Climate Change

Halting the implementation of large dams in the Americas

In times of climate change, we must respect nature

(Column originally published in El País) We are living now with the realities of climate change; to act otherwise would be ignorant and irresponsible. But, in case we forget, nature will surely remind us.  Over the last months, severe landslides have devastated communities in Peru and Colombia. Together, they left more than 500 people dead, dozens missing, and more than 100,000 victims. Tragedies like these have some things in common: they occurred in cities and regions with high rates of deforestation and changes in land use; in both areas there was evidence of poor planning and regulation. Effectively, these disasters were foreshadowed. They make clear once again the vital need to care for our forests and riverbanks, and to avoid deforestation and erosion. Climate change means hard rains, fires, and hurricanes will become increasingly frequent and more intense. In Mocoa, Colombia, the equivalent of 10 days of rain fell in just one night, causing flash flooding that devastated much of the small town. In many cases, nature is only taken into account after tragedy strikes. But nature, when well cared for, can literally save lives. In Mocoa, a native forest helped protect one neighborhood from being washed away. That’s why environmental protection must be taken seriously, and any exploitation of natural resources must be well planned and sensible. Yet in Latin America, there remains a regional tendency towards unregulated extractivism. Over the last few years, governments across the region have been weakening environmental regulations in the name of development. Meanwhile, year after year, hundreds of people in Latin America and the Caribbean—especially children and others in vulnerable situations—die from events associated with droughts and floods. Activists, movements, mayors, and others seeking to protect land and water from extractive activities are frequently criticized, even criminalized and attacked. In the small Andean town of Cajamarca, Colombia, 98 percent of voters recently chose to ban all mining in their territory. It’s a decision that has sparked national controversy. Critics of the referendum have questioned whether the results are mandatory, despite the fact that Colombian law clearly states, “the decision of the people is mandatory.” Through their popular vote, the people of Cajamarca reminded their government of its commitment to protect their water and natural resources. Communities in Guatemala, Honduras, Costa Rica, Peru, and El Salvador have done the same. While some extraction is necessary in modern society, there must be a healthy balance. Not every project is safe, and alternative development models must be embraced and explored. It’s time to incorporate the environment into public policy and development, once and for all. Two Latin American nations have shown what is possible. In 2011, Costa Rica banned all open-pit metal mining. In March, El Salvador did the same. In both cases it’s a big yet viable change, because alternatives exist and it’s understood that protecting land and water is necessary to secure a healthy future. El Salvador has the second-highest rates of deforestation and environmental degradation, which has led to severe water scarcity. This is why the ban on metal mining passed there. It was no favor to environmentalists; it was based on years of sound analysis. Social and economic studies of the proposal concluded that the best thing for the country was to care for and restore its remaining forests and water sources. The decision prioritized environmental restoration—particularly its social and economic benefits—above the perceived benefits of mining. Environmental degradation is not a problem that exists in a vacuum. That’s why States have signed treaties and other international instruments that recognize their obligation to protect the environment. The Paris Agreement on Climate Change, signed by 34 of 35 States on the American continent, is the most recent. Now, more than ever, these commitments must be honored and fulfilled. Not all extractive projects are viable. Determining their worth must involve sound planning, coupled with policies and legal frameworks that are strong and effective. Environmental Impact Studies must be done carefully, objectively, and independently. Decisions should consider short- and long-term impacts on both local and national levels. We are living now with the realities of climate change; to act otherwise would be ignorant and irresponsible. But, in case we forget, nature will surely remind us. 

