The International Civil Aviation Organisation’s draft rules for carbon trading and climate crisis

Emissions from flying continue to rise. In 1986, the aviation industry consumed 2.6 million barrels of jet fuel per day. By 2012, the figure had more than doubled, reaching 5.4 million. The impact on the climate is serious, yet the industry’s response has been worse than useless.

Aviation accounts for about 5% of global greenhouse gas emissions. That figure could reach 22% by 2050 according to a 2015 report produced for the European Parliament.

In October 2016, the UN’s International Civil Aviation Organisation agreed to a plan called Carbon Offsetting and Reduction Scheme for International Aviation. This global carbon trading mechanism will allow aviation emissions to continue to grow.

Until 2020, ICAO’s plan does not require any reductions in emissions from international aviation. After 2020, emissions will continue to increase dramatically, but emissions above 2020 levels will be offset.

Draft rules for burning the planet

In November 2017, ICAO’s Council approved a draft document setting out the rules for its carbon trading scheme. The 192 member states of ICAO have until 5 March 2018 to respond. ICAO’s Council will then approve the document either as it is, or with amendments.

The Brussels’ based NGO Transport & Environment is an observer organisation to ICAO, and has made the document public on its website. (Perhaps more surprisingly, the civil aviation authority of Vietnam has also made the document available on its website.)

At 128 pages, and written in ICAO’s technical language, this is not easy reading.

While ICAO’s carbon market rules are important (to exclude double counting, to exclude carbon credits generated from projects with no beneficial impacts on the climate, to exclude carbon credits generated from projects where any beneficial impacts are likely be reversed, to exclude carbon projects that fail to recognise the rights of indigenous peoples, and so on), the reality is that carbon offsets do not reduce emissions.

As REDD-Monitor has pointed out more than once, carbon offsets may reduce emissions in one part of the world. But as soon as a polluting industry (like the aviation industry) buys a carbon credit, it does so only in order to continue polluting. At best, the one cancels out the other. More likely is that the carbon offsets are generated from projects that have no meaningful impact on climate change, or even exacerbate it.

What’s new in ICAO’s draft rules?

ICAO’s draft document covers various aspects of CORSIA: The administration of CORSIA; How the aviation sector should measure, report and verify its emissions; Offsetting requirements; and Cancelling carbon credits.

The document includes a bit more information about ICAO’s criteria for allowing carbon credits into the CORSIA scheme. Before this document was released, the only publicly available information about the critieria was a list of eight criteria, with no explanation (the list is below). Now we have a short paragraph explaining each criteria in a little more detail.

As FERN points out in its recent report, “Unearned Credit”, forest carbon offsets are highly unlikely to meet at least six of these eight criteria (all except 3 and 4, and these two may also not be met in some cases).

The fact that Virgin Atlantic this week announced that it would no longer buy carbon credits from the Oddar Meanchey REDD project in Cambodia exposes the dangers of using forest carbon projects to offset the emissions from flying.

ICAO’s failure to address the international aviation sector’s impact on the climate is a catastrophe happening in slow motion. ICAO has already decided to use offsets instead of reducing its emissions. The impact on the climate seems less important than the industry’s need to keep expanding.

For what it’s worth, here’s the section from ICAO’s draft document about its criteria for carbon credits:

Extract from draft Standards and Recommended Practices relating to the Carbon Offsetting and
Reduction Scheme for International Aviation (CORSIA)

Carbon Offset Credit Integrity Assessment Criteria: There are a number of generally agreed principles that have been broadly applied across both regulatory and voluntary offset credit programs to address environmental and social integrity. These principles hold that offset credit programs should deliver credits that represent emissions reductions, avoidance, or sequestration that:

1. Are additional.
2. Are based on a realistic and credible baseline.
3. Are quantified, monitored, reported, and verified.
4. Have a clear and transparent chain of custody.
5. Represent permanent emissions reductions.
6. Assess and mitigate against potential increase in emissions elsewhere.
7. Are only counted once towards a mitigation obligation.
8. Do no net harm.

Eligibility criteria should apply at the program level, as the expertise and resources needed to develop and implement ICAO emissions criteria at a methodology and project level is likely to be considerable.

