< Previous 3-28 Environmental Technical Manual 3.3.1.1 Key documents Emissions Monitoring Plan According to Annex 16, Volume IV, Part II, Chapter 2, 2.2.2, the aeroplane operator will draft an Emissions Monitoring Plan and submit this plan for approval by the State. The aeroplane operator monitors its emissions in accordance with the approved Emissions Monitoring Plan. If a material change is made to the Emissions Monitoring Plan or if other changes occur that could affect the authority’s oversight, an aeroplane operator will resubmit the updated plan for approval. Emissions Report Based on the procedures included in the current Emissions Monitoring Plan, the aeroplane operator will draft an annual Emissions Report. This is the main document within the CORSIA MRV as it includes all relevant CO2 emissions-related data as described in Annex 16, Volume IV, Appendix 5. The Emissions Report will be verified by a verification body to demonstrate that it is free from material misstatements and material non-conformities. The verified Emissions Report will be submitted to the State together with the Verification Report of the verification body. Verification Report The verification body will draft a verification report after the completion of verification activities as described in Annex 16, Volume IV, Part II, Chapter 2, 2.4. The Verification Report contains a concluding verification statement. Both the aeroplane operator and the verification body, upon authorisation by the aeroplane operator, will forward a copy of the Verification Report together with the Emissions Report to the State. Together with the Emissions Report, the State will review the Verification Report and may contact the aeroplane operator and the verification body to receive further explanations if required. Verification statement The verification statement is a formal written declaration to the State that provides assurance that the aeroplane operator’s CO2 emissions assertion is stated within the defined level of assurance and materiality as described in Annex 16, Volume IV, Appendix 6, 3.1 and 3.4 respectively and is in accordance with the applicable verification criteria as described in Annex 16, Volume IV, Part II, Chapter 2, 2.4. The verification body will choose only between two types of verification statements, either ‘verified as satisfactory’ or ‘verified as not satisfactory’. ISO GHG standards as basis for CORSIA verification The following ISO standards form the basis for CORSIA verification: a) ISO 14064-3:2006 entitled “Greenhouse gases – Part 3: Specification with guidance for the validation and verification of greenhouse gas assertions”; and b) ISO 14065:2013 entitled “Greenhouse gases – Requirements for greenhouse gas validation and verification bodies for use in accreditation or other forms of recognition”. Volume IV. Procedures for demonstrating compliance with the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) Chapter 3 3-29 ISO standards are applicable in their specific versions as shown above only. This includes potential revisions of the standards. Additional ISO standards are applicable in more general terms as well. For example, ISO 14066 provides the definition of team leader under CORSIA. The verification body will meet the verification requirements additional to these programme neutral ISO GHG standards which are provided in Annex 16, Volume IV, Appendix 6. It is important to note that these standards have to be documented in the contract between verification body and aeroplane operator as part of the conditions for verification in Annex 16, Volume IV, Appendix 6. 3.3.2 Verification body eligibility and accreditation To be eligible to undertake verification activities under CORSIA, verification bodies must meet the following key requirements: a) Be accredited to ISO 14065:2013, “Greenhouse gases - Requirements for greenhouse gas validation and verification bodies for use in accreditation or other forms of recognition”, for a technical scope relevant to aviation; and b) Satisfy the additional accreditation requirements specified in Annex 16, Volume IV, including a requirement related to maximum number of annual verifications. These are described in more detail below. 3.3.2.1 Accreditation framework All verification bodies must be accredited to ISO 14065:2013, “Greenhouse gases - Requirements for greenhouse gas validation and verification bodies for use in accreditation or other forms of recognition”, for a technical scope relevant to aviation. In addition to ISO 14065, verification bodies must also meet the additional accreditation requirements specified in Annex 16, Volume IV, Part II, Chapter 2, 2.4. These include, but are not limited to, requirements related to avoiding conflict of interest, personnel competency and team knowledge and expertise. Verification bodies wishing to become accredited to conduct verifications under CORSIA should contact their national accreditation body (NAB) for additional information. Accreditation of verification bodies is carried out by NABs that operate in accordance with the international standard ISO/IEC 17011:2004, “Conformity Assessment - General requirements for accreditation bodies accrediting conformity assessment bodies.” 