Here is the cover letter for my public comment on the International Civil Aviation Organization (ICAO) offsetting scheme, called CORSIA. The UN agency has received 14 proposals for offsetting programs, and seeks public comment on whether they satisfy evaluation criteria. Perhaps the most difficult criterion, which the proposals I read do not meet, is the additionality criterion. I first heard about the open comment period yesterday.

Dear ICAO:

Here attached are my public comments on the first 5 of the 14 offset proposals (ordered alphabetically). Insufficient time was provided in the public comment period for me to read the remaining proposals.

The due date for comments is Sep. 5, and the first notice I can find announcing the open comment period, anywhere on the internet, is Sep 3. Because the ICAO website does not give an opening date for the comment period, and the ICAO Twitter feed does not contain any announcement of the comment period, I can find no evidence that this comment period was longer than 2 days. Clearly, this is not proper procedure.

Overall, the approach to additionality is not credible. Every sector of society is rapidly paying more attention to the climate crisis. Across the board, the baselines used in these proposals take insufficient account of future actions by external actors (outside of the offset scheme) that will simultaneously be seeking to affect emissions.

To give just one example, suppose an offset program funds fuel-efficient wood stoves to replace open cooking fires in a low-income country. The proposed “additionality” certification states that, in the absence of the offset program, households would continue to cook on open fires. The full emissions reduction from the change to new stoves is credited to the offset program as “additional.” But this is not plausible. In a time of climate crisis, countries around the world are rapidly expanding electrification, and the electric grid in turn is relying more on renewables. Rural people in low-income countries are moving by the millions to cities, where they are more likely to have electricity. To assume the households would all continue using cooking fires is not plausible. So the offset scheme gets credit for far more emissions reduction than was in fact achieved.

This problem is pervasive in the proposals I read today.

Here are my comments in the format of your official rubric, on just 5 proposals, but but my public comment greatly understates the deep emptiness of this offsets approach.

What really is needed from ICAO and CORSIA is actual emissions reductions within the aviation sector. It is a travesty that ICAO only provides overall goals for emissions “net” of offsets, and will not state goals for actual emissions reduction in the aviation sector.

Sincerely,

Parke Wilde

Among the 14 proposals, the Clean Development Mechanism (CDM) sent what appears to be a cover letter. I could not find any proposal in the required format. The cover letter did not mention the additionality criterion, as far as I could tell. The CDM’s ability to deliver additionality has been criticized in the past: How Additional is the Clean Development Mechanism?