< Previous 3-38 Environmental Technical Manual g) Multiple locations for data gathering and processing; h) Centralized vs. decentralized responsibilities for CORSIA; i) Use of CORSIA eligible fuels; and j) Voluntary pre-verification documentation. Verification bodies are encouraged to check the results and documentation of the voluntary pre-verification in detail. Depending on the documentation, results of the pre-verification might significantly reduce the verification risk. On the basis of the risk analysis, verification bodies should identify and quantify inherent and control risks. As with other GHG schemes, the risk analysis is subject to revision should the verification reveal that the risk is actually much higher or lower than originally assessed. This has an influence on the verification plan as well. (4) Verification plan It is recommended that the verification body draft the verification plan by September of the ongoing reporting year directly after the risk analysis. The following elements should be covered: a) Verification programme (incl. name of aeroplane operator, verification objective, verification scope, verification language, arrangements and responsibilities within the verification team, site visit arrangements, activities performed on- and off-site, document list); b) Test plan for control activities (scope and methods of testing, including IT controls, quality assurance in outsourced processes, procedures of the Emissions Monitoring Plan); and c) Data sampling plan (scope and methods, including specific data points such as ACARS triggers, flight logs, fuel uplift statements). Where additional risks are identified or new information is discovered during the actual verification that changes the original assessment of a risk, the associated risk analysis and verification plan must be updated. Site visits are an essential part of the verification activities under the CORSIA whereas the term ‘site’ refers to the place where the aeroplane operator performs the main activities of data processing to calculate the final figures of the Emissions Report (in most cases the headquarters of the aeroplane operator). Site visits are recommended for verification bodies verifying an Emissions Report of an aeroplane operator using Fuel Use Monitoring Methods as described in Annex 16, Volume IV, Appendix 2. This does also apply to verification bodies verifying an Emissions Report of an aeroplane operator eligible to use the ICAO CORSIA CERT which has chosen to apply Fuel Use Monitoring Methods as described in Annex 16, Volume IV, Appendix 2. To a large extent the risk analysis, but also evidence obtained during the verification itself, determine the scope and also the number of site visits necessary for a verification body to conclude on the Emissions Report. During the visit the verification body is, for instance, able to obtain physical evidence of the systems in place, can interview staff of the aeroplane operator, and check the practical application of control procedures. Also, for verification bodies providing verification services for an aeroplane operator using the ICAO CORSIA CERT, site visits are an essential means through which the verification team can collect sufficient and appropriate evidence to confirm whether the Emissions Report is free from material misstatements and material non-compliances. Nevertheless, especially after the initial verification of an aeroplane operator using the ICAO CORSIA CERT, the verification body might discover in its risk analysis a very low verification risk as the processes and internal control procedures of the aeroplane operator have proven to be effective and reliable. In such cases the verification body may choose to Volume IV. Procedures for demonstrating compliance with the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) Chapter 3 3-39 substitute a site visit with an alternative remote verification technique like video-conferencing and direct access to the databases of the aeroplane operator. As with physical site visits, it is very important to not base verification activities on technology which does not allow instant communication (e.g., email). In order to reduce costs for the aeroplane operator, responsible staff might also visit the verification body in its own offices and provide instant data access by carrying company notebooks with them and provide immediate answers to specific questions by initiating (video) calls to responsible staff in the headquarter. If the verification body decides to replace a site visit(s) with other means, this has to be clearly indicated in the Verification Report. This includes the reasoning for the decision on the basis of the risk analysis as well as a detailed explanation of the technical systems used. The verification body should coordinate with the State of the aeroplane operator before replacing the site visit with an alternative approach. (5) Verification In order to obtain sufficient insight but also to avoid any time pressure between the end of the reporting year and the submission of a verified Emissions Report, it is recommended that the verification body perform a preliminary verification during the actual reporting year as well. This can prove especially useful if the verification body was not able to build its verification plan on the basis of its own experiences obtained from previous audits of the same aeroplane operator. For a preliminary verification, at least nine months of flight and fuel consumption data has to be available and processed already. Depending on the individual risk assessment and the confidence obtained in the procedures of the aeroplane operator, a combined approach of a remote and on-site audit can be possible. Results of the preliminary verification inform the actual verification. Consequently, total time spent for a preliminary and a (shortened) actual verification might not necessarily be longer than combining all verification tasks in a single verification. As in other GHG schemes it is expected that the verification body will use standard auditing techniques (such as interviews, analytical data testing approaches, and