January 1,2019 most need to file CERT forms
CERT is a test of whether this is a BURDEN
What will measure “too demanding”
Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) was designed by ICAO as a more reasonable alternative to the EU’s Emission Trading System (ETS). A SCHEME to avoid a SYSTEM is the epitome of uber bureaucratization; UN staff rewriting rules designed by Eurocrats means policies + procedures + paperwork+∞ !!!
As the AINonline article explains, business aircraft are required as of January 1,2019 to start participating in the filing of ICAO reports called the CORSIA Emissions Reporting Tool (CERT).
According to Bruce Parry, IBAC environment director “ICAO has provided a range of CORSIA templates to address concerns that small operators—often with a single aircraft—simply do not have the resources to administer complex schemes.” Only ICAO and the EU would create a form for which the purpose is to prove that filling out a form is too demanding.
[THERE IS NO TRUTH TO THE RUMOR THAT JOSEPH HELLER WAS HIRED TO DRAFT CERT!!!]
IBAC continues its advice:
“Also to reduce the administrative impact on the industry, IBAC and its member business aviation associations have ensured operators are made aware of emissions and exemptions and provided an online “ready reckoner” so operators can quickly assess whether they are likely to ultimately need to take part and pay for offsets.
“If you’re in the exemption zone, you don’t need to do any reporting,” said Parry, the small operator threshold being 10,000 metric tons of CO2 per year and aircraft with less than a 5,700-kg/12,566-pound mtow. NBAA says current-generation business jet fleets need to fly a combined 2,000 hours or more annually in international operations to reach the CO2 threshold.
“If you use more than one million U.S. gallons of fuel a year, you are likely to be in the scheme,” according to Parry. “We’re saying that if you’re within 10 percent of the threshold, you need to engage with your national administering authority,” such as the FAA in the U.S. and the Environment Agency in the UK.
IBAC provided an update (May 2018) on the progress of CORSIA:
CORSIA UPDATE Technical work on guidance for the coming Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) continued at ICAO in April. The Global Market-based Measures Task Force (GMTF) met to advance work on the few remaining areas of the guidance documents to be completed. The GMTF also reviewed development of the CORSIA Emissions Reporting Tool (CERT) that will be available to operators free of charge in order to facilitate participation in the scheme. IBAC participated in the meeting on behalf of business aviation.…
EBAA distributed an update July, 2018:
Immediate Actions Required by Operators Emissions Monitoring Plan (EMP). Operators operating international flights who are not subject to CORSIA exemptions should complete and submit to their administering State an EMP that details how they will conduct emissions reporting. Recommended to be completed by 30/09/2018 (submission mandatory by 28/02/2019)
CORSIA Exemptions Technical exemptions – Apply to all international operators emitting less than 10,000 metric tonnes of CO2 emissions from international aviation per year; aircraft with less than 5,700 kg of Maximum Take Off Mass (MTOM); or humanitarian, medical and firefighting operations
Note; IBAC recommends that any operator that exceeds 9,500 metric tonnes of CO2 engages with their administering State to discuss a way forward should the operator envisages exceeding the exemption level.
State Exemptions – States that are recognised as Least Developed Countries (LDCs), Small Island Developing States (SIDS) and Landlocked Developing Countries (LLDCs), unless individual States have volunteered to be part of CORSIA for the period 01/01/2021 – 31/12/2027 Volunteer States All States that have volunteered (including those that have been identified who would normally be exempt) to participate in CORSIA for the period 01/01/2021 – 31/12/2027. Details of States that have volunteered so far for CORSIA is available via the ICAO website
ICAO has a YouTube explanation of the scheme:
Published on Nov 24, 2016
The international community recently adopted ICAO’s transformational Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA), a major plank in the UN agency’s environmental protection strategy. Watch this video to understand what it is and how it works.
Universal Weather and Aviation, Inc. has produced an excellent webpage explaining CORSIA’s bizarre requirements:
In 2016, ICAO approved guidelines to implement the Global Offsetting and Reduction Scheme for International Aviation (CORSIA). In simple terms, CORSIA requires all aircraft operators to monitor their emissions on ALL international flights (Country A – Country B) beginning 1 January 2019.
Mandatory regulation requires all international operators to submit a Monitoring Plan to their Member State by the end of 2018. Beginning 1 January 2019, operators should track emissions on all INTL operations legs. At the end of each Monitoring Year, operators will compile flight data in an Annual Emissions Report. Based on their annual activity and emissions, operators over 10,000+ T/CO2 Full-Scope (between any two countries) annually must submit to an accredited verifier for certification. Total emissions on applicable flights (between participating Member States) are required to be offset via the purchase of Carbon Credits. Carbon Credits are required to be tallied and surrendered every third monitoring year.
The ultimate demonstration of the complexity of the CORSIA test implementation is that ICAO published on August 9,2018 a 51 page FAQ booklet.
The goals of CORSIA are undoubtedly estimable and point to a future of aviation providing more than its share of the CO2 reduction. As with many international efforts, there are frequently gaps between aspiration and implementation which virtually defeat the goal by exemptions.
Countries covered by CORSIA (blue) and not(Gray) in CO2 reduction effort
One question to which the answer is unfathomable: what objective decisional standard will demonstrate that the CERT test was NOT A BURDEN? How can an international organization comprehend, much less measure, the impact of filling out CERT forms? These two bureaucracies are both staffed to the level beyond any small business AND the essence of these bureaucrats’ work is completing forms.
Seriously, how can ICAO/EU assess the burden on a small, profit-driven company? The time consumed to collect the data (note: its gallons used while in international flights), confirm it, complete the directions, submit the form and answer the likely questions. Minutes or even hours of a company employee’s time may seem inconsequential to the public employee’s judgment. What is not readily visible to the “judges” is that the worker in devoting time to CERT is removed from her/his normal work! Time spent performing CORSIA-related functions may detract from other priorities. That is a metric incapable of measurement.
No answer here for that question.
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