Agri-Waste Technology, Inc.

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Agri-Waste Technology, Inc.

Management System Policy and GHG

Statement of Qualifications

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i. Table of Contents

i. Table of Contents ii. Revision History

1. Legal Status and Company Overview

Legal and Contractual Matters

Governance and Management Commitment Validation/Verification Roles and Responsibilities Impartiality

Avoidance of Conflicts of Interest Mechanism for Oversight to Impartiality Liability and Financing

2. Competencies

Management and Personnel External Expertise

Competencies of Personnel Deployment of Personnel

Use of Contracted Validators/Verifiers Personnel Records

Outsourcing

3. Communication and Records

Information Provided to a Client or Responsible Party

Communication of Responsibilities to Clients or Responsible Parties Confidentiality

Publicly Accessible Information Control of Records

4. Validation/Verification Process

Chicago Climate Exchange (CCX) Climate Action Reserve (CAR) Verified Carbon Standard (VCS) Pacific Carbon Trust (PCT) American Carbon Registry (ACR) California Air Resources Board (ARB)

5. Appointing the Team Leader

Approach

Validation/Verification

Review and Issuance of V/V Statement Facts Discovered After the V/V Statement

6. Complaints, Appeal and Disputes

Complaints

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7. Special Validations or Verifications 8. Management System

Management System Policy Control of Documents Internal Audits Corrective Actions Preventative Actions Management Review 9. Control of Marks

10. Step-by-Step Process for Registry Protocols

Chicago Climate Exchange Climate Action Reserve Verified Carbon Standard Pacific Carbon Trust American Carbon Registry California Air Resources Board

11. Accreditations 12. Project Experience

13. Validation/Verification Team Member Resumes 14. References

15. Authorization of Management System Policy Attachments A. Organizational Charts B. Sample Contracts C. Internal COI D. Impartiality E. Insurance Certificate

F. Process to Select, Train, Formerly Authorize and Monitor Validators/Verifiers G. Training Process for Employees

H. Training Process for Subcontractors I. Contracting of V/V Services J. Confidentiality/Non-Disclosure

K. Control of Documents and Records Policy L. Program Procedures

M. Project Overview

N. Review of Initial GHG Info Checklist O. Risk Assessment Checklist

P. Internal Protocol to Address Facts Discovered After Issuance of V/V Statement Q. Complaints, Appeals and Disputes

R. Internal Audits S. Sampling Plan T. -Reserved- U. -Reserved- V. -Reserved-

W. Verification Field Audit Protocol X. Verification Desk Audit Protocol

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Y. General/Project Specific COI Z. Validation Field Audit Protocol AA. Validation Desk Audit Protocol

AB. Decision Making Process Form for Adding V/V Criteria AC. Validation/Verification Plan

AD. Financial Risk Assessment AE. Project Description Document AF. Internal Project Technical Review

Appendices

1. Verification Report and Statement (CCX) 2. Verification Checklist (CCX)

3. COI (CCX)

4. NOVA/COI (CAR)

5. Verification Statement (CAR) 6. Verification Report (CAR) 7. Validation Report (VCS) 8. Validation Deed (VCS) 9. Verification Report (VCS) 10. Verification Deed (VCS) 11. Validation Report (PCT) 12. Verification Report (PCT) 13. COI (ACR)

14. Verification Statement (ACR) 15. Verification Report (ACR) 16. COI (ARB)

17. NOVS (ARB)

18. Verification Statement (ARB) 19. Verification Report (ARB)

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ii. Revision History (Beginning with version 1.5.1)

Version 1.5.1 (March 11, 2011)

 Added Section i designation for Table of Contents  Added Section ii (Revision History)

 Revised Section 8.1 to include process for updating the MSP and related internal v/v documents

 Revised Section 8.1 to include requirement of documenting decision making process for adding a new v/v criteria

 Revised Section 8.2 to clarify v/v related document locations

 Added Attachment AB (Decision Making Process Form for Adding V/V Criteria) Version 1.5.2 (March 14, 2011)

 Revised Sections 4.1, 4.2, 4.3 and 4.4 to specify development of sampling plan and validation/verification plan as separate documents rather than development of verification proposal document which combined the two documents.

 Revised Section 5.1.2 to specify development of validation/verification plan document for client signature rather than verification proposal document.

 Revised Section 5.1.3 by adding a reference to Attachment S (Sampling Plan), deleting requirement to submit the sampling plan to the client/responsible party, and adding notification of complaints, appeals and disputes procedure to the contents of the validation/verification plan.

 Revised Section 5.2 by removing requirement to submit revised sampling plan to client/responsible party.

 Revised Section 10.1 by changing Step 5 to include only the development of the Sampling Plan, added development of verification plan as a separate step (Step 6), revised Steps 14 and 15 (formerly Steps 13 and 14) to include possible amendment of sampling plan and trigger and revised Step 17 (formerly Step 16) to include a listing of diversions from the original sampling plan in the verification report.

 Revised Section 10.2 by adding assignment of Team Leader by V/V Director to Step 1, revised Step 6 to include only development of Sampling Plan, added development of verification plan as a separate step (Step 7), added review of contract by the Internal Peer Reviewer to Step 8 (formerly Step 7), added trigger to amend sampling plan to Step 11 (formerly Step 10), added list of diversions from original sampling plan to contents of verification report in Step 12 (formerly Step 11) and added review of verification report and verification opinion by the Internal Peer Reviewer as Step 13 (former Step 13 and up were increased by one number).

 Revised Section 10.3 and 10.4 by adding assignment of Team Leader by V/V Director to Step 1, revised Step 5 to include only the development of the sampling plan, added development of validation/verification plan as a separate step (Step 6), added review of contract by Internal Peer Reviewer in Step 10 (formerly Step 9), added trigger for amended sampling plan to Step 13 (formerly Step 12), added amendment of sampling plan to Steps 14 and 15 (formerly Steps 13 and 14) and added list of diversions from original sampling plan to contents of Validation and Verification Reports to Step 16 (formerly Step 15).

 Revised Attachment S to include only those elements required in the Sampling Plan  Added Attachment AC (Validation/Verification Plan)

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Version 1.5.3 (April 5, 2011)

 Revised Attachment R (Internal Audit) to include space for auditor to note facts or documentation reviewed as basis for conclusions drawn.

 Revised Section 2.1.2 to include L.S.S. as an option for licensure to fulfill the Land Use & Forestry scope competency requirements.

 Revised Sections 2.3 and 5.1.1 to include Chris McGee as a Team Leader and Jeff Vaughan as an Internal Peer Reviewer for Land Use & Forestry projects.

