Our news
03-Feb-2012 The EC published the new list of aircraft operators included in the EU ETS
01-Feb-2012 Opening of the EUROCONTROL ETS Support Facility for Aircraft Operators
30-Jan-2012 Single EU Registry activated for aircraft operators
In The Press
14-Feb-2012 EU-ETS Could Cost Bizav Operators Dearly [AINonline]
04-Jan-2012 ETS Goes Live As Political Battles Gather Momentum [AINonline]
22-Dec-2011 Green Machines [Business Airport International]
21-Dec-2011 ECJ ruling in favour of EU's right to include non-EU airlines in its ETS unlikely to stem US political pressure [GreenAir Online]
19-Dec-2011 US demands data from European and US airlines as it fires off first retaliatory salvo in growing dispute with EU over ETS [GreenAir Online]
03-Nov-2011 States opposed to Europe's emissions trading scheme win ICAO Council backing but EU remains defiant [GreenAir Online]
Gap analysis
A gap analysis is a "readiness for legal verification" audit which aims to highlight any weakness in the aircraft operator's EU ETS management and control systems, and to identify any areas where compliance with the rules and requirements require attention.
The benefit of this is that if done early in the reporting period (Q2 or Q3 of the monitoring year), it can highlight any compliance and system design issues enabling correction in a timely manner.
Compliance Review
VerifAvia will compare the approved monitoring plans (Annual Emissions and /or Payload Tonne-Kilometers) with the EU ETS regulations to identify any non-compliance. Also, VerifAvia will review the monitoring plans to determine if they contain sufficient details for each procedure for the Operator's personnel to follow.
It is possible that the Operator's monitoring plans have been approved by the competent authority but do not comply with the MRG or member state specific guidelines. The gap analysis can help identify these problems.
In addition, VerifAvia will consider the following elements:
- Whether there have been any changes to the procedures listed in the monitoring plan(s) and how the operator has communicated them to the Competent Authority
- The nature, scale and complexity of the operator's operations and the associated EU ETS procedures
- The complexity of IT systems used to handle EU ETS data
- Whether all the required control elements (MRG2:2007 Section 10.3) have been accounted for
ETS Management System Review
Having understood the design of the EU ETS management system (organisation, procedures and IT) and control system based upon the outcome of the Compliance Review, VerifAvia will look at how these systems have been implemented in practice, to ensure that they have been implemented correctly, that EU ETS related systems have been integrated properly with other parts of the Operator’s business control systems, and that overall they are robust.
As part of the management system review, VerifAvia will consider:
- The existence of an environmental or a quality management system, for example ISO9000 or ISO14001 or equivalent
- The existence of quality control and assurance processes that specifically focus on EU ETS data and system quality
- The organizational structure of EU ETS management, and how it is integrated with the overall business organisation
- The availability of information and data in terms of ease of access, completeness and accuracy
The aim of these tasks is to ensure that the overview provided by the monitoring plan is sufficient for transparency and robustness; and that the EU ETS systems have been designed effectively and implemented properly.
Data Analysis
VerifAvia will conduct a thorough analysis of EU ETS data collected until the audit day by uploading flight, payload and fuel data into the VerifAvia ETS Data Analysis System (VEDAS) which will automatically identify data gaps, highlight flights whose fuel consumption is outside of the typical range and perform plausibility checks on fuel and payload data.
The data analysis will allow the identification of problems with the data so that the operator can undertake corrective actions if necessary.
VerifAvia will also test a sample of the data to determine if there have been any errors in the data transfer processes from the primary data source (load sheets, fuel delivery notes, etc.) to the reported data.
Reporting
VerifAvia will prepare a pre-verification report to highlight the weaknesses of the EU ETS systems designed and implemented by the operator and will assess the readiness of the operator for the legal verification process.