The ocean needs more from us

For decades, the ocean has protected us from the impacts of climate change, absorbing 90 percent of the excess heat produced by global warming. It’s given us food and the genetic resources we use to produce life-saving drugs. As if that weren’t enough, it’s enabled millions of families to thrive in an economy based on its bounty. Despite its importance, the ocean remains unprotected in large part; no country governs the high seas, international waters that comprise 64 percent of the ocean’s total surface area.  Management measures have given rise to a patchwork of uncoordinated protections. But efforts to care more for our ocean are gaining steam. Negotiations are underway for an international legally binding treaty that seeks to protect life in the high seas. I’ve been involved in the negotiations since they began. AIDA is a member of the High Seas Alliance, which is actively participating in the process; we are also the only Latin American organization represented at the meetings. Last month I participated in the third meeting of the United Nations Preparatory Committee, which is developing elements of a draft text for a treaty under the UN Convention on the Law of the Sea. During that meeting, government representatives from throughout the region actively expressed the need for a strong treaty. The next meeting, July 10-21, is expected to develop recommendations that will hopefully lead to an Intergovernmental Conference to negotiate the treaty’s content. Among other things, the treaty will support the creation and management of Marine Protected Areas, regions of the high seas that will be conserved to help protect the rich biodiversity of our oceans. Protection at a high cost In addition to absorbing a large part of the planet’s excess heat, the ocean absorbs nearly 30 percent of all greenhouse gases. But this protective role comes with serious consequences. By interacting with and absorbing pollutants such as carbon dioxide, the ocean suffers from acidification—a phenomenon that reduces levels of calcium, an element necessary for the formation of shells—and loss of oxygen, essential for life under the sea. These impacts consequently affect the food supply and employment in the fishing and tourism industries. In light of the Paris Climate Agreement, and of the negotiation of this new treaty for the high seas, governments around the world can and must do more to protect marine ecosystems from the impacts of climate change. Marine Protected Areas The International Union for the Conservation of Nature has called on governments to protect 30 percent of the ocean through such conservation measures as the establishment of Marine Protected Areas. Two years ago, one of the smallest countries on the planet, Palau, took a big step toward realizing this goal. Recognizing the benefits of a fully protected marine reserve, the North Pacific island nation designated 80 percent of its marine territory (an area the size of Spain) as a reserve in which trawling, mining, and other harmful extractive activities are forbidden. Palau’s decision protects the nearly 1,300 marine species and 700 varieties of coral that call this small corner of the world home. In Latin America, countries such as Chile, Ecuador, and Costa Rica have followed Palau’s example by safeguarding waters within their national territories. While their intentions are noble, they should also include the high seas. Building on the momentum of marine conservation around the world, the high seas treaty must be developed, and our oceans better protected. In the ten-plus years I’ve worked as an environmental attorney, I have learned a valuable lesson: all of the life that surrounds us comes from the ocean. It’s time to care for it as well as it cares for us. 

