AIRCRAFT OPERATORS BASED OUTSIDE THE EEA STATES

Operators based outside the EU, can find the rules for monitoring and reporting in the Environmental Technical Manual (Doc 9501), Volume IV – Procedure for Proof of Compliance with the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA).

AIRCRAFT OPERATORS WITHIN THE EEA STATES

For aircraft operators within the EU, the rules for the monitoring of the Implementing Regulation (EU) 2012/601 apply (see above). Since 2021, the update of this regulation, that was adopted in the end of 2018 applies: (EU) 2018/2066. In it, the EU Commission is adapting the existing monitoring rules of the EU-ETS for aircraft operators to make a joint monitoring and reporting under CORSIA and the EU-ETS possible. The monitoring plan always is the basis for reporting. It is coordinated between the aircraft operator and the competent authority and ultimately has to be approved by the authority.

During the examination of the annual emissions report, the verification bodies must confirm that aircraft operators are monitoring its emissions in accordance with their monitoring plans. In the event of significant changes to the monitoring procedures, the monitoring plan must be resubmitted to the competent authority for approval.
The ICAO CORSIA_CO2 Estimation and Reporting Tool (CERT) was developed to simplify the monitoring procedure. With it the annual CO₂ emissions of aircraft operators that emit only little amounts of emissions can be estimated. Furthermore, the ICAO CERT can be used by all other aircraft operators to provisionally estimate their own emissions and to close data gaps in the reporting (see also Resolution A39-3 of the ICAO Assembly).

• Besides the use of bespoken ICAO CERT, operators can also monitor emissions by tracking their fuel use, applying one of five recognized methods (see “Fuel Use Monitoring Methods” below). Afterwards, the CO₂ emissions are to be
• calculated.

An aircraft operator’s emission level determines whether the operator is entitled to use the ICAO CORSIA CERT or whether an individual method must be used, to monitor the fuel consumption. Each operator must select a suitable method (see below) and include the selection in the emissions monitoring plan.

Emission thresholds:

• < 500 kt CO₂/a from international flights in the period 2019-2020: Operators can use the ICAO CORSIA CERT to estimate and report the CO₂ emissions.
• > 500 kt CO₂/a or equal to 500 kt CO₂/a from international flights in the period 2019-2020: The operator must choose one of the five possible fuel use monitoring methods.

With the start of stage one (2021), the threshold for the eligibility to use the ICAO CORSIA CERT will change. It will then be< 50 kt CO₂/a. In addition, operators can use the ICAO CORSIA CERT to estimate and report CO₂ emissions that are not covered by compensation requirements.

The ICAO CORSIA CERT furthermore provides aircraft operators with standardized templates for monitoring plans and emissions reports. In particular, these are

• the assessment of operator’s eligibility for using ICAO CORSIA CERT (Annex 16, Volume IV, Part II, Chapter 2, 2.2);
• the assessment of whether the operator is within the scope of the MRV requirements from Chapter 2 or not; and
• the closing of data gaps on CO₂ emissions.

The five fuel use monitoring methods are described in Appendix 16, Volume IV, Appendix 2 and in the Environmental Technical Manual (Doc 9501), Volume IV – Procedures for demonstrating compliance with the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA). An overview:

• “Method A”
  Method A is based on the fuel level in the aircraft tanks directly after refueling, as well as the amount of fuel refueled. This method requires data from the flight under consideration (N) as well as from the subsequent flight (N + 1).
• “Method B”
  Method B is based on the amount of fuel at the on-block time and the amount refueled. This method requires data from the flight to be considered (N) as well as from the previous flight (N-1).
• “Block-off / Block-on method”
  This method only requires data from the flight in question. The fuel calculation refers to the fuel quantities at off-block and on-block. These data points are usually recorded in all aircraft operations for safety reasons.
• “Fuel Uplift”
  The fuel quantities to be recorded for this method are only the quantities refueled. A particular challenge of this method is the allocation of the fuel if airplanes are refueled for more than one flight at once.
• “Fuel Allocation with Block Hour”
  With this method, the total amount of fuel refueled by the aircraft operator is allocated to the flights using block hours. Both, aircraft types and fuel quantities per flight route must then be taken into account.

(According to Delegated Regulation (EU) 2019/1603, only methods A and B are applicable to aircraft operators of EEA States.)
These five methods are considered by the ICAO to be equivalent for the application of CORSIA and reflect established practices. They also give aircraft operators the flexibility to choose the method that best fits their existing fuel consumption monitoring procedures.
An aircraft operator may use different fuel consumption monitoring methods for different types of aircraft in its fleet. If an aircraft operator wants to change a monitoring method, he must indicate the change in the monitoring plan and have it approved by the relevant authority.

AIRCRAFT OPERATORS IN EEA STATES

For European aircraft operators, CORSIA reporting, the emissions report for the European Emissions Trading System and the verification report by the verification body can be issued together, on March 31 of the following year.

AIRCRAFT OPERATORS OUTSIDE THE EEA STATES

Verified emissions reports are to be submitted annually at the same time as the verification reports to the verification body to the responsible government agency. Both the operator and the verification body submit independently their reports.

The following deadlines apply:

• 2019 and 2020: May 31 of the following year
• 2021 to 2035: April 30 of the following year.

The national authorities forward the emissions reports of all participating aircraft operators to the ICAO no later than three months after the submission deadline.

OFFSETTING AND DELETION OF ELIGIBLE EMISSIONS UNITS

As part of its participation in CORSIA, an aircraft operator must meet its offsetting requirements by having emission units permitted under CORSIA (so-called Eligible Emissions Units, see above) cancelled in a quantity that corresponds to the total offsetting requirements in the relevant reporting period.
The cancellation obligation can only be fulfilled with emission units (e.g. offset certificates) that have been declared eligible following an assessment procedure by the ICAO Council. The emission units are acquired on the market by purchase.
The CORSIA SARP define quality criteria for the evaluation of emission units. These include:

• Credits must represent additional emission reductions (additionality)
• It must be ensured that the offsets used in CORSIA are not also counted in national target achievements of emissions reductions (avoidance of double counting).
• Projects must not violate local / regional / national rules and should prove that social concerns and environmental requirements are taken into account (e.g. resettlements for dam projects).

Internationally supervised offset programs such as the Clean Development Mechanism (CDM) and future market mechanisms under the Paris Agreement are applicable. The same is valid for voluntary standards under the supervision of the private organizations (such as The Gold Standard or VERRA) or national offset programs (such as American Carbon Registry). An ICAO working group checks the suitability for use under CORSIA on the basis of defined quality criteria. The permissible offset emission units are published regularly by the ICAO.

From 2021, operators can reduce their CORSIA compensation requirements by claiming emission reductions from the use of sustainable fuels that are permitted in CORSIA. For this purpose, requirements are defined which regulate the use of the so-called CORSIA eligible fuels (e.g. necessity of purchase records, use of life cycle emission values, definition of emission reduction factors for every CORSIA-compatible fuel, valid sustainability certificate). So far, only the criteria for evaluating fuels have been published by the ICAO. A list of the permitted certification schemes for fuels has not yet been published.

At the EU level, the list of emission units that can be used under CORSIA still needs to be transposed into European law.

The first deletion of emission units by aircraft operators will take place no later than January 31, 2025. For this purpose, aircraft operators submit a verified deletion report to the competent state authority. After verification, it will be forwarded to the ICAO.