signed letters from Elbow River Marketing and G&B Fuels (who purchased ethanol from Permolex) stating that they do not intend to make a similar Offset Project Plan for the ethanol they have purchased from Permolex and subsequently distributed and sold within Alberta for the period beginning in 2011 and extending through Project Reviewed the Project Report and supporting Not applicable. Satisfactory August 31,

18 VERIFICATION REPORT FOR PERMOLEX LTD. RED DEER ETHANOL PRODUCTION EXPANSION OFFSET PROJECT ( ) Table 5.1 Verification and Sampling Plan Parameter Procedures Sampling Plan Result Additionality documentation to assess whether the Project Developer is meeting the additionality criteria in the Protocol and the Project continues to be additional to regulations. The Project Plan does not contain any information on additionality, other than asserting that the emission reductions as a result of the Project are surplus to any regulation and there are no regulations mandating Permolex to produce a certain amount of ethanol. Because the Biofuel Production Protocol was updated in 2014, and additionality of potential projects are considered during the review stage of the Protocol, AEP would have considered business as usual and regulatory additionality during the protocol review. With regard to regulatory additionality, the Protocol would not have been approved had there been regulations in place for ethanol production and usage. Therefore, the Project is considered to be additional. Satisfactory The same Baseline and Project boundaries are contained in the Project Report and Project Plan. Similar magnitude of emission reductions claims is present in the Project Report and Project Plan. The following immaterial misstatements were noted and resolved by Permolex. Details on each misstatement and resolution can be found in Table 5.2: A typo for the pre-expansion benchmark period in the Project Plan is detected (shown as January 1, 2001 to November 31, 2003 but the last day of November is the 30th). The Project Report discussed changes to Project Consistency with Project Offset Plan Reviewed the Project Report against the Project Plan for the following criteria: Deviation of the Project from the Project Plan; Same Baseline and Project boundaries for the Project and the Project Plan; and Similar emission reductions claimed. Not applicable. 12 August 31, 2015

19 VERIFICATION REPORT FOR PERMOLEX LTD. RED DEER ETHANOL PRODUCTION EXPANSION OFFSET PROJECT ( ) Table 5.1 Verification and Sampling Plan Parameter Procedures Sampling Plan Result Plan as the Project Plan was updated in June 2015 but does not discuss deviation of the Project from the Project Plan. The only deviation of the Project Report from the Project Plan detected is that diesel and propane consumption was included in the Project (SSRs P11, P24, and P25). Consistency with ISO Assessed the Project Report for transparency. Not applicable. Satisfactory The exact dates of starting and ending period have been included in the Project Report. Assessed the Project Report for accuracy. Not applicable. Satisfactory The GHG assertion within the Project Report was found to agree with the emissions quantified by Permolex. Assessed the Project Report for relevance and completeness. Not applicable. Satisfactory The information presented in the Project Report is relevant. The Project Report was found to contain all information required to be reported according to the Guidance. Assessed the Project Report for consistency. Not applicable. Satisfactory The Project Report is consistent with the Project Plan. Consistent formulas were used for emissions quantification. The following immaterial misstatement was noted and resolved by Permolex. Details on the misstatement and resolution can be found in Table 5.2: The emission reductions occur in the reporting period of January 1, 2011 to December 31, Section 1 of the Project Report shows the reporting period as January 2011 to December The August 31,