Changing the way we approach large dams

Cigarettes once served to cure cough; lead-based makeup was fashionable; and DDT, a highly toxic insecticide, was used in gardens where children played. At the time, little was known of their grave impacts on health and the environment. These facts may shock us now, but once they were normal. Cigarettes, lead, and DDT were widely believed to be more beneficial than harmful to humanity. Thanks to science, we learned of their serious health and environmental impacts. We’re learning the same now about large dams. A photograph of a dam surrounded by trees is as misleading as the doctor-approved cigarette ads once were. In the last decade, we’ve seen that the damage dams do to communities and ecosystems is far greater than the benefits they provide. Recently, an academic study confirmed something even more worrying: large dams aggravate climate change. At the end of 2016, researchers from Washington State University (WSU) concluded that reservoirs around the world, not just those in tropical areas, generate 1.3 percent of the total greenhouse gases produced by mankind. Dams, they found, are an “underestimated” source of contaminating emissions, particularly methane, a pollutant 34 times more effective at trapping heat than carbon dioxide. These findings have not yet been properly absorbed. Large dams continue to be funded and promoted as clean energy. Some countries boast nearly 100 percent renewable energy, yet reports show that at least half of that is hydroelectric energy, produced primarily by large dams. Violating human rights Even before WSU’s study was made public, the damage large dams do to communities and the environment was well documented. Dams disrupt traditional lifestyles, and affected communities are forced to adapt to new environmental conditions, such as altered river flow and species migration. Many communities have also been victims of forced displacement and fall into poverty as a result. In the Brazilian Amazon, the Belo Monte Dam provides a prime example of the ways dams cause negative impacts on both people and the environment. At AIDA, we’ve worked hand-in-hand with the indigenous and river communities of the Xingu River Basin, who have seen the trees fall around them, the red earth spread like a stain across their forest, the fish disappear from their rivers, and their small islands submerged. For those living in Altamira, the city nearest the dam, living conditions also worsened significantly, with increased violence, substance abuse, and prostitution.   This story has been repeated thousands of times around the world. According to International Rivers, 57 thousand large dams had been built by 2015, disrupting more than half of the world’s rivers and causing the displacement of at least 40 million people. What can we do?  Although the WSU study may surprise governments and corporations that promote the construction of large dams, for the health of the planet the trend must be stopped. Environmentally friendly alternatives exist, which do not imply the same social, economic and climatic impacts as dams. Hope can be found in the Brazilian Amazon with the Munduruku tribe. Last year, their long fight paid off with the cancellation of a large dam project on the Tapajós River, the sacred waterway on which their lifestyle depends. The decision to cancel the dam was backed with evidence of the impacts dams have on communities and ecosystems, exemplified by the case of Belo Monte. Recently, the Munduruku gathered to discuss and find solutions for the threats they continue to face as development rages in the Amazon. Solutions include the decentralization of energy sources, the promotion of small-scale projects, and solar and geothermal energy, all of which must be accompanied by adequate community-consultation processes. But they must be studied on a case-by-case basis and according to available resources, as what’s best for one community may not be best for another. Funding must carefully evaluate which projects to support, analyzing in detail the potential socio-environmental impacts. It may sound like people are making all the wrong decisions, but now is no time to be discouraged. We have the scientific information we need to care for our planet. Societal changes prove that we can change our actions to prioritize our health. Why can’t we do the same for the health of our planet? In the last several decades, the number of smokers has drastically decreased, we’ve stopped lacing makeup and other products with lead, and DDT has been regulated. In terms of large dams, the solution lies in re-thinking the way we produce energy and prioritizing the preservation of our free-flowing rivers. 

16 Highlights of 2016: Year in Review

Thanks to the help of our partners and supporters, AIDA achieved many important advances in the defense of human rights and the environment in 2016. 

The role of civil society in the Green Climate Fund

Climate change is real, and its impacts are here to stay. The nations of the world have agreed that, to get out of this mess, they must act together. But beyond setting intentions, little progress has been made. One important opportunity to get things done is the Green Climate Fund, the primary financial mechanism of the United Nations Framework Convention on Climate Change (UNFCCC). It’s a relatively new institution with the ability to move large quantities of money from rich countries to those in development. With these resources, the most vulnerable and least financially equipped nations can develop the projects and programs they need to confront climate change.  How the Fund works in practice The Fund is a complex mechanism in which diverse actors interact. The Board of Directors, in charge of governing and supervising the Fund, is made up of 24 members, 12 representatives from developed nations and 12 from developing ones. The Independent Secretariat implements the decisions adopted by the Board. The Fund relates to countries through the National Designated Authorities or Focal Points, which are entities designated within each nation. The Fund also accredits national, regional and international institutions to channel economic resources through the presentation and implementation of climate proposals. These are called Accredited Entities. Last, but certainly not least, observers from civil society and the private sector play a key role in ensuring that the Fund takes into account the needs of local populations, especially the most vulnerable, when approving projects and programs to combat climate change. How decisions get made In practice, the Fund has been built at meetings of its Board of Directors, held every three months. There, board members discuss and decide on the policies that shape the Fund. They also grant accreditation to entities that will channel funds from the GCF to the different countries, and approve the projects and programs that the Fund will finance. Last October, I was fortunate to participate, as a civil society observer, at the 14th meeting of the Board, which was held at the Fund’s headquarters in Songdo, South Korea. I had the opportunity to see, on the ground, how this complex international mechanism works and, above all, how civil society contributes. It quickly became clear to me that the working conditions of civil society are not easy. To begin with, there is no economic support for civil society representatives that must travel and stay abroad at least three times a year to attend the board meetings. Inside the meetings of the Board, only “active observers” can participate: two from civil society and two from the private sector. The remaining observers sit in an adjoining room, following the meeting on television screens. Civil society has the right to speak, but this right can only be exercised by the two active observers, and only if the Co-Chairmen of the Board of Directors approve. All civil society interventions are previously discussed, prepared and perfected by the coalition of observers. This leads to many sleepless nights, since the subjects are broad and complex. In practice, civil society contributions are relegated to the end of the Board’s discussions. When time is scarce, a common reality, many times the right to speak is denied. This can be extremely frustrating, since crucial contributions are lost. Why civil society support is important Civil society contributes to the construction of the Fund’s policies with the objective of elevating its standards. Among other tasks, each funding proposal is studied, and the communities potentially affected by or benefitting from it are contacted, in order to understand what the project or program may actually involve, beyond what appears on paper. That’s why the informal work that civil society does “behind the scenes” is so important. It is the work done during recess, at lunchtime, and in the corridors. Gradually, civil society observers build relationships with decision makers (Board members and advisors) and are able to share their ideas, concerns and suggestions with them. The results of civil society’s work are being seen in decision-making, slowly but surely. The Green Climate Fund offers hope because its guidelines are correctly posed: it seeks to promote transformation and paradigmatic change, promises transparency, and its decisions are made giving equal weight to representatives of developed and developing nations. Its mandate is to promote “country ownership” of the programs and projects it finances, that is, to ensure they are guided by the needs and priorities of the beneficiary countries. In addition, the Fund has an obligation to act with a gender approach. However, the Fund also has problems and shortcomings. That’s why involvement of civil society is critical. Because they do not represent any government, political party or other interest, civil society observers ensure the protection of the environment, respect for human rights, and the participation and inclusion of people directly affected by climate change. The physical participation of civil society in Board meetings is vital. They ensure the Fund takes into account the voices of the communities directly affected by or benefitting from the financing. Learn more about the Fund on our website!

