verification report for · ssrs* baseline: emissions from decomposition of biomass and methane...

Sundre Forest Product THF Biomass Burner Project (3157-5491)

April 2018 | 704-ENW.EENW03301-01

Verification Report for:


Proponent:

Sundre Forest Products Inc.

Prepared by:

Tetra Tech Canada Inc.

Prepared for:

West Fraser Mills Ltd.

Version:

Final

Date:

April 20, 2018


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Table of Contents

1.0 Summary – Offset Project ............................................................................................. 4

2.0 Introduction ................................................................................................................ 7

2.1 Objective ............................................................................................................ 7

2.2 Scope ................................................................................................................. 8

2.3 Level of Assurance ............................................................................................... 9

2.4 Criteria ............................................................................................................... 9

2.5 Materiality ........................................................................................................... 9

3.0 Methodology ................................................................................................................ 9

3.1 Procedures ........................................................................................................ 10

3.1.1 Verification Procedures ............................................................................. 10

3.1.2 Verification Steps ..................................................................................... 11

3.1.3 Site Visit ................................................................................................. 12

3.1.4 Risk Assessment ...................................................................................... 12

3.1.5 Verification and Sampling Plan ................................................................... 13

3.2 Team ................................................................................................................ 13

3.3 Schedule ........................................................................................................... 15

4.0 Results ..................................................................................................................... 15

4.1 Assessment of Internal Data Management and Controls .......................................... 15

4.2 Assessment of GHG Data and Information ............................................................. 16

4.3 Assessment against Criteria ................................................................................. 17

4.4 Evaluation of the GHG Assertion ........................................................................... 18

4.5 Summary of Findings .......................................................................................... 18

4.6 Opportunity for Improvement .............................................................................. 20

5.0 Closure ..................................................................................................................... 20

5.1 Verification Statement ........................................................................................ 20

5.2 Limitation of Liability .......................................................................................... 20

5.3 Confirmations .................................................................................................... 21

6.0 References ................................................................................................................ 21

Appendix A: Final Verification Plan and Sampling Plan ............................................................ 22

Appendix B: Statement of Qualifications................................................................................ 30

Appendix C: Findings and Issues .......................................................................................... 33

Appendix D: Statement of Verification .................................................................................. 36

Appendix E: Conflict of Interest Checklist .............................................................................. 39

Appendix F: Limitation on Use of this Document..................................................................... 42


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List of Tables

Table 1: Scope ..................................................................................................................... 8

Table 2: Verification Procedures ........................................................................................... 10

Table 3: Risk Assessment and Procedures ............................................................................. 13

Table 4: Schedule .............................................................................................................. 15

Table 5: Summary of Internal Controls ................................................................................. 16

Table 6: GHG Data and Informaiton...................................................................................... 17

Table 7: Offset Criteria Assessment ...................................................................................... 17

Table 8: Summary of Findings ............................................................................................. 19

Table 9: Detailed Findings and Issues Log ............................................................................. 34

List of Figures

Figure 1: Verification Steps ................................................................................................. 12

Figure 2: Data Management and Flow ................................................................................... 16

Instructions are in italics throughout and should not be deleted when report is complete. Some instructions

are specific to the verification of facilities and for offset projects. The document is not restricted but do not

alter the format, the layout, the headings or the overall ‘look and feel’ of the document. If if is more usefule

to paste information outside of the text box, use the empty line just below the text box to drop text or

tables int. This should not change the headings or the formats. There are several dropdown boxes in the

document that must be completed.

• Complete report in Verdana 10pt font (no italics).

• After the report is complete, right click the table of contents and ‘update field’ which will update page numbers in Table of Contents.

• If an instruction only applies to facilities or only applies to offsets indicate ‘not applicable’.

• Appendix F is available for additional tables, diagrams etc.


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1.0 Summary – Offset Project

Item Description

Project Title

Enter project title (must match the registry

project title)

Sundre Forest Product THF Biomass Burner project

Project Description

Provide a brief description of the project and

baseline conditions.

The Project involves direct Greenhouse Gas (GHG)

emission reductions by reducing natural gas

consumption.

Project Location

Include the latitude and longitude for each

unique location or installation. Include legal

land location if applicable and other

information identifying the unique location.

Sundre Forest Products Inc. is located approximately

3 km West of Sundre, Alberta on highway 584. The

legal description of the site is 5541 Hwy 584, 5-05-

032-31 NW.

Latitude: 51.791258. Longitude: -114.705591

Project Start Date

Enter the project start date.

October 2007

Offset Start Date

Enter the start date for offset credit

generation.

January 1, 2008

Offset Crediting Period

Enter the offset crediting period, including the

offset start date. Include day, month year.

Initial project credit duration period: January 1, 2008

to December 31, 2015

Reporting Period

Enter the reporting period being verified.

January 1, 2014 – December 31, 2015

GHG Assertion (Actual Emission

Reductions/Sequestration Achieved)

Enter the actual emissions reductions /

sequestration for the reporting period. Enter

serial numbers if available.

2014: 10,378 t CO2e

2015: 10,340 t CO2e

Protocol

Indicate the relevant protocol (if

applicable)

Diversion of Biomass to Energy from Biomass

Combustion Facilities Quantification Protocol (Version

1.0, September 2007)

Ownership

Enter offset project owner.

Sundre Forest Products Inc.


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Project Activity

State how the project activity meets the

eligibility requirements

Site visit confirmed the reduction occurs in Alberta

Combustion of biomass waste is not required by law

for energy generation.

Project started commercial operations October, 2007

The Project reductions/removals are real,

demonstrable, quantifiable and verifiable: The Project

is creating real reductions that are not a result of

shutdown, cessation of activity or drop in production

levels.

Activity data is measured and emissions are

quantified using the approved protocol.

The verification team meets the requirements set out

in the Standard for Verification (Version 1.0 Dec.

2017) Part 1 Section 3.

Project Contact

Enter contact name, company name, mailing

address, phone number and email address.

Veikko Paivinen, CPA

Financial Manager, Energy and Carbon

West Fraser Mills Ltd.

1250 Brownmiller Road, Quesnel, BC V2J 6P5

Tel: (250) 992-0804

Email: [email protected]

Verifier

Verifier name, verifier’s company name,

address, phone number email etc.

