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The internal pre-verification and the associated control activities in CORSIA MRV


As per the CORSIA SARPs - Annex 16, Volume IV, Part II, chapter 2.4.1, ICAO foresees a three-step verification process, consisting of an internal pre-verification performed by the aeroplane operator, a third-party independent verification, and an order of magnitude check by the administering authority. 

We would like to reiterate that conducting a pre-verification of the data is the first and a very important step in the verification process even though it is voluntary. Pre-verification is essential before the third-party verification as it helps with:

  • Providing a smoother verification process as errors are corrected before the third-party verification
  • Potentially reducing the time frame to perform the external verification
  • Lowering the risk of having to make significant corrections to the flight/fuel data close to the reporting deadline
  • Decreasing the chance for misstatements and non-conformities/non-compliances.
A brief overview of internal pre-verification can also be found in CORSIA: V for Verification. Selected internal auditors can always refer to Environment Technical Manual (ETM), Chapter 3, section for the recommended checklists and procedures to be followed during the pre-verification.

Our highlights from the ETM pre-verification checklist
1. Reviewing the Emissions Monitoring Plan (EMP) and written CORSIA procedures:

The 2nd topic of the ETM checklist table states that the Emissions Monitoring Plan (EMP) should be reviewed by the internal auditor to ensure that it reflects the implemented procedures and that it has been approved by the Administrating Authority. This is also a good opportunity for the auditor to check whether the non-compliances/non-conformities related to the EMP from the latest Verification Report (VR) (if any) have been addressed.

The checklist also states that other relevant written procedures (e.g., a CORSIA manual) should be reviewed, together with data flow charts and the other listed items. As with the EMP, all information and planned procedures should be cross-checked against actual processes in place.

2. Analyzing the data for its quality and identifying data gaps and/or errors:

Under the topic “Analysis to identify report for errors or logic gaps”, ETM checklist specifies several checks. That includes some simple checks on the completeness of the list of flights, namely the check whether the departure aerodrome for the next flight is always the same as the arrival aerodrome for the previous flight. We have observed that many of our clients take the completeness checks a step further, by utilizing Air Traffic Control (ATC) invoices and navigation charges to ensure that all flights they are invoiced for also appear in their data (and vice versa).
The checklist also mentions cross-checking the data for any empty cells or data gaps, which can also be easily expanded to include the check for impossible values such as negatives or zeros. One important point to mention here is that in CORSIA, and as per the ETM, Chapter 3, section 3.1.6, statistical methods are not permitted means to close data gaps – if secondary sources cannot provide the missing information, the CERT tool should be used. For operators based in the EEA region, who report CORSIA through EU ETS, conservative statistical methods are permitted, as long as they are approved in the AEM Plan.
Another item in this topic of the checklist is correlation analysis, which suggests the use of statistical analysis to develop a correlation between fuel consumption data and variables such as flight duration, distance, and average fuel burns. Some of our clients have also used the CERT tool to cross-check consumption on both individual flight and aggregate consumption basis, as well as their aggregate fuel purchase records for a “big picture” overview.
Several additional checks are listed on this topic in the checklist, as well in the “Emission calculation and fuel data used” topic, which can help operators improve the quality of their data as well as the robustness of their internal procedures.
3. Emission calculation and fuel data used:

This section of the ETM checklist concentrates on the importance of Fuel Use Monitoring Method (FUMM) calculations. Detailed information on FUMM calculations can be found in the SARPs, Annex 16, Volume IV, Appendix 2 and ETM Chapter 3, section 3.1.4. Ensuring that the fuel consumption calculations are performed correctly is essential especially for FUMMs such as Fuel uplift/Fuel Allocation with Block Hour methods where operators need to correctly distribute the fuel uplift and potentially consider both domestic and international flights.

4. Correct attribution of flights:

In this topic, the ETM checklist addresses the correct identification and classification of flights, with regards to flights that need to be reported (all international flights), flights on routes subject to offsetting, and flights without a monitoring requirement (exempted flights). The CORSIA States for Chapter 3 State Pairs is the document that includes all states participating in offsetting. Note that the list of participating states is updated annually.

The point about exempted flights is particularly relevant, as all claimed exemptions from the monitoring and reporting requirements must be accompanied by appropriate evidence. This is typically item 18 of the flight plan, though other documents may be accepted on a case-by-case basis. For further details on the exempted flights, kindly refer to the ETM, Chapter 2, section 2.2.5. It is worth noting that the evidence of appropriate exemption will need to be provided to the third-party verifier during the external verification process.

5. CORSIA Eligible Fuel factors:

With the introduction of offsetting requirements from 2021, aeroplane operators now have an option to reduce their offsetting obligations by using CORSIA Eligible Fuels. This will need to be duly documented, as described in ETM Chapter 3, section, and in our article on Sustainable Aviation Fuels (SAFs).
The big picture

The internal pre-verification is an optional yet very important step in the CORSIA MRV process. Performing the internal pre-verification helps an aeroplane operator better prepare for the third-party verification, which will be particularly beneficial in light of the reporting deadline being April 30th, rather than May 31st as in the first two years of CORSIA.

The ETM pre-verification checklist is an important and valuable resource for internal auditors as it highlights the areas to focus on while also suggesting methods for performing control activities. We would like to take this opportunity to strongly recommend all aeroplane operators to perform the internal pre-verification and take the opportunity to continuously improve their MRV processes and procedures.

For any questions regarding the internal pre-verification, the third-part verification, or anything else regarding CORSIA, do not hesitate to contact us.

  1. CORSIA SARPs - Annex 16, Volume IV
  2. Environmental Technical Manual (ETM), 2nd Edition
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