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The policy brief critiques CORSIA for focusing on offsetting growth above 2020 levels rather than reducing overall sector emissions. It highlights the risk of double counting since offsets are sourced from countries with Nationally Determined Contributions (NDCs) under the Paris Agreement. The author recommends that ICAO implement a 'negative list' for harmful project types and a public registry, while urging the UNFCCC to integrate aviation's efforts into the Global Stocktake and Facilitative Dialogue to ratchet ambition toward the 1.5°C goal.

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  • CORSIA is characterized as an insufficient environmental tool because it only compensates for emissions growth above 2020 levels, failing to reduce overall sector emissions or address the 781 million tonnes of CO2 emitted in 2015.
  • There is a significant risk of double counting because CORSIA credits are sourced from countries with NDCs under the Paris Agreement, necessitating a coordinated accounting approach between ICAO and the UNFCCC.
  • The document recommends that ICAO improve credit quality by limiting the eligibility of Clean Development Mechanism (CDM) credits to early action and establishing a 'negative list' to exclude harmful project types.
  • To ensure transparency, ICAO is urged to create a publicly available centralized registry to track emissions, credit use, and airline compliance, allowing external verification of offset obligations.
  • The UNFCCC should integrate aviation's climate efforts into the Global Stocktake (GST) and the Facilitative Dialogue (FD) to measure progress and increase the sector's ambition.
  • The author argues that the CDM should be phased out at the end of the second Kyoto Commitment Period and that the UNFCCC should provide specific guidance for NDC accounting regarding units transferred to CORSIA.

Cite the original document

APA
Carbon Market Watch (2017). Too big to fail? https://carbonmarketwatch.org/wp-content/uploads/2017/05/TOO-BIG-TO-FAIL_-UNFCCC-AND-ICAO-RESPONSIBILITIES-REGARDING-AVIATION’S-NEW-CARBON-MARKET-WEB-SINGLE-FINAL.pdf
Chicago
Carbon Market Watch. Too big to fail? 2017. https://carbonmarketwatch.org/wp-content/uploads/2017/05/TOO-BIG-TO-FAIL_-UNFCCC-AND-ICAO-RESPONSIBILITIES-REGARDING-AVIATION’S-NEW-CARBON-MARKET-WEB-SINGLE-FINAL.pdf.
Wikipedia
{{cite report |author=Carbon Market Watch |title=Too big to fail? |date=May 2017 |url=https://carbonmarketwatch.org/wp-content/uploads/2017/05/TOO-BIG-TO-FAIL_-UNFCCC-AND-ICAO-RESPONSIBILITIES-REGARDING-AVIATION’S-NEW-CARBON-MARKET-WEB-SINGLE-FINAL.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
BibTeX
@techreport{carbonmarketwatch2017too, author = {{Carbon Market Watch}}, title = {{Too big to fail?}}, institution = {Carbon Market Watch}, year = {2017}, month = may, url = {https://carbonmarketwatch.org/wp-content/uploads/2017/05/TOO-BIG-TO-FAIL_-UNFCCC-AND-ICAO-RESPONSIBILITIES-REGARDING-AVIATION’S-NEW-CARBON-MARKET-WEB-SINGLE-FINAL.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }

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