Climate 411

UN aviation agency sets a new standard for sustainable flight by adopting critical fuels criteria

This blog post was authored by Pedro Piris-Cabezas, Director of Sustainable International Transport & Lead Senior Economist at Environmental Defense Fund, and Anna Stratton, Consultant.

ICAO Building in Montreal

As the world convened for COP 26, the United Nation’s civil aviation body announced a major milestone in the transition to sustainable flight by adopting an expanded set of sustainability criteria for sustainable aviation fuel (SAF).   

SAF — jet fuel made from renewable feedstock instead of fossil fuels — provides a distinct opportunity to put aviation on a pathway to net-zero climate impact by 2050. But, to achieve that level of success, the SAF that airlines will use to be eligible for ICAO’s emissions reduction program, the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA), must meet a high standard of environmental integrity, and be accurately tracked and accounted for. Indeed, not all alternative fuels are equal. Some make environmental problems worse. Deploying SAF without a robust accounting and sustainability framework could negate the entire climate benefits and even increase emissions several-fold compared to fossil jet fuels.  

After years of hesitation, ICAO Council Members finally seized the opportunity to set these forward-looking sustainability safeguards, ensuring that SAF eligible under CORSIA lives up to its sustainability potential, and provides certainty for SAF producers as they make investments in the sustainability of their supply chains and operations.  

Not only is this decision a major milestone for ICAO, it is also the first time a UN body has defined a clear standard for what constitutes sustainability for a mitigation action. ICAO has also operationalized it with a full-fledged monitoring, reporting and third-party verification system including a high level of assurance, which makes CORSIA the most comprehensive SAF Framework adopted to date.  

ICAO’s decision also sends a clear signal to countries embarking in SAF policy: support for SAF must include robust environmental safeguards. This is critical because ICAO’s SAF framework can enable the production of truly climate beneficial SAF but only if paired with effective national policies that generate the needed economic incentives. 

The Council’s adoption of the SAF sustainability criteria is a turning point in the aviation sector’s journey to decarbonize—but it is far from its final destination. Now, countries, airlines, and fuel producers must take action to jump-start high-integrity SAF by shaping their national SAF policies accordingly.  

EDF, as a member of the International Coalition for Sustainable Aviation (ICSA), the group of environmental NGOs with observer status at ICAO, took a leadership role in this important development. EDF created the space for this negotiation to take place in ICAO’s Committee for Aviation Environmental Protection and was granted the privilege to co-chair the technical negotiations on SAF sustainability matters together with the International Air Transport Association (IATA). This privileged position gave us the capacity to thoughtfully design the negotiations and create the necessary coalitions to ensure, against all odds, the sequential adoption of the sustainability criteria and framework along ICAO’s political decision-making process. 

What’s the role of the SAF sustainability criteria?  

The role of sustainability criteria is to safeguard against direct and indirect negative effects on ecosystems and communities that are not captured or are underestimated by the lifecycle assessment approach, and to promote sustainable development.  

To be eligible under ICAO’s CORSIA, SAF needs to meet the following overarching goals across its supply chain:  

  1. Reduce greenhouse gas emissions compared to fossil jet fuel on a lifecycle basis. The criteria ensures that SAF provides meaningful emissions reductions, counted across the full lifecycle of the fuel from feedstock to flight, and including key indirect environmental effects such as indirect land use change. The 10% minimum emissions reduction required by ICAO might appear disappointing at first sight, but it should be noted that—in its current shape—it is only intended as a safeguard to ensure that any emission reduction claim in CORSIA is backed up with real emissions reductions that go beyond the uncertainties associated to the lifecycle assessment methodology. Independently, only SAF that delivers large emissions reductions makes sense economically and environmentally speaking, which means that SAF with large land use change emissions is tacitly disqualified as a viable production pathway. That’s the magic of assessing SAF on a lifecycle basis including indirect land use change emissions. 
  2. Protect ecosystems and natural resources. The robust set of sustainability criteria also includes environmental safeguards against negative environmental effects that are not captured by the lifecycle emissions assessment—defending water quality, soil health, air qualitybiodiversity and conservation values. 
  3. Present no risks to human rights, food security, or local economies. Ensuring that SAF feedstock production does not present social risks, ICAO prioritized the inclusion of human and labor rights, land use rights and water use rights for local and indigenous communities. 
  4. Promote the achievement of the UN Sustainable Development Goals. As a United Nations body, the ICAO championed these sustainability criteria aiming for SAF to contribute to the achievement of UN Sustainable Development Goals (SDGs), including eliminating poverty and promoting food security.  

What’s in the SAF sustainability criteria?  

