Verified Carbon Standard (VCS) Program Recognition by the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) – Frequently Asked Questions
In March 2020, the Verified Carbon Standard (VCS) Program was accepted as one of the programs eligible to supply emission reduction units for compliance under the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA). We subsequently held two webinars to review the decision of the International Civil Aviation Organization (ICAO) Council and invited our stakeholders to bring their questions about this decision to the table. Below we capture the most commonly asked questions from the webinar and from other exchanges, as well as our responses.
The following VCS project and program types are currently accepted under CORSIA:
- Any non-Agriculture, Forestry, and Other Land Use (AFOLU) project;
- Standalone AFOLU projects applying one of the following methodologies:
- VM0012, Improved Forest Management in Temperate and Boreal Forests;
- VM0022 Quantifying N2O Emissions Reductions in Agricultural Crops through Nitrogen Fertilizer Rate Reduction;
- VM0026 Methodology for Sustainable Grassland Management (and VMD0040 Leakage from Displacement of Grazing Activities;
- VM0033 Methodology for Tidal Wetland and Seagrass Restoration;
- VM0036 Methodology for Rewetting Drained Temperate Peatlands;
- VM0041 Methodology for the Reduction of Enteric Methane Emissions from Ruminants through the Use of Feed Ingredients, v2.0
- VM0042 Methodology for Improved Agricultural Land Management, v1.0
- AFOLU projects that are nested within a Scenario 2 or 3 Jurisdictional and Nested REDD+ (JNR) program;
- Scenario 2 or 3 Jurisdictional and Nested REDD+ (JNR) Programs which elect a crediting period of at least 20 years.
Verra is seeking clarity from ICAO on some of the conditions placed on select project types (see below) and has high hopes of expanding eligibility as a result. Verra resubmitted its application on 10 April 2020 and expects decisions after the December ICAO Council meeting. The application specifically asks for approval of additional methodologies and clarity on nesting of projects in non-JNR jurisdictional programs (e.g., those inside Forest Carbon Partnership Facility (FCPF) programs); it also recommends that AFOLU projects follow a clear set of principles for eligibility that would be consistent across different geographies and activities under different programs.
Verra is hopeful more AFOLU activities will be eligible (both nested or standalone) in the future and is seeking clarification from ICAO on this. In particular, Verra proposed to assess eligibility of AFOLU activities based on the following principles, as opposed to relying on methodology-level approvals):
- Activities inside jurisdictional programs. Where REDD+ activities are clearly included in a jurisdictional program (i.e., avoided deforestation and degradation, and in some cases Afforestation, Reforestation and Revegetation (ARR), as well as other activities like Improved Forest Management (IFM)), they should be required to be nested within that program and should be allowed as nested activities under any jurisdictional program approved by CORSIA.
- Activities outside jurisdictional programs. Where activities remain outside jurisdictional REDD+ programs (e.g., typically blue carbon and agricultural/soil carbon activities, and in some cases other activities like ARR), these should be allowed as standalone projects.
Verra believes that relying on a set of principles will be a much better solution than the current approach of relying on methodology-level approvals. First, it would streamline the administrative process by obviating the need to have each methodology vetted by the Technical Advisory Board (TAB) and then the ICAO Council. Second, reliance on a set of principles will provide much more clarity to the market. Finally, it would ensure that decisions made by ICAO are consistent across programs, if such principles were implemented broadly.
The ICAO Council approved projects that began their first crediting period on or after 1 January 2016; this includes emission reductions and removals that will occur through 31 December 2020. Projects whose first crediting period started before 2016 are not eligible.
During CORSIA’s pilot phase (2021-2023), emission reductions achieved between 2016 and 2020 are eligible, and therefore VCUs from those vintages are eligible. We anticipate that in future phases, units from later years will be allowed (likely with a Corresponding Adjustment as an additional requirement).
Where VCUs are demonstrated to have met all relevant eligibility criteria, a “CORSIA label” will be applied to such VCUs and displayed on the Verra Registry to indicate eligibility for use in CORSIA. The CORSIA label will be searchable in a similar fashion to other credit-level additional certifications, such as VCU labels for Climate, Community & Biodiversity (CCB) Standards Program certification (i.e., the label will appear on the VCUs as opposed to at the project-level).
Verra envisions that there will be a need to further designate CORSIA-eligible VCUs based on differing eligibility criteria across future compliance cycles. Accordingly, the label for VCUs eligible for the pilot phase (2021 – 2023) will likely appear as “CORSIA-P” (as in, CORSIA Pilot phase); VCUs eligible for the first compliance cycle (2024 – 2026) would appear as “CORSIA-1”, and so on.
The guidance setting out the requirements for labeling VCUs with the CORSIA label can be found here. In addition, Verra is currently in the process of enabling the CORSIA label to be applied to VCUs on the Verra Registry platform and is aiming to have this functionality available as soon as possible.
As noted above, Scenario 2 or 3 JNR (version 1.0) Programs which elect a crediting period of at least 20 years are eligible under CORSIA. Verra is currently updating JNR and, as noted in our JNR consultation webinars, an updated version of JNR is expected to be released by the end of 2020. Because the majority of changes to JNR are structural and provide more guidance on nesting, we anticipate that future versions of JNR would be eligible under CORSIA. Nevertheless, we do anticipate needing to resubmit JNR given that the ICAO Office of Environment has noted that all material changes to programs will need to be-reassessed.
One of the CORSIA emissions unit criteria (EUC) requires projects to report on sustainable development contributions (e.g., “how projects contribute to achieving a country’s stated sustainable development priorities”). VCS project reporting templates currently require projects to describe how they contribute to achieving any nationally stated sustainable development priorities. ICAO has clarified that there could be an issue with this reporting instruction if the host country had not stated national sustainable development priorities.
Accordingly, Verra is now in the process of developing a standalone VCS Sustainable Development Contributions Report template which would allow projects to report on their contributions to the Sustainable Development Goals (SDGs). This report could be voluntarily completed by projects wishing to qualify their VCUs for use in CORSIA. The report could be used to cover historic verification periods in order to qualify already-verified monitoring periods. The report would not need to be assessed by a Verification/Validation Body (VVB). Verra’s understanding is that there is no minimum number of SDGs to which the project must contribute in order to meet the ICAO EUC.
Finally, note that ICAO clarified that projects that have applied the Climate, Community & Biodiversity (CCB) Standards or the Sustainable Development Verified Impact Standard (SD VISta) Program would automatically meet the sustainable development contribution EUC. Such projects would not need to complete a VCS Sustainable Development Contributions Report template.
Verra has also requested specific recognition of how the use of JNR satisfies this Sustainability Reporting Requirement (at the jurisdictional scale) through its existing rules on safeguards and benefits — as we noted in our application — which require compliance with the UNFCCC REDD+ environmental and social safeguards.
Verra resubmitted our application by the 10 April deadline for December ICAO Council decisions (view the resubmitted application here). In that submission we closed the gaps ICAO specifically requested (with respect to sustainable development contributions and the JNR crediting period, extending it to a minimum of 20 years for programs wishing to sell into the CORSIA market). Verra also requested clarifications on the conditions placed on select project types and suggested an alternative approach to assessing AFOLU activities (see questions #1 and #2.)
Under CORSIA, Corresponding Adjus
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