TECHNICAL ADVISORY BODY TAB RECOMMENDATIONS ON CORSIA ELIGIBLE EMISSIONS UNITS The following is an excerpt from the TAB Report of January 2020 4. TAB RECOMMENDATIONS FROM ITS FIRST ASSESSMENT At an inal briefing to the Council on the progress of the first TAB assessment October 2019, TAB Chairs explained that the TAB recommendations aim to answer some fundamental questions about eligibility decisions by the Council. These include a what are the general parameters of eligibility for all CORSIA Eligible Emissions Units and their programmes i.e. in which years can these units be created, and how long can operators use them What further actions should the programmes undertake see Section 4.1; b which programmes does TAB recommend for Council approval see Section 4.2; c what was necessary to agree in order to finalize recommendations see Section 4.3; and d what happens once the programmes have been approved How does ICAO know if something goes wrong see Section 4.4. 4.1 GENERAL ELIGIBILITY PARAMETERS 4.1.1 TAB recommends the general eligibility parameters in this section for approval by the Council. 4.1.2 TAB-recommended eligibility timeframe and unit date eligibility 14.1.2.1 The following parameters of unit date eligibility apply to all CORSIA Eligible Emissions Units that are approved by the ICAO Council for use in the CORSIA pilot phase a eligible for cancellation for use toward CORSIA offsetting requirements in the 2021-2023 compliance cycle hereafter eligibility timeframe; and b issued 1 to activities that started their first crediting period from 1 January 2016 2 ; and 2 in respect of emissions reductions that occurred through 31 December 2020 hereafter eligible unit date. 1 For the purposes of these recommendations, Vintage A40-19, paragraph 20 and Unit Date Annex 16, Volume IV, Appendix 5, Tables A5-7 and A5-8, field 5 have the same meaning. 2According to the crediting period start date specified at the time of registration. - 2 - 4.1.2.2 Extension of unit date eligibility. The dates in paragraph 4.1.2.1 above may only be extended to apply to eligibility timeframes beyond the CORSIA pilot phase, and/or eligible unit dates after 31 December 2020, subject to Council decision and TAB recommendations. TAB may recommend such an extension to the Council where TAB’s analysis identifies that an emissions unit programme is fully consistent with all of the EUC and guidelines when assessing the eligibility of emissions units with eligibility dates beyond 31 December 2020. 4.1.2.3 A summary of TAB’s discussions and analysis that ined these recommendations is in Section 5. 4.1.3 CORSIA Eligible Emissions Unit Programme-designated registries 4.1.3.1 Once determined by the Council to be eligible to supply CORSIA Eligible Emissions Units, each programme must provide for and implement its registry system to identify its CORSIA Eligible Emissions Units as defined in these general eligibility parameters, and its respective programme-specific eligibility parameters; and to enable the public identification of cancelled units that are used toward CORSIA offsetting requirements if the registry does not already feature this capability. This should be done consistent with the capabilities described by the programme in its communications with ICAO and the TAB, and any further requirements decided by the Council for CORSIA Eligible Emissions Unit Programme-designated Registries. 4.2 PROGRAMME RECOMMENDATIONS 4.2.1 Programmes recommended for immediate eligibility 4.2.1.1 TAB recommends that the following emissions unit programmes should be approved to supply CORSIA Eligible Emissions Units - American Carbon Registry see further details in Section 4.2.2 - China GHG Voluntary Emission Reduction Program see further details in section 4.2.3 - Clean Development Mechanism see further details in Section 4.2.4 - Climate Action Reserve see further details in Section 4.2.5 - The Gold Standard see further details in Section 4.2.6 - Verified Carbon Standard Program see further details in Section 4.2.7 4.2.1.2 The eligibility of the emissions units should be subject to the general eligibility parameters set out in Section 4.1 and any programme-specific parameters set out for each given programme, respectively, in Sections 4.2.2 to 4.2.7, which should be clearly described in the ICAO document titled “CORSIA Eligible Emissions Units” see also Section 4.4. - 3 - 4.2.2 American Carbon Registry ACR General findings 4.2.2.1 TAB found that ACR’s procedures, standards, and related governance arrangements that were in place and assessed by TAB in 2019 were fully consistent with all EUC, for emissions units generated under the programme prior to 1 January 2021. 