 Revised Sections 2.3 and 5.1.1 to include Kevin Davidson as a Team Leader and Hal Langenbach as an Internal Peer Reviewer for Agriculture, Waste Handling & Disposal & GHG Emission Reductions from Fuel Combustion projects.

 Renamed Voluntary Carbon Standard, Verified Carbon Standard throughout document.  Updated Attachment E – Insurance Certificate

 Updated Attachment Q – Appeals, Complaints and Disputes indicating that the form only needs to be signed if the client utilizes the appeals, complaints and disputes process.  Updated Appendix 7-10 with VCS version 3.0 documents

Version 1.6 (April 6, 2011)

 Incorporated revisions from 1.5.1, 1.5.2 and 1.5.3 Version 1.7 (January 23, 2012)

 Revised Section 1 to include ANSI accreditation and approval by CAR, VCS, PCT and ACR as an offset project verifier.

 Revised Sections 1.1.1 and 1.1.2 to include all authorized team leaders as possible contract signatories.

 Revised Section 1.5 to include ACR conflict of interest evaluation requirements.  Revised Section 1.7 to reflect professional liability coverage of $4mil/$4mil  Revised Sections 2, 4 and 5.1.3 to include ACR.

 Revised Section 2.2 to include external expert, Matt Lamb

 Revised Section 2.3 to include Michael Wittig and Matt Lamb as technical experts.  Revised Section 5.1 to include Michael Wittig and Matt Lamb as subcontractors.  Revised Section 10.2 to reflect the current CAR verification process.

 Added Section 10.5 ACR Step-By-Step Process.  Revised Section 11 to update accreditations.  Revised Section 12 to update experience.

 Removed subcontractor resumes from Section 13.  Revised Attachment A to update V/V organization chart.  Updated Insurance Certificate in Attachment E.

 Revised Attachment I to add document version # and made language more general to apply to all projects.

 Revised Attachment L to include references to program documents on client server rather than providing details within Attachment L.

 Revised Attachment Y to update insurance information, add ACR COI criteria and add ACR and CAR specific COI forms.

 Revised Attachment S and AC to include frequency of subsequent verifications in Sampling Plan (Version 1.2) and Validation/Verification Plan (Version 1.1).  Revised Appendix 5 to replace outdated Verification Opinion template with current

Verification Statement template.

 Revised Appendix 6 to reflect change in terminology from verification opinion to verification statement and added details to checklist.

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 Added Appendix 13 (American Carbon Registry COI Form)

 Added Appendix 14 (American Carbon Registry Verification Statement Requirements)  Added Appendix 15 (American Carbon Registry Verification Report Requirements) Version 1.8 (October 24, 2012)

 Revised Section 1 to include ISO 14066 as a guideline and added CAR Landfill and Livestock as categories for which AWT can perform verifications.

 Revised Section 1 and Section 11 to add language clarifying that AWT needs to purchase $5 million professional liability coverage in order to perform VCS verifications.

 Revised Section 1.1.1 to provide more flexibility to the Team Leader regarding the timing of the contract.

 Revised Section 1.7 to clarify that the contract is developed after COI investigation but prior to the start of verification activities. Also updated VCS professional liability insurance requirement ($5M) and indicated AWT will not offer VCS verification services unless we hold $5M in professional liability insurance.

 Removed references to “GHG emission reductions from fuel combustion” in Section 2 and throughout the MSP.

 Revised Section 2.4.2, 2.5, 2.7 and Section 4 to include ISO 14066.

 Revised Sections 2.4.8 and 2.4.10 to remove the requirement to have a CSA Greenhouse Gas Verifier certification.

 Revised Section 3.5 to tie records retention requirements to the applicable registry requirements.

 Revised Sections 4.1, 4.2, 4.3, 4.4 and 4.5 to clarify that the contract is developed at any point after the COI investigation but prior to the execution of the Project Overview document.

 Revised Section 4.2 to indicate list of findings, verification report and verification statement are uploaded to CAR.

 Revised Section 5.1 to update personnel information.

 Revised Section 5.1.3 to remove the requirement to submit the v/v plan to the client prior to executing the contract.

 Revised Sections 10.1, 10.2, 10.3, 10.4 and 10.5 to provide flexibility to the Team Leader to execute the contract at any point after the COI determination and before the Project Overview document is executed.

 Revised Sample Contracts in Attachment B to remove sections not applicable to GHG project verification/validation.

 Revised Attachment C to remove reference to the CCX.

 Revised Attachment C, D, N, O, S, AC to add footnote including Client Name, Project Name and Year.

 Revised Attachment F, G, H, I to add ISO 14066.

 Revised Attachment J to further define confidential documents.  Revised Attachment K to tie records retention to registry requirements.

 Revised Attachment M to show Sampling Plan and Verification Plan as separate documents.

 Revised Attachment N, O to add Document Version, remove text boxes, number items.  Revised Attachment R to remove text boxes, number items, revise CAR items.

 Revised Attachment Y, Appendix 4 to include the July 2012 CAR NOVA/COI document.

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Version 1.8.1 (November 9, 2012)

 Revised Attachment I, to include reference to the AWT MSP  Removed all external experts with the exception of Michael Wittig

 Removed reference to ISO 14064 A, B, C throughout the document and replaced with ISO 14064.

 Revised Attachment B, to include provision to accommodate observers.

 Revised Section 1.1 to further clarify that AWT is not currently a VB for VCS projects.  Revised Section 8.6 to provide an avenue to conduct an annual management review for

instances where the team leader functions as the team for all projects in a given year. Version 1.8.2 (November 21, 2012)

 Revised references to CSA Certified Greenhouse Gas Verifier to note expiration of certification in 2012 and to clarify that the continued certification is not required to demonstrate competency requirements but that successfully passing the certification exam is a valid avenue for demonstrating competencies.

Version 1.9 (December 14, 2012)

 Incorporated revisions from 1.8.1 and 1.8.2 Version 2.0 (January 24, 2013)

 Revised Sections 1 and 11 to include ARB accreditation

 Revised Section 1 to include language regarding verification of projects not listed on carbon registries

 Revised/Added Sections 1.5, 2.1.5, 4.6 and 10.6 to include ARB information  Revised Sections 2.3 and 5.1.1 to include Chris Love as a Team Member  Revised Section 9 to allow AWT use of the AWT logo on GHG materials  Revised Section 13 to include Chris Love’s resume

 Revised Attachment A to include Chris Love

 Revised Attachment E to include new insurance certificate  Revised Attachment L and Y to include ARB information

 Revised Attachment R Internal Project Technical Review Form to include ARB specific requirements

 Added Appendix 16 – ARB COI Forms  Added Appendix 17 – ARB NOVS Form

 Added Appendix 18 – ARB Verification Statement Forms  Added Appendix 19 – ARB Verification Report Requirements Version 2.0.1 (August 5, 2013)

 Added Attachment AD – Financial Risk Assessment and added references to this document in Section 10.

