CORSIA - FAQ for SCS Evaluation

Frequently Asked Questions for CORSIA SCS Evaluation

Questions

Answers

Introduction

Q28. What is the current status of utilizing Book and Claim frameworks for claiming under CORSIA?

As required by Paragraph 16 of the ICAO global framework on SAF, LCAF and other aviation cleaner energies, ICAO is undertaking, with technical contributions of CAEP, a study of fuel accounting systems for international aviation currently used in the open market. This study would include preliminary exploration of the so-called 'book and claim' concept to assess its relevancy and applicability, and taking into account relevant developments in other UN bodies, including the Article 6 of the Paris Agreement. The intent of the study would be to better understand these accounting systems and concepts and identify potential areas for further investigation. This work can help determine what, if any, role ICAO could have in supporting these systems to facilitate access to environmental benefits of SAF, LCAF and other aviation cleaner energies for international aviation and ensure environmental integrity, with a view to fostering without disincentivising the global production of such fuels, in particular in developing countries. Further details will be provided once this study is concluded.

CORSIA Sustainability Criteria Compliance

Q22. How frequently should Economic Operators be audited by an SCS for certification?
Answer:
Based on the ICAO document CORSIA Eligibility Framework and Requirements for Sustainability Certification Schemes, Table 5 Section 2 states that ‘the SCS requires that certification bodies being recognized within its CORSIA certification programme apply the audit objectives to meet CORSIA certification requirements’, and that subsequent audits following the initial audit should be performed on an annual basis. There are no further requirements for a greater frequency.

Q26. Can a single economic operator produce batches of material with different certified LCA values?

A given economic operator may have batch level changes in input material (e.g., feedstock) or process conditions. Therefore, certified LCA values may be different among different batches or sets of batches.

Q14. Is a State consulted when an SCS conducts its assessment in the State?

The ICAO document "CORSIA sustainability criteria for CORSIA eligible fuels" states that "Compliance with Themes 4 to 8 will be assessed by SCS […] and in accordance with the following procedure: "Prior to an SCS conducting an assessment in a State in which it never operated before, the SCS will consult with the competent authority of the State concerned […]. With a view to implementing this consultation process, Member States which require consultation will notify ICAO which competent authority should be contacted by the SCS".

As of January 2024, ICAO hasn't received any notification from any Member State on the competent authority that should be contacted by the SCS. The approved SCSs will be informed accordingly once such a notification is received by ICAO.

Q20. The CORSIA Sustainability Criteria document indicates that “Compliance with Themes 10, 11 and 12 can be demonstrated to the SCS by a national attestation from the State in whose territory the SAF is produced, without further assessment by the SCS.” a. Which national authorities would be appropriate to provide this attestation, and what requirements are there for format and/or information included? b. Does the language indicating the attestation “can be” used indicate there is another way to demonstrate compliance?

The economic operator would be responsible for acquiring the attestation from the State authority for the criterion in question (e.g., the associated ministry or department) should they follow that option.

There is no defined format nor set of information this attestation must include; this would be defined by the State.

The national attestation is one option for demonstrating compliance with Themes 10-12. If no attestation is provided, then the economic operator would be responsible for demonstrating compliance based on the SCSs requirements for such criteria, similarly to the other Sustainability Criteria. If not using the attestation option, the details of what is reviewed or considered compliant is delegated to the SCSs.

Q21. The CORSIA Sustainability document indicates that “Compliance with Themes 13 and 14 will be demonstrated to the SCS by the economic operator reporting to the SCS the actions being taken to meet the related criteria, without further judgement of those actions by the SCS”. Are there specific minimum requirements for what the economic operator should report?

The SCS is given no authority to review or judge the set of actions taken, and no detailed requirements have been provided. Therefore, there is no minimum requirement or format for what the economic operator provides. Whatever is provided is taken at face value as long as there is an indication of actions being taken to comply.

Q24. If a facility has two parallel fuel production streams, one of which is fossil and one of which is renewable/SAF, but the two material streams are never mixed, can the sustainability attributes of the renewable stream be assigned to the fossil products instead of the renewable products as long as the site-level mass balance of sustainable material is correct?