4.2.2.2 TAB found that ACR demonstrated technical consistency with most, but not all, contents of the criterion Are only counted once towards a mitigation obligation. This common finding is further discussed in Section 4.3. It also ined on the general eligibility parameters in Section 4.1. TAB noted that ACR has made substantial progress toward putting in place measures to ensure that emissions reductions resulting from its activities are consistent with the EUC contents and guidelines pertaining to the avoidance of double-claiming, in the context of the Paris Agreement and decisions taken under the UNFCCC. Programme-specific eligibility parameters 4.2.2.3 Scope ACR ted for TAB’s assessment all activity types and scales, unit types, ologies, and procedural categories supported by ACR. TAB does not, at this time, recommend any exclusions from or limitations to the scope of the programmes eligibility beyond those set out in the general eligibility parameters in Section 4.1. 4.2.2.4 Further actions requested of the programme TAB recommends that the Council request ACR to update, or finalize updates to, programme procedures related to the guidelines for host country attestation, for TAB to assess in respect of future recommendations on the extension of the eligibility dates referred to in Section 4.1. This action does not need to be taken prior to describing the ACR in the ICAO document titled “CORSIA Eligible Emissions Units”. 4.2.3 China GHG Voluntary Emission Reduction Programme CCER General findings 4.2.3.1 TAB found that the CCER’s procedures, standards, and related governance arrangements that were in place and assessed by TAB in 2019 were consistent with the EUC, for emissions units generated under the programme prior to 1 January 2021. 4.2.3.2 TAB found that the CCER demonstrated technical consistency with some, but not all, contents of the criterion Carbon offset programmes must generate units that represent emissions reductions, avoidance, or removals that are additional. The CCER does not have procedures in place to ensure that emissions reductions credited by the programme “exceed any greenhouse gas reduction or removals required by law, regulation, or legally binding mandate”. TAB acknowledged that this finding was typical for programmes that were modelled after the CDM, at least in their initial stages. This finding is further discussed in Section 4.3. 4.2.3.3 TAB found that the CCER demonstrated technical consistency with some, but not all. contents of the criterion Are only counted once towards a mitigation obligation. This common finding is further discussed in Section 4.3. It also ined on the general eligibility parameters in Section 4.1. TAB noted that the programme representative, specifically, the Ministry of Ecology and Environment, Department of Climate Change, indicated its willingness to put in place the measures to ensure that emissions reductions resulting from its activities are consistent with the EUC contents and guidelines pertaining to the avoidance of double-claiming, in the context of the Paris Agreement and decisions taken under the UNFCCC. - 4 - Programme-specific eligibility parameters 4.2.3.4 Scope CCER ted for TAB’s assessment most, but not all, activity types and scales, unit types, ologies and procedural categories supported by the programme. The programme’s eligibility scope described in the ICAO document titled “CORSIA Eligible Emissions Units” should reflect the exclusions requested by the programme in its application , in Appendix B of its application submission, or otherwise conveyed to TAB. TAB does not, at this time, recommend any further exclusions from or limitations to the scope of the programmes eligibility beyond those set out in the general eligibility parameters in Section 4.1 and in these programme- specific eligibility parameters. 4.2.3.5 Further actions requested of the programme TAB recommends that the Council request CCER to update, or finalize updates to, programme procedures related to the guidelines for host country attestation, for TAB to assess in respect of future recommendations on the extension of the eligibility dates referred to in Section 4.1. This action does not need to be taken prior to describing the CCER in the ICAO document titled “CORSIA Eligible Emissions Units”. 4.2.4 Clean Development Mechanism CDM General findings 4.2.4.1 TAB assessed the CDM’s EUC-relevant procedures, standards, and related registry and governance arrangements, which were publicly available or communicated to ICAO by the CDM before and during TABs assessment. TAB found that the CDM’s programme elements that were in place and assessed by TAB in 2019 were consistent with the EUC, for emissions units generated under the programme prior to 1 January 1 2021. 4.2.4.2 TAB found that the CDM demonstrated technical consistency with some, but not all, contents of the criteria Safeguards System and Carbon offset credits must represent emissions reductions, avoidance, or carbon sequestration from projects that do no net harm. In TAB’s analysis across all programmes, it assessed social and environmental safeguards in place at the programme- level, consistent with the EUC. TAB noted that the CDM addresses environmental safeguards related to greenhouse gas emissions in programme procedures, whereas non-GHG environmental risks are addressed through other measures e.g., environmental impact assessments that are applied subject to expert judgement. Under the CDM, social safeguards are considered as a host Party prerogative not at the programme level. 