Environmental NGOs call on ICAO's governing Council to adopt CORSIA draft emission credits criteria with no changes
Tue 5 Mar 2019 – NGOs have joined the call for ICAO’s governing Council to adopt unchanged draft proposals for the Emissions Unit Criteria (EUC) that are essential to the environmental integrity of the global CORSIA carbon offsetting scheme for international aviation. The Council’s 216th Session concludes this week and representatives on the 36-State Council are due to discuss the criteria and to establish a Technical Advisory Body (TAB) that will make recommendations to the Council on eligible emission units for use under the scheme. European representatives on the Council have already urged their colleagues to approve a robust set of criteria during the session. In an open letter, the International Coalition for Sustainable Aviation (ICSA) calls on Council members to approve the draft EUC with no changes, ensure CORSIA emissions are not double-counted and to make TAB membership publicly available and its processes transparent.
ICSA, which is made up of six NGOs, is the only environmental civil society group accredited as an observer at ICAO. Its letter says CORSIA is at a critical juncture and the Council’s decisions on the EUC could help international aviation achieve carbon-neutral growth from 2020 and create a global market that drives investment in low-carbon economic development.
“But if you choose to create a CORSIA that invites bad quality, double-counted emissions credits and secret backroom deals on programme eligibility, you will destroy CORSIA’s potential effectiveness, compromise the credibility of ICAO and the world’s airlines, and make global climate change worse,” warns the letter. “For CORSIA and ICAO, the stakes could not be higher.”
ICSA is urging the Council to approve the draft EUC with no changes. This is the position of Europe, the United States and other Western countries, although China has expressed concerns with terms like “social risks” and “social safeguards”.
ICSA points out the EUC are the product of three years of technical discussions in ICAO’s Committee on Aviation Environmental Protection (CAEP), the subject of discussion in many regional dialogues and have been circulated to Member States on several occasions.
Any weakening or changing of the EUC – particularly with regard to the crucial double-counting criterion – could cripple CORSIA’s integrity, it argues, adding: “Approving the EUC with no changes will send an important signal to stakeholders around the world that ICAO is serious about addressing international aviation’s environmental impact.”
Avoiding double-claiming, which occurs if an emissions reduction is counted towards the climate mitigation effort of both an airline and the host country of the emissions reduction activity, is fundamental to CORSIA’s environmental credibility, says ICSA.
“If aeroplane operators use double-claimed units to meet their CORSIA obligations, global emissions will go up, not down. ICAO and airlines will face harsh criticisms if units are double-counted in any way.”
Rules on double-counting were not agreed at the UNFCCC’s COP in Poland last December so as yet there are no international provisions in place with which airlines or emissions unit programmes can comply. “While ICAO can look to UNFCCC for signals on this issue, in the absence of clear rules issued by the UNFCCC COP, the Council should either require the TAB to adhere to the EUC provisions on avoiding double-counting, or ask CAEP to address the issue during the next CAEP/12 [three-year] cycle,” suggests ICSA.
A European call that a vintage restriction is adopted on the eligibility of units is supported by ICSA, which fears there will be a significant quantity of accumulated credits available to meet CORSIA demand that are of low environmental quality. It recommends that eligible units should be limited to those issued from projects with a start date of 2020 or later.
“Failure to agree on a vintage restriction based on projects start date would have serious implications on the mechanism’s climate impact and could potentially lead to an increase in overall emissions.”
The Council is due to discuss the procedures under which the TAB should operate but ICSA says these should be rejected unless the membership is made public in advance of the TAB’s work, its processes are made more transparent and its recommendations are published well in advance of Council decisions on programme eligibility.
With many millions of dollars at stake in airline purchases of carbon credits over the lifetime of CORSIA, the TAB must be open to public scrutiny to ensure stringent conflict-of-interest requirements for TAB membership are maintained, says ICSA. It calls for TAB meetings to be open to observation by representatives from Member States and observers who are not TAB members, recommendations on programme eligibility to be made public and Council decisions to follow or reject those recommendations to be explained clearly and publicly.
“Approving the EUC in their current form, ensuring that the EUC’s provisions on avoiding double-counting are respected and establishing a transparent, free of conflicts-of-interest TAB are crucial steps to make CORSIA a reality,” concludes the ICSA letter. “The Council must be aware that ICAO will experience substantial backlash if CORSIA fails to deliver on its promises. While airlines are eager to know as soon as possible which emission units will be eligible, the risks to CORSIA are enormous. The Council should not rush but should get it right.”