20 VERIFICATION REPORT FOR PERMOLEX LTD. RED DEER ETHANOL PRODUCTION EXPANSION OFFSET PROJECT ( ) Table 5.1 Verification and Sampling Plan Parameter Procedures Sampling Plan Result exact dates of starting and ending period have not been included in Section 1 of the Project Report. Project Developer signature page in the Project Report was not appropriately filled out (execution date was missing). Satisfactory Ethanol production data were obtained from direct measurement using a flow meter. Data were captured and recorded through the plant DCS (Distributed Control System). Daily ethanol production data were also presented in plant production reports. Pre-expansion ethanol volume was found to be supported by appropriate evidence. Quantification and Monitoring Conducted a trend analysis for monthly ethanol production. Traced ethanol production volume used in the calculators to the plant production reports. Reviewed historical monthly ethanol production for preexpansion ethanol volume. Trended all monthly ethanol production volumes. Traced all 12 months for 2011 and three random months for each year of 2012, 2013, and Reviewed historical monthly ethanol production data for January 2001 to September Traced HHV of ethanol used in the calculators to the US EPA reference value Not applicable Satisfactory The default HHV of ethanol used in the calculators is supported by the reference. Unit conversion was performed correctly. Traced moisture content of ethanol used in the calculators to laboratory reports. Reviewed a sample of Karl fisher laboratory report. Conducted internet search for marketing ethanol moisture content for reasonableness check. Satisfactory The moisture content of ethanol used in the calculators for adjusting the value of HHV of ethanol is consistent with the laboratory report and comparable with marketing ethanol. 14 August 31, 2015

21 VERIFICATION REPORT FOR PERMOLEX LTD. RED DEER ETHANOL PRODUCTION EXPANSION OFFSET PROJECT ( ) Table 5.1 Verification and Sampling Plan Parameter Procedures Sampling Plan Result Assessed eligible ethanol included in the Project. Reviewed all records for ethanol shipments and sold in Alberta against the data used in the calculators. Satisfactory Other than in Q1 of 2011, the percent ethanol sold in Alberta in the calculators is supported by the ethanol shipment records, RFSR reports and RFSR validation numbers. For Q1 of 2011, Permolex received an letter from Alberta Environment and Parks (AEP) that allows Permolex to bring forward the tonnage from January 1 to March 31, 2011 under the Protocol without having to provide the Renewable Fuels Standard compliance reports (as required by the Protocol). Although there is verifiable evidence for the ethanol produced by Permolex, other than self-assertion by Permolex, there is no independent data to support the amount of eligible ethanol as the RFSR was not in place. However, the AEP letter allows for this. The following immaterial misstatement was noted and resolved by Permolex. Details on the misstatement and resolution can be found in Table 5.2: Project period ethanol production data in the 2011calculator for three months (September, October, and December) out of twelve months of 2011 are not consistent with the plant production reports. The following material misstatements were noted and resolved by Permolex. Details on the misstatement and resolution can be found in Table 5.2: No RFSR reports supporting the 6,043 L of ethanol being claimed for the period January March August 31,

22 VERIFICATION REPORT FOR PERMOLEX LTD. RED DEER ETHANOL PRODUCTION EXPANSION OFFSET PROJECT ( ) Table 5.1 Verification and Sampling Plan Parameter Procedures Sampling Plan Result 2011 was provided. No RFSR reports supporting the 832,016 L of ethanol being claimed for the period January March 2011 was provided. Ethanol volumes from Alberta (origin) to Saskatoon, Saskatchewan (destination) were included in the 2011 GHG assertion. Conducted a trend analysis for monthly feedstock weight. Traced feedstock weight used in the calculators to feedstock receipt records. Trended all monthly feedstock weights. Traced all feedstock receipt records for 2011 through Satisfactory The annual corn, wheat and rye/barley consumption in the calculators is consistent with the feedstock receipt records for The following immaterial misstatements were noted and resolved by Permolex. Details on each misstatement and resolution can be found in Table 5.2: The annual corn, wheat and rye/barley consumption for 2012 in the calculation was not consistent with the feedstock receipt records (calculator = 17,462 tonnes, records = 17,783 tonnes). Percent local feedstock (%R) for January 2011 in the calculator was not consistent with the records (calculator = 99.24%, records = 0.76%). The annual wheat feedstock was incorrectly calculated (the expansion production as a percent of total production was not applied). 16 August 31, 2015