 Added Attachment AE – Project Description Document and added reference to this document in Section 10.

 Revised Attachment Y and Appendix 4 to include the 5/9/13 version of the CAR NOVA/COI form.

 Revised Section 1 to include information about Movalada, LLC.

 Revised Section 1 and Section 11 to include capability to perform CAR Rice Cultivation and Nitrogen Management project verifications

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 Revised Table in Section 5.1.1 to remove reference to GHG Emission Reductions from Fuel Combustion

 Revised Sections 8.4 and 8.5 to revise the process for documenting corrective and preventive actions.

Version 2.0.2 (August 23, 2013)

 Added a timeline to Attachment AC (Validation/Verification Plan) to address pertinent milestones in the v/v process.

Version 2.1 (September 6, 2013)

 Incorporated revisions from 2.0.1 and 2.0.2 Version 2.1.1 (April 7-11, 2014)

 Revised Section 1.1.1 to indicate that the Director or the Team Leader can prepare the verification quote or proposal (if one is required). Revised Section 1.3.1 and 1.3.2 to include development of proposals/quotes as responsibilities of the V/V Director and Team Leader.

 Revised Section 1.1 .1, Section 1.6, Section 4.1, Section 5.1.2 and Sections 10.1-10.6 to further clarify that the contract cannot be executed prior to the registry approval of our COI evaluation.

 Revised Section 4.2 and Section 4.6 to remove the description of the kick-off meeting. Section 10 contains the description of the kick-off meeting.

 Revised Section 1.4.1, 1.6, 4.2, 4.6, 10.1-10.6, Attachment D and Attachment Y to clarify that the Internal Conflict of Interest and Impartiality need to be fully executed on or before the date the registry specific COI evaluation is signed.

 Revised Section 5.3 and 10.1-10.6 to emphasize the Internal Project Technical Review form, requiring the form to be completed prior to the verification report/statement in order to create an objective record that the internal review took place.

 Revised Attachment R to remove the internal project technical review. Moved the internal project technical review form to a new attachment (Attachment AF). Removed the post project assessments from the internal project technical review form allowing the form to be completed prior to submittal of the verification report/statement to the client. Added reference to Attachment AF to Section 5.3.

 Revised Section 9, Attachment B, Attachment I, Attachment Q to include the new address for AWT.

Version 2.2 (May 6, 2014)

 Incorporated revisions from 2.1.1 Version 2.2.1 (January 5, 2015)

 Removed all references to Land-Use

 Revised Sampling plan (Attachment S) to include category of risk for all identified sources of risk

Version 2.2.2 (February 12, 2015)

 Removed forms from Attachment Y, Appendix 4-5 and 16-18 and replaced with weblink  Updated shareholder list and Attachment AB to include Chris McGee

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 Changed references to ISO 14065:2007 to ISO 14065 throughout  Added Tiffany Preddy to table in Sections 2.3 and 5.1

 Added Tiffany Preddy to the Team Member list in Section 5.1  Added Tiffany Preddy’s resume to Section 13

 Revised Attachment A to include Tiffany Preddy  Revised resumes to note expired certifications

 Added clarification regarding validation/verification statements to Section 5.3 regarding issuance of v/v statements that reflect material discrepancies that remain after the conclusion of the validation/verification

 Removed actual insurance certificate from Attachment E. Added reference to insurance company instead.

Version 2.3 (February 13, 2015)

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1. Legal Status and Company Overview

Agri-Waste Technology, Inc. (AWT) is a professional engineering and soils firm, specializing in environmental consulting. AWT is a private, registered small business that operates from its lone corporate office, located in Raleigh, North Carolina. AWT was incorporated on February 2, 1984 by the State of North Carolina.

AWT’s ownership structure includes 5 shareholders:

 Jeffrey Vaughan, President

 Chris Mosley, Vice President

 Hal Langenbach, Secretary

 Kevin Davidson, Treasurer

 Chris McGee

The company structure is depicted in block diagram form in Attachment A. AWT has

been providing engineering, agronomy, and soils consulting services, with extensive expertise in waste systems engineering and nutrient planning to residential, industrial, municipal, and commercial clients nationwide and internationally in Russia, China, India, Mexico and Canada, for over 25 years.

AWT’s diverse and highly-skilled staff has 75 years of combined experience along with diverse educational backgrounds and continual industry related training. This diverse staff includes professional engineers, licensed soil scientists, agronomists, GIS/GPS computer mapping technicians, irrigation designers, GHG verifiers and subsurface/surface waste system operators.

AWT can assist facilities with quantifying or validating/verifying carbon credits. AWT is experienced with a variety of GHG offset protocols including those used by Chicago Climate Exchange, Climate Action Reserve, American Carbon Registry, Verified Carbon Standard, Pacific Carbon Trust and California Air Resources Board. AWT follows the guidelines associated with ISO 14064, ISO 14065, ISO14066, IAF MD6 and ANSI requirements, which are standards that provide clear and consistent specifications for quantifying, monitoring, reporting and verifying GHG emission offsets.

Since 2006, AWT has been providing independent verification to agricultural clients and carbon offset project developers nationwide and in India.

AWT is currently certified by the Chicago Climate Exchange (CCX) as an approved third-party verifier for offset projects in the following categories:

 Agricultural Methane and Combustion

In 2011, AWT received accreditation by the American National Standards Institute as a greenhouse gas verification body based on its meeting the ANSI accreditation program requirements and those set forth in ISO 14065. The scope of our accreditation includes

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verification of assertions related to GHG emission reductions and removals at the project level for Group 5 – Livestock and Group 6 – Waste Handling and Disposal.

As a result of our ANSI accreditation, AWT is an approved verifier for Pacific Carbon Trust projects for the following sectors:

 ANSI Group 5 (Livestock)

 ANSI Group 6 (Waste Handling and Disposal)

In 2011 and 2012 AWT was recognized and qualified as a verification body for the Climate Action Reserve for offset projects in the following categories:

 Organic Waste Composting (2011)

 Organic Waste Digestion (2011)

 Livestock (2012)

In late 2011, AWT was officially approved as a verifier for American Carbon Registry projects in the following categories:

 Livestock Waste Management

In early 2013, AWT was accredited as a verification body by the California Air Resources Board in the following category:

 Livestock

Additionally, as a result of an agreement between CAR and the Verified Carbon Standard, AWT has the capability to be qualified as a verification body for the Verified Carbon Standard for offset projects in the following categories (pending purchase of $5 million professional liability coverage):

 Organic Waste Composting

 Organic Waste Digestion

 Livestock

AWT may verify projects not affiliated with any of the preceding registries provided a clear basis for quantification of offsets is provided and verification criteria are agreed upon prior to initiating the verification process. ISO 14064-3 will be included in the verification criteria.