3.3.2.2 Accreditation requirements A number of additional accreditation requirements beyond ISO 14065:2013 are specified in Annex 16, Volume IV, Appendix 6. Key CORSIA specific requirements are as follows: Maximum number of annual verifications Consistent with the ISO Standards 14064-3:2006 and 14065:2013, verification bodies are required to demonstrate impartiality and remain free from bias and conflict of interest at all times. To minimize the potential for a conflict of interest, the CORSIA requires that the leader of the verification team not undertake more than six annual verifications under any greenhouse gas emissions programme for the same aeroplane operator. After six years, the leader of the verification team will take a three consecutive year break from providing CORSIA verification services to the aeroplane operator. The six-year maximum includes verifications performed for the aeroplane operator prior to it requiring verification services under CORSIA. 3-30 Environmental Technical Manual Personnel and team competency Annex 16, Volume IV also specifies a number of personnel and team competency requirements in addition to the ISO standards. These relate primarily to the aviation verification engagement and the competence of the team as a whole, including documenting and evaluating team competencies and ensuring continual professional development and training for verification bodies. Confidentiality Additional confidentiality requirements relate to the submission of the Verification Report to the State. In CORSIA, both the aeroplane operator and the verification body submit a copy of the Verification Report to the State. However, before the verification body submits the Verification Report, it must have the appropriate authorization to do so from the operator. The mechanism for authorizing this consent will be specified in the contract between the verification body and aeroplane operator. Record keeping Under CORSIA, verification bodies are required to keep full verification records for a minimum of 10 years. 3.3.3 Verification fundamentals 3.3.3.1 Objective of the verification Verification activities under CORSIA ensure that the monitoring of CO2 emissions takes place according to the approved Emissions Monitoring Plan (in accordance with Annex 16, Volume IV) and that the reported emissions are correct and reliable (free from material misstatements and material non-conformities). In accordance with Annex 16, Volume IV, Appendix 6, the verification statement must provide, inter alia, a conclusion on whether: a) the aeroplane operator CO2 emissions assertion is materially fair and an accurate representation of emissions over the period of the Emissions Report and is supported by sufficient and appropriate evidence; b) the aeroplane operator has monitored, calculated and reported its emissions over the period of the Emissions Report in accordance with Annex 16, Volume IV and the approved Emissions Monitoring Plan; c) the aeroplane operator has correctly applied the method of flight attribution documented in the approved Emissions Monitoring Plan and in accordance with Annex 16, Volume IV, to ensure a correct attribution of leased aeroplane and international flights operated by other aeroplane operators under the same corporate structure; d) the stated amount of emission reductions from the use of CORSIA eligible fuels by the aeroplane operator is materially fair and an accurate representation of emission reductions over the reporting period, and is supported by sufficient and appropriate internal and external evidence; e) the claimed batches of CORSIA eligible fuels from the aeroplane operator have not been claimed by another aeroplane operator under any other voluntary or mandatory schemes it has participated in (where the emission reductions from CORSIA eligible fuels may be claimed), during the current Volume IV. Procedures for demonstrating compliance with the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) Chapter 3 3-31 compliance period, as well as the compliance period immediately preceding it; f) the aeroplane operator has monitored, reported and verified its emission reductions from the use of CORSIA eligible fuels use over the period of the reporting period in accordance with Annex 16, Volume IV; g) the aeroplane operator has accurately reported its CORSIA Eligible Emissions Unit cancellations in accordance with Annex 16, Volume IV; h) the aeroplane operator has quantities of cancelled CORSIA Eligible Emissions Units that are sufficient for satisfying the offsetting requirements associated with the relevant compliance period, after accounting for any claimed emission reductions from the use of CORSIA eligible fuels, and the aeroplane operator can demonstrate sole right of use to such cancelled CORSIA Eligible Emissions Units; and i) the aeroplane operator has used the cancelled CORSIA Eligible Emission Units to meet its total final CO2 offsetting requirements for a given compliance period under Annex 16, Volume IV, and not been used to offset any other emissions. 