document reviews) when implementing the verification plan. See section 3.3.5 of this manual for CORSIA and aviation-specific considerations related to the implementation of the Emissions Monitoring Plan and data testing. The verification body assesses the material impact the identified misstatements and non-conformities are likely to have on the reported data (as described in section 3.3.6.2 of this manual). (6) Addressing misstatements and non-conformities The aeroplane operator will correct all misstatements and non-conformities discovered during the verification. If it is not possible to correct the corresponding values, or if the verification body has not achieved sufficient confidence in the aeroplane operator’s Emissions Report, the verification body has to follow the instructions as described in section 3.3.6.3. (7) Verification Report The verification body will draft a Verification Report after the completion of verification activities as described in Annex 16, Volume IV, Appendix 6. The Verification Report contains a concluding verification statement. 3-40 Environmental Technical Manual (8) Independent review Before submission of the Emissions Report to the State, all documentation of the verification engagement as well as the Verification Report itself have to be reviewed by an independent reviewer. The independent reviewer will confirm that all verification activities have been completed by the verification team and that the evidence collected is appropriate and sufficient and leads to the conclusions formed by the team. This additional final quality check is essential for the verification body and the aeroplane operator. All identified errors by the independent reviewer have to be corrected. Due to the large amount of data involved in the CORSIA verification process, the independent reviewer should focus on assessing whether the verification team was able to gather sufficient and appropriate evidence to support the verification statement included in the Verification Report. This includes the documented sample size and the documented analytical procedures applied to the datasets of the aeroplane operator. As in other GHG schemes, the independent reviewer will not be part of the verification team. (9) Authorization to forward Emissions Report The verification body will forward the Verification Report and the Emissions Report to the State. To avoid the unintended submission of the Verification Report and the Emissions Report by the verification body, the verification body will forward these reports upon authorization by the aeroplane operator. Specifics regarding this provision should be contained in the contract between the verification body and the aeroplane operator. (10) Submission of Verification Report and Emissions Report As well as the verification body sending the Verification Report together with the Emissions Report to the State, the aeroplane operator will also provide the State with a copy of the Verification Report and the Emissions Report. The State will review the documents and may contact the aeroplane operator and the verification body to receive further explanations if required. 3.3.4.3 Order of magnitude check by State The State will perform an order of magnitude check of the Emissions Report of the aeroplane operator as described in Annex 16, Volume IV, Part II, Chapter 2, 2.4.1.5. The order of magnitude check will follow a set of standardized requirements as outlined in Table 3-9. For an average sized aeroplane operator with a satisfactory verified Emissions Report, the order of magnitude check should not take longer than approximately three hours. Volume IV. Procedures for demonstrating compliance with the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) Chapter 3 3-41 Table 3-9. State order of magnitude checklist No. Question / Issue Additional information Status: OK/Yes/No /Not Applicable Notes and results of checks Aeroplane operator 1 Aeroplane operator/verification body both separately submit Emissions Report and Verification Report. Is the content of both submissions identical? Minimum check: reported fuel consumption and number of flights. Get back to aeroplane operator in case of deviations. 2 Is the name of the aeroplane operator given and unambiguous? Ensure unambiguous identification of aeroplane operator. Get back to aeroplane operator in case of uncertainties. 3 Is there a valid ICAO Designator for aeroplane operating agencies? Does it have the correct character length? Ensure unambiguous identification of aeroplane operator. Get back to aeroplane operator in case of uncertainties. 4 Basic information (address, AOC etc.) plausible? Ensure unambiguous identification of aeroplane operator. Get back to aeroplane operator in case of uncertainties. 5 Has the aeroplane operator correctly identified its competent and responsible authority? If there is indication of another State being in charge, get back to relevant State and aeroplane operator. 6 Has the Emissions Report been submitted in due time? 7 Are the documents submitted complete? Any blank boxes? Verification Report included? If not, contact aeroplane operator. 8 Does the verification body´s Verification Report contain special indications to follow up on? Verification body´s indication have to be paid special attention. If they have an impact on the amount of emissions, get back to aeroplane operator. 9 Other defects/ comments? Emissions Report information 10 Has the latest Emissions Report template version been used? Ensures capturing and reporting fuel consumption according to latest requirements. 11 Date of creation of Emissions Report within the underlying reporting period? If so, there is the risk of incomplete reporting of flight data. End of year flights might be missing. 3-42 Environmental Technical Manual No. Question / Issue Additional information Status: OK/Yes/No /Not Applicable Notes and results of checks 12 Requirement to report? Check of threshold for annual CO2 emissions from international flights, as defined in Annex 16, Volume IV, Part II, Chapter 1.1.2, and Chapter 2, 2.1, are greater than 10 000 tonnes. 