Tag Archives: Carbon Markets


Thank you Mr. Chair,

I am Silvia Ribeiro speaking on behalf of the ENGO- Global Campaign to Demand Climate Justice.

We would like to emphasize three key aspects in these Dialogues:

1. We urge you to not narrow the importance and multiple functions of marine and coastal ecosystems to concepts such as “blue carbon” that reduce ecosystems only to carbon sinks. This is especially dangerous in the light of the pressure to commercialize oceans functions calling them services or credits to sell in new carbon markets.

2.   There are currently more than 40 outdoor marine geoengineering experiments planned or underway, most of them conducted for commercial purposes, which violate UN Treaty decisions and the rights of indigenous peoples and coastal communities.

It is essential that UNFCCC, honoring the precautionary approach, rejects any form of geoengineering applied to marine and coastal ecosystems, including so called “ocean carbon removal technologies” such as seaweed and biomass industrial cultivation and sinking; enhanced alkalinization of the ocean, ocean artificial upwelling; as well as other geoengineering technologies on marine ecosystems, like marine cloud brightening and albedo enhancement involving reflective particles.

In doing so, UNFCCC should recognize and uphold the decisions taken by the Convention on Biological Diversity establishing a de facto moratorium on the deployment of geoengineering techniques that may affect biodiversity (decision CBD X/33 (w)) and the London Convention and London Protocol amendments from 2008 and 2013 related to marine geoengineering techniques.

The London Protocol has since 2022 taken up the evaluation of the impacts on the above mentioned geoengineering techniques, and stated in 2023 that they have “ the potential for deleterious effects that are widespread, long-lasting or severe; and there is considerable uncertainty regarding their effects on the marine environment, human health, and on other uses of the ocean”, signaling their intent to extend regulation to this broader suite of technologies.

This Convention must avoid legitimizing marine geoengineering under Article 6.4  guidance on carbon markets – recognising that a key factor in banning experiments under the LC / LP is the commercial element. 

3.         The Ocean Dialogues and UNFCCC needs to recognize the main actors in maintaining the biodiversity of marine and ocean ecosystems: the indigenous peoples and coastal communities, whose traditional knowledge and livelihoods have conserved and increased biodiversity in these ecosystems. Their right to Free Prior and Informed Consent must be affirmed and honored for any activities and techniques that are proposed to be developed in ocean and marine ecosystems that would affect their territories.


Thank you for the opportunity to take the floor. I am Dr. Tamra Gilbertson with the Indigenous Environmental Network and I am speaking on behalf of Demand Climate Justice and Climate Action Network International that constitute the environmental NGO constituency group. This is our overall general statement but we may come back on the other two groups of questions in more detail. 

While we welcome the initiative to hold this engagement session and would encourage more sessions in the future, we are disappointed in the limited opportunity for participation provided for non-Party rightsholders, given that only one slot has been provided to all constituencies and to ENGOs (which is comprised of two constituencies). This is unfortunately reflective of how the Supervisory Body has implemented consultations and engagement with stakeholders, where consultations and submission timelines are far too short and engagement with stakeholders is often late in the meetings leaving little opportunity to engage prior to when decisions are made.

Given the limited time, numerous questions that were circulated, and that I am representing many groups, my remarks will focus on general cross-cutting issues.

Overall, we remain concerned about the ongoing process of the Article 6.4 Supervisory Body to revise its draft recommendations on removal activities and methodological requirements, while concurrently developing numerous related operational tools given the limited time of Supervisory Body members to adequately consider ongoing concerns about permanence and related issues in submissions by multiple observer organizations. Activity Participants and the acquiring Parties must address reversal risk. Those who will be “benefitting” from projects by buying and using the credits to offset their emissions rather than taking direct action should ensure that there are no reversals. This should include monitoring well beyond the crediting period as reversals could occur later in time. 

Numerous NGOs, CSOs, and groups representing Indigenous Peoples from a range of countries have continually voiced serious concerns about the environmental, social and human risks that carbon markets can pose, which the past work of the Supervisory Body has not appropriately addressed. The SD Tool will not be sufficient. We continue to share these concerns and are not convinced that the Supervisory Body will be able to adequately resolve these outstanding issues in the limited time remaining before COP29, where there is considerable pressure on Parties to agree on the Supervisory Body’s recommendations on removals and methodological principles.

Regarding question 3, we do not believe that REDD+ activities should feature in the Article 6.4 mechanism at the project-level or jurisdictional-level. First, to be clear, REDD+ under the Warsaw Framework is not meant to generate carbon credits and was not designed for this purpose. Second, regarding REDD+ on the voluntary carbon markets, numerous peer-reviewed studies have shown that REDD+ used has led to unchecked over-issuance of credits. While many in these halls continue to hail REDD+ as a successful program, there are several documented cases of REDD+ projects leading to serious violations to the rights of Indigenous Peoples.  REDD+ has a history of ignoring Free Prior and Informed Consent, increasing conflict within communities, and giving rise to  human rights violations. These are serious concerns that continue to go unchecked and what seems to be purposely ignored. 

Further, we would like to note that the appeal and grievance process was rushed and now lacks appropriate human rights language and the rights of Indigenous Peoples under UNDRIP. 

Regarding question 4, carbon markets and offsets are NOT climate finance and should not be regarded as such or substituted for the much needed direct and non-debt causing finance for mitigation, adaptation, and loss & damage that is the responsibility of developed countries.  It is beyond the mandate of this SB. 

We strongly urge the SB to urge Parties to understand that there is no room in the global carbon budget for offsetting if we are to limit temperature rise to 1.5* and to prohibit the use of REDD+ as a carbon offsets in Article 6.4. Carbon markets are not climate finance. This would be a remarkably dangerous precedent to set. Parties agreed to a Fossil Fuel Phase Out at COP28, and should progress with [scaled up climate finance, ambitious NDCs, and] long-term strategies to accomplish this phase-out of fossil fuel and greenhouse gas emissions.

For the sake of time, I will conclude my remarks here.