Min Si, M.N.R.M, GHG-V


115, 200 Rivercrest Drive SE, Calgary, AB T2C 2X5

Tel: (403) 369 5254

Email: [email protected]

Verification Team Members

Include verification team members, roles,

training, training dates and qualifications.

Nelson Lee, M.A.Sc, P. Eng., GHG-V, Designated

Signing Authority. Mr. Lee has completed ISO 14064-

3 training in March 2006.

Min Si, M.N.R.M, GHG-V, Lead Verifier. Mr. Si

completed ISO 14064 – 3 training in December 2015.

Nancy Wellhausen, Peer Reviewer. Ms.Wellhausen

completed ISO14064 -3 training in June 2017.

Kathleen Dunnett, P.Eng., Verifier

Designated Signing Authority

Enter the designated signing authority for this

verification.

Nelson Lee, M.A.Sc, P. Eng., GHG-V


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Verification Strategy

Describe the verification strategy used for the

verification, including rationale for the

approach. Note, if a controls reliance is used,

provide justification for how the project is

able to support this approach.

The strategy used in this verification approach relies

on substantive procedures. Tetra Tech applies

predominantly substantive procedures during the

verification process, with a focus on source data and

evidence gathered during site visits and sampling

procedures. Tetra Tech has developed the following

steps to substantiate the GHG assertion:

• Conducted a site visit to confirm the boundary, physical sources, sinks and reservoirs (SSRs) at the facility.

• Observed, interviewed personnel, and verified various processes, instrumentation and data management procedures during the site visit.

• Conducted sampling on primary documentation to confirm the processes resulting in the GHG assertions.

• Reviewed original data sources and calculations.


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2.0 Introduction

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

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

summary of changes at the project since the offset project start date or baseline period.

For Facilities: Description of compliance or baseline report, facility/project boundary, facility identification

information, GHG historical performance, summary of changes since the baseline or since the last

compliance report.

Tetra Tech Canada Inc. (Tetra Tech) was contracted by Sundre Forest Products Inc. (Sundre), a

division of West Fraser Mills Ltd.(West Fraser) to conduct verifications of greenhouse gas (GHG)

emission reductions for its Sundre Forest Product Lumber Thermally Heated Fluid (THF) Biomass

Burner Project (Project) for the period of January 1, 2014 to December 31, 2015.

Revision 1 to the Verification Report

The verification report was original issued on October 6, 2016 (Tetra Tech File Number 704-

ENVIND03938-01.002). The project developer – West Fraser submitted the verification report to

the CSA Registry for serialization in 2018.

As required by Alberta Environment and Parks - Climate Change Office (ACCO), offset project

verification reports submitted after January 1, 2018 must use the updated template (dated

December 2017). This revision is to update the verification report using the new template.

Summary of Offset Project Baseline

The Project is a biomass to energy carbon offset project at the Sundre facility. Prior to the Project,

lumber was dried in a kiln by a natural gas – fired forced hot air system. The offset project involved

the design and installation of a dual biomass furnace to produce thermal energy from the wood

waste generated by the facility. The thermal energy heats a hot oil system, and heated thermal oil

is circulated through the kilns to dry dimensioned lumber.

Summary of Changes to Baseline or at the Project Condition

There are no changes or modifications to the project operations and data collection. Quantification

changes are provided in the Offset Project Report.

2.1 Objective

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

The objective of this verification is to provide an independent assessment of the offset project to

identify any material and immaterial errors, omissions or misrepresentations, and to provide our

opinion on the GHG assertion in the Offset Project Report.


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2.2 Scope

Define the scope in terms of: geographical, organizational, activities and processes, sources, sinks,

categories and greenhouse gases included (considering the completeness of the inventory), GHG assertion

time period.

For offset verifications: include the serial range (i.e. XXXX-XXXX-XXX-XXX-XXX-XXX to XXXX-XXXX-XXX-

XXX-XXX-XXX) if assigned (i.e. in the case of government verification a serial range will be available,

otherwise not applicable).

For Facilities: ensure all specified gases and source categories are evaluated. Include list of negligible

emission sources and justification for Emission Performance Credits (EPCs). Include listing of end products.

The scope of this Project level emission reduction verification includes the project boundaries,

physical infrastructure, activities, technologies, and processes of the project, GHG sources, sinks,

and/or reservoirs (SSRs), types of GHGs, and time periods covered.

The scope of the verification is listed in Table 1

Table 1: Scope

Item Sundre Forest Product THF Biomass Burner project

Geography Sundre Forest Products Inc. is located approximately 3 km West of

Sundre, Alberta on highway 584. The legal description of the site is

5541 Hwy 584, 5-05-032-31-NW.


Organization Sundre Forest Products Inc.

Activities and Processes Thermal energy generation from biomass combustion.

SSRs* Baseline: Emissions from decomposition of Biomass and Methane

collection and destruction (B9 and B10), Electricity production (B11),

Thermal energy produced (B12), Fuel extraction and processing

(B13)

Project: Emissions from facility operation P6, P8 to P11, P13, P14 and

P16, Combustion of biomass (P12), Fuel extraction and processing

(P22)

GHG Carbon dioxide (CO2), Methane (CH4), Nitrous oxide (N2O)

GHG Assertion 2014: 10,378 t CO2e

2015: 10,340 t CO2e

Time Period January 1, 2014 to December 31, 2015

*included sources as specified in the Protocol.


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2.3 Level of Assurance

The verification was conducted to a reasonable level of assurance.

Choose type of verification from the dropdown box above.

Provide explanation on level of assurance.

The level of assurance is used to determine the depth of detail that a verifier designs into their

verification plan to determine if there are any material errors, omissions, or misrepresentations.

Reasonable level of assurance is conducted to evaluate whether the GHG assertion is deemed to be

presented fairly and substantiated by sufficient and appropriate evidence. As such, the goal of

verification is to provide positive, but not absolute assurance regarding the GHG assertions.

2.4 Criteria

Outline the program criteria used and relevant supporting documentation (acts, regulations, protocols,

standards, guidance documents, project documentation etc).