Aside from the carbon credit verification services, AWT has also assisted organizations with carbon offset calculations/models and project design documents, general GHG offset consulting, feasibility determinations, alternative protocol development for unique GHG offset projects, monetization evaluations and review of engineering designs for anaerobic digesters. In 2009, three staff members of AWT became Certified Greenhouse Gas Verifiers with CSA America, Inc. However, these certifications were allowed to

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lapse in 2012 due to the fact that the certification is not a requirement for any of the programs of which we are aware.

AWT maintains a website, www.agriwaste.com, which describes our services. The website provides an avenue for AWT to make pertinent validation/verification documents publicly available. The owners of AWT also own two separate businesses, Advanced Septic, Inc. and Movalada, LLC which were both founded in 2010. Advanced Septic, Inc. provides septic system installation and repair services. Movalada, LLC owns the offices that AWT and ASI rent.

1.1 Legal and Contractual Matters 1.1.1 Agreement

Once AWT is contacted by a client for validation or verification of a GHG assertion, the V/V Director or anticipated Team Leader takes into account the following key issues when developing a quote (if a quote is requested):

 Proposed level of assurance, materiality, criteria, objectives and scope, complexity of the GHG assertion

 Complexity of the project and its measurement/monitoring processes

 Organizational environment including the structure of the organization that develops and manages the GHG assertion

 Baseline scenario for project validation/verification, including selection and quantification of GHG sources, sinks and reservoirs and their monitoring

 Physical infrastructure, activities, technologies and processes of the GHG project

 Types of GHGs

 Processes that deliver the information and data associated with the GHG assertion

 Organizational links and interactions between stakeholders, responsible parties, client and intended users and validation or verification criteria

 Allotted time needed to successfully carry out the validation or verification

 In the case of grouped projects, logistics and planning related to validation or verification of the individual project(s) input to the grouped project single GHG assertion, and its impact on the duration of the validation or verification

 In the case of multi-facility projects, logistics and planning related to verification of the input from individual and combined facilities data and related information to the GHG assertion, and its impact on the verification duration.

A contract is developed during the early stages of the verification process. This contract outlines the level of assurance agreed upon with the client, scope of services, objectives, amount and type of evidence necessary to achieve the agreed level of assurance, methodologies for determining representative samples and risks for potential errors, omissions or misrepresentations. The following information is completed for each client:

 Page 1-clients name, address, phone number and email address

 Page 5-clients name and address

 Page 6-contract is signed by the client and AWT’s team leader

 Attachment A-updated with project specific information

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 Attachment B-only applicable for projects that are financially associated with Time and Materials, this page with also be signed by the client and AWT’s team leader

 For flat rate contracts, section 3.1 in the contract is modified and Attachment B is removed

Each validation/verification project is bound by a signed and executed contract, which is developed by the Team Leader. The contract if finalized (signed) after the registry has approved our COI evaluation and prior to our execution the project overview document. Hal Langenbach or Kevin Davidson will develop and sign contracts (Sample Contracts are included in Attachment B). Clients are authorized to use any statements contained

within their verification document, as long as AWT is properly referenced. Clients are not permitted to use the AWT logo on any of their marketing material, public information sources or documents, unless a signed written request by the client has been authorized. 1.2 Governance and Management Commitment

1.2.1 Management

AWT’s senior management has overall authority and responsibility as follows: a) Development of operational policies: V/V Director/VP—Chris Mosley b) Supervision of the implementation of policies and procedures: V/V

Director/VP—Chris Mosley

c) Supervision of finances: V/V Director/VP—Chris Mosley

d) The adequacy of validation/verification activities: V/V Director/VP—Chris Mosley

e) The resolution of appeals, disputes and complaints: Team Leader/President— Jeff Vaughan

f) Validation/Verification statements: Team Leader/Secretary—Hal Langenbach or Team Leader/Treasurer Kevin Davidson

g) Delegation of authority to committees or individuals to undertake, as required, defined activities on its behalf: V/V Director/VP—Chris Mosley

h) Contractual arrangements: Team Leader/Secretary—Hal Langenbach or Team Leader/Treasurer—Kevin Davidson

i) Providing adequate, competent resources for validation/verification activities: V/V Director/VP—Chris Mosley

1.2.2 Operational Policy

It is the responsibility of the Validation/Verification (V/V) Director to develop the operational policy for validation/verification services and to gain approval by the board of directors. The operational policy shall be reviewed on an annual basis by the Director and updated as necessary. Approval by the board shall be documented by annual signature of the management system policy by the board of directors. If the management system policy requires more frequent updates due to personnel, scope or programmatic changes, etc., then the Director shall make necessary modifications and obtain approval by the board of directors (signatures by all board members).

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1.2.3 Supervision of the Implementation of Policies/Procedures

It is the responsibility of the V/V Director to ensure that validation/verification policies and procedures are implemented properly. This is accomplished through internal audits of the validation/verification program. It is the responsibility of the V/V Director to audit all aspects of the V/V body with the exception of the functions of the V/V Director. It is the responsibility of the President to audit the functions of the V/V Director.

1.2.4 Supervision of Finances

It is the responsibility of the Validation/Verification Director to supervise the finances associated with the validation/verification program. The Director shall utilize the expertise of the company bookkeeper and COI auditor in order to make viable financial decisions and maintain freedom from conflicts of interest. An annual financial report shall be prepared by the Director for presentation to the board of directors detailing accounts payable and accounts receivable relevant to validation/verification services. 1.2.5 Adequacy of Validation/Verification Activities

It is the responsibility of the Validation/Verification Director to ensure that validation/verification activities are adequate. This is accomplished through internal audits of the validation/verification program and supplemented by periodic communication with the team leaders, internal peer reviewers, team members and COI auditor. All relevant communication shall be documented by the V/V Director.

1.2.6 Resolution of Appeals, Disputes and Complaints

It is the responsibility of the Secretary to resolve appeals, disputes and complaints that may occur for Land Use & Forestry projects. It is the responsibility of the President to resolve appeals, disputes and complaints that may occur for Livestock, Waste Handling & Disposal & GHG Emission Reductions from Fuel Combustion projects. The procedure for resolving appeals, disputes and complaints is detailed in Section 6 of the management system policy.