1. Eligibility Criterion: Carbon offset programs must generate units that represent emissions reductions, avoidance, or removals that are additional. Additionality means that that the carbon offset credits represent greenhouse gas emissions reductions or carbon sequestration or removals that exceed any greenhouse gas reduction or removals required by law, regulation, or legally binding mandate, and that exceed any greenhouse gas reductions or removals that would otherwise occur in a conservative, business-as-usual scenario. Eligible offset credit programs should clearly demonstrate that the program has procedures in place to assess/test for additionality and that those procedures provide a reasonable assurance that the emissions reductions would not have occurred in the absence of the offset program. If programs pre-define certain activities as automatically additional (e.g., through a “positive list” of eligible project types), then they have to provide clear evidence on how the activity was determined to be additional. The criteria for such positive lists should be publicly disclosed and conservative. If programs do not use positive lists, then project’s additionality and baseline setting should be assessed by an accredited and independent third-party verification entity and reviewed by the program.
2. Eligibility Criterion: Carbon offset credits must be based on a realistic and credible baseline. Offset credits should be issued against a realistic, defensible, and conservative baseline estimation of emissions. The baseline is the level of emissions that would have occurred assuming a conservative “business as usual” emissions trajectory i.e., emissions without the emissions reduction activity or offset project. Baselines and underlying assumptions must be publicly disclosed.
3. Eligibility Criterion: Carbon offset credits must be quantified, monitored, reported and verified. Emissions reductions should be calculated in a manner that is conservative and transparent. Offset credits should be based on accurate measurements and quantification methods/protocols. Monitoring, measuring, and reporting of both the emissions reduction activity and the actual emissions reduction from the project should, at a minimum, be conducted at specified intervals throughout the duration of the crediting period. Emissions reductions should be measured and verified by an accredited and independent third-party verification entity. Ex-post verification of the project’s emissions must be required in advance of issuance of offset credits; Programs that conduct ex-ante issuance (e.g., issuance of offset units before the emissions reductions and/or carbon sequestration have occurred and been third-party verified) should not be eligible. Transparent measurement and reporting is essential, and units from offsetting programs/projects eligible in a global MBM should only come from those that require independent, ex-post verification.
4. Eligibility Criterion: Carbon offset credits must have a clear and transparent chain of custody within the offset program. Offset credits should be assigned an identification number that can be tracked from when the unit is issued through to its transfer or use (cancellation or retirement) via a registry system(s).
5. Eligibility Criterion: Permanence – Carbon offset credits must represent emissions reductions, avoidance, or carbon sequestration that are permanent. If there is risk of reductions or removals being reversed, then either (a) such credits are not eligible or (b) mitigation measures are in place to monitor, mitigate, and compensate any material incidence of non-permanence.
6. Eligibility Criterion: A system must have measures in place to assess and mitigate incidences of material leakage. Offset credits should be generated from projects that do not cause emissions to materially increase elsewhere (this concept is also known as leakage). Offset credit programs should have an established process for assessing and mitigating leakage of emissions that may result from the implementation of an offset project or program.
7. Eligibility Criterion: Are only counted once towards a mitigation obligation. Measures must be in place to avoid:
   a) Double issuance (which occurs if more than one unit is issued for the same emissions or emissions reduction).
   b) Double use (which occurs when the same issued unit is used twice, for example, if a unit is duplicated in registries).
   c) Double claiming (which occurs if the same emissions reduction is counted twice by both the buyer and the seller (i.e., counted towards the climate change mitigation effort of both an airline and the host country of the emissions reduction activity)). In order to prevent double claiming, eligible programs should require and demonstrate that host countries of emissions reduction activities agree to account for any offset units issued as a result of those activities such that double claiming does not occur between the airline and the host country of the emissions reduction activity.
8. Eligibility Criterion: Carbon offset credits must represent emissions reductions, avoidance, or carbon sequestration from projects that do no net harm. Offset projects should not violate local, State/provincial, national or international regulations or obligations. Offset programs should show how they comply with social and environmental safeguards and should publicly disclose which institutions, processes, and procedures are used to implement, monitor, and enforce safeguards to identify, assess and manage environmental and social risks.