The verification assesses the Project against Alberta Offset program eligibility criteria, including

• Alberta Carbon Competitiveness Incentive Regulation (CCIR), December 18, 2017;

• Standard for Greenhouse Gas Emission Offset Project Developer (Version 1.0, December 2017);

• Standard for Verification (Version 1.0 December 2017);

• Quantification Protocol for Quantification Protocol for Diversion of Biomass to Energy from Biomass Combustion Facilities (Version 1.0, September 2007);

• Offset Project Plan for Sundre Forest Product THF Biomass Burner Project; and

• Offset Project Report for Sundre Forest Product THF Biomass Burner Project.

2.5 Materiality

Define the materiality of the verification.

A 5% materiality threshold is set to assess errors, omissions, and misrepresentations in the GHG

assertion as required by the CCIR. Quantitative discrepancies are aggregated and assessed on the

basis of net and absolute values. Qualitative discrepancies are evaluated by professional judgement

of the verification body, and assessed to determine if the discrepancies could be deemed to be

material errors.

3.0 Methodology

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

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

The verification is performed according to ISO 14064-3: Specification with Guidance for the

Validation and Verification of GHG Assertions.


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Tetra Tech applies predominantly substantive procedures during the verification process, with a

focus on source data and evidence gathered during site visits and sampling procedures. Tetra Tech

has developed the following steps to substantiate the GHG assertion:

• Conducted a site visit to confirm the boundary, physical sources, sinks and reservoirs (SSRs) at the facility.

• Observed, interviewed personnel, and verified various processes, instrumentation and data management procedures during the site visit.

• Conducted sampling on primary documentation to confirm the processes resulting in the GHG assertions.

• Reviewed original data sources and calculations.

The assessments, tests, reviews, and/ or evaluations that were conducted during the verification

include inspection, observation, inquiry, confirmation, recalculation, and analytics test. The detailed

verification procedures are provided in below Section.

3.1 Procedures

Description of how the verification was conducted including: description of the nature, scale and complexity

of the verification activity, confidence and completeness of the responsible party’s GHG information and

assertion, assessment of GHG information system and its controls, assessment of GHG data and

information, assessment of GHG information system and controls, assessment against criteria, evaluation of

the GHG assertion.

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

preparation.

Describe how the risk based approach was implemented in the sampling plan. Identify categories of risk

including inherent risk, and detection risk (organization and verifier). Include the Verification Plan with the

Sampling Plan in Appendix A. Paste the risk assessment table in this section.

3.1.1 Verification Procedures

Verification procedures for the key components are provided in Table 2.

Table 2: Verification Procedures

Verification Component Procedures

Description of the nature, scale

and complexity of the verification

activity

The verification is conducted for Sundre THF Biomass Burner

project. The project is a biomass to energy generation

project, replacing natural gas consumption at the Sundre

facility to dry lumber.

The quantification of the offset project is assessed against

Quantification Protocol Diversion of Biomass to Energy from

Biomass Combustion Facilities (Version 1.0, September

2007).

The offset project generated approximately 12,000 tonnes of

CO2e emission reductions annually in 2008 – 2015.


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The complexity of the verification is deemed to be low, as

there are limited emission sources, including:

• Baseline: Emissions from Thermal energy produced (B12), Fuel extraction and processing (B13)

• Project: Emissions from Facility operation (P6, P8 to P11, P13, P14 & P16), Combustion of biomass (P12), Fuel extraction and processing (P22)

Comparability with the baseline • Review the baseline calculations and supporting documents.

• Review Project Plan and Report.

• Interview facility operators.

Confidence and completeness of

the responsible party’s GHG

information and assertion

• Conduct a site tour to determine GHG sources and compare with the Protocol and calculation tool for completeness.

• Check the quantification against the Protocol.

• Interview personnel for completing GHG quantification.

Assessment of GHG information

system and its controls

• Review data collection and transfer processes.

• Interview personnel for internal control procedures.

• Inquiry data verification procedures for double entries.

• Examine natural gas and biomass records reconciliation.

Assessment of GHG data and

information

• Compare sources and sinks inspected through site visit to the GHG identified in the Project Report and calculator.

• Review raw data, including metering data and 3rd party records.

• Review emission factors used.

Assessment against criteria • Review and check against related criteria.

• Conduct site visit for physical boundary.

Evaluation of the GHG assertion • Recalculate GHG assertions.

• Evaluate supporting documents.

3.1.2 Verification Steps

The verification follows the steps outlined in the following diagram (Figure 1).


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Figure 1: Verification Steps

3.1.3 Site Visit

Mr. Min Si of Tetra Tech visited the facility on June 9, 2015. The purpose of the site visit was to

gain an understanding of the offset project’s operation, equipment, and control processes for

assessment of the Project’s conformance with the Criteria. During the site visit, the emission

sources, various processes, data acquisition and onsite records handling processes were observed.

The control devices that were used to collect and monitor activity data for emission calculations

were also observed.

3.1.4 Risk Assessment

As part of the verification process, a risk-based verification and sampling plan must be developed

that outlines:

• The amount and type of evidence necessary to achieve the agreed level of assurances;

• Methodologies for determining representative samples; and

• Risks of potential errors, omissions, or misrepresentation

Tetra Tech’s verification team utilizes the risk assessment process to develop a compliant

verification and sampling plan. The risk assessment includes considerations associated with

regulatory requirements, GHG program requirements, industry/sector specific factors, and other

non-technical risks.

Acceptance

•Client and verification evaluation• Independence and team evaluation

Planning

•Gain an understanding - data and process flow, historical analysis•Risk assessment, planining analytics, contribution analysis and materiality analysis•Verification strategy, verification plan, sampling plan

Execution

•Conduct verification procedures and collect evidence•Review evidence against program criteria•Document findings log and unadjusted differences

Completion

•Conclusion: senior review, Issue for Review verification report•Peer review: approval and sign off• Issuance: Issue for Use verification report


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The risk assessment considers inherent risk, control risk and detection risk. Inherent risk is the

Responsible Party’s risk of material error, omission, or discrepancy due to the complexity of the

facility or lack of capacity by staff at the facility. Control risk is the risk that the Responsible Party’s

control system will not detect and rectify a material error, omission or discrepancy. Detection risk

is the risk that the Tetra Tech verification team will not identify a material discrepancy. The method

to determine the risk is provided in Appendix A – Verification Plan.