The ICAO Document “CORSIA Eligibility Framework and Requirements for Sustainability Certification Schemes” Table 3 Theme 1.1 on mass balance applies to mixtures of materials with different sustainability characteristics. Since the two streams are never mixed, the fossil stream cannot acquire the sustainability attributes of the renewable stream, even if the site mass balance is respected.

SCS Applications and Evaluation

Q23. For what period are SCSs approved once the ICAO Council approves them?

The SCSs approval by the ICAO Council is not associated with a specific period. However, the CAEP SCSEG is tasked to monitor the compliance of the SCS, and ensure SCS eligibility is re-assessed at least every five years. In addition, the SCSs submit proposed system changes to SCSEG for review. Based on this, SCSEG is tasked to make technical recommendations to Council to decide on the continuity of the SCSs being on the list of eligible SCS. There are currently no plans for an increased frequency for such reassessments.

Q5. What is the procedure and duration of the review process for SCS applicants?

The SCS applications are reviewed by the ICAO Sustainability Certification Scheme Evaluation Group (SCSEG), which provides its recommendations for SCS approval to ICAO Committee
for Aviation Environmental Protection for review, followed by submission to the ICAO Council for review and acceptance of recommendations. The SCS can expect that the approval process will take approximately six months from submission.

Q2. Is there a process by which the SCS may receive questions and/or input from ICAO during the application review process?

Yes, ICAO Secretariat will reach out to the applicant if questions arise and/or if minor changes are suggested to facilitate approval.

Q1. Can our certification program include sustainability requirements or thresholds that exceed the requirements currently included under CORSIA?

To receive approval, the SCS must have one option for CORSIA Eligible Fuel certification that requires only the currently approved CORSIA sustainability criteria and SCS eligibility
requirements. This option should be clearly named to indicate that it is sufficient for CORSIA eligibility.

If an SCS chooses to have a more stringent or comprehensive certification process that applies at least the ICAO-approved sustainability criteria as well as other principles/criteria, this is also permissible as long as it is clear that the additional criteria are voluntary and not required by CORSIA. This level of certification should be clearly named to indicate that it includes voluntary components beyond the CORSIA certification to differentiate it from the CORSIA eligibility requirements.

The two approaches should be presented equally without prejudice to the selection of the certification by the fuel producer.

Q6. The CORSIA Framework and Eligibility Requirements for SCS document includes Table 1 Requirement 9: “SCS uses an accreditation body complying with ISO 17011 to ensure that certification body requirements listed herein are implemented by the certification bodies.” A related requirement is in Table 5, Requirement 1: “SCS requires certification bodies to be accredited to ISO standard 17065 by an accreditation body operating in compliance with ISO 17011.” Does this requirement mean that the accreditation body must be a signatory member of the International Accreditation Forum Multilateral Recognition Agreement (IAF MLA)?

The accreditation body will comply with ISO 17011 requirements and this will be periodically audited externally by independent experts and/or peer reviewers to confirm compliance, identify shortcomings, and recommend corrective measures. Corrective measures will be implemented and documented. Independent auditing of compliance or membership in an organization that requires such compliance and review (e.g., IAF MLA, ISEAL) can be used to demonstrate that this criterion has been met.

Q3. Is an SCS required to recognize other ICAO-recognized SCS?

While SCSs are not required to recognize each other, a supply chain may use certifications from different SCSs for different economic operators as long as the appropriate information is passed through the chain of custody and each economic operator is certified by an approved SCS up to and including the blend point.

ICAO CORSIA Recognition of other Certifications

Q4. Does CORSIA recognize certification of fuels that has been performed under other existing regulatory programs (e.g., fuel producers certified under the European Union’s Renewable Energy Directive certification process)?

Fuels certified under other programs are not currently recognized/cross-certified under CORSIA.

Q25. Do ICAO Approved SCSs recognize each other’s certifications under CORSIA?

SCS CORSIA certificates are recognized among the ICAO approved SCSs, allowing different SCS certifications be used in a single supply chain, such as one SCS certifying feedstock and another SCS certifying the fuel producer.