Why Chile is burning and what we can do about it

Uncontrollable wildfires in Chile have burned more than 500,000 hectares, an area three times the size of Mexico City. With each day that passes, the figure grows. It’s the worst environmental catastrophe the country has seen. Eleven people have died and nearly 4,000 have been affected. The flames have engulfed at least six of Chile’s 15 regions. Causes of the tragedy Much has been said about what could have started these voracious fires. Below is a compilation of the various causes, in hopes that understanding them may help us avoid and better control such fires in the future: Climate change. With the extreme changes in climate, temperatures have risen, causing an eight-year-old drought in the center of the country. This reality has enabled the fulfillment of the so-called “30-30-30” rule, which facilitates the perfect scenario for wildfires: a temperature of 30 degrees Celsius, 30 percent humidity, and winds of 30 kilometers per hour. The human factor. According to the National Forestry Corporation (CONAF), the organization responsible for fighting wildfires in Chile, the vast majority of fires are actually caused by human neglect. In this case, there have been indications that some of the fires were started intentionally. Forest plantations. This cause has the deepest roots. In the central and southern regions of the country, forest plantations have been replacing native forest. That means heterogeneous and biodiverse forests have been transformed into thousands of hectares of one single species, eliminating the natural barriers against fire. These monocultures, mostly pine and eucalyptus, quickly absorb large amounts of water, drying the soil around them and stifling most other life. In addition, both of these trees contain flammable elements that contribute to the spread of fire. Inadequate legislation. Decree Law 701, issued in 1974, sought to boost forestry development through economic incentives, leading to the explosion of large-scale pine and eucalyptus plantations in Chile.  By financing up to 75 percent of monocultures, the decree most benefited those who already owned large tracts of land. It promoted the felling and burning of native forest to replace it with monocultures of exotic species. High voltage cables. When passing over forests, these cables generate high-temperature heat waves. If a branch falls on a cable, it can easily cause a fire. Lack of prevention and preparedness. The factors mentioned above were all known realities; the risk of the current fires was latent. More should have been done to prevent them, and to have been better prepared to face them. Chile has no public policy to address the issue. There is no law on fighting wildfires or confronting other such emergencies. Prevention would involve actions ranging from regulating the activities of forest companies, to implementing effective firefighting, to avoiding the accumulation of garbage in places where fires may emerge.  What we can do about it Institutional and forestry planning appropriate for a changing climate. Changes in weather patterns have made wildfires far more likely to occur. For this reason, adequate plans and policies must be developed to deal with such situations, which will continue to be an underlying threat. Planning should be geared towards building a forest landscape resilient to a drier and hotter future. Strengthening firefighting capacities. The budget afforded to CONAF and the firefighting companies must be sufficient to cover the necessary equipment and human capacity needed to effectively battle such blazes. Regulations to prevent and protect. Legal measures must be taken to ensure that reforestation incorporates firebreaks and ample buffer zones around sensitive areas (villages, water sources and productive areas, among others). This reduces the ability of wildfires to progress and protects local biodiversity and ecosystem services. Impose responsibilities. The owners of forest plantations must be responsible for setting up firewalls and other safeguards, as well as for having emergency plans. Stop promoting monocultures and reestablish native forest. Because they are harmful to the environment and propagate wildfires, the State must stop encouraging monocultures and instead encourage the cultivation of diverse and native forests. Plan reforestation after the fire. Local development must be ensured throughout the process of reforestation, involving affected communities and stakeholders. Education and training of residents and local authorities. Those who live and keep watch over high-risk areas should know how to respond in the case of an emergency, and they must know how to prevent it. How YOU can help now The platform “movidos x Chile” has information on how to help those affected by the fires (donations, volunteering, etc.). The following organizations are receiving money to help victims: Desafío Levantemos Chile (includes information on how to donate from abroad). Un Techo para Chile. Hogar de Cristo. Ministry of the Interior (includes information on how to donate from abroad). The Red Cross (receives in-kind and monetary donations). There are also organizations focused on helping affected animals: Veterinary Medical College of Chile (receives in-kind and monetary donations). The website abandonados.cl (contains information on various organizations that offer help to the animals affected by the fires). Also, on this page you can find information about all the organizations and institutions that are receiving donations for both victims and animals, including locations across the country where material support can be provided. 

