International Civil Aviation Organization Attn: Secretary General Dr. Fang Liu 999 University Street, H3C 5H7, Montreal, Quebec Canada. Dear Dr.

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1 International Civil Aviation Organization Attn: Secretary General Dr. Fang Liu 999 University Street, H3C 5H7, Montreal, Quec Canada Your ref AN 1/ /129 Our ref 16/795- Date 5 March 2018 ICAO State Letter 17/129 - Proposal for the First Edition of Annex 16, Volume IV, concerning Standards and Recommended Practices relating to the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) - reply from Norway Dear Dr. Liu, Norway welcomes the adoption of a Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) at the 39 th Session of the ICAO Assembly held from 27 Septemr to 7 Octor 2016, as an important and significant step in the right direction for the international aviation sector taking responsibility for its own emissions. General remarks Norway lieves a global market-based mechanism has an important role to play in line with the other elements of the ICAO Basket of Measures. However, progress made in the other elements will likely not enough to handle the significant growth of international aviation in the foreseeable future. Norway lieves the continuous progress on aircraft technology, operational improvements and sustainable alternative fuels are essential. Norway and its aviation industry take measures in all these areas, as reflected in the State Action Plan on CO2 emissions reduction activities submitted by Norway to ICAO (last update in August 2016). Moreover Norway takes measures together with the other memr States of the European Civil Aviation Conference (ECAC) and the memr States of the European Union as reflected in the State Action Plan. Postal address Postboks 8010 Dep 0030 Oslo postmottak@sd.dep.no Office address Akersg Telephone Org. nr Department Department of Civil Aviation, Postal Services and Telecommunications Reference Karl Koefoed

2 It could notably mentioned that the Norwegian government intends to introduce a jet biofuels blending mandate of 1 % from 2019, and has a goal of gradually increasing the blending mandate up to reach 30% by 2030, depending on the availability of sustainable jet biofuel, as well as technical opportunities. Moreover, the electric aircraft technologies are developing very fast. The Norwegian government wishes to encourage the development of aviation based on electricity. Electric aircrafts could notably interesting for use on the network for flights of relatively short distances tween regional airports in Norway with short runways. We are grateful for the opportunity to comment on the "CORSIA package", as we lieve the high environmental integrity of the CORSIA Package in its entirety is key. Despite the positive efforts made by the international aviation community through ICAO, the ambition of Carbon Neutral Growth by 2020 and the voluntary participation in CORSIA will not sufficient to achieve the Paris Agreement goals. Efforts to limit and then reduce the emissions from international civil aviation must further strengthened and accelerated consistent with the Paris Agreement goals. The three-year review foreseen by ICAO Assembly resolution A39-3 will an important milestone in this respect. Norway would in addition with respect to CORSIA like to underline the need to create a structure with clear accounting rules and creation of units, ensure transparency to avoid as much as possible of competitive distortions, and avoiding double counting. Norway would like to see a CORSIA Package with higher ambitions linked to the need to make sure that CORSIA delivers on its objectives. The quality of the eligible Emission Units used to offset aviation emissions, including their vintages and accounting, and the sustainability of alternative fuels claimed for emission reductions, are critical to CORSIA's environmental effectiveness, and uniform application are essential to the overall credibility of the scheme. Recalling the global agreement in the ICAO Council achieved at the 212th Council Session, as recorded in C-DEC 212/7 and circulated with State Letter AN 1/ /129, we like to underscore the importance of a Council decision in June 2018 that allows CORSIA to enter into force as planned. It is important to swiftly move towards the implementation of CORSIA and undertake the follow-up work that will remain to completed in due time. We are willing to contribute to a global compromise, but not with a lower environmental integrity than the State Letter proposal. In case of re-opening of the compromise, we are in favour of the modifications as proposed here low. Specific comments Emission units criteria - Status As we have pointed out throughout the process of developing CORSIA, Norway would certainly prefer and highlight as ing important that; the Annex 16 Volume IV; make direct reference to the CORSIA Emissions unit eligibility criteria, the list of CORSIA Eligible Page 2