23 VERIFICATION REPORT FOR PERMOLEX LTD. RED DEER ETHANOL PRODUCTION EXPANSION OFFSET PROJECT ( ) Table 5.1 Verification and Sampling Plan Parameter Procedures Sampling Plan Result Assessed eligible feedstock (direct grind) included in the Project. Reviewed all grain receipt records for 2011through 2014 for the percent locally grain received. Satisfactory Grain receipt records for 2011through 2014 is consistent with the feedstock receipt records for No ineligible grains have been included. Conducted a trend analysis for monthly natural gas consumption. Traced natural gas consumption in the calculators to the third party invoices. Trended all monthly natural gas consumption with ethanol production. Traced all 12 months for Sampled eight random months for 2012 and three months for each year of 2013, and Satisfactory The trend analysis indicated that natural gas consumption corresponded well with ethanol production. No outliers were detected. Third party natural gas invoices cover all calendar years (from January 1 to December 31). No errors detected in the final calculators. The following immaterial misstatement was noted and resolved by Permolex. Details on the misstatement and resolution can be found in Table 5.2: The 2012 natural gas consumption for April and May are not consistent with the invoices (April: calculator = 57,384 GJ, invoice = 57,473 GJ; May: calculator = 52,157 GJ invoice = 52,207 GJ). Reviewed pre-expansion natural gas benchmark (GJ) climate records) Traced gluten production in calculators to plant production reports for four random months for each year of 2011 to Traced ethanol production - see above, under ethanol production Satisfactory The gluten production used in the calculators is supported by the plant production reports. August 31,

24 VERIFICATION REPORT FOR PERMOLEX LTD. RED DEER ETHANOL PRODUCTION EXPANSION OFFSET PROJECT ( ) Table 5.1 Verification and Sampling Plan Parameter Procedures Sampling Plan Result volume. Conducted a trend analysis for monthly diesel consumption. Traced diesel consumption in the calculators to the third party invoices. Trended all monthly diesel consumption. Sampled high consumptions (July 2012; January, June, July, and August 2013; January and July 2014.) Satisfactory Diesel consumption used in the calculators are consistent with sampled diesel invoices from a third party supplier. Conducted a trend analysis for monthly propane consumption and reviewed annual propane consumption for reasonableness. Reviewed all annual propane consumptions ( ) for reasonableness as propane combustion has insignificant impact to emission reduction. Satisfactory Annual propane consumption was consistent from year to year (approximately 7,300-7,900 lb/year). No outliers detected from the trend analysis. Conducted a trend analysis for monthly grid electricity consumption and inquired on outliers detected. Traced grid electricity consumption in the calculators to the third party invoices. Trended all monthly electricity consumption. Sampled four months for 2011 and 2012 and three months for 2013 and 2014 (representing outliers and average consumptions). Satisfactory Grid electricity consumption used in the calculators was supported by third party electricity invoices. Outliers (high consumption) of grid electricity consumption were in line with non-operating periods of the co-generation facility. Third party grid electricity invoices cover calendar years (from January 1 to December 31). Assessed the Project for inconsistent quantification methodologies outlined in the Protocol. All methodologies (including Baseline emissions, Project emissions, and emission reductions). Satisfactory Stantec found that the quantification methodologies used were consistent with the Biofuel Production Protocol. 18 August 31, 2015

25 VERIFICATION REPORT FOR PERMOLEX LTD. RED DEER ETHANOL PRODUCTION EXPANSION OFFSET PROJECT ( ) Table 5.1 Verification and Sampling Plan Parameter Procedures Sampling Plan Result Inspected calibration and verification records for the ethanol production meter and truck weigh scales Review calibration certificates. Satisfactory Ethanol mass flow meter was calibrated on bi-annual basis. Stantec reviewed the calibration certificates for 2012 and 2014 during the site visit. Stantec received truck scale calibration certificates for No discrepancies noted. Recalculated Baseline emissions. Not applicable. Satisfactory Stantec successfully recalculated the Baseline emissions. Recalculated Project emissions. Not applicable. Satisfactory The final version of the GHG calculators present appropriate emission reductions. Assessed whether emission factors were appropriate and agree with the sources. Reviewed all applicable emission factors: Biofuel (ethanol) distribution and dispensing factor (CO2e); Ethanol combustion emission factors (CH4 and N2O); Fertilizer/pesticide production and transportation factors for wheat, corn, and barley (CO2e); Feedstock production and processing factor for wheat, corn, and barley (CO2e); Satisfactory Appropriate biofuel (ethanol) distribution and dispensing factor of 3.76 kg CO2e/ GJ ethanol per the Biofuel Production Protocol was used. Appropriate ethanol combustion emission factors of 0.56 g CH4/liter ethanol and 0.66 g N2O / liter ethanol per Environment Canada, 2015 National Inventory Report (NIR), Part 2, Table A6-11were used. Appropriate fertilizer/pesticide production and transportation factors of 87.6 kg CO2e/tonne wheat, 48.6 kg CO2e/tonne corn, and 103 kg CO2e/tonne barley per the Biofuel Production August 31,

