Verifier’s Perspective of 2019 Emissions Report Verification
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 in 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 uncertainty and 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 manage risks and arrive at a reasonable assurance where possible.
Having concluded 188 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, 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 EMP
A non-compliance with the EMP arises when the monitoring, reporting was not performed according to what is declared in the Emissions Monitoring Plan.
We came across a number of varied non-compliances with the EMP. By far one of the most common one 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, owing to its importance. 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 to the actual used data and was many a times accompanied by the incorrect application of a fuel use monitoring method.
Non-Compliances of the EMP with the SARPS
A non-compliances 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) is to take place based on an EMP approved by the national authority. We have had to conclude some verifications with this non-compliance because the operator couldn’t get their EMP approved by their authority. As explained above there was missing necessary information from the EMPs which counts as 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 (fuel use monitoring method) selected as primary methods within the same period.
- It was also noted in certain cases that the implementation of the selected fuel use monitoring method was incorrect, which reflected a lack of understanding. This was the case with operators choosing to use the fuel uplift and fuel allocation by block hour methods. On a similar note, the incorrect use of the declared data gap approach was also encountered.
*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 deemed a non-conformity. These will always result into a misstatement. Misstatements are errors in the data/report ER 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.
- The use of incorrect, 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 ICAO template.
- In a few rare cases, missing international flights were counted as data gaps, international positioning flights were missed while some wet leased out flights were included.
- In one particular case, the operator was unable to edit the destination airport of a flight on their system. Their IT system prevented editing of the airport codes due to linkages with several other systems. This led to a situation where when an aircraft was diverted to another airport and subsequently left from the diverted airport it would result in a break in sequence. Often this diversion would be international, which would impact the state pairs to be reported.
Other Notable Points Of Improvement
Keeping the above aside, we also encountered a diverse assortment of issues. These do not qualify for any of the above categories as long as they are corrected/rectified prior to the issuance of the verification report.
- Perhaps the most common one was regarding filling in the Emissions report. Which aircrafts to declare in the fleet tab, how to fill the reporting/identification sheets, which dates and what is the approved aggregation were a few of the many points on which we have had to work.
- Some operators had duplicated flights, which were discovered during the verification.
- Most operators had breaks in sequence which upon investigation would at times reveal missing flights. It is highly recommended that all operators implement some measures to ensure that the each aircraft has a logical sequence of consecutive flights.
- Most operators haven’t 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 which haven’t been exposed to the EU ETS. Admittedly, the COVID crisis will present a new set of challenges during the verification season for 2020, but with concerted efforts we can overcome them and continue growing.