3.3.3.2 Scope of verification The scope of the verification must cover the entire reporting period as stated in the Emissions Report and is determined by the activities necessary to achieve the objective of the verification. Before a verification body can accept the verification engagement, the verification body should have developed a clear understanding of the aeroplane operator’s activities and the complexity of the verification activities necessary. The scope of the verification has to be stated and defined in the contract between the aeroplane operator and verification body, including necessary site visits and access to aeroplane operator’s data. 3.3.3.3 Level of assurance In the CORSIA the verification body will provide reasonable assurance that the aeroplane operator’s Emissions Report is materially fair and an accurate representation of emissions over the period of the Emissions Report. Sufficient and appropriate evidence has to be gained through the verification process to guarantee the level of assurance and to make resilient statements about the GHG assertion in the Verification Report. 3.3.3.4 Materiality Annex 16, Volume IV prescribes the following materiality levels: Aeroplane operators with annual CO2 emissions from international flights, as defined in Annex 16, Volume IV, Part II, Chapter 1.1.2, and Chapter, 2.1 above 500 000 tonnes will meet a materiality threshold of 2 per cent, as defined in Annex 16, Volume IV, Appendix 6, 3.4. Aeroplane operators with annual CO2 emissions from international flights equal or less than 500 000 tonnes will meet a materiality threshold of 5 per cent. Over and understatements should be allowed to balance out in both cases. The verification activities to be undertaken by the verification body, and the data points to be sampled, can be expected to be more extensive and detailed in the case of a 2 per cent materiality level than they will for a 5 per cent materiality level. Errors, omissions and misrepresentations in the Emissions Report have to be taken into account. 3-32 Environmental Technical Manual 3.3.4 Verification process under the CORSIA The verification process under the CORSIA can be broken down into 12 steps involving the 3 key participants: the verification body, the aeroplane operator and the State. In advance of seeking verification of its Emissions Report by a verification body, it is highly recommended that the aeroplane operator conducts an internal pre-verification of its Emissions Report to improve data quality and the underlying data gathering processes. As depicted in Figure 3-8 the verification process itself, as conducted by the verification body and appointed team, involves 10 steps leading up to the submission of a final Verification Report to the aeroplane operator and the State. Each of these steps are described in further detail in this Chapter. Following submission of the Verification Report to the State, the State will conduct an order of magnitude check in accordance with the timeline as defined in Annex 16, Volume IV, Appendix 1. The order of magnitude check will follow a mandatory set of requirements to enable global consistency among States. Figure 3-8. Overview of the verification process Volume IV. Procedures for demonstrating compliance with the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) Chapter 3 3-33 3.3.4.1 Voluntary pre-verification by the aeroplane operator In order to prepare for third-party external verification, aeroplane operators should consider conducting a voluntary internal pre-verification in order to ensure there will be no large data issues during the verification. The value of a pre-verification conducted internally by the aeroplane operator is to ensure quality assurance and quality control of the internal data gathering process and calculation systems and ensure that the aeroplane operator has passed certain logic checks in advance of a verification body coming on site. The team that manages the day-to-day MRV of CORSIA should select an internal auditor who will be able to assess what has already been done. While the exact internal voluntary pre-verification may differ by aeroplane operator, the checklist included in Table 3-8 should be used as a guideline on evaluating the monitoring and reporting process. Table 3-8. Voluntary pre-verification checklist guide Completed by Topic Task MRV2 Simplified MRV3 Aeroplane operator CORSIA management team Selecting an internal auditor Choose a qualified internal auditor/audit team x x Ensure that the internal auditor(s) have the required knowledge and skills and is independent from the activity being audited x x Internal auditor Understand aeroplane operator monitoring and reporting process Review Emissions Monitoring Plan and other relevant written procedures; data flow charts; preliminary draft Emissions Report versions; historical reports; communication with State etc. x x Internal auditor in conjunction with aeroplane operator CORSIA management team Identify scope of voluntary pre-verification audit plan Develop data sampling plan based on analysis of documents x x Confirm that data gathering, calculation and summation processes are as per procedures. It is recommended that this analysis include quantitative analysis x x Check that data sources match what has been identified in the Emissions Monitoring Plan x x If a data flow chart exists, compare it with actual data flow and identify any determined problems x x Internal auditor Evaluate staff competence Collect information through interviews, observations of activities, review of documents x x Does aeroplane operator CORSIA management team have adequate knowledge of: monitoring and reporting as relating to GHG monitoring and reporting responsibilities x x 2 Fuel Use Monitoring Method, as described in Annex 16, Volume IV, Appendix 2. 