A Voluntary CO2 Report for Good Reasons

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FAA Details Operator CORSIA Reporting

FAA issues a “Notice” requesting voluntary reporting

Not via NPRM for a good reason

Good participation needed for US credibility in future CORSIA talks

Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) is coming and aptly the scheme is the least worst option to deal with the CO2 crisis. The FAA has issued a CORSIA Notice of Monitoring, Reporting, and Verification (MRV) Program; MRV is VOLUNTARY.[1]

ARSA has already demonstrated that voluntary can equal, practically mandatory (data collection tools (DCT)) and that such a “requirement” falls under the Paperwork Reduction Act, 44 U.S.C. § 3507(a). It was determined that the required voluntary submission criticized by ARSA needed to be subjected to a full Benefit/Cost review; so the FAA downgraded the DCT.


This administration has previously used an informal notice procedure to expedite the announcement of a new policy. The prior such procedure had to be and was followed by a formal NPRM with publication in the Federal Register. This MRV meets the Administrative Procedure standard due to its voluntary status.


The MRV is not so bad for good policy reasons. Some background is needed to support this conclusion.


Without regard to whether Climate Change is or is not a threat, it is clear that many countries support some form of controlling carbon emissions and collectively they have the clout to deliver a vote at ICAO (particularly because some Members are exempt and thus support the measure). A greater threat exists that individual nations and/or intracontinental organizations could impose their own measures and create a patch work of requirements for air machines that work on an intercontinental basis.



The carbon offsetting system will be phased in starting in 2021 on a voluntary basis and will become mandatory for all countries, excluding the least developed countries and nations with very low levels of aviation activity, in 2027. In preparation for the first stage, the CORSIA nation participants have agreed to collect data on the CO2 metric tons to establish a baseline. That information will be used to review the policy options— reliance on technology improvement, operational strategies which limit the CO2 emissions or some trading/offset mechanism.











The ICAO process did not determine the specifics of the data request for the MRV until November, 2018. That delay made it impossible for the FAA to complete an NPRM review, thus the voluntary MRV. One might be inclined to ignore anything that is voluntary, but the US’s/ FAA’s credibility in limiting the impact of a final CORSIA regime depends on a credible report of how much CO2 US operators are emitting.

There are some nations which doubt the US’s sincerity in participating in the setting of global measures; a report filled with estimates rather than hard numbers would give reason to doubt our sincerity.

Thus, it is urged that all operators[2] submit their data. [NOTE: according to a source, the commitments in response to the MRV have been positive.]

What does the MRV request:

“Participation in the CORSIA MRV Program is intended for U.S. airplane operators that produce annual CO2 emissions greater than 10,000 tonnes (i.e., 10,000 metric tons) from international flights, excluding emissions from excluded flights. The following are excluded from the CORSIA MRV Program: –

-Domestic flights;

– Humanitarian, medical, and firefighting operations, including flight(s) preceding or following a humanitarian, medical, or firefighting flight provided such flight(s) were conducted with the same airplane, were required to accomplish the related humanitarian, medical, or firefighting activities or to reposition thereafter the airplane for its next activity;

– Operations using an airplane with a maximum certificated take-off mass equal to or less than 5,700 kg;

– Operations on behalf of the U.S. military, provided that the flight plan is properly marked (i.e., Item 8 of the flight plan is marked “M”) or as otherwise consistent with condition(s) in the operator’s Emissions Monitoring Plan under this CORSIA MRV Program.”

The full technical details of the MRV are explained in the 7page Notice.

Voluntary is voluntary, but your participation in the MRV will help the FAA work out a reasonable set of CORSIA measures with other sovereigns, a difficult diplomatic assignment.



[1] Use of the term “will” in this document is aspirational only, and is not intended to be read as imposing any obligation or right on either the FAA or Program Participants. Use of the terms “must,” “require,” “shall,” “has to,” or “mandatory” and references to “requirements” or “standards” refer generally to the CORSIA SARPs. The FAA anticipates that, if appropriate, it will conduct rulemaking or take other action to implement the offsetting and other mandatory provisions of the CORSIA

[2] 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).


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