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Carbon Market Watch’s input to ICAO public consultation on greenhouse gas programs

The International Civil Aviation Organisation (ICAO) invited greenhouse gas programmes (i.e. standards) to apply for assessment against the CORSIA Emissions Unit Criteria (EUC) by the Technical Advisory Body of ICAO. 14 organisations responded to the call. The public was invited to submit comments on the responses to the call for applications, including regarding their alignment with the EUC. 

Carbon Market Watch’s response can be downloaded below. Key findings include:

  • Several programmes do not have appropriate safeguards in place to prevent social and environmental harms or to ensure that projects monitor their contribution towards sustainable development objectives.
  • Currently, no program complies with criteria to avoid double-counting of climate efforts, given the absence of an international agreement on the avoidance of double claiming inter alia for Emission Reductions (ERs) claimed under CORSIA and a country’s Nationally Determined Contribution as communicated to the UNFCCC. All programmes should implement the Guidelines on Avoiding Double Counting for CORSIA, and we recommend that TAB members use these guidelines to evaluate programmes’ progress towards successfully complying with the avoidance of double claiming requirements.
  • Only programmes which meet the EUC today should be eligible for CORSIA. Many applicants have communicated their intent for future revisions to align with the criteria but this is not sufficient and opens the door for significant confusion and uncertainties.

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