3 CORSIA CO2 Estimation and Reporting Tool (CERT), as described in Annex 16, Volume IV, Appendix 3. 3-34 Environmental Technical Manual Completed by Topic Task MRV2 Simplified MRV3 and activities related to the CORSIA? Assess the different responsibilities assigned and recorded in the Emissions Monitoring Plan for MRV and if the various staff members complete those tasks correctly x x Check if responsibilities assigned to various staff have been completed x x Internal auditor Analysis to identify report for errors or logic gaps How does the data compare to previous years? x x Adequacy of input, output, and transformation error checking routines x x Are there any inconsistencies such as empty cells or error messages? x x Check completeness of list of flights by adding logical tests and consistency checks in the report i.e. below two lines x x Is the departure aerodrome for the next flight the same as the arrival aerodrome for the previous flight? x x Correlation analysis – determination of the correlation between data and dependent variables (e.g. consistency between duration of flights and fuel use, average fuel burns) x Intra-project analysis – comparison of data across multiple sites (e.g. consistency of data between aerodromes, is arrival fuel of the previous flight plus the recorded fuel uplift roughly the same figure as the departure fuel?) x Management system elements in place supporting collection and reporting of emissions data x Adequacy of reporting processes for the periodic comparisons and reconciliation of emissions data with other data (e.g. comparing emission estimates against production and capacity utilization data) x Internal auditor Assess scope and technical exemptions Are the appropriate flights included for the CORSIA monitoring and reporting? x x Are the correct international flights subject to offsetting requirements, as defined in Annex 16, Volume IV, Part II, Chapter 1, 1.1.2 and Chapter 3, 3.1? x x Are exempted flights recorded correctly (i.e. has a medical flight really been classified as a medical flight and are all classified medical flights real medical flights or have they been classified incorrectly?) x x Volume IV. Procedures for demonstrating compliance with the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) Chapter 3 3-35 Completed by Topic Task MRV2 Simplified MRV3 Internal auditor Emission sources and aeroplane used Set up a checklist of emission sources / aeroplanes used and operated by operator x x Internal auditor Emission calculation and fuel data used Consult Emissions Monitoring Plan to determine how emissions are calculated and perform some cross checks to see if the applied calculation works by adding logics to the report x x If based on real fuel figures, cross-check how those are recorded and if this has been done correctly or if there are any recurring error sources e.g. below x Calculate if the arrival fuel of the previous flight plus the recorded fuel uplift are roughly the same figure as the departure fuel x Cross check if two equal fuel uplifts have been recorded for two or more consecutive flights and if those are genuine or typing errors x x Check report for very low/high fuel uplifts/figures to see if those are correct or typos x x Aviation fuel to CO2 conversion; fuel density; CORSIA eligible fuel factors Aviation fuel’s fuel to CO2 conversion factor used correctly x Check if the fuel density process in the Emissions Monitoring Plan has been consistently applied for all flights x Check if any volume of CORSIA eligible fuel has been used and if those have been certified as being eligible in the CORSIA x Internal auditor Pre-verification audit documentation Record complete list of voluntary pre-verification findings including: x x Recommended/required actions x x Timeline for closure of finding x x Follow up checks by auditor to ensure corrective actions have been completed satisfactorily and findings are closed x x Aeroplane operator CORSIA day-to-day management team Execute corrective actions Evaluate list of findings and execute corrective actions to prepare for external third-party verification by verification body x x 3-36 Environmental Technical Manual 3.3.4.2 Verification by the verification body Given the general provisions in the CORSIA relevant to ISO GHG standards (cf. reference) and the additional requirements in Annex 16, Volume IV, Appendix 6, this section provides additional guidance on the CORSIA-specific verification characteristics which are not already mentioned in the aforementioned documents. (1) Pre-contract stage It is recommended that aeroplane operator and verification body agree on the contractual matters of the verification