1.2.7 Validation/Verification Statements

It is the responsibility of the Team Leader to develop validation/verification statements. Validation/verification statements shall be developed at the conclusion of the validation/verification activity summarizing the findings of the validation/verification team. The validation/verification statement shall include: reference to the program and approved project implementation document used by the project proponent to prepare the GHG assertion, GHG information and performance verified, level of assurance provided by the verification consistent with the agreed verification scope, objectives, time period and criteria, presentation of the resolution of any qualifications and conclusions on the GHG assertion. The validation/verification statement shall be signed by the Team Leader and Internal Peer Reviewer.

1.2.8 Delegation of Authority

The power to delegate authority to committees or individuals to undertake, as required, defined activities on behalf of AWT is held by the Validation/Verification Director. This

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delegation of authority extends only to the validation/verification function of AWT. The individual or committee to whom authority is delegated for a given activity must demonstrate competency to perform the activity. Delegated authority and associated competencies shall be documented by the Director and maintained for internal review. 1.2.9 Contractual Arrangements

Contractual arrangements are the responsibility of the Team Leader. Team leaders have full authority to develop and execute contracts for validation/verification services. The required contents of the contract are described in Section 1.1.1.

1.2.10 Provision of Adequate, Competent Resources

It is the responsibility of the Validation/Verification Director to ensure that adequate, competent resources are provided for validation/verification activities. The determination of the efficiency of resources shall include evaluation of project timelines, client feedback, and review of inventory including materials required for field audits and computer hardware/software requirements. These internal reviews shall occur at least annually, be documented by the Director and retained for internal review.

1.3 Validation/Verification Roles and Responsibilities

AWT’s validation/verification function requires 5 roles to be filled: V/V Director, Team Leader, Internal Peer Reviewer, Team Member and COI Auditor. The responsibilities assigned to each role are as follows:

1.3.1 V/V Director

 Development of operational policies

 Supervision of implementation of policies and procedures  Supervision of finances

 Evaluation of adequacy of validation/verification activities  Delegation of authority to committees or individuals

 Providing adequate, competent resources for validation and verification activities  Selection of team leader/reviewer

 Development of proposals/quotes

 Internal audit – functions of team leader, internal peer reviewer, COI auditor, team members (including contract team members) and external experts (if utilized)

 Records retention  Personnel records  Testing of competencies  Evaluation of financial risk  Hiring of personnel

 Public information access

 Training requirements and implementation  Program revisions

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1.3.2 Team Leader

 Development of proposals/quotes  Select team members

 Review of preliminary documentation, project design documents/monitoring plans/implementation documents and previous assessments (if applicable)  Determine eligibility of projects

 Assess controls for sources of potential errors, omissions and misrepresentations  Develop validation/verification plan

 Develop sampling plan

 Negotiate/execute contract with contracted validators/verifiers (if applicable)  Negotiate/execute contract for validation/verification services

 Develop validation/verification statement

 Oversee the validation/verification team including contracted validators/verifiers  Communicate with client

 Clearly establish roles/responsibilities of the team members  Review and evaluation of GHG assertions

 Review supporting documentation  Conduct field audits

 Project budget oversight

 Resolution of Appeals, Disputes and Complaints

 Technical expert for scope(s) in which technical competencies are demonstrated  Management Review

 Internal audit – function of V/V director

 Report concerns and/or need for procedural changes to carry out assigned duties to the Director

1.3.3 Internal Peer Reviewer

 Technical review of the validation/verification process at the project level  Technical review of the validation/verification report

 Technical review of the validation/verification statement

 Technical expert for scope(s) in which technical competencies are demonstrated  Report concerns and/or need for procedural changes to carry out peer review to

the Director 1.3.4 Team Member

 Plan and prepare for field audits  Conduct field audits

 Conduct document review under the direction of the Team Leader

 Prepare project maps (if applicable) under the direction of the Team Leader  Communication/coordination with other team members

 Develop validation/verification report

 Report concerns that may arise during the validation/verification process to the Team Leader

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1.3.5 COI Auditor

 Assess corporate conflict of interest issues including sources of income and prior professional relationships with project proponents, consultants and aggregators.  Assess personal conflict of interest issues including family relations, stock

ownership, etc.

 Ensure assembled team is free from conflict of interest, can operate with impartiality and objectivity exists between the validation/verification team, the client and responsible parties

 Educate employees and subcontractors regarding definition and importance of impartiality

 Report concerns and/or need for procedural changes to carry out oversight of impartiality to the Director

1.4 Impartiality

1.4.1 Commitment to Impartiality

AWT guarantees to act impartially and avoid unacceptable conflicts of interest in all validation and verification projects, by management, staff members and contracted verifiers. AWT is able to avoid potential or actual organizational conflicts of interest because there are no other related entities involved (i.e. a parent company or subsidiaries). AWT utilizes a COI Auditor to oversee the mechanism for impartiality. The COI auditor is responsible for educating employees and subcontractors about issues relevant to maintaining impartiality, as well as ensuring impartiality is maintained as validation/verification activities are accomplished.

AWT will review all information received from clients and/or responsible parties to determine potential risks to impartiality. Potential personal conflicts of interest are determined by the utilization of an Internal Conflict of Interest (Attachment C) document

that is signed by each validation/verification team member for every validation/verification project. Impartiality is documented through the use of an

Impartiality (Attachment D) document. These documents need to be fully executed on or

before the date the registry specific COI evaluation is signed in order to provide an objective record that internal evaluations of impartiality and conflict of interest have been carried out.

Specific risks to impartiality could include:

 Self interest: if any member of AWT acts partially for any financial benefit

 Familiarity: having a personal relationship with a client and not receiving proper validation or verification evidence to complete the project

 Self review: having an individual on staff review their own work and/or by providing consultancy and then assessing their validation or verification activities

 Sources of revenue: having a GHG project validation/verification client who is also a client in other areas of the business

 Intimidation: an individual being coerced openly or secretly to do something that is not impartial

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 AWT’s value of their reputation and any legal liability they could face

 AWT’s commitment to abide by the professional standards and regulatory requirements regarding independence through ANSI

 By understanding the needs and expectations of our clients

 AWT’s oversight by the COI Auditor, which is then audited by the V/V Director

 By establishing and applying methods to determine the efficiency and effectiveness of each project, by having an internal audit performed by the internal peer reviewer

 By identifying potential conflicts of interest and dealing with them appropriately

 Commitment by team leader, team members, internal peer reviewer and appeals, complaints and disputes representative to support the v/v process and to act impartially throughout the project’s entirety, by signing an Impartiality (Attachment D) document for every validation and verification project that they

are a part of.