13 Are there any State pairs reported which are subject to offsetting requirements? If so, in depth investigation of these reported State pairs. 14 Has the Emissions Report been verified? If verification is missing, get back to aeroplane operator and request verification of Emissions Report. 15 Has the Emissions Report been created on the basis of an Emissions Monitoring Plan which is available to the State? If not, Emissions Monitoring Plan version used by aeroplane operator should be requested. Verification body notes should be considered. 16 Is the underlying Emissions Monitoring Plan approved by the State? If not, investigate reason. Check and approve Emissions Monitoring Plan. It has to be ensured that the number of flights and fuel quantity are monitored completely. 17 Are any collateral clauses part of the approval of the Emissions Monitoring Plan? If so, implementation has to be tracked and checked. 18 Have thresholds of approved Fuel Use Monitoring Methods been exceeded? Is the use of simplified procedure permissible? In case of inappropriate deviation resulting in lower accuracy, get back to aeroplane operator. 19 Is there any deviation in capturing CO2 emissions in relation to the approved Emissions Monitoring Plan? Mainly data flow and monitoring method have to be checked in depth. Refer to the Verification Report. 20 If there is a deviation from approved Emissions Monitoring Plan, is it described accurately? Is the deviation traceable? Did it lead to any material changes? 21 If applicable, how does the Verification Report assess deviations from the approved Emissions Monitoring Plan? Has the verification body investigated and specified any deviation in its Verification Report? 22 In case of deviations, is reapproval of Emissions Monitoring Plan necessary? If so, aeroplane operator has to be requested to amend Emissions Monitoring Plan and submit for approval. Volume IV. Procedures for demonstrating compliance with the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) Chapter 3 3-43 No. Question / Issue Additional information Status: OK/Yes/No /Not Applicable Notes and results of checks 23 Is the amount of reported CO2 emissions roughly plausible? Individual corresponding parameters like e.g. aeroplane activity and size of aeroplane fleet in relation to amount of emissions have to be considered and cross-checked. 24 Is the number of flights plausible? Individual corresponding parameters like e.g. aeroplane activity and size of aeroplane fleet in relation to air activity have to be considered and cross-checked. 25 Other defects/ comments? Aeroplane fleet 26 Aeroplane fleet complete and plausible? If applicable, cross-check with available data sources (e.g. website of aeroplane operator or public databases). Cross-check, if size of aeroplane fleet fits to reported aeroplane activities. 27 Have registration marks been indicated multiple times? If so, get back to aeroplane operator. 28 Other defects/ comments? OPTION 1 State pairs 29 Are the data sets complete? Incomplete data sets have to be clarified by aeroplane operator. 30 Is the given information regarding number of flights plausible? Does aeroplane operator report a noticeable small number of flights on typical destinations of the airline? 31 Are the types of fuel reported plausible and contained in Emissions Monitoring Plan? Since emissions factor is fuel type-specific, deviation might lead to implausible amount of calculated emissions. 32 Generally, is the reported fuel consumption plausible? In this regard, historical data should be consulted for plausibility checks. 33 Have outbound and inbound flight been reported separately? Outbound and inbound flight have to be reported separately. Aggregation is not possible. In case of uncertainty get back to aeroplane operator. 3-44 Environmental Technical Manual No. Question / Issue Additional information Status: OK/Yes/No /Not Applicable Notes and results of checks 34 In case of usage of multiple fuel types on a certain State pair, has an appropriate number of State pairs been reported? In this case State pairs have to be reported corresponding to the amount of different types of fuels. Aggregation is not possible. In case of uncertainties get back to aeroplane operator. 35 Is classification of State pairs in regard to offsetting requirements correct? In general, the reporting template generates the classification automatically. However, checking is recommended. 36 State pairs with equal type of fuel listed multiple times? In this case only one State pair has to be reported. The amounts have to be summed up. Get back to aeroplane operator if necessary. 37 Departure and destination in the same State? If yes, get back to aeroplane operator to reinsure. 38 Are there State pairs with more than 250 tonnes average fuel consumption per flight? Calculation is: fuel consumption of respective State pair divided by number of flights. In case of fuel consumption greater than 250 tonnes per flight get back to aeroplane operator. This refers to all reported State pairs. 39 Are there State pairs with less than 2.5 tonnes of fuel consumption per flight? Calculation is: fuel consumption of respective State pair divided by amount of flights. In case of fuel consumption below 2.5 tonnes per flight get back to aeroplane operator. This refers to all reported State pairs. 40 Random calculation of average fuel consumption per flight (per State pair) and comparison with typical average consumption from the ICAO CORSIA CERT. The ICAO CORSIA CERT should be consulted for cross-checks. Typically used aeroplane type can be obtained from public flight tracking data bases or official flight plans of the aeroplane operator. 41 Other defects/ comments? OPTION 2 Aerodrome pairs 42 Are the data sets complete? Incomplete data sets have to be clarified by aeroplane operator. 43 Is the given information regarding number of flights Does aeroplane operator report a noticeable small number of flights on typical destinations Volume IV. Procedures for demonstrating compliance with the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) Chapter 3 3-45 No. Question / Issue Additional information Status: OK/Yes/No /Not Applicable Notes and results of checks plausible? of the airline? 