The criteria cover 12 themes that encompass the three pillars of sustainability: social, environmental, economic. Provisions pertain to emissions reductions, carbon hotspots, water, soil, air, conservation, waste and chemicals, human and labor rights, land use rights and land use, water use rights, local and social development, and food security. For each theme, a principle a set of criteria are outlined. The criteria capture the binding provisions.  

To be eligible under ICAO’s CORSIA to generate emissions reductions for compliance purposes, SAF must meet the following criteria: 

Theme Principle Criteria 
1.  Greenhouse Gases (GHG) Principle: Sustainable Alternative Jet fuel should generate lower carbon emissions than conventional kerosene on a life cycle basis. Criterion 1: Sustainable alternative jet fuel shall achieve net greenhouse gas emissions of at least 10% compared to fossil jet fuel on a life cycle basis. 
2. Carbon stock 

  

Principle: Sustainable alternative jet fuel should not be made from biomass obtained from land with high carbon stock. Criterion 1: Sustainable alternative jet fuel shall not be made from biomass obtained from land converted after 1 January 2008 that was primary forests, wetlands, or peat lands and/or contributors to degradation of the carbon stock in primary forests, wetlands, or peat lands as these lands all have high carbon stocks. 
Criterion 2: In the event of land use conversion after 1 January 2008, as defined based on IPCC land categories, direct land use charge (DLUC) emissions shall be calculated. If DLUC greenhouse gas emissions exceed the default induced land use change (ILUC) value, the DLUC value shall replace the default ILUC value. 
 3. Water Principle: Production of sustainable alternative jet fuel should maintain or enhance water quality and availability. Criterion 1: Operational practices shall be implemented to maintain or enhance water quality. 
Criterion 2: Operational practices shall be implemented to use water efficiently and to avoid the depletion of surface or groundwater resources beyond replenishment capacities. 
 4. Soil Principle: Production of sustainable alternative jet fuel should maintain or enhance soil health. Criterion 1: Agricultural and forestry best management practices for feedstock production or residue collection shall be implemented to maintain or enhance soil health, such as physical, chemical and biological conditions. 
5. Air  Principle: Production of sustainable alternative jet fuel should minimize negative effects on air quality. Criterion 1: Air pollution emissions shall be limited. 
6. Conservation Principle: Production of sustainable alternative jet fuel should maintain or enhance biodiversity, conservation and ecosystem services. Criterion 1: Sustainable alternative jet fuel shall not be made from biomass obtained from areas that are protected for their biodiversity, conservation value, or ecosystems services, unless evidence is provided that shows the activity does not interfere with the protection purposes.
Criterion 2: Low invasive-risk feedstock shall be selected for cultivation and appropriate controls shall be adopted with the intention of preventing the uncontrolled spear of cultivated non-native species and modified microorganisms. 
Criterion 3: Operational practices shall be implemented to avoid adverse effects on areas that are protected for their biodiversity, conservation value, or ecosystem services. 
7. Waste and Chemicals Principle: Production of sustainable alternative jet fuel should promote responsible management of waste and use of chemicals. Criterion 1: Operational practices shall be implemented to ensure that waste arising from production processes as well as chemicals used are stored, handled and disposed of responsibly. 
Criterion 2: Operational practices shall be implemented to limit or reduce pesticide use. 
8. Human and labour rights Principle: Production of sustainable alternative jet fuel should respect human and labour rights. Criterion 1: Sustainable alternative jet fuel production shall respect human and labour rights. 
9. Land use rights and land use Principle: Production of sustainable alternative jet fuel should respect land rights and land use rights including indigenous and/or customary rights. Criterion 1: Sustainable alternative jet fuel production shall respect existing land rights and land use rights including indigenous people’s rights, both formal and informal. 
10. Water use rights Principle: Production of sustainable alternative jet fuel should respect prior formal or customary water use rights. Criterion 1: Sustainable alternative jet fuel production shall respect the existing water use rights of local and indigenous communities. 
11. Local and social development Principle: Production of sustainable alternative jet fuel should contribute to social and economic development in regions of poverty. Criterion 1: Sustainable alternative jet fuel production shall strive to, in regions of poverty, improve the socioeconomic conditions of the communities affected by the operations. 
12. Food security Principle: Production of sustainable alternative jet fuel should promote food security in food insecure regions. Criterion 1: Sustainable alternative jet fuel production shall, in food insecure regions, strive to enhance the local food security of directly affected stakeholders. 

Figure:  Sustainability Themes, Principles and Criteria recommended by ICAO’s Committee on Aviation Environmental Protection at its 2017 Steering group Meeting. The version eventually adopted by Council contains some enhancements but does not change fundamentally. The new version will be publicly released soon as an amendment to the ICAO CORSIA Document with the Sustainability Criteria.