 AWT has a strict policy when hiring, training and promoting personnel, which emphasizes the importance of impartiality, the potential risks that could arise and evaluating their impartiality regarding each client, so that they are successful at mitigating or eliminating any risks

AWT follows a zero-tolerance policy. If impartiality were compromised the following steps would take place:

 The team leader would discuss the findings with the V/V Director

 A conference call would then be placed with the client

 AWT would then inform the protocol administrator about the findings

 A solution would try to be resolved to include:

o Removing the particular team member who compromised impartiality, or o Declining the project altogether if a reasonable solution cannot be reached 1.4.2 Commitment to Objectivity

AWT will accomplish validation/verification activities with objectivity so that the process retains the utmost credibility. AWT will rely on internal process documents developed by the V/V Director in order to carry out assignments objectively. Team members will rely on the Team Leader to resolve gray issues that may occur during the process. A “gray” issue is defined as any issue not directly addressed in the program protocols.

1.5 Avoidance of Conflicts of Interest

AWT determines and reports any conflicts of interest or lack thereof to the administering program. AWT will strive to avoid any conflicts of interest for validation/verification projects through the following measures:

 AWT and its subcontractors avoid any actual or potential conflicts of interest with the responsible party and the intended users of the information.

 AWT and its subcontractors will not validate and verify GHG assertions from the same GHG project unless authorized by the applicable GHG program

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 AWT and its subcontractors will not validate or verify GHG assertion where it provided GHG consultancy services to the responsible party that support the GHG assertion

 AWT and its subcontractors will be independent

 AWT and its subcontractors will not validate or verify a GHG assertion where a relationship with those who provided GHG consultancy services to the responsible party that support the GHG assertion poses an unacceptable risk to impartiality which could be based on: ownership, governance, management, personnel, shared resources, finances, contracts, marketing, and payment of a sales commission or other inducement for the referral of a new client

 AWT and its subcontractors will not validate or verify a GHG assertion using personnel who were engaged by those who provided GHG consultancy services to the responsible party in support of the GHG assertion

 AWT and its subcontractors will not offer products or services that pose an unacceptable risk to impartiality

 AWT and its subcontractors will not outsource the review and issuance of the validation or verification statement

 AWT and its subcontractors will not state or imply that verification of a GHG assertion would be simpler, easier, faster or less expensive if a specified GHG consultancy service were used

 AWT and its subcontractors will demonstrate competence and due professional care consistent with their roles and responsibilities

 AWT and its subcontractors will demonstrate ethical conduct throughout the validation/verification

 AWT and its subcontractors will reflect truthfully and accurately validation/verification activities, conclusions and reports

 AWT and its subcontractors will meet the requirements of the standards or the GHG program to which the responsible party subscribes

Climate Action Reserve

CAR requires that all verifiers must demonstrate that they do not have significant conflicts of interest with participants in the following ways:

 Organizational COI—In the application process, AWT demonstrates that we have internal mechanisms in place to help maintain our objectivity in verification activities. (NOVA/COI Form-Appendix 4)

 Case-by-Case COI—Before a contract is signed, AWT demonstrates that any pre-existing relationship between us and the participant will not impair impartiality in verifying a GHG offset project report

 Emerging COI—For a period of one year following verification, AWT will monitor our relationship with the participant to ensure impartiality has been protected throughout the verification process.

If AWT identifies a potential or actual COI, AWT will also submit a plan to avoid, neutralize or mitigate the COI situation. Furthermore under the CAR regulations, if AWT has completed any consulting services for a client, AWT waits a minimum of 3 years prior to providing any validation/verification services.

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AWT demonstrates that our organization is capable of identifying and mitigating situations that would impair our ability to render an impartial verification opinion by demonstrating:

 Clearly-defined organizational boundaries, internal structures and relationships with other companies that have management or financial control over the applicant

 The presence of internal mechanisms to identify and mitigate organizational and personal COIs with any potential clients

 The ability to be objective in providing verification activities Chicago Climate Exchange

The Chicago Climate Exchange requires that all verifiers must demonstrate that they do not have significant conflicts of interest with participants, by submitting the following:

 Statement of any potential or actual conflicts of interest that may result from undertaking verification projects

 CCX Project Specific Conflicts of Interest form (Appendix 3)  CCX Conflict of Interest Questionnaire (Appendix 3)

 All forms must be signed by both the participant and AWT and submitted to CCX VCS

The VCS does not have any registry specific COI requirements, therefore for all VCS projects, AWT will follow the CCX requirements listed above to satisfy this objective until the VCS requires a different approach.

Pacific Carbon Trust

PCT does not have any registry specific COI requirements, therefore for all PCT projects, AWT will follow the CCX requirements listed above to satisfy this objective until the PCT requires a different approach.

American Carbon Registry

ACR requires a project specific COI form be completed for each verification project

(Appendix 13).

California Air Resources Board

Specific procedures related to COI determination and mitigation for verification of ARB offset projects follow the requirements of Subchapter 10 Climate Change, Article 5, Subarticle 13, Section 95979.

The potential for conflict of interest is deemed high where any of the situations described in Section 95979 (b) occur. The potential for conflict of interest is deemed low where any of the situations described in Section 95979 (c) occur. The potential for conflict of interest is deemed medium where any of the situations described in Section 95979 (d) occur.

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AWT will not provide verification services for a client if the potential for conflict of interest is deemed high. If the potential for conflict of interest is deemed medium and AWT intends to provide verification services for the client, AWT will submit a plan to avoid, neutralize, or mitigate the potential conflict of interest situation. The mitigation plan will include: 1) demonstration that members with potential conflicts of interest have been removed and insulated from the project, 2) explanation of any changes to the organizational structure or company to remove the potential conflict of interest and 3) any other circumstances that addresses other sources for potential conflict of interest. Prior to providing any offset verification services, AWT will submit an evaluation of the potential for conflict of interest (Appendix 16) that AWT, its staff, its related entities or

any subcontractors may have with the potential client. The evaluation will include the following:

 Identification of whether the potential conflict of interest is high, low or medium  Identification of whether any member of the offset verification team has

previously provided offset verification services for the potential client and if so, which years.

 Identification of whether any member of the offset verification team or related entity has provided any non-offset verification services of any nature to the potential client during the past 3 years. If so, the following will also be submitted:

o Identification of the nature and location of the work performed for the client and an evaluation of whether the work is similar to the type of work to be performed during the verification

o Description of the nature of past, present or anticipated future relationships with the client including:

 Instances when any member of the verification team has performed or intends to perform work for the client

 Identification of whether work is currently being performed for the client and the nature of such work

 Dollar value of work performed for the client in the last 3 years

 Whether any member of the verification team has any contracts to perform work for the client or a related entity

 Dollar value of work performed related to GHG reductions and removal enhancements for the client or related entities.

o Explanation of how the amount and nature of work previously performed is such that any member of the verification team’s credibility and

impartiality should not be questioned.

o A list of names of the staff that would perform verification services for the client and a description of any instances of personal or family

relationships with management or employees of the client that represent a potential conflict of interest

o Identification of any other circumstances known to AWT or the client that could result in conflict of interest

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o Attest in writing the following: “I certify under penalty of perjury of the laws of the State of California the information provided in the Conflict of Interest submittal is true, accurate and complete.”