2016: 6 reasons to maintain hope for the environment

By Laura Yaniz 2016 was not an easy year. It was especially trying for the fight to protect the environment in Latin America. The loss of brave defenders broke our hearts. The international political environment became so tense after the US presidential election that we learned to take nothing for granted. The effects of climate change hit us hard, and then harder. But it has not all been grim. This year has also given us important reasons to keep the hope alive. Progress, good news and important victories lay a path to a brighter new year. Here are six pieces of good news to help you recharge and have hope for our natural world:  1. The World Bank said “No” to mining in the Santurbán páramo Just ten days before the end of the year, the International Finance Corporation, part of the World Bank Group, decided to divest from Canadian company Eco Oro Minerals. Their funding withdrawal includes the Angostura mining project, which has for years threatened the Santurbán páramo, a water source for millions of people in Colombia. It is a victory to which AIDA and our allies have contributed greatly. Now it’s the government’s turn—in accordance with national laws, they must deny all environmental permits for mining projects in Santurbán, and all other Colombian páramos. The fight for Santurbán isn’t over. Next year we’ll continue to closely monitor Eco Oro, who has filed an international arbitration suit against Colombia for measures the nation has taken to protect its páramos, among them, the high court decision to ban all mining in these sensitive ecosystems.  2. The Indigenous struggle gains strength, and wins! The struggle of the Sioux tribe against the Dakota Access pipeline became a global movement. The largest gathering of Native Americans in history inspired solidarity from artists, veterans, activists, and indigenous groups around the world. They won an important victory when the project was suspended. In Brazil, after years of perseverance, the Munduruku people of the Amazon also emerged victorious when the government denied the environmental license for a dam on the Tapajós River that would have threatened their culture and way of life. These important achievements give us hope. They highlight the need to uplift the voices and support the struggles of the world’s indigenous peoples who, according to the World Bank, protect 80 percent of our planet’s biodiversity.  3. A new climate accord is underway On November 4, the Paris Agreement on climate change entered into force. It happened years sooner than anticipated. The global political achievement was propelled by the ratification of the accord by Latin American and European nations, as well as by China and the United States (the two largest emitters of greenhouse gases). The validity of the agreement impels all nations, developed and developing, to make their commitments a reality. During the 22nd UN Climate Convention in Morocco, as a civil society observer, AIDA contributed to ensuring progress was made on securing funding to help developing countries confront the impacts of climate change. The additional news that the ozone is recovering—a fact made possible by the Montreal Protocol—gives us hope that global commitments like this one can actually bear fruit.  4. Our oceans are protected Important steps were made, nationally and internationally, to protect our world’s oceans and the many incredible creatures that call them home. Mexico created the largest expanse of natural protected areas in its history; the nation’s protected oceans are now nearly half the size of its landmass. In the United States, the expansion of a Hawaiian marine reserve made it one of the largest protected areas on Earth. In Ecuador, the Galapagos Islands reserve was also expanded to protect the sensitive marine life it shelters. Beyond national borders, the global community made important progress on protecting our common waters through the development of a new treaty to protect the high seas. AIDA has brought the voice of Latin America into that discussion. 5. Dam-free rivers In Chile, after decades of strong opposition, one company announced it was giving up on building large dams on five virgin rivers. In Peru, the new government announced that Amazon dams are not on their agenda. In Brazil, the government denied a dam that would have altered the course of the Tapajós River. In the United States, dam removal is well underway, enabling the return of native species and the restoration of ecosystems. Additionally, a recent scientific study confirmed that dam reservoirs are a major source of greenhouse gases, worsening climate change. The findings strengthen arguments we’ve been making for years—large dams are not a solution to climate change; they are part of the problem.  6. Your support Our work this year on behalf of Latin America’s environment would not have been possible without your support. When you write to us, donate photographs, join our team of volunteers and interns, or make a donation, you encourage us to keep fighting. These are messages of hope that remind us how important it is to keeping working for a better future for our children, for yours, and for those of the communities we support. We know that you don’t just follow our work, but bring it home and do all you can, in your daily life, to care for the planet, our collective home. Thank you for giving us hope! Happy 2017! 

