As non-CO₂ emissions enter the regulatory spotlight, aircraft operators are now required to monitor and report their broader climate impacts. However, not all airlines face the same level of compliance complexity. If your airline qualifies as a Small Emitter, you may be eligible for a streamlined reporting path.
This article explains what defines a Small Emitter and how to leverage this status to reduce administrative burden while remaining fully compliant.
What Is a Small Emitter?
A Small Emitter is typically defined as an operator that emits below a certain threshold of CO₂ per year on flights within the regulatory scope (usually within or departing from the European Economic Area). These thresholds are based only on emissions from flights covered by the MRV regulation—not your entire global network.
If your total annual emissions fall below the defined threshold, you may use the simplified Method D for monitoring non-CO₂ effects.
What Is Method D?
Method D is the Climatological Approach designed specifically for Small Emitters. It relies on:
- Pre-calculated, average emissions response surfaces based on altitude and route
- No need for real-time weather, trajectory, or aircraft-specific performance data
- A user-friendly, lower-cost option using tools like OpenAirClim
This approach simplifies your Monitoring Plan and reduces the burden on internal data teams and verifiers.
Advantages of Method D for Small Emitters
- Lower Data Requirements
No need to collect flight-specific weather, mass, or engine performance data. - Faster Setup
Quicker Monitoring Plan approval and less IT integration. - Cost-Efficient Verification
Simpler evidence packs and fewer audit triggers. - Regulatory Alignment
Fully compliant under EU non-CO₂ MRV rules for eligible emitters.
What You Still Need to Do
Even with simplified compliance, Small Emitters must still:
- Submit a Monitoring Plan that clearly states the use of Method D
- Identify Covered Flights within the regulated airspace
- Use Approved Tools like OpenAirClim or validated third-party software
- Maintain Records and prepare for basic verification procedures
Small Emitters should also monitor emissions over time. If your airline grows or takes on more covered routes, you may need to transition to Method C in a future reporting period.
How Vurdhaan Supports Small Emitters
Vurdhaan offers tailored support for Small Emitters navigating non-CO₂ MRV compliance. We help you unlock the benefits of simplified monitoring without risking regulatory missteps.
Our services include:
- Emissions threshold analysis and eligibility assessment
- Monitoring Plan development optimized for Method D
- Tool configuration and data preparation for OpenAirClim
- Verification support and streamlined evidence pack templates
- Transition planning in case you exceed the Small Emitter threshold
Whether you’re a regional carrier or a niche charter operator, Vurdhaan ensures your compliance is efficient, scalable, and low-risk.
Think you might qualify as a Small Emitter? Let Vurdhaan assess your eligibility and simplify your non-CO₂ compliance.