How are  SAF sustainability criteria implemented?  

The ICAO sustainability framework works as an umbrella standard that relies on ICAO-approved independent Sustainability Certification Schemes (SCS) for its implementation.  These organizations define the sustainability certification requirements including the indicators and metrics to evaluate compliance with the criteria, set the requirements for certification bodies, auditors and accreditation bodies, and monitor the effectiveness of the assurance system. To become ICAO-approved SCS must undergo a thorough evaluation process and meet a comprehensive set of requirements in line with ICAO’s eligibility framework 

In conclusion, the newly adopted sustainability criteria take a robust and equitable approach, placing environmental and social safeguards on the production of SAF across its entire supply chain. It also provides a harmonized approach to ensure that airlines across the world strive for these same values of climate ambition, environmental integrity, human rights, and social equity.  

This new set of sustainability criteria and the broader sustainability frameworkare designed to ensure the future of flight allows travelers to see new horizons, connect with other cultures, visit faraway loved ones and collaborate internationally – while doing less harm to our climate, and respecting our environment, and local and indigenous communities.  As more countries, airlines, and fuel producers adopt and adhere to this robust criteria, the faster we can reach our destination of a net-zero emissions flight by 2050.  

Also posted in International, Policy, United Nations / Read 1 Response

UN aviation agency has an opportunity to bolster sustainable flight by adopting critical fuels criteria

This blog post was authored by Pedro Piris-Cabezas, Director of Sustainable International Transport & Lead Senior Economist at Environmental Defense Fund, and Anna Stratton, Consultant

ICAO building, Montreal

This month, the International Civil Aviation Organization, the United Nation’s aviation agency, is holding its 222nd Council meeting. On the agenda: an opportunity for ICAO Council to signal its commitment to a sustainable future for aviation by adopting an expanded set of sustainability criteria for sustainable aviation fuel (SAF).

SAF provides a distinct opportunity to put aviation on a pathway to net-zero climate impact by 2050, provided the SAF deployed actually reduces emissions, meets a high standard of environmental integrity, and is accurately accounted for. In 2017, ICAO’s Committee on Aviation Environmental Protection (CAEP) recommended a set of sustainability criteria to the Council, which adopted a portion of the criteria for its emission reduction program and delayed a decision on the rest. Environmental NGOs have called on members of the Council, who are 36 elected members from ICAO’s 193 Member States, to adopt CAEP’s full set of recommendations ever since.

ICAO’s emissions reduction program, the Carbon Offsetting and Reduction Scheme for International Aviation, or CORSIA, includes a comprehensive SAF framework. CORSIA’s design incentivizes the deployment of SAF that supports decarbonization. If ICAO Council adopts the full set of sustainability criteria recommended by CAEP, it will further strengthen the CORSIA SAF framework and help ensure that CORSIA SAF (1) promotes rather than undermines the achievement of the UN Sustainable Development Goals and (2) mitigates the emissions, ecosystem and community risks otherwise present in alternative fuel production and use.

EDF is a member of the International Coalition for Sustainable Aviation (ICSA), the group of environmental NGOs with observer status at ICAO. ICSA sent a letter to all Council Members calling for the adoption of the sustainability criteria as originally recommended by CAEP. In ICSA’s view, not only does the full set of criteria provide clear environmental benefits, adopting the criteria now will provide much needed certainty to SAF producers, as they make investments in the sustainability of their supply chains. Postponing the adoption of the sustainability criteria poses the risk of delaying investments in SAF production capacity, the scale-up of which is critical to the decarbonization of civil aviation.

What’s in the sustainability criteria?

Read More »

Also posted in United Nations / Comments are closed

CORSIA: No, the ICAO Council can’t legally change CORSIA’s rules

ICAO building, Montreal

In March 2020 the International Air Transport Association (IATA) wrote to the 36-member Governing Council of the International Civil Aviation Organization (ICAO) requesting that the Council re-write the rules of ICAO’s flagship Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA). CORSIA requires airlines to offset their carbon emissions above the average of 2019-2020 emissions.

Citing the unexpectedly low aviation emissions due to the tragedy of the COVID-19 pandemic, which could result in an increase in offset obligations at such time as air travel emissions increase above this average level, IATA wants the ICAO Council to change the emissions baseline to 2019 only. They argue that implementing CORSIA with the 2019-2020 emissions baseline, as originally written, would impose an “inappropriate economic burden on international aviation.”