4.2.4.3 TAB found that the CDM assigns to host Parties the responsibility to define sustainable development priorities in their respective national contexts, rather than defining Sustainable Development criteria at the programme level, in line with TAB’s interpretation of the criterion Sustainable Development Criteria, which is further described in Section 4.3. TAB found that the CDM offers host Parties a Voluntary Sustainable Development co-Benefits Tool enabling proponents to report their projects’ Sustainable Development co-benefits according to a list of co- benefits. TAB noted that, as of the time of TAB’s assessment, the tool had been used by 68 out of 7 817 registered projects and programmes since its 2014 launch. 4.2.4.4 TAB found that the CDM demonstrated technical consistency with some, but not all, contents of the criterion Carbon offset programmes must generate units that represent emissions reductions, avoidance, or removals that are additional. The CDM does not have procedures in place to ensure that the credited emissions reductions “exceed any greenhouse gas reduction or removals required by law, regulation, or legally binding mandate”. TAB acknowledged that this finding was also typical for programmes that were modelled after the CDM, at least in their early stages. This finding is further discussed in Section 4.3. - 5 - 4.2.4.5 TAB found that the CDM’s approach to temporary crediting, as a measure to compensate for the potential reversal of emissions reductions from afforestation or reforestation activities, is technically incompatible with the use of these units in CORSIA. TAB noted that units from this activity type must be explicitly excluded from the programmes eligibility scope. 4.2.4.6 TAB found that the CDM demonstrated technical consistency with some, but not all, contents of the criterion Are only counted once towards a mitigation obligation. This common finding is further discussed in Section 4.3. It also ined on the general eligibility parameters in Section 4.1. TAB noted that any future measures taken to ensure that emissions reductions resulting from the CDM’s activities will not be double-counted, will be decided by Parties in the context of Paris Agreement negotiations and decisions taken in the UNFCCC. Programme-specific eligibility parameters 4.2.4.7 Scope The programme’s eligibility scope described in the ICAO document titled “CORSIA Eligible Emissions Units” should reflect the exclusion of any type of emissions units issued from afforestation or reforestation activities under the CDM. TAB does not, at this time, recommend any further exclusions from or limitations to the programme’s scope of eligibility, beyond those set out in the general eligibility parameters in Section 4.1 and in these programme-specific eligibility parameters. 4.2.4.8 Eligible Emissions Unit Programme-designated registry The CDM registry, including its Voluntary Cancellation Plat interface, was found to be consistent with the EUC. TAB did not assess the consistency of any national registries that may contain emissions units from CDM activities. At this time, only the registry system referred to in this paragraph should be described in the ICAO document “CORSIA Eligible Emissions Units”. 4.2.4.9 Further actions requested of the programme TAB does not, at this time, recommend that the Council request the programme to take any further actions prior to being described in the ICAO document titled “CORSIA Eligible Emissions Units”. 4.2.5 Climate Action Reserve The Reserve General findings 4.2.5.1 TAB found that the Reserve’s procedures, standards, and related governance arrangements that were in place and assessed by TAB in 2019 were consistent with the EUC, for emissions units generated under the programme prior to 1 January 2021. 4.2.5.2 TAB found that the Reserve encourages its activities to report on their Sustainable Development contributions or co-benefits according to listed criteria, but does not require this use, in line with TAB’s interpretation of the criterion Sustainable Development Criteria, which is further described in Section 4.3. 4.2.5.3 TAB found that the Reserve demonstrated technical consistency with some, but not all, contents of the criterion Carbon offset credits must be quantified, monitored, reported, and verified. This criterion prohibits the eligibility of emissions units issued on a registry on an ex ante 3basis, which is allowed under the Reserve’s Climate Forward program. Noting this, the Reserve itself explicitly excluded from its application submission all units