Open letter to ICAO – the CORSIA scheme should not be weakened, just because of Covid

Thirteen organisations concerned with aviation carbon emissions and carbon trading, have written to ICAO to ask that they stick to the intentions for how the CORSIA scheme is set up, and do not weaken it. The stated purpose of CORSIA is to help the international aviation sector achieve “carbon-neutral growth from 2020”. It is due to use as a baseline the aviation CO2 emissions from 2019 and 2020. However, with the Covid pandemic, airline carbon emissions will be much lower than anticipated this year. If ICAO used 2019 and 2020, the amount of carbon the sector could emit, and the cost of emitting it, would be far lower than anticipated. So IATA wants to change the rules, so the carbon baseline only considers 2019, not including 2020, which would result in significantly lower offsetting requirements for airlines compared to the current CORSIA design. In fact, under most recovery scenarios, the change sought by IATA would eliminate all offsetting requirements for the duration of the CORSIA pilot phase and potentially several years thereafter. The rules need to be adhered to.



Letter to: ICAO Council members

Subject : Open letter by carbon market stakeholders on the CORSIA impacts of COVID-19


Dear ICAO Council members,

The ongoing global health crisis has led to a drop in air traffic which in turn has already caused tremendous economic hardship for the aviation sector’s workers.

This situation has also led to a drop in CO2 emissions from international flights in 2020. This will result in lower baseline emissions for the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA).

As CORSIA’s stated purpose is to help the international aviation sector achieve “carbon-neutral growth from 2020”, the ICAO Assembly set CORSIA’s baseline at the average of 2019 and 2020 emissions.

Last month, the International Air Transport Association (IATA) asked the ICAO Council to change this baseline, from the current 2019-2020 average to a 2019-only level. This change would result in significantly lower offsetting requirements for airlines compared to the current CORSIA design. In fact, under most recovery scenarios, the change sought by IATA would eliminate all offsetting requirements for the duration of the CORSIA pilot phase and potentially several years thereafter.

This would result in a de facto postponement of the start of the CORSIA by three to five years.

As organisations active in various aspects of the aviation carbon market (including programmes, developers, brokers, NGOs and businesses), we would like to highlight the importance of safeguarding the integrity, stability, and regulatory predictability of CORSIA as adopted by the Assembly.

We, therefore, urge you not to modify the CORSIA baseline. Changing the rules and thereby eliminating three to five years of offset obligations would damage the credibility and long-term stability of CORSIA. A predictable process is a key feature of a successful carbon market.

This applies to programme review, evaluation, and potential adjustments to strengthen
climate goals. The aim is to limit the uncertainty for covered entities, offset developers, and others developing compliance or investment strategies.

Consistency – applying fixed rules objectively and automatically, and making rule changes only in accordance with established processes for making such changes – is crucial. Without it, investors will not have the confidence to make the near-term and longterm investments needed to achieve environmental goals.

The lack of durable investment would contribute to worsening the climate crisis.

While we fully acknowledge the difficult times that the aviation industry is experiencing at the moment, CORSIA’s built-in tools – special flexibility during the pilot phase, and triennial reviews – can be used to address the current situation. It is important to ensure that the COVID-19 crisis is not a catalyst for ad hoc changes that would hinder a sustainable global recovery.

CORSIA is an important mechanism for carbon markets around the world. Changes to elements as fundamental to its design as the baseline should be treated very cautiously.

We thank you for the attention you will dedicate to this issue, and urge you to promote and protect the integrity and stability of CORSIA.

Best regards,

The letter is signed by 13 organisations, including: 

Carbon Market Watch
Environmental Defense Fund
Climate Neutral Group
Native Energy
Natural Capital Partners
Atmosfair    …. and others


See earlier:

IATA calls for change in CORSIA baseline to protect airlines from future higher offsetting requirements

Fri 3 Apr 2020
By GreenAir online

As a result of the coronavirus pandemic, IATA has called on the ICAO Council to change the baseline calculation used for the CORSIA offsetting scheme for international aviation emissions.

Under rules agreed by ICAO, the baseline is set at the average emissions for the years 2019 and 2020. For the 15-year duration of CORSIA starting next year, airlines are required to purchase offsets to cover any annual growth in emissions above the baseline.
The collapse in global air traffic as a result of the outbreak, with demand unlikely to recover this year, will lead to significantly lower 2020 emissions. This in turn will lower the baseline considerably than was previously projected and result in much higher anticipated offsetting requirements and therefore costs once the sector returns to previous levels, says IATA.
It requests the Council to make the change no later than the end of June.

