Preparing for 2020 EU ETS, Swiss ETS & CORSIA emissions reporting

 

 
2021 marks the beginning of the CORSIA Pilot phase, but the focus in the first five months will be on the verification of the 2020 emissions data – since there is no change to the Monitoring, Reporting and Verification (MRV) obligations of the 2020 data.
 
For clarification regarding the fuel use monitoring methods change and/or use of CERT for 2020, please see below.
 
Criteria for changing the monitoring methods

With the emissions reduced drastically in 2020, the possibility of using simplified monitoring, i.e., the CERT tool (for operators who emitted less than 500,000 t CO₂ on international routes in 2020) could come as a thought while preparing the 2020 report. Also, few operators may have a desire to change to a different Fuel Use Monitoring Method (FUMM) when generating the 2020 Emissions Report.
 
What must be considered is that based on the SARPs, Annex 16 Volume IV, the Emissions Monitoring Plan (EMP) is approved without an expiration date, and it is recommended to use the same monitoring method for the entire baseline period, i.e., to use the same monitoring method in 2019 and 2020. Furthermore, it is also recommended to use the same monitoring method in each compliance cycle.
 
Noting the above recommendations from the SARPs, operators must discuss all requests for changes with their Administering Authorities, who have the final say on the matter. If you as an operator want to make any material changes to your EMP, which includes a change in the monitoring method, we urge you to get in touch with your Administering Authority as soon as possible.
 
For further details, please refer to sections 2.2.1.1 and 2.2.1.2 of the ICAO Annex 16, Volume IV-Part II, or the FAQ 3.48.
 
There is a possibility that operators (especially cargo carriers) who opted for the use of CERT in the 2019-2020 period might have exceeded the 500,000 t CO₂ eligibility threshold in 2020. Such operators should reach out to their Administering Authority who shall, at their discretion, permit the use of CERT as the primary monitoring method in 2020 as well (FAQ 3.53).
 
An important update for existing CERT users

The new 2020 version of the CERT is available online on the ICAO website. We would like to reiterate that all operators must use the 2020 CERT in their 2020 Emissions Reports for filling data gaps.
 
For further information about what the new CERT brings, kindly refer to our CERT 2020 newsletter article.
 

In response to the pandemic, many aircraft operators might have performed humanitarian and medical flights. To exempt those flights from CORSIA or EU ETS reporting, all relevant documents, and preferably the flight plans, must be stored securely and should be provided at the verifier’s request. Only flights with the appropriate documentation can be exempted. If you have any doubts, contact your Administering/Competent Authority as soon as possible! In the absence of evidence that fulfills the exemption criteria, flights should be considered as “regular” reportable flights.

As a reminder, a list of exempted flight categories in EU ETS and CORSIA is included below.

 
For some of the exempted flight categories, the flights preceding or following exempted flights might also be exempted if they were required to perform the exempted flight. Kindly review the program-specific requirements, reach out to your State authorities, or contact us at corsia@verifavia.com to discuss the specifics.
 

Due to the COVID-19 Pandemic, aircraft operators around the world are facing various challenges like reduced operations as a response to the slump in passenger demand, staff cuts/furloughs, financial difficulties, etc., which could also have an impact on their CORSIA/EU ETS verifications.

Some of the likeliest challenges regarding the 2020 data verification are listed below:

Reduced International Operations:

Nearly all airlines in the world have significantly reduced their international operations over the course of 2020. The main challenge associated with this is the differentiation between the operated flights and the planned but cancelled flights. As a reminder, all EU ETS and CORSIA reporting is done based on flown segments.

In response to the pandemic, some operators might have relocated their aircraft to other aerodromes for parking due to various economic benefits. These operations would have most likely been conducted as ferry/positioning flights, and would therefore be reportable under CORSIA and EU ETS.

Reduced staffing/furloughs:

Most aircraft operators around the world have introduced some changes to the staffing levels in response to the COVID-19 pandemic. Consequently, EU ETS and/or CORSIA responsibilities might have shifted to different personnel who might have little or no experience with the reporting & verification processes. In this case, we strongly recommend to review the relevant documentation, such as the SARPs (Annex 16, Volume IV) for CORSIA, the latest EU legislation and the linking agreement with the Swiss ETS for EU ETS, as well as the pertinent program pages on our website. Additionally, we encourage you to start the verification process early – our expert auditors are ready to answer your questions and help you navigate the path to compliance.

CORSIA:

> ICAO's CORSIA SARP's 
> CORSIA Program 
> CORSIA FAQ’s

EU ETS:

> EU ETS Program
> EU ETS FAQ’s

Swiss ETS (CH-ETS):

> Swiss ETS Program 
> Swiss ETS FAQ’s 

Exemptions from 2020 CORSIA Reporting:

Due to the reduction in international operations as a consequence of the pandemic, some aircraft operators might find themselves near the 10,000 tCO₂ exemption threshold. We still recommend to complete the verification process and obtain a verified 2020 CORSIA Emissions Report, as it could be useful in later stages of CORSIA and to prove your exemption if you fall below the threshold.

Aircraft wet lease in/out:

Following the post-pandemic scenario, for the purpose of operational flexibility, many operators engaged in fleet re-structuring through leasing activities. As a reminder, all flights should be attributed to operators based on the aircraft identification as per the Emissions Monitoring Plan – which includes wet-lease flights as well as positioning/ferry flights.

As we start the new year, the complete 2020 flight and fuel data should be available. With the EU ETS and CORSIA reporting deadlines less than three/five months away, respectively, we at Verifavia are already in advanced stages of preparation for your verifications. The 2020 data verification season has already started despite the COVID crisis, as many operators are already preparing themselves for the verification. With that in mind, let us briefly analyze the implications of COVID to our usual verification activities.

The most notable change in the verification process for this year is the replacement of physical site visits with virtual site visits, as a response to the numerous travel restrictions imposed all over the world and as a mitigation measure for the risk of spread of COVID-19.

We will still be closely examining the conformity and the compliance of your procedures against the pertinent plans and regulations, but we will be doing so via computer screens instead of face-to-face communication, by the virtue of videoconferencing, real-time screen sharing, and remote staff interviews. Depending on when the verification of your 2019 data was completed, you might already be familiar with some or all of the methods described above.

At the start of verification, your auditor will familiarize you with the technical requirements for the virtual visit and propose an agenda. This will allow for effective preparation from a technical and organizational perspective. We will work with you to find an appropriate time slot for the virtual visit, and we remain at your disposal for any questions you might have about this new process.
 
We look forward to working with you in 2021 and successfully complete the verification of your 2020 Emissions Report!

The VERIFAVIA Aviation Team