The risk assessment for the applicable reporting elements are provided in Table 3.

Table 3: Risk Assessment and Procedures

Line Item Risk Procedures

GHG Assertions • Incomplete inventory

• Inappropriate data and emission factors used

• Incorrect GHG assertions

• Conduct site visit to inspect boundary and SSRs.

• Check emission factors, raw data, and quantification methodologies

• Check calculations

Biomass Combustion • Incorrect measurement

• Incorrect emission factors

• Inspect raw data records

• Review the method used to estimate biomass volume and moisture content

• Check the emission factors

Natural Gas

Consumption

• Incorrect fuel consumption

• Inaccurate calculation

• Review raw data records

• Recalculation

Thermal Energy

Produced

Inaccurate calculation Recalculation

Electricity consumption incorrect calculation Review the method used to estimate

electricity consumption

3.1.5 Verification and Sampling Plan

Convenience sampling methods are used for the verification. The sample plan is developed based

on the risk assessment to achieve an overall low detection risk. The sample size is based on the

Guidance Document for GHG verification sampling by the European Commission with verifier’s

professional judgement. The sample size varies based on the number of evidence records. The type

and amount of evidence reviewed for each emission source is provided in the Final Verification Plan

(Appendix A).

3.2 Team

List verification team members including peer reviewer(s).


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

training and certifications.

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

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

The verification team meets the requirements under the Carbon Competitiveness Incentive

Regulation (CCIR) and have the technical knowledge of GHG emission quantification methodologies

required by Standard for Verification (ACCO Version 1.0 December 2017) Part 1 Section 3. The

team members have experience in completing third party GHG verifications, reviews and audits

related to emission inventories, including verifications in Alberta. Verification team members have

been trained under ISO 14064-3.

Nelson Lee, M.A.Sc., P.Eng., GHG-V is the Designated Signing Authority and Lead Verifier for

this verification. Mr. Lee has a B.Sc. in Chemical Engineering from the University of Alberta, and a

M.A.Sc. in environmental engineering from the University of British Columbia. He has 20 years of

experience in the oil and gas industry, and has completed over 100 GHG verifications in Alberta

and BC. Mr. Lee completed ISO 14064 – 3 training with Environment Canada in March 2006. Mr.

Lee is a CSA certified GHG verifier, and a California Air Resources Board (ARB) registered offset

project lead verifier.

Mr. Lee is responsible for ensuring:

• the verification acceptance requirement have been met as outlined in the Technical Guidance;

• the verification was conducted in accordance with ISO 14064-3 standard, and the Tetra Tech’s management system for quality assurance and control and independence has been applied during the verification;

• the verification was conducted in a professional manner; and

• the verification report was presented appropriately.

Nancy Wellhausen is the Peer Reviewer for this audit. Ms. Wellhausen is a Senior Air Quality

Scientist specializing in emission inventory development, dispersion modeling, air quality impact

analysis and assessments, and regulatory reporting. Ms. Wellhausen had GHG verification training

with California ARB, and is a ARB registered lead verifier. Her responsibilities include independent

review of verification deliverables and supporting documentation to confirm all verification activities

have been completed, and conclude whether the GHG assertion is free of material discrepancy and

the verification activities conducted achieved a reasonable level of assurance.

Kathleen Dunnett, P.Eng. is a Verifier for this audit. Ms. Dunnett is a Professional Engineer with

a degree in Chemical and Petroleum Engineering and is an Environmental Auditor with over 20

years of experience in regulatory compliance auditing and environmental management systems.

Ms. Dunnett has training in ISO 9001 and 14001 auditing standards. She conducted data review for

this project.

Min Si, M.N.R.M., GHG-V is the Lead Verifier for this verification. Mr. Si is an Environmental

Scientist with Tetra Tech in Calgary. He has worked on GHG verification and quantification projects

for a wide range of sectors, including oil and gas, pulp and paper, agriculture, manufacturing, etc.

His emission experience includes GHG life cycle assessment, GHG quantification and verification for

carbon offset projects, compliance report verification, National Pollution Registry Inventory (NPRI)

and corporate GHG reporting. Mr. Si has completed CSA ISO 14064 3 training with CSA in

December 2015. Mr. Si is responsible for:


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• managing the verification project;

• ensuring the team has appropriate competencies for the verification;

• communicating to key members of the responsible party regarding the verification objectives and results

The Statement of Qualifications is provided in Appendix B

3.3 Schedule

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

The schedule for the verification is presented in Table 4.

Table 4: Schedule

Activity Date

Kick-off Meeting and Initial Information Request April 14, 2015

Site Visit June 9, 2015

Desktop Review April 14, 2015 – August 6, 2016

Submit “Issued for Review” Report September 9, 2016

“Issued for Use” Report Delivered October 6, 2016

Revision to the Issue for Use Report April 20, 2018

4.0 Results

Add introduction to results section here, if desired.

4.1 Assessment of Internal Data Management and Controls

Provide a summary the information system(s) and its controls for sources of potential errors. Include

information on the selection and management of data, process for collecting and consolidating data, data

accuracy systems, design and maintenance of the GHG system, the systems and processes that support the

GHG information system and results from previous assessments if applicable.

The data management and flow is presented in Figure 1.


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Figure 2: Data Management and Flow

The internal control procedures are summarized in Table 5.

Table 5: Summary of Internal Controls

Reporting Element Controls

Natural Gas Consumption 3rd party invoices and internal accounting

Biomass Consumption Internal accounting and DCS operator

Electricity Engineering

GHG Quantification Quantifier and facility manager review

Conclusion

The internal data management and controls are assessed based on the review of the Offset Project

Plan, observations during the site visits, and interviews with key project personnel. The internal

data management and controls for the offset project are deemed to be adequate.

4.2 Assessment of GHG Data and Information

Provide a summary of the information found during the verification of the GHG data and a summary of the

GHG Assertion that was assessed.

Natural gas Biomass Quantity Electricity

3rd party invoice DCS, # of dumps Estimated

Accounting: Separate gas usage

of wood treating facility

from the invoice

Accounting: Compile natural gas and biomass data

into spreadsheet

Quantifier: Quantify the GHG reductions using the spreadsheet

Offset project report

Manual Auto


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For Facilities: Confirm that the quantification methodologies that were used in the compliance report are the

same as those reported in the BEIA.