Clear accounting for dams and climate change

By Astrid Puentes Riaño (column originally published in El País) “Our climate is warming at an alarming, unprecedented rate and we have an urgent duty to respond,” world leaders concluded at the 22nd United Nations Climate Conference (COP22). Representatives from more than 200 nations gathered in Morocco from November 7 to 18 for the first global meeting since the Paris Agreement on climate change entered into force. We should respond with urgency, but also with intelligence. Today, thousands of large dams are being planned and built around the world. More than a million dams already block half the rivers on the planet. Hundreds of hydropower projects are planned or under construction in the Amazon alone. Many are promoted as clean energy and as solutions to climate change. But that’s just not true. Researchers at Washington State University recently concluded that dams are an important source of greenhouse gas emissions. In addition to carbon dioxide and nitrous oxide, dams release large amounts of methane, a gas that traps 34 times more heat than carbon dioxide. The findings were published in the scientific journal Bioscience. Far from being a solution, dams actually aggravate climate change. Until now, scientific evidence had suggested that dams in tropical areas emit greenhouse gases. The WSU study, however, concluded that reservoirs emit greenhouse gases regardless of their latitude or their purpose (power generation, flood control, navigation or irrigation). The researchers concluded that, globally, reservoirs emit approximately 1.3 percent of all greenhouse gas emissions generated by mankind. That’s greater than the total annual emissions of Canada. Further studies are required to quantify exactly how much dams emit and to understand how they vary according to the particular conditions of each reservoir. For now, it seems that variables such as temperature and eutrophication (increased nutrients in water that increase algae and decrease oxygen) may be the most relevant. Currently, greenhouse gas emissions from dams aren’t monitored. Yet every day, they’re released into the atmosphere, contributing to climate change. Globally, our climate accounts aren’t complete. The WSU study marks a milestone in our understanding of the true role dams play in creating climate change. It’s essential that scientific policies, programs, standards, and analyses take these emissions into account. National and international bodies—including the Intergovernmental Panel on Climate Change, the World Bank, the Inter-American Development Bank, the Green Climate Fund, and private companies—must incorporate current and future dam emissions in their assessments. Only then will be have clear accounts. Only then can we avoid, by ignoring clear evidence, continuing to make climate change worse—particularly for the most vulnerable among us. It’s worth noting that dams have severe impacts on human rights. They’re also very expensive and take decades to plan and complete. What’s more, viable alternatives to dams have already been found—cheaper, more efficient, and quicker to build.  To respond to climate change with urgency, intelligence, and effectiveness, we have to be clear on its causes. We have to account for all significant contributors, including dams. We have this opportunity today. And we have no more time to lose. 