3 Emission Units resulting from these criteria's application, and require their application for the implementation of the SARPs without any discretion or exception. This also to ensure a level playing field tween States and airline operators. Annex 16 Vol. IV Current text Proposed text Part II. Chapter 1. Administration, Note 2. The ICAO documents referred to in this Volume of Annex 16 and listed low are material approved by the Council for publication by ICAO to support this Volume and are essential to the implementation of the CORSIA. These documents are available on the ICAO CORSIA website and may only amended by the Council. The ICAO documents referred to in this Volume of Annex 16 and listed low are material approved by the Council for publication by ICAO to support this Volume and are essential to the implementation of the CORSIA. Their use is mandatory where this Volume of Annex 16 requires their application. These documents are available on the ICAO CORSIA website and may only amended by the Council. Quality offsets, avoidance of double counting, and vintage dates We would stress that the quality of the offsets are key and critical to CORSIA environmental integrity, credibility, effectiveness and uniform application. Only emission units fulfilling CORSIA Emissions Unit Eligibility Criteria as defined in the current draft implementation elements must eligible under CORSIA. The programs and projects should represent real, additional, permanent and verified reductions of greenhouse gases that are accounted for only once towards any climate mitigation or voluntary action. Regarding unit vintages, we are of the view that only emission units from projects with a start date after the entry into force of CORSIA, should admissible. The same must apply for UNFCCC credits. Annex 16 Vol. IV Current text Proposed text Part II. Chapter 4. Emission units, 4.2 Cancelling CORSIA Eligible Emissions Units, paragraph The aeroplane operator shall meet its offsetting requirements according to 3.4.4, as calculated by the State to which it is attributed, by cancelling CORSIA Eligible Emissions Units in a quantity equal to the sum of its final offsetting requirements for a given compliance period (i.e., FORc). The The aeroplane operator shall meet its offsetting requirements according to 3.4.4, as calculated by the State to which it is attributed, by cancelling CORSIA Eligible Emissions Units in a quantity equal to the sum of its final Page 3

4 CORSIA Eligible Emissions Units are only those units descrid in the ICAO document entitled CORSIA Eligible Emissions Units, which meet the CORSIA Emissions Unit Eligibility Criteria contained in the ICAO document entitled CORSIA Emissions Unit Eligibility Criteria. These ICAO documents are available on the ICAO CORSIA website. offsetting requirements for a given compliance period (i.e., FORc). The CORSIA Eligible Emissions Units shall represent real, additional, permanent and verified reductions of greenhouses gases, that are accounted for only once towards any climate mitigation obligation or voluntary action, and are generated from programmes and project types which started after 31 Decemr The CORSIA Eligible Emissions Units are only those units descrid in the ICAO document entitled CORSIA Eligible Emissions Units, which meet the CORSIA Emissions Unit Eligibility Criteria contained in the ICAO document entitled CORSIA Emissions Unit Eligibility Criteria. These ICAO documents are available on the ICAO CORSIA website. Sustainable aviation fuels Norway attaches great importance to the role sustainable aviation fuels can play in reducing emissions from the aviation sector. CORSIA can a tool to promote the use of sustainable aviation fuels. In accordance with ICAO 212th Council decision, CAEP should continue to review SARPs provisions relating to the use of Sustainable Aviation Fuels in the CAEP/11 and CAEP/12 cycles, with the objective of recommending enhanced sustainability criteria to the ICAO Council as soon as possible and, in any case, fore the end of the A clear signal should sent to markets so that only truly sustainable alternative fuels will developed. When the ICAO CORSIA sustainability criteria are complemented and updated, compliance of all sustainable aviation fuels with the additional criteria should required and certified from no later than the 1st January We lieve however that it is of utmost importance that applicable sustainability criteria take into account all aspects of sustainability, in compliance with the United Nations Sustainable Development Goals. This would include environmental, social and economic criteria. Concerning environmental criteria, a wider range of aspects must covered than the Page 4

