Carbon offsetting programme applicants fall short of meeting criteria for CORSIA scheme, finds study
Cheakamus Community Forest, British Columbia
Mon 9 Dec 2019 – None of the 14 carbon offsetting programmes that have applied for eligibility under ICAO’s CORSIA currently perform well against the most important criteria stipulated by the scheme, according to a paper prepared for the German environment ministry by Öko-Institut and others. Some applicants hardly meet any of the emissions unit criteria (EUC) and are unlikely to be even considered carbon offsetting programmes. The report recommends that programmes should only be approved by ICAO once they have adopted the necessary standards and procedures to satisfy all EUCs. The approval process and the environmental integrity of CORSIA would be greatly facilitated if the current UN climate conference in Madrid adopted rules that explicitly addressed offset credits under the scheme. ICAO’s Technical Advisory Body (TAB) is due to submit recommendations on eligible programmes to the ICAO Council’s next Session in March.
ICAO has agreed on eight integrity assessment criteria that programmes must comply with in order to be considered eligible under CORSIA and the study by Öko-Institut, with input from Perspectives Climate Group and the Stockholm Environment Institute, evaluated the programmes against five of what it considered the most important, namely that carbon offset credits are:
Based on a realistic and credible baseline;
Represent permanent emission reductions;
Are only counted once towards a mitigation obligation; and
Do no net harm.
The paper does not attempt to include an assessment of specific programmes but rather summarises general observations from the evaluation of the 14 applications. However, it points out that four of the programmes – the World Bank’s Forest Carbon Partnership Facility, State Forests of the Republic of Poland, myclimate and REDD.plus – do not fulfil the basic features of being an eligible offset standard. The first is a fund that supports programmes that may generate carbon certificates but lacks key elements of a full carbon offsetting programme, while the other three do not have procedures for the approval of projects and issuance of carbon market units, managing protocols for the quantification of emission reductions and operating or accessing a registry system.
It is understandable, given the adoption of the EUCs by the Council only last February, that none of the programmes have standards and procedures in place that address all EUCs, says the paper. It notes that many programmes claim they will address those requirements in the future but, it argues, it is essential they are not approved based on promised “plans” to do so. Approval should only take place after programmes have adopted all necessary amendments to their standards, procedures, guidelines, forms and programme operations have been assessed by the TAB, it says. As long as offset credits are not yet eligible for use under CORSIA, it adds ICAO may alternatively consider approving programmes ‘provisionally’, subject to changes that they need to implement and subject to a final assessment by ICAO of whether these changes have been implemented appropriately.
It recommends the TAB itself should develop a transparent and clear procedure for the initial establishment of programme eligibility, the subsequent continuous surveillance of programmes in relation to their performance against the EUCs, as well as procedures for suspension of termination of programme eligibility if the programmes do not continue to meet all requirements. This procedure should be publicly available and public comments should be invited on the procedure prior to its final adoption. Some programmes do not include any substantive information on how they plan to meet a criterion in the future and there is a lack of sufficient information to inform public comments, says the paper.
The researchers point out that offset credits issued by carbon offsetting programmes are often used for multiple purposes that may involve different requirements than those under CORSIA. For the integrity of CORSIA, it is important that programmes distinguish units that meet all CORSIA requirements from those that do not, they recommend.
The study says there is a lack of clarity in the ICAO documents on a number of features that are important for the overall integrity of the scheme and which need to be addressed, for example on how long programmes will be approved and how it will be ensured that they continue to satisfy the EUC after their approval.
“We recommend specifically that the TAB develops a transparent and publicly available procedure for the initial approval, ongoing supervision, re-approval, suspension and termination of programme eligibility for CORSIA,” say the researchers.
The TAB is reported to be continuing its assessment of programmes against the EUC alongside discussions on vintage and timeframe approach. At its fourth meeting in January, the TAB is expected to finalise its recommendations and report for submission in time for the Council’s 219th Session in March. A second application process is envisaged to start in March.