Carbon Market Watch inputs to the Article 6.4 Supervisory Body ahead of its 10th meeting: appeal and grievance processes

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Carbon Market Watch argues that the draft procedure for appeal and grievance processes under the Article 6.4 mechanism prioritizes limiting access over upholding human rights. The organization recommends a complete rewrite based on principles of accessibility and independence, specifically calling for the removal of all fees for marginalized groups, the expansion of eligibility for grievants to include indirect and potential harms, and the implementation of diverse submission channels beyond online forms to ensure inclusivity for Indigenous Peoples and local communities.

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  • Carbon Market Watch contends that the current draft procedure is flawed because it prioritizes "limiting access out of a fear of abuse of the mechanisms" instead of focusing on minimizing barriers to provide remedy and uphold human rights.
  • The organization recommends that the Supervisory Body conduct a structured consultation lasting at least one month with rightsholders and Indigenous Peoples and Local Communities (IPLCs) to ensure the grievance process is designed by and with its users.
  • Carbon Market Watch argues that the proposed reduced appeal fee of USD 2,500 remains a significant financial barrier and recommends that there be "no appeal fee" for Indigenous Peoples, local communities, non-profit organizations, or activities in least developed countries and small island developing States.
  • The document criticizes the eligibility requirements for filing grievances, stating that requiring residency or domicile and a "substantial presence" in the geographic area risks preventing marginalized groups from receiving support from more powerful actors, such as non-profit organizations.
  • Carbon Market Watch suggests broadening the scope of grievances to include "indirect and potential adverse effects," arguing that it is often difficult to establish a direct causal relation to harm and that grievances should be possible before harm occurs (ex-ante) rather than only after (ex-post).
  • The organization asserts that limiting grievance submissions to a website form is exclusionary and recommends multiple channels, such as WhatsApp, toll-free hotlines, email, and in-person meetings, similar to the Green Climate Fund’s Independent Redress Mechanism.
  • Regarding safety, the document argues that confidentiality should be the default rather than an option, and that the process must include retaliation safeguards such as risk assessments and secure communication channels.
  • Carbon Market Watch emphasizes that the mechanism must not be limited to English, as this creates an "insurmountable barrier" for those without translation funds; it recommends allowing all official UN languages and offering case-by-case translation services.

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APA
Carbon Market Watch (2024). Carbon Market Watch inputs to the Article 6.4 Supervisory Body ahead of its 10th meeting: appeal and grievance processes. https://carbonmarketwatch.org/wp-content/uploads/2024/02/02-2024-CMW-inputs-to-A6.4SB-on-the-appeal-and-grievance-processes.pdf
Chicago
Carbon Market Watch. Carbon Market Watch inputs to the Article 6.4 Supervisory Body ahead of its 10th meeting: appeal and grievance processes. 2024. https://carbonmarketwatch.org/wp-content/uploads/2024/02/02-2024-CMW-inputs-to-A6.4SB-on-the-appeal-and-grievance-processes.pdf.
Wikipedia
{{cite press release |author=Carbon Market Watch |title=Carbon Market Watch inputs to the Article 6.4 Supervisory Body ahead of its 10th meeting: appeal and grievance processes |date=15 February 2024 |url=https://carbonmarketwatch.org/wp-content/uploads/2024/02/02-2024-CMW-inputs-to-A6.4SB-on-the-appeal-and-grievance-processes.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
BibTeX
@misc{carbonmarketwatch2024carbon, author = {{Carbon Market Watch}}, title = {{Carbon Market Watch inputs to the Article 6.4 Supervisory Body ahead of its 10th meeting: appeal and grievance processes}}, publisher = {Carbon Market Watch}, year = {2024}, month = feb, url = {https://carbonmarketwatch.org/wp-content/uploads/2024/02/02-2024-CMW-inputs-to-A6.4SB-on-the-appeal-and-grievance-processes.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }

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