Verifier's Perspective of 2019 Emissions Report Verification
01/10/2020
As the verification season for the first CORSIA monitoring period draws to an end, its magnitude dawns on us. We have just taken the monumental first step on our journey towards a cleaner and greener aviation industry. The verification of the first CORSIA baseline year was overshadowed by the pandemic which wrought havoc on the entire aviation industry. Nevertheless, airlines strove to comply with the CORSIA regulations amidst all the uncertainty and the hardships.
From a verification body’s point of view, we found it inspiring that despite the COVID crisis, national authorities were holding the airlines to their obligations under CORSIA albeit with prolonged deadlines. We witnessed several airlines struggle to access and provide certain documents needed for the verification due to the restrictions and mandated remote work policies. In these situations, we had to pivot and get creative under the guidance of the ISO 14064 standards and the SARPs to find other ways to mitigate risks in order to always verify Emissions Reports with reasonable assurance.
Having concluded 190 CORSIA verifications with another 45 underway, we have learnt a lot and wish to share our experience with everyone. The purpose of this article is to share our perspective on the various issues we observed during these verifications with the intention of sharing best practices and recommended improvements that all operators can benefit from. In line with the above, readers will find below a list of the most commonly observed “non compliances”, “misstatements” and other points of improvement. The below sections have been compiled with inputs from VERIFAVIA’s team of auditors.
Non-Compliances with the Emissions Monitoring Plan (EMP)
A non-compliance with the EMP arises when the monitoring and/or reporting was not performed according to what is declared in the EMP.
We came across a number of varied non-compliances with the EMP. One of the most common by far was that the EMP did not have a procedure listed for the handling of wet-leased flights and their data. This is also a non-compliance with the SARPs if the operator uses one of the five Fuel Use Monitoring Methods (FUMMs). Similarly, it was also noted that a lot of the EMPs were lacking information about the procedures concerning the handling of exempted flights, documentation and record keeping, identification and handling of data gaps. In a few cases, the source of flight data was found to be different from the actual used data and was frequently accompanied by the incorrect application of a FUMM.
Non-Compliances of the EMP with the SARPs
A non-compliance of the EMP with the SARPs occurs when the EMP has procedures listed which do not comply with a particular aspect of the regulation (SARPs, ETM, National Regulation for CORSIA).
From a verification body’s point of view, we found it inspiring that despite the COVID crisis, national authorities were holding the airlines to their obligations under CORSIA albeit with prolonged deadlines. We witnessed several airlines struggle to access and provide certain documents needed for the verification due to the restrictions and mandated remote work policies. In these situations, we had to pivot and get creative under the guidance of the ISO 14064 standards and the SARPs to find other ways to mitigate risks in order to always verify Emissions Reports with reasonable assurance.
Having concluded 190 CORSIA verifications with another 45 underway, we have learnt a lot and wish to share our experience with everyone. The purpose of this article is to share our perspective on the various issues we observed during these verifications with the intention of sharing best practices and recommended improvements that all operators can benefit from. In line with the above, readers will find below a list of the most commonly observed “non compliances”, “misstatements” and other points of improvement. The below sections have been compiled with inputs from VERIFAVIA’s team of auditors.
Non-Compliances with the Emissions Monitoring Plan (EMP)
A non-compliance with the EMP arises when the monitoring and/or reporting was not performed according to what is declared in the EMP.
We came across a number of varied non-compliances with the EMP. One of the most common by far was that the EMP did not have a procedure listed for the handling of wet-leased flights and their data. This is also a non-compliance with the SARPs if the operator uses one of the five Fuel Use Monitoring Methods (FUMMs). Similarly, it was also noted that a lot of the EMPs were lacking information about the procedures concerning the handling of exempted flights, documentation and record keeping, identification and handling of data gaps. In a few cases, the source of flight data was found to be different from the actual used data and was frequently accompanied by the incorrect application of a FUMM.
Non-Compliances of the EMP with the SARPs
A non-compliance of the EMP with the SARPs occurs when the EMP has procedures listed which do not comply with a particular aspect of the regulation (SARPs, ETM, National Regulation for CORSIA).
- As per the SARPs, the monitoring, reporting and verification (MRV) shall take place based on an EMP approved by the national authority. Unfortunately, some operators were not able to receive an approval of their EMP by their authority, which resulted in a non-compliance with the SARPs
- The EMPs often lacked information required by the SARPs which was both a non-compliance with the EMP and a non-compliance with the SARPs.
- Some EMPs had conflicting declarations in the methods tab, with both CERT and a FUMM selected as primary methods within the same period.
- It was also noted in certain cases that the implementation of the selected FUMM was incorrect, which reflected a lack of understanding. This was the case with operators choosing to use the Fuel Uplift and Fuel Allocation with Block Hour methods. On a similar note, the incorrect use of the declared data gap approach was also encountered.
Non-Conformities and Misstatements*
*These pertain solely to the Emissions Report (ER).
When the process in place does not conform to the procedures described in the EMP resulting in incorrect numbers or missing information in the ER it is considered to be a non-conformity. These might result in a misstatement. Misstatements are errors in the data/report resulting in incorrect numbers or missing information in the ER. These misstatements can be material or non-material.
*These pertain solely to the Emissions Report (ER).
When the process in place does not conform to the procedures described in the EMP resulting in incorrect numbers or missing information in the ER it is considered to be a non-conformity. These might result in a misstatement. Misstatements are errors in the data/report resulting in incorrect numbers or missing information in the ER. These misstatements can be material or non-material.
- The wrong use of method A or method B due to an improper chronological order of flights.
- The use of incorrect or outdated ICAO codes for airports and in some cases the incorrect attribution of an airport to another State. On a similar note, many reports used State names that were not in line with the official name list of ICAO Member States.
- In few rare cases, missing international flights were considered as data gaps, international positioning/delivery flights were missed while some wet leased out flights were included.
- In one particular case, due to the limitations of its IT system, the operator was unable to edit the destination airport of a flight within the system. This resulted in incorrect handling of diversions and impacted the reported emissions on the State pair level.
Other Notable Points of Improvement
Keeping the above aside, we also encountered a diverse assortment of issues. These did not qualify in any of the above categories since they were generally corrected/rectified prior to the issuance of the verification report.
Keeping the above aside, we also encountered a diverse assortment of issues. These did not qualify in any of the above categories since they were generally corrected/rectified prior to the issuance of the verification report.
- Nearly all operators made some mistakes when filling out the ER. Some of the most common issues were related to incomplete fleet declarations, emissions aggregated incorrectly in the reporting tabs, incomplete identification sections of the report, and various date inconsistencies.
- Some operators had duplicated flights, which were discovered during the verification.
- Most operators had breaks in flights sequence which would upon investigation occasionally reveal missing flights. It is highly recommended that all operators implement some measures to ensure that each aircraft has a logical sequence of consecutive flights.
- Most operators have not prepared a CORSIA manual or included CORSIA in their internal annual audits. This builds to the point that operators attest that they have several quality control activities in place but do not possess any documents/reports to back them up.
In conclusion, CORSIA 2019 is one small step for airlines but a giant leap for the Planet. Yes, there have been many challenges along the way and most of the procedures associated with reporting and verification are novel to most operators that had not been exposed to the EU ETS. Admittedly, the COVID crisis will present a new set of challenges during the verification season of the 2020 data, but with concerted efforts we can overcome them and continue improving.
Azhar Sayeed, CORSIA Auditor, VERIFAVIA
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Azhar Sayeed, CORSIA Auditor, VERIFAVIA