In a position paper, IATA says the baseline must be adjusted “to ensure the sustainable development of international aviation and avoid an inappropriate economic burden on the sector.” It recommends that only emissions for 2019 be used for calculating the baseline.

In support of its justification for a change in the baseline, the IATA paper quotes paragraph 16 of the A40-19 CORSIA resolution passed at the last ICAO Assembly in 2019,  “… on the need to provide for safeguards in the CORSIA to ensure the sustainable development of the international aviation sector and against inappropriate economic burden on international aviation, and requests the Council to decide the basis and criteria for triggering such action and identify possible means to address these issues …”.

The IATA paper argues: “Allowing the use of 2019 emissions as an alternative would preserve the environmental benefits that were forecast to be achieved through CORSIA as the adjusted baseline would remain more stringent than what the baseline would have been without the Covid-19 crisis.”

The airline trade body is also concerned that countries already signed up to join the voluntary pilot and first phases of CORSIA, and those still considering joining, may reconsider their positions in order to protect their airlines from potential higher compliance costs if no change is made to the 2019/20 calculation. States have until June 30 to notify ICAO of their intention to join the scheme from the beginning or decide to discontinue their voluntary participation.

Accordingly, IATA urges the Council to take a decision on a baseline adjustment before this date at the latest.

IATA also calls on ICAO to urge States to extend the May 31 deadline for the submission by aeroplane operators of their 2019 verified emissions report until at least the end of October 2020. It argues Covid-19 travel restrictions and confinement measures in many countries “have made it impossible for verification bodies to conduct verification activities.”

Historically, air transport activity has rebounded quickly after previous global crises but IATA’s March 24 Covid-19 impact assessment points to the potential for a deep financial recession following the outbreak that would delay the air transport sector’s recovery to previous levels. If this was to be the case and a 2019 only baseline applied to CORSIA, this could considerably reduce airline demand for offsets, at least in the 2021-23 pilot phase.Although it is too early to predict the impact of the pandemic on total emissions from international aviation this year, IATA’s current forecast is for a 38% fall in global passenger traffic in 2020. According to IATA, global emissions in 2019 – from domestic as well as international flights – totalled 915 million tonnes. Emissions from international aviation activity, which will be covered by CORSIA, account for around 60% of the global total.


European Commission will keep intra-European aviation within the ETS, as well as being in the ICAO’s CORSIA scheme

ICAO’s planned global scheme for offsetting emissions from international flights will supplement, not replace, the European Union carbon market, the EU’s transport commissioner has now said. With the United Nations (ICAO) planning a 2021 launch of CORSIA, clarity is needed that the European Commission will not remove aviation from the EU emissions trading system (ETS). Transport Commissioner, Adian Valean said:  “CORSIA will not put the ETS at stake. It will not replace the ETS. It will complement the ETS.”  The ETS only covers flights between European countries, not outside Europe. It is a more effective scheme, in incentivising lower carbon emissions, than CORSIA – which is very weak. But ICAO wants the EU to remove these flights from its carbon market so that CORSIA can be the only market-based measure tackling international aviation emissions. The Commission, the 27-nation EU’s executive is assessing how the two systems will co-exist.  It is important that EU flights outside Europe are in the CORSIA scheme, and Europe participates – otherwise other countries may also decide not to take part.

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Open letter from 90 academics to European governments – carbon offset markets (eg. CORSIA) will not effectively cut carbon

There is an interesting letter from 90 academics calling for governments to withdraw support from new carbon offset markets – with a specific reference to the UN Corsia scheme for aviation emissions. The academics call on European governments that care about climate change to withdraw their support for the creation of a new doomed carbon offset market at the COP25 this December. The proposals for carbon offsets are entirely unable to meet necessary criteria, needed to ensure they actually succeed in “offsetting” carbon. The letter says: “Yet, beyond the well-known issues of excess permits and frauds, it has also been demonstrated that carbon markets have major conceptual flaws that cannot be fixed, such as the inability to provide a reliable price signal or the fact that the climate impact of offset projects is not calculable….It is well documented that carbon markets have failed spectacularly in achieving their environmental objectives and that many carbon offset projects have a devastating social impact. In spite of this evidence, carbon markets remain the main policy tool to address climate change in Europe, based on the misguided hope that they will work “once the price is right”.”