For Offset Projects: Confirm that the quantification methodologies that were used by the project proponent

are the same as those described in the project plan. Indicate which quantification methodologies were used

by the project proponent.

The GHG data and information provided to support the GHG assertion is deemed to be sufficient.

The quantification methodologies used are consistent with the Offset Project Plan and the

Quantification Protocol.

The GHG data and information used to support the Assertion are presented in Table 6.

Table 6: GHG Data and Informaiton

Project Component Data and Information

Natural gas consumption 3rd party invoices

Biomass quantity Production Accounting records

Electricty consumption Field measurement

4.3 Assessment against Criteria

Provide a description of how eligibility criteria is met or not met.

For Offset Project: Complete Table 1 to indicate if the GHG Assertion conforms to the Regulation and

Standard for Greenhouse Gas Emission Offset Project Developers eligibility criteria.

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

The assessment against program eligibility criteria is provided in Table 7. It is our opinion that the

eligibility criteria are met.

Table 7: Offset Criteria Assessment

Offset Eligibility Criteria Assessment

Reduction or sequestration occurs in

Alberta

Site visit confirmed the project’s physical location.

Result from actions not required by Law

at the time the action is taken

Combustion of biomass waste is not required by law

for energy generation.

Result from Actions taken on or after

January 1, 2002 and occur on or after

January 1, 2002

Project started commercial operations January 1,

2008.


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Reduction or sequestrations is real and

demonstrable

The Project reductions/removals are real and

demonstrable. The Project is creating real reductions

that are not a result of shutdown, cessation of

activity or drop in production levels.

Quantifiable and measureable Activity data is measured and emissions are

quantified using the approved protocol.

Verified by a third party verifier that

meets the requirements in Part 1 for the

Standard for Verification.

The verification team meets the requirements set

out in the Standard for Verification (Version 1.0 Dec

2017) Part 1 Section 3.

4.4 Evaluation of the GHG Assertion

Provide an assessment of the evidence collected during the verification. Determine if the data and

information available support the GHG assertion. Provide a conclusion on whether the assertion meets the

materiality requirements and the level of assurance agreed to at the beginning of the verification process.

The verification assessment is that the GHG Assertion meets the requirements of the Carbon

Competitiveness Incentive Regulation

The GHG data and supporting documents are deemed to be sufficient and appropriate. The GHG

assertion is calculated in accordance with the approved quantification protocol.

It is our opinion that

• 10,378 t CO2e of the emission reductions for the period of Jan 1, 2014 to December 31, 2014 and

• 10,340 t CO2e of the emission reductions for the period of Jan 1, 2015 to December 31, 2015

meet the materiality requirements and the reasonable level assurance criteria.

4.5 Summary of Findings

Provide a summary of material and immaterial discrepancies expressed in tonnes and as net and absolute

error in Table 2. Include whether the discrepancy was an understatement or an overstatement.

Include a more detailed description and log of results in Appendix C the “Issues Log”. This log will include

both resolved and unresolved issues from the verification. Unresolved issues should be brought forward to

Table 2.

During the verification, no material misstatements were identified. There are no unresolved

immaterial findings remained. The detailed description of the findings is provided in Appendix C.


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Table 8: Summary of Findings

Number the finding with the year and provide a unique # for each finding.

Note: A detailed description of all material and immaterial findings should be provided in Table 3 of Appendix C.

Provide only a summary statement (1-4 sentences) for each unresolved immaterial finding and each material finding (resolved or unresolved). If

the finding is a resolved material finding, then put the tonnes net and absolute in the summary description column and indicate n/a in the net and

absolute columns. Do not include the tonnes in the total error calculation.

Indicate the type of error (qualitative or quantitative).

Indicate the Source Category (for facilities) or the Source/Sink (for offsets).

Indicate if the finding is an understatement or overstatement.

Provide both net and absolute error in tonnes of CO2 eq and as a % of the assertion.

Provide the total net error and the total absolute error in tonnes of CO2 eq and as a % of the assertion.

Result # Type Summary Description of Finding Source

Category or Source/Sink

Understatement/

Overstatement

Tonnes CO2 eq

% net

Tonnes CO2 eq

% absolute

N/A N/A N/A N/A N/A N/A

Total Error


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4.6 Opportunity for Improvement

Provide feedback on the data management system and controls, transparency, completeness of the

inventory, additions to the quantification methodology document or diagrams, etc. Include positive

considerations and observations also.

Identify strengths and weaknesses that may help to improve the report/s for the current facility, sector, and

compliance program. Identify ways in which the project/facility could be more easily verified.

The quantification is conducted using Excel. The calculator is transparent. The data management

and controls are described and the justification for excluding specified SSRs are provided in the

calculator to facilitate the verification.

5.0 Closure

5.1 Verification Statement

Include the signed verification statement in Appendix D.

Instructions to insert a pdf: 1. Click Insert>Object 2. In the Object dialog box click Create from File and

then click Browse. 3. Find the pdf you want to insert then click Insert. 4.Click OK.

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

For Facilities: paste a signed version of the Verification Statement from the facility compliance form. Include

the conclusion on the GHG assertion and any qualification or limitations and the level of assurance.

Provide the verification conclusion in the drop down box below.

The verificaion conclusion is: Positive

Based on our review, it is our opinion that Emission Reductions, including



contained in the GHG assertion generated from the Sundre Forest Product THF Biomass Burner

project offset project are materially correct and presented fairly in accordance with the relevant

criteria.

The Statement of Verification is provided in Appendix D.

5.2 Limitation of Liability

Include signed Conflict of Interest Checklist in Appendix E.

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

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

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

Tetra Tech has undertaken the verification of the asserted emission reductions associated with the

Project in accordance with related program criteria. Tetra Tech has assessed the offset project GHG


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assertion using reasonably ascertainable information as defined by ISO 14064. The assessment

represents the condition in the subject area at the time of the assessment. Tetra Tech did not

conduct direct GHG emissions monitoring or other actual environmental data sampling or analysis

as part of this verification.