Letter to Green Climate Fund Board: Improve Decision Making

Letter signed by 70 international civil society organizations:  As members of civil society following the Green Climate Fund (GCF), we are writing to express our concern about the way the Board reached some of its most important decisions during the 14th Board Meeting (B.14). We would also like to share some thoughts on how to improve upon this process in the future. We are especially referring to the practice of “package approval” that was used to approve funding proposals and new accredited entities. Weak process. The Board approved 10 proposals worth $745 million without discussing each one separately. The Board’s assessment of each of the funding proposals should be made individually and with the utmost care, to ensure that the objectives, principles, policies, and operational modalities of the Fund are respected and complied with. Furthermore, there was no opportunity for active observers to highlight individual comments for each of the funding proposals (they could merely air some concerns during the overarching discussion of all funding proposals). The same can be said with regard to the package approval of eight accredited entities. There was no public discussion of the merits and/or shortcomings of each approved applicant entity and no possibility of civil society input. Civil society has vital contributions to make, and for our engagement to be meaningful, active observers must be given the opportunity to share important points regarding each proposal and accreditation application during Board meetings. Indeed, the Board’s way of working has actually been in conflict with the GCF’s own Governing Instrument, which states that “the Fund will operate in a transparent and accountable manner”. Approval despite clear failures of GCF policy compliance. The Board repeatedly overlooked the failure of a number of proposals to comply with GCF policies and procedures. For example, public notification for a number of projects was out of compliance with the Fund’s information disclosure policy, which requires a 120-day notification period for proposals with high social and environmental risk. Mandatory gender action plans were missing from several projects, and stakeholder consultations in some cases were highly inadequate. Yet the Board approved all of the projects with one package decision. The Board even pushed through proposals without the requisite guiding policy in place. For example, programs to be implemented via sub-projects were approved, yet the GCF does not have a policy regarding whether or not high risk sub-projects must come back to the Board for approval. We believe they should, to ensure the GCF’s accountability, and to preempt some of the serious environmental, development, and social shortcomings widely seen at other multilateral institutions that finance sub-projects via financial intermediaries. Precedent-setting. While the Board stated that “the approach taken to approving funding proposals at B.14 does not constitute a precedent,” we are concerned that, at this point, the Board has taken such an approach multiple times. Steps to put a stop to these modalities becoming the de facto modus operandi must be taken in the lead up to B.15, including: Timely public disclosure on the GCF’s own website that, at minimum, follows GCF rules (i.e. 120 days for ESIAs for high risk funding proposals, 30 days for medium risk, and three weeks prior to board meetings for all other materials). All annexes and the Secretariat’s due diligence should also be disclosed for funding proposals; Publication of applications for accreditation as soon as they are filed, as well as operationalization of formal mechanisms for third party input (from affected communities, indigenous peoples, civil society, etc.); Individual consideration of each funding proposal and each applicant for accreditation during public sessions of the Board; Opportunities to consider civil society interventions during the debate on each individual proposal, rather than at the end of agenda items; Where formal (or informal) working groups are established to consider conditions to be placed on proposals, there should be a clear process to allow the consideration of civil society feedback, at a minimum in writing, but preferably through the direct participation of the CSO active observers or their alternates; Discussions on more complex and/or controversial proposals require several rounds of debate. In these cases, civil society observers should be given the opportunity to make further interventions responding to new proposals, conditions and amendments. Civil society observers are committed to working with the Board to improve the accountability and transparency of Board decisions, in particular on funding and accreditation approvals. As a learning institution, the GCF needs to take the time to look at the merits of individual proposals and applicants in order to clearly elaborate how they can support the paradigm shift in recipient countries. We therefore urge the Board to better prioritize valuable time during the upcoming Board meetings to allow for meaningful discussions.