As aviation regulators move beyond carbon dioxide, the introduction of non-CO₂ MRV (Monitoring, Reporting, and Verification) adds new complexity to emissions compliance. Aircraft operators must now account for additional climate effects like NOx, water vapour, contrails, and particulate matter—each requiring accurate data, specialized tools, and a robust verification process.
Here are the five most common mistakes operators make when implementing non-CO₂ MRV—and how to avoid them.
1. Ignoring Efficacy in CO₂e Calculations
The mistake: Some operators report Global Warming Potential (GWP) values without applying the required efficacy weighting.
Why it matters: Efficacy adjusts for the actual temperature impact of non-CO₂ effects, making your CO₂-equivalent (CO₂e) values scientifically and regulatorily accurate.
How to avoid it: Use models or tools that automatically apply efficacy factors, such as NEATS or approved alternatives, and clearly document these in your Monitoring Plan and evidence pack.
2. Using Non-Approved or Incomplete Tools
The mistake: Operators attempt to use in-house or third-party tools that lack formal approval or integration with NEATS.
Why it matters: Only tools reviewed and accepted by the regulatory authority can be used for compliance reporting. Non-compliant tools risk rejection during verification.
How to avoid it: Select platforms listed by the regulator or submit your tool for technical evaluation early. Always ensure compatibility with required data formats and model outputs.
3. Over-Reliance on Default Values
The mistake: Filling data gaps with conservative default values rather than actual flight or fuel data.
Why it matters: Defaults are intentionally pessimistic to ensure completeness. Overuse inflates emissions and may signal poor data governance to verifiers.
How to avoid it: Prioritize collecting primary data for key variables such as aircraft mass, fuel properties, and trajectory. This not only improves accuracy but also reduces over-reporting.
4. Inadequate Preparation for Verification
The mistake: Treating verification as a final-step formality instead of building verification-readiness into the process.
Why it matters: Verifiers require structured, traceable documentation across all modules—data sources, tool outputs, default justifications, and GWP assumptions.
How to avoid it: Start assembling your evidence pack during data collection. Include flight logs, fuel invoices, engine IDs, and tool validation records. Work with a Scope 12b-accredited verifier early.
5. Misclassifying as a Small Emitter
The mistake: Assuming eligibility for the simplified Method D without formally assessing total CO₂ emissions from covered flights.
Why it matters: If you’re over the emission threshold but using Method D, your monitoring approach will be rejected.
How to avoid it: Run emission estimates for all covered flights. If close to the threshold, build readiness for Method C and document your plan for transitioning.
How Vurdhaan Helps You Avoid These Mistakes
Vurdhaan is a trusted partner for aviation operators navigating non-CO₂ MRV complexities. We combine regulatory fluency, data science, and operational insight to help you avoid costly missteps.
Our support includes:
- GWP and efficacy validation checks
- Technical review and approval support for monitoring tools
- Data architecture to minimize reliance on defaults
- Evidence pack design for verification success
- Small Emitter assessments and transition planning
Whether you’re just starting your MRV journey or refining your systems, Vurdhaan ensures you’re accurate, auditable, and aligned with expectations.
Need an MRV health check or tool validation review? Get in touch with Vurdhaan to de-risk your compliance process.