The purpose of this report is to identify noted exceptions and observations in the quantification of

emission reductions. This report is not intended to imply exhaustive compliance or non-compliance

by the verification team. The verification team has made diligent effort to sample applicable

information available regarding emission reductions by the Project during the verification. It should

be noted that the inherent limitation in verification sampling and review practices may result in the

verifier not identifying all potential aspects of the project. Observations, exceptions and conclusions

are based on the judgment of the verifier.

The Conflict of Interest Checklist is provided in Appendix E.

5.3 Confirmations

Document information confirmed, including any discrepancies or inconsistencies, as per the Confirmations

section in the Standard for Greenhouse Gas Verification.

As required by ACCO, the verifier has confirmed the following information:

• Consistency of offset project information across offset project documentation;

• Offset project location;

• Methodology document/Project Report exists;

• Offset project contact and the amount of GHG emission reductions; and

• Completeness and accuracy of process and data flow diagram.

6.0 References

Author. Year. Title. (no hyperlinks)

International Organization for Standardization. 2006, ISO 14064-3: Specification with Guidance for

the Validation and Verification of GHG assertions.

Alberta Environment and Parks. 2015. Carbon Offset Emission Factors Handbook (Version 1.0)


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Appendix A: Final Verification Plan and Sampling Plan


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

Revisions to the sampling plan

Date originally sent to Facility/project

Level of assurance agreed with the facility/project developer

Verification scope

Verification criteria

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

assurance

Methodologies for determining representative samples

Sampling Plan and Procedures

Risk Assessment: Risks of potential errors, omissions or misrepresentations that are identified throughout

the verification process including:

- Details of site visit

-offset/facility boundaries

- Methodologies, emissions factors and conversions used

- Comparability with the approved baseline

- Conformance to the program criteria

- Integrity for the responsible party’s data management system and control (organization chart, GHGH

management plan, personnel/consultant training, protocols used, control system documentation,

software/program documentation/certifications)

- Greenhouse gas data and information, including the type of evidence collected, verification testing and

crosschecking, inventory of emission sources

- Discussion of data management, (measurement, fuel sampling, calibration, consistent use

of standard conditions, data storage, procedures to fill missing data; procedures to repair inconsistent data,

adjustment of variables and factors)

- Other relevant information


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April 20, 2018

Attention: Mr. Veikko Paivinen, CPA Financial Manager, Energy and Carbon

Subject: Verification Plan Edson Biomass Energy Generation Project October 1, 2013 to December 31, 2014

A1.0 Introduction

Tetra Tech Canada Inc. (Tetra Tech) was contracted by Sundre Forest Products Inc. to conduct

verifications of greenhouse gas (GHG) emission reductions for its Sundre Forest Product Lumber

Thermally Heated Fluid (THF) Biomass Burner Project (Project) for the period of January 1, 2014 to

December 31, 2015.

A1.1 Objective

The objective of this audit is to provide an independent assessment of the offset project to identify

any material and immaterial errors, omission or misrepresentations and to provide our opinion on

the GHG Assertion in the Offset Project Report.

A1.2 Assurance

The scope and level of effort of this verification is planned to achieve a reasonable level of assurance.

The level of assurance is used to determine the depth of detail that a verifier designs into their

verification plan to determine if there are any material errors, omissions, or misrepresentations.

Reasonable level of assurance is to evaluate whether the GHG assertion is deemed to be presented

fairly and substantiated by sufficient and appropriate evidence. As such, the verification is to provide

positive, but not absolute assurance regarding the GHG assertions.

A1.3 Scope

The scope of this Project level emission reduction verification includes the project boundaries,

physical infrastructure, activities, technologies, and processes of the project, GHG sources, sinks,

and/or reservoirs (SSRs), types of GHGs, and time periods covered.

The scope of the verification is listed in Table A1.

Table A1: Scope

Item Sundre Forest Product THF Biomass Burner project

Geography Sundre Forest Products Inc. is located approximately 3 km West of Sundre,

Alberta on highway 584. The legal description of the site is 5541 Hwy 584, 5-

05-032-31-NW.


Organization Sundre Forest Products Inc.


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Activities and Processes Thermal energy generation from biomass combustion.

SSRs* Baseline: Emissions from decomposition of Biomass and Methane collection

and destruction (B9 and B10), Electricity production (B11), Thermal energy

produced (B12), Fuel extraction and processing (B13)

Project: Emissions from facility operation P6, P8 to P11, P13, P14 and P16,

Combustion of biomass (P12), Fuel extraction and processing (P22)

GHG Carbon dioxide (CO2), Methane (CH4), Nitrous oxide (N2O)

GHG Assertion 2014: 10,378 t CO2e

2015: 10,340 t CO2e

Time Period January 1, 2014 to December 31, 2015

*included sources as specified in the Protocol.

A1.4 Verification Standard

The verification is performed according to ISO 14064-3: Specification with Guidance for the Validation

and Verification of GHG Assertions.

A1.5 Verification Criteria

The verification assesses the Project against Alberta Offset program eligibility criteria, including:

• Alberta Carbon Competitiveness Incentive Regulation (CCIR), December 18, 2017;

• Standard for Greenhouse Gas Emission Offset Project Developer (Version 1.0, December 2017);

• Standard for Verification (Version 1.0 December 2017);

• Quantification Protocol for Quantification Protocol for Diversion of Biomass to Energy from Biomass Combustion Facilities (Version 1.0, September 2007);

• Offset Project Plan for Sundre Forest Product THF Biomass Burner Project; and

• Offset Project Report for Sundre Forest Product THF Biomass Burner Project.

A1.6 Materiality

A 5% materiality threshold is set to assess errors, omissions, and misrepresentations in the GHG

assertion as required by the SGER. Quantitative discrepancies are aggregated and assessed on the

basis of net and absolute values. Qualitative discrepancies are evaluated by professional judgement

of the verification body, and determined if the discrepancies could be deemed to be material errors.

A2.0 Data Management and Controls

The Responsible Party’s GHG data management and controls are provided in Section 4.1 in this report.

A3.0 Team

The verification team is presented in Table A2.

Table A2: Verification Team


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Team Role

Nelson Lee, M.A.Sc., P.Eng. Designated Signing Authority

Min Si, M.N.R.M., GHG-V Lead Verifier

Kathleen Dunnett, P.Eng. Verifier

Nancy Wellhausen Independent Peer Reviewer

A4.0 Schedule

The schedule for the verification is presented in Table A3.

