International Civil Aviation Organization (ICAO) and CORSIA

In the Kyoto Treaty of 1997, Annex 1⁹countries are asked to work on reducing emissions from aviation through ICAO. The successor is the Paris Agreement under the UNFCCC, agreed by most countries in the world, in 2015.¹⁰The Paris Agreement entered into force in November 2016. Here, aviation is not mentioned, nor ICAO.

However, the Paris Agreement calls on all countries and sectors to reduce their emissions to attain the targets of a maximal of 2 degrees Celsius warming and with the aim to attain a maximum of 1.5 degrees global warming by 2050. Emissions from international flights are generally not accounted for in the nationally determined contributions of the participating member states. However, the EU’s 2030 target includes outbound aviation emissions.¹¹

9. Annex 1 countries are the signatories of the Kyoto Treaty that committed to reduce their GHG emissions through a binding commitment.

10. The United States is leaving the Paris Agreement in 2020, and some large territories and self-governing regions like Greenland are not part of the agreement. Nicaragua joined the agreement in 2017.

11. https://www.transportenvironment.org/what-we-do/aviation-and-eu-ets

Emissions from international flights are reported every year to UNFCCC by Annex 1 countries, but only domestic flights are included in the national commitments. ICAO has issued many resolutions against the internalisation of environmental costs for the aviation sector and recommends that the members for international air services shall not impose any kind of duty or tax (ICAO, 2016; Pirlot & Wolff, 2017).

In the period from 2009–2016, ICAO created for the first time a fuel efficiency standard for new aircrafts. This standard is to be implemented by its member states from 2020 onwards for new types and from 2028 for new aircrafts of existing types.

ICAO has also set an aspirational goal of a global fuel efficiency improvement rate of 2 percent per annum from 2021 to 2050 (Fleming & Lépinay, 2019; ICAO, 2020b;

Kharina et al., 2016, p. 2). According to an analysis of various scenarios made for ICAO, the combined impact of improved fuel efficiency and operations under the most optimistic assumptions will be 1.37% per year (Fleming & Lépinay, 2019).

In 2013, ICAO set the target of stabilizing emissions from aviation at the level of 2020 until 2050, i.e. all growth in aviation from 2020 onwards will be carbon neutral.

This target is also aspirational (Fleming & Lépinay, 2019). From 2021, the

implementation of the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) will require airlines to offset increased emissions by buying quotas representing emission reductions in other sectors (ICAO, 2020b, 2020c). In comparison, the aviation industry’s own and more ambitious target from 2009 is that airlines should cut their emissions from flight operations by 50% by 2050 compared to the level in 2005 (IATA, 2018a).

CORSIA will have a route-based approach, meaning that emissions from all flights between participating countries are covered by the scheme. Participation in CORSIA will be voluntary. By the end of 2018, 78 states had signed up to participate,

including all EU member states. The years 2021–2023 is a pilot phase. The “first phase” of CORSIA is from 2024 to 2027. In the “second phase” from 2027 until 2035, CORSIA participation will be mandatory for most members of the ICAO. Small island states, landlocked countries, countries with little aviation and the least developed countries are exempted (European Parliament, 2019; ICAO, 2020b, 2020c;

Norsk klimastiftelse, 2018).

Another key strategy under CORSIA is substituting jet fuel with sustainable aviation fuel. In principle, the sustainability requirements are similar to the EU’s second renewables directive (RED 2, for further details about it, see 3.5): “CORSIA eligible fuel should not be made from biomass obtained from land with high carbon stock”.

Such lands include primary forests, peat and wetlands, and goes back to how they were used before 2008, before they were converted to other land categories. To ensure that this happens, CORSIA has created independent certification schemes (ICAO, 2019a). Sustainable fuels shall have at least 10% lower GHG emissions than ordinary jet fuel. However, critics claim that: “Given the uncertainties that exist in these calculations, it’s therefore possible that alternative fuels used will actually result in emissions equal to, or in excess of, kerosene” (T&E, 2019, p. 4).

However, in reality, the sustainability criteria under EU’s renewables directives, RED I and RED II, are much stronger than those of CORSIA. 10 out of 12 of EU’s

sustainability criteria have been dropped in CORSIA. The only current sustainability criteria in CORSIA are that: a) the sustainable fuel shall have 10% lower emissions than conventional jet fuel in the life cycle, and b) biomass shall not come from areas that have a high biomass stock (Ministry of Transport, 2019, p. 91; T&E, 2019, p. 8).

The sustainability criteria 3 to 12 did not pass ICAO Council initially but was referred back to the environmental committee CAEP for further work. However, at ICAO 219th Council session the additional 10 themes were adopted and are now going on State Letter procedure’ writes y (personal communication with Swedish Energy Agency, 29 April 2020). The results will be presented at the ICAO Council in November 2020 (Danish ministry of Transport, 28 August 2020).

To prepare for CORSIA, the airlines need to keep track of, verify and report their emissions from 2019 onwards. 2019 and 2020 were to be the baseline years to calculate average CO₂emissions from international aviation (European Parliament, 2019; ICAO, 2020b), but due to large declines in air traffic in 2020 caused by the Covid-19 pandemic, leading to very skewed results, the baseline will only rely on 2019 data.

This means that the airlines will also not necessarily have to buy carbon offsets, as long as they have not increased their emissions to pre-Covid-19 levels. If the average of the two years is applied as a baseline, the emission limits for the airlines will be very strict, and likely meet harsh resistance from the aviation industry. International Air Transport Association (IATA) has, for example, asked the ICAO council to use only the 2019-level as an average (IATA, 2020).

CORSIA has been strongly criticized by environmental organizations like Transport &

Environment (T&E), for a number of reasons:

• First, it does not deal with reducing international aviation emissions directly on the CORSIA covered routes, because the individual airlines can continue to emit as previously for an indefinite amount of time, and then buy offsets for their pollution instead of reducing it. As long as offsetting is cheaper than

CO₂-reduction in the aviation sector, airlines will have limited incentive to reduce own emissions (T&E, 2019).

• Second, participation is voluntary until 2027. A state may decline to participate hereafter through filing a reservation. For the states not wanting to participate, CORSIA has no enforcement mechanisms (T&E, 2019).

• Third, critics, including researchers, claim that CORSIA does not necessarily deliver reduced GHG emissions within the aviation sector, it will mainly provide revenues to various types of green projects. Buying offsets from such projects will be significantly cheaper than implementing other measures. The projects should be "additional", which means that they would not be established without the buying of offsets. This is difficult to prove in practise (Bergskaug, 2020;

Interview consultant, 2020; T&E, 2019). The critics seem to be backed by research: German Öko Institut has evaluated the first 14 carbon offsetting programs for eligibility under CORSIA and conclude:¹²

The evaluation shows that the degree to which the applicants satisfy the ICAO requirements differs substantially. Some applicants hardly met any of the requirements and may not even be considered carbon-offsetting programs. However, there are also notable differences in relation to specific criteria (Schneider et al., 2019, p. 5).

• Fourth, it seems to be an unresolved issue how to avoid double counting, i.e.

that the offsetting projects both count toward their country’s GHG emissions

12. Due to this, from 2021, international credits will not any longer be allowed to use in the EU ETS.

reduction targets and the host country of an airlines’ targets. If this is not hindered, it could result in states setting weaker targets so that they can sell potential overachievements as offsets. Thus, rules to avoid this situation need to be developed, according to T&E (2019). Another risk is that targets are not specified in certain sectors of a country so that projects there can be used as offsetting projects for international financing provided through the CORSIA (T&E, 2019).