5 aspects that are currently proposed. This would include water use, soil quality and biodiversity. Annex 16 Vol. IV Current text Proposed text Part I. Chapter 1. Definitions Sustainable aviation fuel. An aviation alternative fuel that meets the CORSIA Sustainability criteria under this Volume. Sustainable aviation fuel. An aviation alternative fuel that meets the CORSIA Sustainability Criteria as defined within the ICAO document entitled, "CORSIA Sustainability Criteria for Sustainable Aviation Fuels" that is available on the ICAO CORSIA website. Voluntary response form for States wishing to comment on the draft ICAO CORSIA implementation elements The text referred to above and published on the ICAO CORSIA website should read as follows. Proposed text for ICAO CORSIA Implementation Elements, section CORSIA Sustainability Criteria for Sustainable Aviation Fuels This ICAO document entitled, CORSIA Sustainability Criteria for Sustainable Aviation Fuels will include the criteria descrid in the table low. Themes Principles Criteria 1. Greenhouse Gases (GHG) Principle: Sustainable alternative jet fuel should generate lower carbon emissions than conventional kerosene on a life cycle basis. fuel shall achieve net greenhouse gas emissions reductions of at least 10% compared to fossil jet fuel on a life cycle basis. 2. Carbon stock Principle: Sustainable alternative jet fuel should not made from biomass obtained from land with high carbon stock. fuel shall not made from biomass obtained from land converted after 1 January 2008 that was primary forest, wetlands, or peat lands and/or contributes to degradation of the carbon stock in primary forests, wetlands, or peat lands as these lands all have high carbon stocks. Page 5

6 3. Water Principle: Production of sustainable alternative jet fuel should maintain or enhance water quality and availability. Criterion 2: In the event of land use conversion after 1 January 2008, as defined based on IPCC land categories, direct land use change (DLUC) emissions shall calculated. If DLUC greenhouse gas emissions exceed the default induced land use change (ILUC) value, the DLUC value shall replace the default ILUC value. Criterion 1: Operational practices shall implemented to maintain or enhance water quality. 4. Soil Principle: Production of sustainable alternative jet fuels should maintain or enhance soil health. Criterion 2: Operational practices shall implemented to use water efficiently and to avoid the depletion of surface or groundwater resources yond replenishment capacities. Criterion 1: Agricultural and forestry st management practices for feedstock production or residue collection shall 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 limited. 6. Conservation Principle: Production of sustainable alternative jet fuel should maintain or enhance biodiversity, conservation and ecosystem services. fuel shall not made from biomass obtained from areas that are protected for their biodiversity, conservation value, or ecosystem services unless evidence is Page 6

7 7. Waste and Chemicals 8. Human and labour rights 9. Land use rights and land use Principle: Production of sustainable alternative jet fuel should promote responsible management of waste and use of chemicals. Principle: Production of sustainable alternative jet fuel should respect human and labour rights. Principle: Production of sustainable alternative jet fuel should respect land rights and land use rights including indigenous and/or customary rights. provided that shows the activity does not interfere with the protection purposes. Criterion 2: Low invasive-risk feedstock shall selected for cultivation and appropriate controls shall adopted with the intention of preventing the uncontrolled spread of cultivated non-native species and modified microorganisms. Criterion 3: Operational practices shall implemented to avoid adverse effects on areas that are protected for their biodiversity, conservation value, or ecosystem services. Criterion 1: Operational practices shall 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 implemented to limit or reduce pesticide use. fuel production shall respect human and labour rights. fuel production shall respect existing land rights and land use rights including indigenous peoples rights, both formal and informal. Page 7

8 10. Water use rights Principle: Production of sustainable alternative jet fuel should respect prior formal or customary water use rights. 11. Local and social Principle: Production of sustainable development alternative jet fuel should contribute to social and economic development in regions of poverty. 12. Food security Principle: Production of sustainable alternative jet fuel should promote food security in food insecure regions. fuel production shall respect the existing water use rights of local and indigenous communities. fuel production shall, in regions of poverty, improve the socioeconomic conditions of the communities affected by the operation. fuel production shall, in food insecure regions, enhance the local food security of directly affected stakeholders. The sustainability criteria must enhanced as soon as possible and in any case by the end of the pilot phase to ensure that the production and use of alternative aviation fuels is sustainable on a large scale. In particular, Norway lieves that one should consider strengthening the threshold for emission reductions in criteria 1, ideally towards reaching 30%. Accept the assurances of my highest consideration, Øyvind Ek Deputy Director General This document is signed electronically and has therefore no handwritten signature Copy Ministry of Climate and Environment Civil Aviation Authority Norway Norwegian Environmental Agency Nordic delegation to ICAO Attachment Response Form - Norway Page 8