Airlines worldwide are on track to submit their first full year of emissions data under ICAO’s Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA), although some regulators have been slow to react to the new rules.

ICAO adopted CORSIA, a global market-based carbon offset program, in October 2016. Since then, ICAO has been working to create the technical framework for CORSIA implementation.

Under CORSIA, airlines were mandated to monitor international flight emissions from Jan. 1, 2019 under an approved monitoring plan. The final 2019 reports must be verified and submitted to a national administering body before the end of May 2020. Each member state will then report back to ICAO. This will form the baseline data for the offsetting phase of CORSIA.

During emissions-monitoring workshops, IATA senior environment manager Michel Adam said airlines gave feedback on their early CORSIA experiences.

“If I had to flag two of the key challenges raised during these workshops, the first one has been preparedness of states,” Adam said, speaking at Aviation Carbon in London on Nov. 5.

“In some jurisdictions, the requirements were put in place very quickly, but in many countries there is little or no clarity on who’s in change. They [the airlines] have an emissions-monitoring plan ready—and they are doing the monitoring—but they couldn’t get approval from an administrator.”

The second issue is the availability of verifiers. “I am not sure we have enough [verifiers] to meet the huge demand. We have close to 1,000 operators and several hundred of these need to get their reports verified,” Adam explained.

This situation is further complicated because each country transposes CORSIA into their national law, potentially creating minor differences between jurisdictions. “You need verifiers who are able to read local law without using Google Translate,” Adam said.

However, airlines have engaged well with CORSIA preparations and Adam said the overall level of readiness and compliance has been good. “I am quite confident, at least at operating level, that the monitoring is taking place and they will be ready to report.”

British Airways (BA) environment manager Andy Kershaw said he feels ready to comply with CORSIA, partly because of the experience BA has built up under the EU emissions trading system (EU ETS).

“We feel confident we can meet the requirements, but at same time we are staying a bit flexible, because the UK is working towards exiting the EU,” Kershaw said. This means BA could have to comply with the EU ETS, a new UK ETS, a new Swiss ETS and CORSIA, all of which could have slightly different requirements.

“The alignment [between EU ETS and CORSIA] isn’t 100% pure. There’s still a few elements that are not aligned,” he said. For example, EU ETS allows two monitoring methods, while CORSIA allows five. BA uses an approach that is accepted in both systems.

“There are two different calculations that we were doing, one for ETS and one for CORSIA, so one flight can have two different fuel figures, one for ETS and one for CORSIA, but we’re ready to handle that,” Kershaw said. “If they all move towards the way CORSIA looks and feels, that would take away a lot of the burden.”

Cathay Pacific climate change manager Yee Chow said the initial CORSIA challenges were mainly internal, as the airline set up its processes and IT systems for emissions reporting. Cathay is now going through a request for proposals (RFP) for verification suppliers.

“We’ve solved some challenges, but there’s going to be many more and bigger ones to come,” Chow said. “The bigger challenge that we are having right now is how do we prepare ourselves for carbon credits and carbon offsetting going forward.”

Carbon-emissions offsetting under CORSIA is set to begin in 2021, although this only applies to the 81 states that volunteered to participate in the pilot phase. Once a state has volunteered to join CORSIA, airline compliance is mandatory.

Chow said CORSIA gets “very complicated very quickly,” because of the number of airline functions that it involves. “When we look back at our EU ETS experience, there was some misalignment among different departments. We ended up buying more credits than we needed because our policy wasn’t so clear.”

Air Transat senior director for environment, ETS and strategic projects Keith Lawless estimated that the cost of CORSIA could be up to $10 million a year for his airline, but there is still a real lack of clarity on the likely financial impact.

“There is so much uncertainty,” said Adam from IATA. “Yes, you can forecast a number, but whether that’s going to be the real cost, no one knows. We don’t know what emissions units will be available.”

Speaking via video link, ICAO environmental unit chief Jane Hupe said the CORSIA emission unit criteria (EUC)—which establish suitable offsets—were approved in March. A technical advisory board (TAB), made up of representatives from 19 ICAO states, was then formed to assess the suitability of potential projects. In June, TAB invited the first round of applications for CORSIA offsetting programs.

“They have been evaluating the first 14 offset programs, which applied for assessment against the CORSIA emissions unit criteria,” Hupe said. “We expect the TAB to make recommendations to ICAO’s council on programs eligible for use under CORSIA in March 2020.”

This will give airlines greater clarity on where they can source CORSIA eligible emissions units (EEUs), ahead of the offset part of CORSIA coming into force in 2021.

Hupe said there has also been a “big step forward” in establishing how sustainable fuels will be accounted for under CORSIA. She added that the central registry, where states will report their emissions, is now in the final testing phase.

“The states have now submitted the airplane operators attributed to them [for oversight] for the purposes of CORISA,” she said. “We have close to 700 operators reporting.”

Other issues discussed at the conference included whether sufficient offsets will be available, the risk of offsets being double-counted under both CORSIA and national targets, a need for greater transparency from ICAO and a requirement for offsets to be high-integrity, if CORSIA is to succeed.

“CORSIA will only be as good as its weakest [carbon] credit,” IAG group head of sustainability Jonathon Counsell said.

However, Air Transport Action Group executive director Michael Gill urged the industry to have faith in ICAO. “If ICAO has set the criteria, it has not been done on a whim; it’s the result of a significant amount of work identifying criteria and eligible units. Within that framework, we have to trust in ICAO’s system for producing those criteria and the units that will be recognized. Then it will be individual decision of airlines, which units they choose to work with.”

Victoria Moores