CORSIA: V for Verification
MRV rules, the rules for Monitoring, Reporting and Verification, are the backbone of any Market-Based Measure (MBM) scheme. It is MRV which ensures accountability, transparency and the overall credibility of any MBM. ICAO has agreed on the set of the MRV rules to be followed by aeroplane operators subject to CORSIA compliance in the fresh new SARPs edition as Annex 16, Volume IV, Chapter 2.
Monitoring and Reporting will be done by the aeroplane operators. However, the Verification is a 3-stage process performed by 3 different stakeholders. Internal pre-verification is carried out by the aeroplane operator, verification is undertaken by a third party accredited verification body and the order of magnitude check performed by the State.
The SARPs specifically recommend an internal pre-verification be performed by the aeroplane operator. The pre-verification is an important step of the quality control procedures and should be undertaken in order to prepare for third-party external verification of the emissions report. Essentially, the aeroplane operator must make sure that its Emissions Report is 100% correct.
The aeroplane operator should select an internal auditor who will be able to assess what has already been done. The internal pre-verification may include the following tasks:
- Review Emissions Monitoring Plan.
- Confirm that data gathering, calculation and summation processes are as per procedures.
- Check that data sources match what has been identified in the Emissions Monitoring Plan.
- Check if responsibilities assigned to various staff have been completed.
- Analyze how does the data compare to previous years.
- Check if there are any inconsistencies such as empty cells or error messages.
- Check completeness of list of flights by adding logical tests and consistency checks in the report.
- Perform correlation analysis – determination of the correlation between data and dependent data (e.g. consistency between duration of flights and fuel use, average fuel burns)
- Check if the appropriate flights are included for the CORSIA monitoring and reporting.
- Check that the correct international flights are subject to offsetting requirements.
- Calculate if the arrival fuel of previous flight plus the recorded fuel uplift are roughly the same figure as the departure fuel.
- Check report for very low/high fuel uplifts/figures to see if those are correct or typos.
- Evaluate list of findings and execute corrective actions to prepare for external third-party verification by verification body.
3rd party verification
The aeroplane operator must contract an accredited external verification body (VB). The VB will conduct independent verification of the annual Emissions Report before the submission deadline.
The VB must be accredited to ISO 14065:2013 (Greenhouse gases - Requirements for greenhouse gas validation and verification bodies for use in accreditation or other forms of recognition) by a national accreditation body in accordance with ISO 17011 (Conformity assessment - General requirements for accreditation bodies accrediting conformity assessment bodies). An aeroplane operator may engage a verification body accredited in another State, subject to rules and regulations affecting the provision of verification services in the State to which the aeroplane operator is attributed.
The specific competencies required for a verification team, including knowledge requirements, technical expertise, and data and information auditing expertise are provided in:
- ISO 14065:2013 entitled “Greenhouse gases – Requirements for greenhouse gas validation and verification bodies for use in accreditation or other forms of recognition”.
- ISO 14066:2011 entitles “Greenhouse gases – Competence requirements for greenhouse gas validation and verification teams”.
- SARPs Annex 16, Volume IV, Appendix 6.
- Pre-contract stage,
- strategic analysis,
- risk analysis,
- verification plan,
- addressing misstatements and non-conformities,
- verification report,
- independent review,
- authorization to forward Emissions Report, and
- submission of Verification Report and Emissions Report.
The aeroplane operator must correct all misstatement and non-conformities discovered during the verification. If they cannot be corrected, the verification body must assess the material impact the identified misstatement and non-conformities are likely to have on the reported data.
Once the verification is finalized, the verification body will complete the Verification Report that will be reviewed by an independent technical reviewer (authorized verifier who was not part of the verification team). The Verification Report contains a concluding verification statement that can be either ‘satisfactory’, ‘satisfactory with comments’, or ‘not satisfactory’. Upon approval from the aeroplane operator both the Verification Report and the Emissions report will be forwarded to the State by the VB.
Order of Magnitude Check by the State
The State will perform an order of magnitude check of the Emissions Report of the aeroplane operator. According to the Environmental Technical Manual, this check shouldn’t take longer than three hours for an average sized aeroplane operator with a satisfactory verified Emissions Report.
The following questions can be found within the set of standardized requirements used for the order of magnitude check:
- Is the name of the aeroplane operator given and unambiguous?
- Has the Emissions report been submitted in due time?
- Does the verification body’s Verification Report contain special indications to follow up on?
- Is the underlying Emissions Monitoring Plan approved by the State?
- Is there any deviation in capturing CO2 emissions in relation to the approved Emissions Monitoring Plan?
- Is the amount of reported CO2 emissions roughly plausible?
- Is the number of flights plausible?
- Have outbound and inbound flight been reported separately?
- Random calculation of average fuel consumption per flight (per State pair) and comparison with typical average consumption from the ICAO CORSIA CERT.
- Has the operator closed/completed data gap according to the Emissions Monitoring plan?
- Has the verification body issued a satisfactory verification opinion with comments?
The VERIFAVIA team is available for any questions you may have about EU ETS and CORSIA related issues.
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Beata Kusova, Aviation & Airports Director, VERIFAVIA & VERIFAVIA SHIPPING
+33 651 015 622, +33 143 227 194
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