engagement at the latest by July of the calendar year for which the verification will be carried out. It is advised that the verification body perform a preliminary strategic analysis on the basis of publicly available data (such as web page of the aeroplane operator) to assess the potential complexity and length of the verification engagement. The verification body may confirm with the aeroplane operator before offering a contract whether the aeroplane operator makes use of the voluntary pre-verification approach as this may result in reduced costs for the verification. For each verification engagement, the verification body must ensure that a competent and impartial verification team and independent reviewer are appointed prior to signing a legally enforceable agreement with the aeroplane operator. Depending on the outcomes of the strategic and risk analyses, however, team composition may require adjustment to ensure its continued competence. The specific competencies required for a verification team, including knowledge requirements, technical expertise, and data and information auditing expertise are provided in: a) ISO 14065:2013 entitled “Greenhouse gases — Requirements for greenhouse gas validation and verification bodies for use in accreditation or other forms of recognition”; b) ISO 14066:2011 entitled “Greenhouse gases — Competence requirements for greenhouse gas validation team and verification teams”; and c) Annex 16, Volume IV, Appendix 6. Verification bodies must ensure that, at a minimum, the verification team include a team leader, as defined in ISO 14066:2011, who leads the engagement planning and management of the verification team. While it is possible that a single individual, or team leader, may fulfil all the competence requirements for a verification team, ISO 14065 requires that someone not directly involved with the verification activities confirm that all verification activities have been completed and determines whether the Emissions Report is free from material discrepancies. The internal reviewer is typically appointed at the same time as the verification team members, and must have competencies equivalent to a team leader. All verification team members must be identified in the Verification Report. In order to perform all verification activities sufficiently, the verification body requires access to all relevant documents including the aeroplane operator’s data and data systems. The identification of all relevant data sources should be done in advance. Access should also be granted to premises and staff of the aeroplane operator (e.g. for interviews), if this is needed to conduct the verification in an appropriate manner. Volume IV. Procedures for demonstrating compliance with the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) Chapter 3 3-37 (2) Strategic analysis It is recommended that the verification body conduct the strategic analysis4 by September of the ongoing reporting year. In addition to the programme-neutral content of the strategic analysis, the CORSIA-specific parts should at least include the following items: a) Operating environment of the aeroplane operator (e.g. type of flights, number of flights and aeroplane, organizational structure, subsidiaries, key commercial data such as growing or shrinking business, web page information, AOC, technical details regarding internal and external database accesses); b) Emissions Monitoring Plan (e.g. approved or not, data flow activities, specific conditions set out by the State, sufficient descriptions and explanations contained, meets requirements of Annex 16, Volume IV, potential modifications after approval); c) Previous versions of Emissions Report and Verification Report; d) Relevant communication between aeroplane operator and State; and e) Share of reported emissions with an actual offsetting requirement. If the verification body has not achieved a sufficient level of understanding to assess the scope and complexity of the verification, it will not be possible to perform a risk analysis, determine if a modification to the verification team is required or assess whether the contractually agreed time allocation for this specific verification engagement is indeed sufficient. (3) Risk analysis It is recommended that the verification body conduct the analysis of risks5 by September of the ongoing reporting year directly after the strategic analysis. In addition to the programme-neutral content of the risk analysis, the CORSIA-specific parts should at least include the following items: a) Complexity of the Emissions Monitoring Plan (number of aeroplane types, different monitoring methods, use of simplified MRV); b) Maturity of the internal control activities; c) Maturity of the data flow activities; d) Assessment whether CORSIA data and information is part of a certified management system; e) Internal audit reports; f) Number of data gaps; 4 Definitions of strategic analysis are contained in the IAF Mandatory Document for the Application of ISO 14065:2013, Issue 2 (IAF MD 6:2014). 5 Definitions of the assessment of risks are contained in the IAF Mandatory Document for the Application of ISO 14065:2013, Issue 2 (IAF MD 6:2014). Next >