Table A3: Verification Schedule

Activity Date

Kick-off Meeting and Initial Information Request April 14, 2015

Site Visit June 9, 2015

Desktop Review April 14, 2015 – August 6, 2016

Submit “Issued for Review” Report September 9, 2016

“Issued for Use” Report Delivered October 6, 2016

Revision to the Issue ofr Use Report April 20, 2018

A5.0 Risk Assessment

As part of the verification process, a risked-based verification and sampling plan must be developed

that outlines:

The amount and type of evidence necessary to achieve the agreed level of assurances;

Methodologies for determining representative samples; and

Risks of potential errors, omissions, or misrepresentation.

Tetra Tech’s verification team utilizes the risk assessment process to develop a compliant verification

and sampling plan. The risk assessment includes considerations associated with regulatory

requirements, GHG program requirements, industry/sector specific factors, and other non-technical

risks.

The risk assessment considers inherent risk, control risk and detection risk. Inherent risk is the

Responsible Party’s risk of material error, omission, or discrepancy due to the complexity of the

facility or lack of capacity by staff at the facility. Control risk is the risk that the Responsible Party’s


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control system will not detect and rectify a material error, omission or discrepancy. Detection risk is

the risk that the Tetra Tech verification team will not identify a material discrepancy.

The inherent risk and control risk are rated by likelihood multiplied by consequence in accordance

with the matrix provided in Table A4. The detection risk is based on the combination of the inherent

and control risks.

Table A4: Rating Matrix for Inherent Risk and Control Risk

Risk Matrix

Consequence

Immaterial Minor Moderate Major Material

1 2 3 4 5

Lik

eli

hoo

d

5

5 10 15 20 25 Almost

Certain

4 4 8 12 16 20

Likely

3 3 6 9 12 15

Possible

2 2 4 6 8 10

Unlikely

1 1 2 3 4 5

Rare

The definition for the scoring is provided in Table A5, adapted from Intergovernmental Panel on

Climate Change (IPCC) 2007.

Table A5: Scoring Definition

Score Likelihood Consequence

5 possibility of misstatement >95% misstated GHG assertion (threshold) >5%

4 66% < possibility of misstatement <95% 4%<misstated GHG assertion <5%



1 possibility of misstatement <5% misstated GHG assertion<1%

Inherent risk is determined to be Medium based on the following:

• Natural gas consumption at the sawmill is determined by third party invoice minus Sundre

treating gas usage;

• Biomass quantify is determined estimated biomass volume per dump times numbers of the

dumps; and

• Quantifier is the first time to do this project.

Control risk is determined to be low - medium based on the following:


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• Natural gas usage for sawmill is manually assigned by production accountant at the Sundre

treating facility; and

• Third party invoice data is manually entered into spreadsheet.

Detection risk is the risk that Tetra Tech’s procedures do not detect a misstatement in the GHG

Assertion. The detection risk is determined based on Table A6, as outlined in the Technical Guidance

for Greenhouse Gas Verification at Reasonable Level Assurance (V1, January 2013).

Table A6: Design of Detection Risk

Control Risk

High Medium Low

Inherent Risk Score from

Table A5

12-25 6-10 1-5

High 12-25 Lowest Lower Medium

Medium 6-10 Lower Medium Higher

Low 1-5 Medium Higher Highest

The verification procedures were designed and performed to achieve low detection risk so that the

overall verification risk is low for a reasonable level of assurance, as specified in the Verification

Technical Guidance.

A summary of risk assessment is provided in Table A7.

Table A7: Summary of Risk Assessment

Element Risk Assessment

Site Visit Low. Sundre facility is a relatively small facility, major

equipment were observed during the site visit.

Offset boundary Low. Site visit confirmed the offset boundary

Methodologies, emission factors and conversion

used

Medium. Quantification methodologies follow the

approved protocol and emission factors. Quantification is

conducted in the Excel spreadsheet. Emission factors and

conversions are transparent.

Comparability with the baseline Low. No operational changes since baseline.

Conformance to the program criteria Low. The project conforms to the program criteria.

Responsible Party’s data management system

and controls (e.g. organization chart, GHGH

management plan, personnel/consultant training,

protocols used, control system documentation,

software/program documentation/certifications)

Medium. The GHG data and information are mainly

supported by the 3rd party invoices. Majority of data is

transferred manually.

GHG data and information (e.g. including the type

of evidence collected, verification testing and

crosschecking, inventory of emission sources)

Medium. Suppliers’ invoices reviewed. The verification

tests conducted include vouching, recalculation, and

tracing.


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Data management (e.g. measurement, fuel

sampling, calibration, consistent use

of standard conditions, data storage, procedures

to fill missing data; procedures to repair

inconsistent data, adjustment of variables and

factors)

Low. The GHG data and information are supported by

sufficient and appropriate evidence.

A6.0 Sampling Plan

The type and amount of evidence reviewed during the verification are summarized in Table A8.

Table A8: Sampling Plan

Reporting Element Type of Evidence Amount of Evidence Reviewed

Natural gas 3rd party invoices 2 years records

Electricity consumption Field tests

Engineering estimate Methodology reviewed

Biomass Production Records 2 years records

A7.0 Closure

If you have any questions or comments, please contact Min Si (403.723.1565,

[email protected]).

Respectfully submitted,


Prepared by: Reviewed by:

Min Si, M.N.R.M., GHG-V Nelson Lee, P.Eng.

Environmental Scientist Designated Signing Authority


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Appendix B: Statement of Qualifications


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Statement of Qualification

Offset Report

Project Name Sundre Forest Product THF Biomass Burner Project

Project ID 3157-5491

Project Developer Sundre Forest Products Inc.

Protocol Diversion of Biomass to Energy from Biomass Combustion

Facilities Quantification Protocol (Version 1.0, September 2014)

Report Period January 1, 2014 – December 31, 2015

Signature of Third Party Verifier

I, Nelson Lee (Third Party Verifier), meet or exceed the qualifications of Third-party verifiers

described in Section 29 of the Carbon Competitiveness Incentive Regulation.