Q27. Can a batch of CORSIA Eligible Fuels be certified as meeting the requirements of additional regulatory schemes (e.g., CORSIA and the European Union Emissions Trading Scheme (ETS))?

An SCS can certify an economic operator’s fuel batches to more than one regulatory scope (e.g., CORSIA and the ETS), allowing the producer more options for selling the fuel into different markets. However, for compliance purposes, claims can only be made under compatible regulatory schemes to avoid double claiming. Details of acceptable certification documentation, compatible schemes, and avoidance of double claiming can be found in the “Guidance On Verification Of Corsia Eligible Fuel Claims”, from the ICAO Environmental Technical Manual, Vol IV.

CORSIA Default LCA Values

Q10. In the CORSIA Default Life Cycle Emissions Values for CORSIA Eligible Fuels some default values are presented for pathways for which various “oils” are indicated as the feedstocks. However, the pathway descriptions in the supporting document indicate that the LCA begins with the oilseeds. Should “oilseeds” be considered instead?

Some references are made in the CORSIA documents to "oil" as fuel feedstock, but as the seeds are the starting point for the LCA calculations, it should be read as "oilseeds" An update to the documents is foreseen to clarify this information.

Q12. Is processing of wastes in preparation for conversion to fuels (e.g., rendering of tallow, cleaning/deodorizing of used cooking oil) included in the Core LCA system boundary?

The LCA system boundaries are defined to properly capture any relevant inputs of the process of fuel making. Therefore, if preprocessing of wastes and residues is needed to adjust the quality of the feedstock for the following process steps, all associated emissions must be included in the GHG LCA analysis.

Q9. Can the LCA default value for tallow be used for mixed fats or other fats?

Due to variation in water and other components (e.g., fatty acid content), and also differences in hydrogen requirements for the fuel production, the default values have been updated as of October 2024 to separate beef tallow, poultry fat, lard fat and mixed animal fat default values. However, because the type of fats were not originally specified, the original tallow value of 22.5 can be used for any of these fats or mixed fats through 31 December 2029 as indicated in the sixth edition of the CORSIA Default Life Cycle Emissions Values for CORSIA Eligible Fuels (October 2024). The new default values are specific as to the type of fats covered. The previous "Tallow" value can be used for mixed fats through the period of applicability indicated in the Default Values document. Other specific fats or mixed fats not including tallow would require request of a new default value.

Q11. Are plastics considered a feedstock to produce SAF under CORSIA?

As of today, plastics are not included in the list of wastes, residues or by-products approved by ICAO to produce SAF and claim emissions reductions under CORSIA. Under MSW, plastics will be considered as non-biogenic content.

Q13. For the MSW default values, what types of waste are considered to be included under MSW? Are construction and demolition wastes or industrial wastes included if they would be landfilled in the business-as-usual case?

The definition of waste is regulated by national laws. However, it should be noted that the LEC and REC methodology (particularly LEC) included under CORSIA currently is tailored to wastes that fall in the categories defined in the methodology, which are primarily materials that would come from household and municipal wastes, not construction/demolition wastes or industrial wastes.

Q15. How can new feedstocks be added to the queue for the generation of default values?

The application process for any feedstock to be considered for new default values is defined in the CORSIA Supporting Document “CORSIA Eligible Fuels – Life Cycle Assessment Methodology.” and can be submitted to caep [at] icao.int. Data must be provided in order for a pathway default value to be considered by ICAO. The more complete the data, the more quickly a default value can be considered and developed. The applicant should provide an explanation of why the feedstock is of high importance to be considered (e.g., significant GHG reductions and/or significant volumes likely to be made available) to aid ICAO is determining the priority of the feedstock for limited modelling/analysis resources.

Q16. Is low quality roundwood from a commercial harvest that is not acceptable to a sawmill due to size, etc., eligible to be considered a “forestry residue” under CORSIA’s wastes, by-products, and residues positive list?

Low quality roundwood is not part of precommercial thinning/forestry residues. If the economic operator wanted to seek positive list inclusion for this, a residue a case would need to be made that there are no incentives to artificially create additional low quality roundwood to be able to sell it to a SAF producer. In a previous case, this was done by showing that the potential selling price for the main product is higher than the feasible feedstock price for non-standard product, which indicates that there are no commercial incentives to label one as the other.