Conflict of Interest situations will be monitored during the process of providing verification services and for a period of 1 year after the completion of verification services for an ARB offset project. If any situations arise that increase the potential for conflict of interest, these will be made known to ARB in writing and will include the description of actions that AWT has taken or proposes to take in order to avoid, neutralize or mitigate the potential for conflict of interest. If AWT or any of the verification team members enters into a contract with the client within one year after verification services for an ARB offset project are completed, AWT will notify ARB of the contract and the nature of the work to be performed within 30 days. AWT will notify ARB of any emerging conflicts of interest during the time verification services are being offered. Additionally, AWT will report any changes to its organizational structure including mergers, acquisitions or divestitures to ARB if any occur within one year after completion of verification services.

1.6 Mechanism for Oversight of Impartiality

The COI Auditor, provides oversight to guarantee that impartiality is being achieved throughout each validation/verification project. The COI Auditor provides impartial monitoring and review to ensure independence. The following step-by-step procedures include:

 AWT is contacted by a client to provide validation or verification services.

 The COI Auditor is then provided with contact information for all involved parties and research regarding impartiality and conflict of interest takes place.

 The COI Auditor then researches the source(s) of income. The V/V Director oversees Validation/Verification finances. The combination of financial oversight provided by the Director and evaluation of sources of income by the COI Auditor demonstrates that commercial, financial and other factors do not compromise impartiality. Both the COI auditor and the V/V Director are completely independent from the validation or verification project.

 As long as there are no red flags regarding the sources of income and evaluation of finances, then the COI Auditor researches each company to determine the client’s parent company and any subsidiaries.

 All staff members are then made aware of these findings at the initial team meeting to determine if impartiality will be compromised by any of the members.

 If impartiality is compromised at this point, AWT would determine the necessary steps to maintain impartiality to include:

o Removing the particular team member that poses risks to impartiality, or o Declining the project altogether if a reasonable solution cannot be reached.  Once it is determined that impartiality is not compromised, the team leader, team members, internal peer reviewer and appeals, complaints and disputes representative then sign the Impartiality (Attachment D) document, which

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Impartiality document must be fully executed on or before the registry specific

COI evaluation is signed in order to provide an objective record that internal evaluation of impartiality has been carried out.

 At this point the members discuss any potential conflicts of interest, as well as any potential conflicts of interest that could arise and all members then sign the

Internal Conflict of Interest (Attachment C) document. The Internal Conflict of Interest document must be fully executed on or before the registry specific COI

evaluation is signed in order to provide an objective record that internal evaluation of conflict of interest has been carried out.

 If a conflict of interest would arise at this point, AWT would determine the necessary steps to eliminate conflict of interest entirely to include:

o Removing the particular team member that poses a conflict of interest, or o Declining the project altogether.

 Registry specific COI evaluation forms are completed and submitted to the applicable registry for review and approval.

 Once impartiality is established and it is determined that no conflicts of interest exist according to internal processes and registry evaluation, a contract is finalized (signed) by the team leader.

1.7 Liability and Financing

AWT evaluates financial risks associated with all validation/verification projects. AWT enters into a contract with each client, prior to beginning verification activities (after COI evaluation is complete). The contract outlines the budgeted allotment to successfully complete their validation/verification project. Once the contract is signed, the client is obligated to pay AWT the full amount according to the terms of the contract.

AWT has sufficient arrangements, including money in reserves and through our insurance company, to cover liabilities arising from the activities and areas in which we operate. AWT is covered by professional liability insurance, which includes $4,000,000 per claim and $4,000,000 aggregate (Attachment E) which meets the requirements of

CAR, CCX, PCT, ACR and ARB. VCS requires professional liability insurance of $5,000,000. No VCS verification services will be offered unless this requirement is met. AWT retains authority and responsibility for all validation/verification activities, decisions and verification statements.

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2 Competencies

AWT is committed to maintaining all relevant competencies to offer v/v services for the livestock and waste handling/disposal sectors under the CAR, CCX, VCS, PCT, ACR and ARB programs.

2.1 Management and Personnel

2.1.1 Procedure for Determining Required Competencies for Each Sector AWT operates in the following sectors: livestock and waste handling/

disposal. Procedures for determining required competencies for each sector are detailed below.

2.1.2 (Removed)

2.1.3 Livestock and Waste Handling and Disposal Sectors

It is the responsibility of the Validation/Verification Director to determine competency requirements for the livestock and waste handling and disposal sectors. The Director sets the competency requirements based on the requirements of the professional licensing board relevant to engineering professionals. AWT specifically utilizes the requirements of the North Carolina Board for Engineers and Land Surveyors. AWT must maintain a professional holding an active license issued by the North Carolina Board for Engineers and Land Surveyors in order to maintain livestock and waste handling & disposal sector competency. It is the policy of AWT to rely on professional licensing bodies to dictate competency requirements for the livestock and waste handling and disposal sectors. Additionally, the license holder must select a minimum of 10 professional development hours (PDHs) per year directly related to the aforementioned scopes. A maximum of 10 hours from one year may be carried over to meet the requirements of the following year. Evidence of the PDHs will be submitted to the V/V Director and will be kept on file as long as the person is employed by AWT.

On an annual basis, the Director determines if the requirements are being met by reviewing the submitted evidence of the PDHs and accessing the on-line database and documenting a minimum of one current license among the validation/verification team in the livestock and waste handling and disposal sectors. The requirements and any updates to the requirements are communicated to the livestock and waste handling & disposal Team Leaders by the Director on an annual basis in the form of written notification. Any additional registry specific training is carried out at the discretion of the V/V Director internally unless specific courses are required by the registry.

2.1.4 Procedure to Demonstrate That Management, Validators, Verifiers and Technical Experts Have Appropriate Competencies in Activities Associated with the Validation or Verification

AWT personnel, whether they are employees or subcontractors, are required to exhibit the competencies relevant to their assigned validation/verification activities. These requirements are detailed throughout this Section. The V/V Director verifies competencies in a variety of ways including 3rd party certifications, educational

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backgrounds, professional licensing, experience, training and internal witnessing of validation/verification activities. Documentation of applicable competencies for all AWT personnel is prepared and maintained by the Director.

