CORSIA – How are we going to police international aviation emissions?

October 24, 2019 By , ,

October 24, 2019
By Megan Boutwell

As we explained in our CORSIA 101 article a few months back, the goal of CORSIA – the International Civil Aviation Organization’s (ICAO) carbon offsetting and reduction scheme for international aviation – is to cap carbon emissions from international aviation at 2020 levels. In many ways, this United Nations effort to reduce emissions in the aviation sector is similar to its effort to reduce sulfur emissions in the marine sector through IMO 2020. Both schemes must gain the participation of most nations and industry stakeholders, create new opportunities for innovative alternative fuels, and require member states to enforce rules the U.N. does not have the legal right to enforce. CORSIA may not have the same impact on the refining sector as IMO 2020, but it is similarly complicated. This article looks at how CORSIA will be implemented and enforced.

How will CORSIA be implemented?

The ICAO, a U.N. specialized agency, is implementing CORSIA with a phased approach. The initial phases are voluntary for member states. Eighty-one member states, including the U.S., have volunteered to participate. All operators working in the volunteer states with emissions greater than 10,000 tons of CO2 will be required to monitor, report, and verify their emissions. Each compliance period is three years. If emissions at the end of the compliance period exceed the baseline, operators will have to demonstrate they have met the requirements by canceling the appropriate number of emissions through the purchase of offsets. Emissions reports must be verified by an independent third-party before they can be submitted to their regulatory body. For operators in the U.S., this information will go to the Federal Aviation Administration (FAA).

The first voluntary phase – Monitoring, Reporting, & Verification (MRV) – began on January 1, 2019 and will continue through the end of 2020. This phase will help develop the baseline CO2 emissions to which operators must adhere once the Pilot Phase begins. The MRV Baseline phase also allows operators to develop their MRV systems for accurate reporting before the compliance phases begin.

During the next two phases – Pilot Phase and First Phase – only international flights between states that have volunteered for the program will be subject to CORSIA.

Compliance with CORSIA becomes mandatory for all international flights in 2027.

Who is exempt from CORSIA?

States who are exempt from the mandatory compliance period include:

  1. Least developed countries, small island developing states, and landlocked developing countries as defined by the U.N.
  2. States which represent less than 0.5% of international revenue tonne-kilometers (RTK)

Exempt states may still volunteer to participate in CORSIA.

How will CORSIA be enforced?

As part of the U.N., the IACO has no legal authority for enforcement. Therefore, it will rely on member states to adopt CORSIA into their laws governing aviation emissions and to enforce compliance. To date, no member state has adopted CORSIA rules into its aviation emissions law. However, the European Union’s Emissions Trading System (EU ETS) does have a model for aviation emissions enforcement. Under the EU ETS, the penalty for non-compliance is €100 per ton of CO2 emitted, plus additional local fees and penalties. Each member state is allowed to legislate the enforcement as they choose, so penalties may vary from country to country.

CORSIA faces the same issue with enforcement as is faced by the marine industry under IMO 2020. One can imagine that enforcement may be stringent in countries with the resources to police emissions properly, while less wealthy countries may allow non-compliance because they lack the resources for enforcement. This begs the question: Will weak enforcement be the downfall of CORSIA’s effort to reduce aviation emissions?

Stillwater will be following this story in the coming months and years. Sign up for our monthly newsletter to stay tuned.

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