Tetra Tech Canada Inc. Per:

Signature of Third Party Verifier Date

April 20, 2018

Training Received Under ISO 14064 Part 3

Nelson Lee received ISO 14064-3 training with Environment Canada, he has over 4 years of

experience in providing verification.

Name Nelson Lee

Professional Designation P.Eng.

Email [email protected]

Phone Number 778-317-7613

Lead Verifier

☐ Same as third party verifier?

Name Min Si, M.N.R.M., GHG-V


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Professional Designation P. Ag.


Phone Number (403) 369 5254


Mr. Si is a CSA certified GHG verifier, and completed ISO 14064 – 3 with CSA.

Peer Reviewer

Name Nancy Wellhausen

Professional Designation


Phone Number 805.455.0604


Nancy Wellhausen received ISO14064 training from California Air Resources Board and State of

Washington Department of Ecology.


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Appendix C: Findings and Issues


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Table 9: Detailed Findings and Issues Log

Number the issue with the year and provide a unique # for the issue. If the issue resolved during the verification, indicate that in the resolution

column. If the issue is not resolved during the verification, or if the issue was material (whether resolved or not) record it as a finding in Table 2

and provide a cross reference to the finding # in the resolution column.

Describe the issues investigated. State the verification criteria that are not met. Provide a description of how it is not met and provide the

evidence. Indicate the Source Category (for facilities) or the Source/Sink (for offsets).

Indicate if the finding is an understatement or overstatement.

Summarize information between verifier and client.

Provide a conclusion including % discrepancy, if applicable.

Item

(YR-##)

Description of the Issues

Investigated During the

Verification

Summary of information exchanged

between verifier and client

Resolution Conclusion

(including %

discrepancy if

applicable)

16-01 Please provide explanation on how

the biomass quantify/volume is

determined in the calculator. Please

provide confirmation for the test

results

Our controller, Lee Dyer, was the one

who did this test to determine the

amount of biomass each dump count

holds. Here is the explanation of the

test:

We dropped 5 dumps of biomass and

collected into bins which had a volume

of 47lt (0.047 m3). What you see on C4

– C8 is the number of 47 lt bins that

were filled using each dump. Once we

know the number of bins and volume,

we can calculate how much biomass

was there in each dump. You see that

in D27. Hence the formula for wt of

biomass is as follows:

No.of bins/dump (C9) x Wt of each bins

(A26) / average volume per dump (D9)

Resolved No further

questions


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17-02 Project condition, facility operation is excluded in the calculator. The convery system consumed electricity, and the offset project indicate the facility operation is included. Please explain the discrepancy.

Electiricty included Resolved No further

questions


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Appendix D: Statement of Verification


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Statement of Verification

Offset Report




Protocol Diversion of Biomass to Energy from Biomass Combustion

Facilities Quantification Protocol (Version 1.0, September 2014)


Statement of Verification

Total Baseline Emissions 2014: 14,761 t CO2e

2015: 14,761 t CO2e

Total Project Emissions 2014: 4,383 t CO2e

2015: 4,421 t CO2e

Other N/A

Net Reduction 2014: 10,378 t CO2e

2015: 10,340 t CO2e

Statement of Assertion In the period of January 1, 2014 – December 31, 2015, the net

reductions are 10,378 and 10,340 t CO2e respecitively.

Responsibilities of Project Developer and Third Party Verifier

West Fraser was responsible for the preparation and presentation of information within the

Project Report and GHG Assertion. Tetra Tech was responsible to provide a reasonable level of

assurance to ACCO on the GHG Assertion contained the Sundre Forest Product THF Biomass

Burner Project for the period of January 1, 2014 – December 31, 2015.

The objective of this verification is to provide an independent assessment of the offset project to

identify any material and immaterial errors, omission or misrepresentations, and to provide our

opinion on the GHG assertion in the Offset Project Report.

The verification was conducted to a reasonable level of assurance in accordance with ISO 14064-

3: Specification with Guidance for the Validation and Verification of GHG Assertions.

The evidence reviewed includes but not limited to production records, natural gas records, etc.

Conclusion


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The verificaion conclusion is: Positive

Based on our review, it is our opinion that Emission Reductions, including



contained in the GHG assertion generated from the Sundre Forest Product THF Biomass Burner

project offset project are materially correct and presented fairly in accordance with the relevant

criteria.




April 20, 2018

Name Nelson Lee





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Appendix E: Conflict of Interest Checklist


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Conflict of Interest Checklist

Offset Report




Protocol Diversion of Biomass to Energy from Biomass Combustion Facilities

Quantification Protocol (Version 1.0, September 2014)


Conflict of Interest Checklist

1.The relationship between my firm and this reporting company poses

unacceptable threat to or compromises the impartiality of my firm. False

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

impartiality of my firm. False

3.The personnel my firm has scheduled to participate in the verification

may have an actual or potential conflict of interest. False

4.

My firm participated in some manner in the development or

completion of the associated offset submission for this reporting

company.

False

5.My firm provided greenhouse gas consultancy services to this

reporting company. False

6.My firm will use personnel that have, are, or will be engaged or

previously employed by the reporting company. False

7.My firm will outsource the Statement of Verification for the associated

offset submission. False

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

impartiality. False

Important: If you have checked "True" to any of the above, you may not fulfill the "independence"

requirement for third party verifiers. Please contact Alberta Environment and Parks for further instruction. If

the potential conflict of interest is a sufficient threat to impartiality (perceived or actual), or cannot be

effectively managed, you Third Party Verification Report will not be acceptable to Alberta Environment and

Parks.


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I, Nelson Lee (Third Party Verifier), have personally examined and am familiar with the

information contained in this Conflict-of Interest Checklist, and can demonstrate freedom from

any conflict of interest related to the reporting company for which the verification was

performed. I hereby warrant that the information submitted in this Conflict-of Interest Checklist

is true, accurate and complete to the best of my knowledge, and that all matters affecting the

validity of this Conflict-of-Interest Checklist have been fully disclosed. Impartiality shall be

monitored over the duration of the verification and any identified actual or potential conflict-of-

interest situations will be communicated to AEP directly.



April 20, 2018

Name Nelson Lee





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Appendix F: Limitation on Use of this Document


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verification report for · ssrs* baseline: emissions from decomposition of biomass and methane...

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