In less than three months, all International Civil Aviation Organization Council member states with aircraft operators undertaking international flights are expected to start compiling and transmitting their airlines’ carbon dioxide (CO2) emissions information to the Montreal-based body to ready its planned Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) for takeoff.
The global-market-based measure, which aims to cap the growth of international aviation CO2 at 2020 levels, starts with a pilot phase in 2021, but all airlines producing annual CO2 emissions above 10,000 tonnes will need to measure their emissions on cross-border flights beginning in January to allow for the calculation of a sectoral 2020 emission baseline. The average emissions of 2019 and 2020 will form this baseline.
“The more airlines that contribute to the baseline, the better the scheme will be,” explained European Business Aviation Association (EBAA) senior environment manager Bruce Parry.
ICAO did work very quickly to put guidelines and key templates in place since its Council adopted CORSIA’s international standards and recommended practices (SARPs) at the end of June, he said. “So far so good,” he told AIN, noting that both the emissions monitoring plan (EMP) and the CO2 emissions reporting tool (CERT)—which can be downloaded from the ICAO website—are straightforward Excel spreadsheets. The EMP template was released in July and the CERT followed in August.
Airlines will need to submit their EMP to their administering state, the country where their aircraft are registered, by February 28, 2019. EBAA, however, advised its members to do it as soon as possible and preferably before September 30 to “get familiar with the scheme,” Parry said, while warning it “may take a bit of determination” to find out to which authority or agency the EMP has to be submitted. “There is no consistency. In the U.S. it is with the FAA and in the UK with the Environmental Agency.”
Also the CERT—which needs only four data sets: origin, destination, aircraft type, and number of flights—has been designed with an eye toward the small operator, Parry said. He admits it is confusing to know which country is participating in the scheme’s voluntary pilot and first phases from 2021 to 2026, “but that is up to ICAO to know,” he stressed, as he reiterated the association’s frustration with the European Commission for failing to provide clarity on how the EU ETS for intra-EEA flight will be aligned, and hopefully replaced by CORSIA. “I’m not going to speculate on what the EU is going to do, but our members want to know where they stand.”
EBAA is not alone in its frustration. In August, the heads of 11 airline associations from across the world urged the European Commission to “take all necessary measures” to fully implement CORSIA and remove EU ETS duplication. “All international flights to/from/between airports in the EEA should be subject exclusively to CORSIA and removed from the scope of the EU ETS as from 1 January 2021,” they wrote in a joint letter to European Transport Commissioner Violeta Bulc and her counterpart for Environment Miguel Arias Cañete, warning that failing to do so would “compromise the implementation of CORSIA.”
The trade bodies also asked the commissioners to ensure that the EU ETS monitoring, reporting, and verification (MRV) requirements for international flights be aligned with the CORSIA SARPs to prevent an “unnecessary administrative burden” for both operators and authorities in Europe having to administer and comply with two schemes in parallel, using two sets of rules. Aligning EU ETS MRV requirements with the ICAO rules “would not raise any significant difficulties as the SARPS have been developed on the basis of the experience gained under EU ETS and with the same guiding principles,” they pointed out.
Environmental campaign groups, however, last month called on Brussels to reject the airlines’ request, demanding the EU continues to regulate aviation emissions under the bloc’s ETS “given CORSIA’s unresolved issues, its environmental weakness, and lack of alignment with European climate ambition.”
The non-governmental organizations—among them Transport & Environment, Carbon Market Watch, and Aviation Environment Federation—asked the European Commission to delay a response to ICAO about the SARP draft rules until the completion of the ETS review, which they point out is mandated by EU law. ICAO member states have a December 1 deadline to notify their differences to the SARP rules. The Commission is not an ICAO member state but it will propose a common position for EU member states to adopt. It did not respond to AIN’s request for comment on the issue.