44 Are the types of fuel reported plausible and contained in Emissions Monitoring Plan? Since emissions factor is fuel type-specific, deviation might lead to implausible amount of calculated emissions. 45 Have outbound and inbound flights between two aerodromes been reported separately? Outbound and inbound flights have to be reported separately. Aggregation is not possible. In case of uncertainty get back to aeroplane operator. 46 In case of usage of multiple fuel types on a certain aerodrome pair, has an appropriate number of State pairs been reported? In this case aerodrome pairs have to be reported corresponding to the amount of different type of fuels. Aggregation is not possible. In case of uncertainties get back to aeroplane operator. 47 Is the classification of aerodrome pairs as regards offsetting requirements correct? In general, the reporting template generates the classification automatically. However, checking is recommended. 48 Is the classification of aerodrome pairs as regards offsetting requirements correct? In general, the reporting template generates the classification automatically. However, checking is recommended. 49 Have aerodrome pairs with equal type of fuel listed multiple times? In this case only one aerodrome pair has to be reported. The amounts have to be summed up. Get back to aeroplane operator if necessary. 50 Plausibility check: departure and destination in the same State? If yes, plausibility check and get back to aeroplane operator to clarify if aeroplane operator’s intention was to report another aerodrome pair. 51 Does the aeroplane operator report more than 3 500 flights on an aerodrome pair? If so, get back to aeroplane operator to check plausibility. 52 Are there aerodrome pairs with more than 250 tonnes fuel consumption per flight? Calculation is: fuel consumption of respective aerodrome pair divided by amount of flights. In case of fuel consumption greater than 250 tonnes per flight contact aeroplane operator. This refers to all reported aerodrome pairs. 3-46 Environmental Technical Manual No. Question / Issue Additional information Status: OK/Yes/No /Not Applicable Notes and results of checks 53 Are there aerodrome pairs with a fuel consumption of less than 2.5 tonnes per flight? Calculation is: fuel consumption of respective aerodrome pair divided by amount of flights. In case of fuel consumption less than 2.5 tonnes per flight get back to aeroplane operator. This refers to all reported aerodrome pairs. 54 Random calculation of average fuel consumption per flight (per aerodrome pair) and comparison with typical average consumption from the ICAO CORSIA CERT. The ICAO CORSIA CERT should be consulted for cross-checks. Typically used aeroplane type can be obtained from public flight tracking data bases or official flight plans of the aeroplane operator. 55 Other defects/ comments? Data gaps 56 Did data gaps occur during the reporting year? If yes, detailed assessment of the State required. 57 Is the applicable threshold of 5 per cent for significant data gaps exceeded? If yes, which explanations have been provided by the verification body and the aeroplane operator? 58 Has the operator closed/completed data gaps according to the Emissions Monitoring Plan? A comparison with the method described in the Emissions Monitoring Plan must be carried out. 59 Have data gaps been closed even though secondary data were available? If secondary data is available, this data has to be used to close data gaps. 60 Is the estimated fuel consumption plausible? The ICAO CORSIA CERT can be used to perform random checks. 61 Did the operator indicate that data gaps occurred during the reporting year, but did not report data gaps? If so, get back to aeroplane operator. 62 Other defects/ comments? Verification body 63 Does the verification body have a valid accreditation? A comparison with the published list of ICAO must be carried out. The verification body will be accredited. Otherwise, the Emissions Report does not meet the requirements of Annex 16, Volume IV. Volume IV. Procedures for demonstrating compliance with the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) Chapter 3 3-47 No. Question / Issue Additional information Status: OK/Yes/No /Not Applicable Notes and results of checks 64 Have all the indications and notes of the verification body been considered? It is important to pay close attention to the details given in the Verification Report. 65 Are there any negative assessments from the verification body? If so, check whether the issues identified affect the amount of reported emissions. 66 Has the verification body not issued a statement, or issued a negative verification statement? Is the report verified as “not satisfactory”? The reasons must be examined in depth. Contact the aeroplane operator. 67 Was the verification statement issued during the underlying reporting period already? If so, the reasons have to be clarified with the verification body. It is necessary to check whether the verification body verified the entire reporting year. 68 Has the verification body issued a satisfactory verification opinion with comments? The verification comments must be examined in depth. 69 Is the content provided in the Verification Report sufficient? Size of data sample and verification programme sufficient? It is necessary to determine whether the verification body carried out a proper and complete verification. 70 Is there any evidence that the verification body violated the principle of independence? e.g. has the verification body supported with the Emissions Monitoring Plan? Has the verification body provided support in drafting the Emissions Report? It is important to inform the responsible accreditation body. 71 How is the quality of the verification body assessed? A rating (good, medium, poor) is useful. Contact with verification body if necessary. It is important to provide feedback to the responsible accreditation body about the performance of verification bodies. 72 Other defects/ comments? Change of data by State 73 Change of data necessary? Next >