Consumers Energy : 2020 GHG ASSURANCE STATEMENT

Statement of Verification for CMS Energy Related to Scope 1, Scope2, and Scope 3 Greenhouse Gas Inventory for Calendar Year 2020

Trinity Consultants (Trinity) has conducted an independent third-party verification of the CMS Energy Corporation (CMS Energy) greenhouse gas (GHG) inventory for 2020. CMS Energy is comprised of multiple subsidiaries, most notably Consumers Energy Company (Consumers Energy) and CMS Enterprises Company (CMS Enterprises). For the purpose of this verification, the GHG emissions reported by each entity are filed under the parent company CMS Energy.

CMS Energy prepared a GHG inventory for calendar year 2020 which covers Scope 1, Scope 2, and selected Scope 3 emissions for its US portfolio of electricity generating sites, compressor stations, and administrative offices. Trinity was engaged to review supporting evidence and provide assurance to CMS Energy that the activity data, calculations, and formulas used in the company's GHG inventory are accurate, reliable, and of suitable quality to characterize enterprise-wide GHG emissions for the reported year.

Organizational and Operational Boundaries

• Equity Ownership
• US Portfolio
• Scope 1 emissions addressing stationary combustion sources and fugitive leaks from natural gas transport equipment
• Scope 2 emissions (location-based) addressing purchased electricity
• Scope 3 emissions addressing Business Travel (Category 6) and Use of Sold Products (Category 11)

GHG Calculation and Reporting Protocol

• The Climate Registry: General Reporting Protocol
• The Climate Registry: Electric Power Sector (EPS) Protocol
• US EPA Mandatory Greenhouse Gas Reporting Rule Equations, Subparts C, D, NN and W
• US EPA Emissions & Generation Resource Integrated Database (eGRID)
• The Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard (Revised Edition), World Resources Institute (WRI)/World Business Council for Sustainable Development (WBCSD)
• WRI/WBCSD Scope 2 Guidance (amendment to the GHG Protocol Corporate Standard)
• WRI/WBCSD Greenhouse Gas Protocol, Corporate Value Chain (Scope 3) Accounting and Reporting Standard
• US EPA Center for Corporate Climate Leadership GHG Emission Factors Hub

GHG Verification Protocol

• Environmental Resources Trust Corporate GHG Verification Guideline (Tier II), appropriate for basic reporting, and voluntary efforts for which there are no requirements for GHG emissions reduction compliance, suitably adapted

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Level of Assurance

• Limited

Data Verified and Period Covered

• Scope 1: 14,834,761 metric tons of CO2 equivalent
• Scope 2, location-based: 593,656 metric tons of CO2 equivalent
• Scope 3, Business Travel (Category 6): 379 metric tons of CO2 equivalent
• Scope 3, Use of Sold Products (Category 11): 13,898,100 metric tons of CO2 equivalent
• January 1, 2020 to December 31, 2020

GHG Verification Methodology

• Conducted data verification remotely with Consumers Energy and CMS Enterprises staff.
• Reviewed corporate GHG inventory management procedures.
• Ensured that Consumers Energy and CMS Enterprises' scope and boundaries reflected in the GHG inventory are fair and accurate.
• Interviewed Consumers Energy's Senior Environmental Planner and CMS Enterprises' Environmental Support personnel.
• Selected and reviewed input data and calculations for Consumers Energy and CMS Enterprises' facilities: four electricity generating facilities, one compressor station, eight administrative offices, and affiliated US EPA 40 CFR Part 98 Mandatory Reporting Rule Subpart W emissions.
• The GHG emissions for which data were verified account for more than 90 percent of CMS Energy's total Scope 1 emissions and of more than 80 percent CMS Energy's total Scope 2 emissions.
• Ensured that GHG calculations and emissions factors used result in overall estimates that are accurate, reasonable and without material discrepancies.

Assurance Opinion

Based on Trinity's procedures to verify CMS Energy's Scope 1 direct, Scope 2 location-based indirect, and Scope 3 (Business Travel, Category 6 and Use of Sold Products, Category 11) GHG inventories for calendar year 2020, no discrepancies were identified that would indicate that the activity data, emissions calculations, and equations supporting the company's GHG emissions statements are not represented fairly in accordance with the WRI/WBCSD GHG Protocol and CMS Energy data management procedures.

Trinity has concluded that CMS Energy has implemented sufficient systems and controls for the accurate collection and analysis of activity data used to determine Scope 1, Scope 2 location-based, and Scope 3 (Business Travel, Category 6 and Use of Sold Products, Category 11) emissions.

Professional Competence, Due Diligence and Impartiality

Trinity Consultants is an international consultancy with more than 45 years of experience developing, reviewing, and providing assurance on emission inventories of all types - including GHG inventories. Professional competence, due diligence and impartiality were exercised via:

• Independence - Neither Trinity Consultants nor the Verification Team had any participation in development of the enterprise-wide GHG inventory for CMS Energy. The Verification Team maintained objectivity throughout the GHG assurance process and made determinations based on objective evidence gathered and generated during the evaluation.

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• Ethical Conduct - The Verification Team demonstrated discretion and observed appropriate confidentiality procedures throughout the GHG assurance process.
• Fair Presentation - The findings and conclusions presented in this report are presented truthfully and accurately. No significant obstacles were encountered in executing the GHG verification.
• Due Professional Care - The Verification team members possess more than 50 years of collective experience in developing and reviewing GHG inventories. Due professional care and judgment were exercised in conducting the GHG inventory assurance.

Trinity consents to the release of this letter by CMS Energy to CDP in order to satisfy the terms of CDP disclosure requirements, but without accepting or assuming any responsibility or liability on our part to CDP or to any other party who may have access to this verification statement or our assurance report.

Trinity has prepared a separate report to CMS Energy management detailing the scope and approach for our GHG verification activity and confirming the verification opinion expressed above.

Rich Pandullo, MEM, CM

Director, Sustainability and Environmental Management

Trinity Consultants, Inc.

Dallas, TX

www.trinityconsultants.com

July 27, 2021

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