The request is ironic: In an effort to lure back customers, airlines are publicly touting their commitments to reducing emissions – including to carbon offsetting. But behind the closed doors of the ICAO Council, they’re pushing a re-write that would give them a free pass to escape offsetting requirements for three to five years or more, according to analyses by EDF and other experts.

The request for a hasty re-write raises an important legal question. Does the ICAO Council have the legal authority to change a decision of the ICAO Assembly? It appears that while the Council could, at the current session, recommend that the ICAO Assembly change the baseline, ICAO’s Council lacks the legal authority to undertake this change itself. Below we review (a) the legal authority of the Assembly; (b) the legal authority of the Council; and (c) the legal character of the CORSIA baseline and Council’s authority in light of that legal character.

Read More »

Also posted in Carbon Markets, United Nations / Comments are closed

CORSIA: 5 reasons why the ICAO Council shouldn’t move now to rewrite the rules of its aviation climate program

Airplane, jumbojet on runway preparing for takeoff at sunset at the airport. iStock

The International Civil Aviation Organization’s (ICAO) Council is meeting through June 26, and Council members have been asked to make a decision at this session that could undermine the agency’s flagship climate program.

ICAO’s Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) requires airlines to offset emissions above a baseline set at the average of 2019-2020 emissions. However, the International Air Transport Association has asked the ICAO Council to change the baseline to reflect only 2019 emissions, citing the unexpectedly low aviation emissions in 2020 due to COVID-19 and concomitant potentially greater offset requirements for the industry.

Airlines have taken a massive hit due to the pandemic. They argue that they need to escape CORSIA requirements to save money. But hastily rewriting the fundamental structure of the industry’s market-based program to address airline carbon emissions would be penny-wise and future-foolish. Even as airlines are publicly touting their commitment to “sustainability measures like carbon offsetting,” the rule rewrite they are seeking behind the closed doors of the Council would give them a free pass to pollute with no offsetting requirements for three to five years or more, according to analyses by Environmental Defense Fund and other experts.

EDF is calling on the ICAO Council not to move now to change the rules of CORSIA. Deciding, at this Council session, to change the baseline year for CORSIA to 2019-only:

Read More »

Also posted in Carbon Markets, News, United Nations / Comments are closed

CORSIA: Industry-sought rule change threatens aviation climate program

https://www.pexels.com/photo/silhouette-of-airplane-during-sunset-99567/

Silhouette of Airplane during Sunset. Pixels.com

The coronavirus pandemic has created a global health and economic crisis that has affected families all over the world and nearly all industries, with aviation taking a particularly steep toll.

Airlines may feel under pressure to save money at any cost, but hastily rewriting the fundamental structure of the industry’s flagship market-based program to address airline carbon emissions would be penny-wise and future-foolish.

In a new analysis by Environmental Defense Fund, we look at the implications of a rule rewrite sought by the International Air Transport Association (IATA) to the Carbon Offsetting and Reduction Scheme for International Aviation, or CORSIA.

Read More »

Also posted in Carbon Markets, International, United Nations / Comments are closed

California’s experience with buyer liability shows how aviation can help ensure environmental integrity

https://www.flickr.com/photos/140970794@N06/30345941512

Airplane flying at sunset. Adam Clark, Flickr

The International Civil Aviation Organization is preparing to stand up its market-based emissions reduction program, the Carbon Offsetting and Reduction Scheme for International Aviation, or CORSIA. As it does so, ICAO must maintain CORSIA’s environmental integrity.

To that end, airlines should not be allowed to count, for CORSIA compliance, carbon credits that have been found to be invalid, e.g., fraudulently issued or otherwise not meeting CORSIA’s standards for credit quality. To ensure that all credits represent actual emission reductions, such substandard credits should be invalidated – even if the fraud isn’t exposed until after airlines have canceled the credits in CORSIA. The emissions for which the credits had been tendered have occurred, and still need to be covered by valid reductions in order to meet CORSIA’s promise of “carbon neutral growth.”

California offers one approach to how CORSIA can do this. In its market-based climate program, California has developed a way to cover the emissions from invalidated credits to uphold the integrity of its program and encourage emitters to invest only in high-integrity offsets. It’s known as “buyer liability,” which means that if the California Air Resources Board (CARB), the regulatory body, invalidates offset credits, then those who purchased the credits for compliance with California’s emissions limit must replace the invalidated credits. This ensures that emitters meet their full compliance obligations and that they are more diligent in selecting offsets.

Early on, California’s buyer liability approach caused some uncertainty among offset project developers. But seven years of experience demonstrates that buyer liability has worked in California’s carbon market. Here’s how we know:

Read More »

Also posted in California, Carbon Markets / Comments are closed