Draft Code of Best Practice for Carbon Offset Providers ...

Draft Code of Best Practice for Carbon Offset Providers: Accreditationrequirements and proceduresResponse of the Air Transport Users CouncilThe Air Transport Users Council is the UK’s passengers watchdog for air passengers.Air passengers are likely to be one of a number of groups of consumers who purchasecarbon offset credits.The AUC responded to the consultation on establishing a voluntary code of bestpractice for the provision of carbon offsetting to UK customers. In its response, theCouncil supported the Government’s proposal to establish a code because it wouldensure that offset providers deliver products against consistent and measurablecriteria. And it would enable passengers to make informed choices about whether topurchase offset products.The AUC now welcomes the publication of the draft code. This paper sets out theresponses of the AUC to those questions where it considers there to be a directpassenger interest.Q4 Should aviation emissions factors be applied to great circle distances,distance bands or by city pairs? Are there any alternatives to these and whatmight their merits be?A measure based on great circle distances would more accurately reflect theenvironmental impact of each flight. However, a system based on bands would havepractical advantages. It would be easier for passengers to understand and it wouldmean passengers would know the cost of offsetting their flight before entering thebooking process. In addition, a bands system based on set amounts would potentiallybe easier for offset providers to administer, and for the accreditation body to manage.Q5 We are of the opinion that additional emissions factors may be proposed forsurface transport, air transport and individual electricity suppliers (based onfuel mix). Do you agree with this approach? Are there any other areas wherebespoke emissions factors might be applied?Yes. The environmental impact of different airlines varies considerably according tofactors such as the fuel efficiency of the aircraft fleets of each airline. The amountpassengers pay to offset their flights should reflect, as accurately as possible, theenvironmental impact of the particular flight they take.

2Q7 Is 6 months + five days an appropriate timescale for purchasing andcancelling allowances? If not, why not, and what timescales would beappropriate?The Council acknowledges that practical considerations might make a shortertimescale for purchasing and cancelling allowances untenable; if so, it would not wantoffset providers to be unduly discouraged from providing offsets.Q10 At what point during the purchasing process should transparent pricinginformation be displayed?Transparent pricing information should be displayed at the point during the processdirectly before the consumer makes a commitment to purchasing the offset.Q11 When should any such confirmation be sent, bearing in mind therequirement to purchase allowances within 6 months of the offset purchase?The Council notes that the code does not appear to include a requirement for offsetproviders to provide consumers with written confirmation of purchase. In the airlinecontext, the AUC would expect airlines to include written confirmation of purchase aspart of the confirmation process for the purchase of tickets and any other services.Q12 Are these appropriate conditions of use for the quality mark? If not howcould this be changed?Yes, the conditions appear appropriate for promoting accredited offsets to consumersand helping passengers to distinguish between accredited and non-accredited offsets.Q13 Is it reasonable to request an accredited offset provider to make thisinformation available?Yes, the evidence is required in order to ensure that the Accreditation Body is in aposition to do all it can to protect consumers against rogue traders.Air Transport Users Council (AUC)CAA House45-59 KingswayLondonWC2B 6TE18 th March 2008