2.1.5 Procedure to Have Access to Relevant Internal or External Expertise

AWT requires internal expertise in all sectors and programs under which it operates. Technical expertise requirements for each sector AWT operates in are detailed in Sections 2.1.2 and 2.1.3. Technical expertise requirements for CCX verification, CAR verification, VCS validation/verification, PCT validation/verification and ACR validation/verification are detailed below. Team leaders and internal peer reviewers shall exhibit these competencies via testing or observation by the V/V Director.

CCX Verification:

 Technical experts shall have knowledge of the CCX specific protocols under which they will be operating.

 Technical experts shall have knowledge of the CCX specific step-by-step process for accomplishing verification activities.

 Technical experts shall have received all applicable CCX specific training required by CCX for the specific protocols/sectors under which they will be operating.

 Technical experts shall have sector specific competencies as demonstrated by an applicable active professional license or documented professional experience in the sector.

CAR Verification:

 Technical experts shall have knowledge of the CAR specific verification protocols under which they will be operating.

 Technical experts shall have knowledge of the CAR specific step-by-step process for accomplishing verification activities.

 Technical experts shall have received all applicable CAR specific training required by CAR for the specific protocols/sectors under which they will be operating.

VCS Validation/Verification:

 Technical experts shall have knowledge of the VCS specific validation/verification protocols under which they will be operating.

 Technical experts shall have knowledge of the VCS specific step-by-step process for accomplishing validation/verification activities.

 Technical experts shall have received all applicable VCS specific training required by VCS for the specific protocols/sectors under which they will be operating.

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PCT Validation/Verification:

 Technical experts shall have knowledge of the PCT specific validation/verification protocols under which they will be operating.

 Technical experts shall have knowledge of the PCT specific step-by-step process for accomplishing validation/verification activities.

 Technical experts shall have received all applicable PCT specific training required by PCT for the specific protocols/sectors under which they will be operating.

ACR Verification:

 Technical experts shall have knowledge of the ACR specific validation/verification protocols under which they will be operating.

 Technical experts shall have knowledge of the ACR specific step-by-step process for accomplishing validation/verification activities.

 Technical experts shall have received all applicable ACR specific training required by ACR for the specific protocols/sectors under which they will be operating.

ARB Verification:

 Technical experts shall have knowledge of the ARB specific verification protocols under which they will be operating.

 Technical experts shall have knowledge of the ARB specific step-by-step process for accomplishing verification activities.

 Technical experts shall have received all applicable ARB specific training required by ARB for the specific protocols/sectors under which they will be operating.

2.2 External Expertise

If AWT does not have internal technical expertise in a subset of a certain sector, external expertise will be utilized to fulfill scope specific competency requirements.

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2.3 Competencies of Personnel

AWT shall employ personnel having sufficient competence for managing the type and range of its validation/verification activities. Senior management is responsible for managing the validation/verification services performed by AWT as set forth in Section 1.2.1. Competency requirements for each of their functions are outlined in the applicable sections of the management system policy. Should management turn over, individuals within the company shall be promoted as appropriate as a first option or qualified personnel shall be hired. The V/V Director is responsible for ensuring management of AWT's validation/verification services is performed by those with sufficient competence for the full range of v/v services offered. The same or similar competency requirements shall be maintained when implementing internal promotion or new hiring. Should the competency requirements change, the board of directors shall approve the new requirements.

AWT shall employ or have access to a sufficient number of validation/verification team leaders, validators/verifiers and technical experts to cover the range and volume of its validation/verification activities. AWT shall maintain the following positions for handling v/v activities in the livestock and waste handling/disposal scopes.

AWT’s V/V Roles and Responsibilities Team Leader: Hal Langenbach or

Kevin Davidson

Appeals/Complaints/Disputes: Jeff Vaughan

Internal Peer Reviewer:

Kevin Davidson or Hal Langenbach

Team Members: Chris McGee Chris Love Tiffany Preddy COI Auditor: Lisa Tilley V/V Director: Chris Mosley

Audit for V/V Director

Jeff Vaughan-President

The only positions not critical for providing full v/v services are the team member positions. V/V can be handled without the “team members” based on the competency requirements of the team leaders. The personnel requirements of CCX, CAR, VCS, PCT, ACR and ARB are met by the assignments listed above (it should be noted that the internal peer reviewer serves as the backup for the team leader in order to fulfill the requirement of CAR). Any changes in personnel requirements by these programs shall

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be monitored by the V/V Director and implemented on a schedule, as required by the programs.

It is the responsibility of the V/V Director to determine if additional personnel are required to execute the workload of v/v activities. Should AWT fail to maintain sufficient staff to accomplish v/v activities under a certain scope or program, AWT shall discontinue offering those services until sufficient personnel are added as employees or subcontractors. The V/V Director shall manage the hiring of additional staff and/or subcontractors, such that competencies are maintained in all v/v activities for each program and scope under which AWT operates.

AWT shall use validators, verifiers and technical experts only for specific validation/verification activities where they have demonstrated competence. It is the responsibility of the V/V Director to test competencies of validators, verifiers and technical experts and to maintain records of competency testing. Competencies required and the corresponding testing mechanisms are detailed in Sections 2.1.2, 2.1.3, 2.1.5, 2.4.2-2.4.7 (team leaders and internal peer reviewers) and Sections 2.4.2 and 2.4.4 (team members).

AWT shall make clear to appropriate personnel relevant duties, responsibilities and authorities. Duties, responsibilities and authorities are described in detail for each position in Section 1.3. The V/V Director has full authority to delegate to AWT personnel provided relevant competencies are demonstrated. The V/V Director communicates broad expectations to each employee either through group training activities or individual conference. Additionally, team leaders communicate specific responsibilities to the team members during the initial project specific team meeting.

AWT selects, trains, formally authorizes and monitors validators/verifiers using a documented process (Attachment F). AWT selects technical experts used in the v/v process based on technical needs of the validation/verification scopes and programs under which it operates. Both the team leader and internal peer reviewer for each v/v project hold relevant technical expertise. Should specific technical expertise be required that is not exhibited by AWT staff, AWT will enlist external experts. Applicable technical expertise is documented via curriculum vitae or resume.

It is the responsibility of the V/V Director to ensure that AWT validators/verifiers have access to up-to-date information on GHG validation/verification processes, requirements, methodologies, activities, GHG program provisions and applicable legal requirements. The V/V Director maintains all of the latest process documents and GHG program provisions on file and communicates to AWT staff and subcontractors via email, internal meetings, teleconference or training, any modifications, additions or subtractions as necessary. Furthermore, validators/verifiers must demonstrate knowledge of GHG validation/ verification processes, requirements, methodologies, activities, GHG program provisions and applicable legal requirements. It is the responsibility of the V/V director to test and maintain records for AWT validators/verifiers indicating these competencies. AWT requires that the team leaders and internal peer reviewers have the competence to