CORSIA Actual LCA Values

Q7. The ICAO document ‘CORSIA Methodology for Calculating Actual Life Cycle Emissions Values’ states that “The system boundary of the core LCA value calculation shall include the full supply chain of CEF production and use. As such, emissions associated with the following life cycle stages of the CEF supply chain must be accounted for: (1) production at source (e.g., feedstock cultivation); (2) conditioning at source (e.g., feedstock harvesting, collection, and recovery); (3) feedstock processing and extraction; (4) feedstock transportation to processing and fuel production facilities; (5) feedstock-to-fuel conversion processes; (6) fuel transportation and distribution to the blend point; (7) fuel transportation from the blending point to the aircraft uplift location; and (8) fuel combustion in an aircraft engine”.

What elements of the supply chain and aspects of feedstock collection should be accounted for when executing an actual greenhouse gas life cycle value calculation?

The same system boundary as used in the default LCA value calculations¹ must be used for any actual GHG LCA value calculated under CORSIA. The system boundary is defined in the CORSIA Supporting Document for each pathway, and the execution of the calculation must follow the methodology outlined in the CORSIA Methodology for Calculating Actual Life Cycle Emissions Values. An actual value is just a default with updated data from a real process; therefore, changing the system boundaries is not permitted.

¹Available in CORSIA Default Life Cycle Emissions Values for CORSIA Eligible Fuels

Q8. How should transportation emissions downstream of the blender be accounted for, considering that the LCA shall encompass the entire supply chain through to aircraft engine combustion?

The emissions associated to transportation downstream of the blender can be estimated by the economic operator (blender) according to the CORSIA Methodology for Calculating Actual Life Cycle Emissions Values or by the use of default values from the CORSIA supporting document on Life Cycle Assessment Methodology, both options being valid for the emissions accounting.

Q17. Can an economic operator purchase offsets/carbon credits to reduce their LCA value?

Purchasing offsets to reduce the LCA value of a CORSIA Eligible Fuel is not permitted under CORSIA. Offsets/purchased carbon credits are outside the system boundary for the CORSIA LCA. Offsets/purchased carbon credits are incorporated under CORSIA’s Emissions Units Credits rather than under CORSIA Eligible Fuels

Q18. When pursuing an actual value certification, can an economic operator mix and match default LCA elements (e.g., as indicated in the CORSIA LCA Supporting Document) with actual values for only specific LCA elements?

No, the Economic Operator must choose a default value or an entirely reassessed actual value. No mixing and matching is allowed with the exception of the transportation value downstream of the blending point per FAQ Question # 8.

Q29. Is it possible to certify SAF produced from an intermediate feedstock that is not itself on the CORSIA positive list for wastes, residues, and by-products, but for which the original raw material(s) (feedstocks) are listed? <<e.g. Renewable Natural Gas (RNG) from manure and MSW, using the Fischer-Tropsch pathway>>

The positive list is specifically for feedstocks, not intermediates. CEF produced exclusively from feedstocks on the positive list (regardless of intermediates) are assigned zero ILUC, and an actual value can be calculated.

CORSIA ILUC Values

Q19. Can the economic operator use the same ILUC value for both the ethanol to jet pathway ‘integrated conversion design’ and the ‘standalone conversion design’? Or would an adjustment of the ILUC value be necessary for application for ‘standalone conversion design’?

Work on default values for each of these is ongoing, but in the meantime, the ILUC value is acceptable for either version of the ETJ pathway (integrated or standalone).

Frequently Asked Questions for CORSIA SCS Evaluation

Questions

Introduction

CORSIA Sustainability Criteria Compliance

SCS Application and Evaluation

CORSIA Recognition of other Certifications

CORSIA Default LCA Values

CORSIA Actual LCA Values

CORSIA ILUC Values

Answers

Introduction

CORSIA Sustainability Criteria Compliance

SCS Applications and Evaluation

ICAO CORSIA Recognition of other Certifications

CORSIA Default LCA Values

CORSIA Actual LCA Values

CORSIA ILUC Values