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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.