26 VERIFICATION REPORT FOR PERMOLEX LTD. RED DEER ETHANOL PRODUCTION EXPANSION OFFSET PROJECT ( ) Table 5.1 Verification and Sampling Plan Parameter Procedures Sampling Plan Result Local feedstock transportation factor (CO2e); Non-local feedstock transportation factor (CO2e); Chemicals production and transportation factors for wheat, corn, and barley (CO2e); Natural gas emission factors (CO2, CH4, N2O); Diesel emission factors (CO2, CH4, N2O); Propane emission factors (CO2, CH4, N2O); and Grid electricity use factor (CO2e). Protocol were used. Appropriate local feedstock transportation factor of 84.7 kg CO2e/ tonne feedstock per the Biofuel Production Protocol was used. Appropriate non-local feedstock transportation factor of 39.9 kg CO2e/ tonne feedstock per the Biofuel Production Protocol was used. Appropriate chemicals production and transportation factors of 6.3 kg CO2e/tonne wheat, 6.47 kg CO2e/tonne corn, and 4.42 kg CO2e/tonne barley per the Biofuel Production Protocol were used. Appropriate natural gas emission factors of kg CO2/GJ natural gas, 9.916E-4 kg CH4/GJ natural gas, and 9.38E-4 kg N2O/GJ natural gas per Alberta Carbon Offset Emission Factors Handbook, March 31, 2015 (Handbook) were used (based on 1918 gco2/m 3 natural gas, gch4/ m 3 natural gas, and gn2o/ m 3 natural gas for Residential, Construction, Commercial/Institutional, Agriculture and converted to kg/gj using Alberta Energy's conversion factor of 26.8 m 3 /GJ). Appropriate diesel emission factors of kg CO2/liter propane, kg CH4/ liter propane, and kg N2O/ liter propane per the Handbook were used. The calculation used propane emission factors 20 August 31, 2015

27 VERIFICATION REPORT FOR PERMOLEX LTD. RED DEER ETHANOL PRODUCTION EXPANSION OFFSET PROJECT ( ) Table 5.1 Verification and Sampling Plan Parameter Procedures Sampling Plan Result of kg CO2/liter propane, kg CH4/ liter propane, and kg N2O/ liter propane. The CH4 and N2O factors are supported by 2015 NIR, Part2, Table A6 3. Appropriate grid electricity use factor of 0.64 kg CO2e/kWh per the Handbook was used. The following immaterial misstatements were noted and resolved by Permolex. Details on each misstatement and resolution can be found in Table 5.2: An error was detected for conversion from g/l to kg/gj for CH4 and N2O emission factors for ethanol combustion. Permolex multiplied the emission factors in kg/l with GJ/L of the HHV of ethanol which did not result in kg/gj. The CO2 emission factor of propane used in the Project emission calculations is kg CO2/liter propane which is slightly different from the 2015 Environment Canada National Inventory Report of kg CO2/liter propane. GHG Data Management and Quality Control Assessed whether Permolex s GHG data management system, including quality control, is adequate. Entire system for completeness, accuracy, validity, and restricted access, through interviews, Project documentation, and site visit. Satisfactory Stantec reviewed Permolex s data management system through a review of on-site monitoring systems, personnel interviews, and inspecting the quantification spreadsheet, Project Plan, Project Report, and supporting information. Stantec found that Permolex s data management system adequately collects and aggregates Project data and performs checks on the August 31,