Complaints in Climate Change Projects: A look at adaptation and mitigation grievances

  • Article type Blog
  • Publication date 26 Aug 2021

Is there a difference between complaints and grievances in adaptation projects and mitigation projects? Should a different set of criteria be considered in designing grievance systems for climate adaptation and mitigation projects? These were two thought-provoking questions posed to the Head of the IRM at a recent event hosted for mediators of the Compliance Advisory Ombudsman (CAO).

Interested in further interrogating this query and its potential impact on how grievance redress mechanisms consider complaints in climate adaptation and mitigation, the Independent Redress Mechanism (IRM) undertook a desk study to further understand if there is a difference between the types of complaints filed for mitigation and adaptation projects. This research would be used to determine if grievance mechanisms or procedures should be designed with these differences in mind.

Following this study, we have determined that with the current data available, we are unable to make any concrete conclusions as to whether there is a significant difference between complaints received on mitigation and adaptation projects. From the relatively small sample size of the IRM’s seven case-related complaints that were considered in this study, we could not draw any correlation between certain types of complaints and the kinds of climate change projects they stem from. As a result, we cannot form a definitive view as to whether or not grievance mechanisms need to apply separate standards, criteria, or procedures to these project complaints. As the IRM collects more data through receiving complaints, we will be able to reconsider this question and hope to be able to form a more holistic view in the future.

How do we define mitigation and adaptation?

Following the initial trigger question presented at the CAO mediation summit, we first sought to establish a baseline definition and framework for understanding the differences between adaptation and mitigation projects by asking how the GCF defines mitigation and adaptation in projects and programmes.

To answer this, a review of publicly available GCF information was undertaken using the GCF website. Consulted documents include the Mitigation and Adaptation Performance Measurement Frameworks, Initial Investment Framework, and Thematic brief: Adaptation.

The review of GCF documents shows that the GCF does not define mitigation and adaptation in academic or theoretical terms, but rather defines them practically, through their expected results in projects and programmes.

The GCF definition of mitigation, as outlined in expected project outcomes in the Mitigation and Adaptation Performance Measurement Frameworks, centers around CO2 emissions reduction and accessibility of low-carbon alternatives. These outcomes aim to result in a paradigm shift to low-emission sustainable development pathways, which, along with maximum emissions reduction, is the ultimate goal of GCF mitigation projects. This can include projects reducing emissions through energy generation and access, greening transport and infrastructure, and increasing forest conservation and restoration.

Where mitigation revolves around emissions reduction, according to GCF standards, adaptation focuses on improving and increasing resilience, with the Mitigation and Adaptation Performance Measurement Frameworks giving improved resilience as the key outcome of adaptation projects and programmes. This includes resilience of communities, infrastructure, livelihoods, and ecosystems (indicated in the Adaptation Thematic Brief), but also includes resilience in institutions, regulatory systems, and decision-making processes.

Put into simpler terms, a successful mitigation project or programme as defined by the GCF is one that results in a maximum amount of greenhouse gas emissions reductions, whereas a successful adaptation project or programme is one that increases the maximum amount of resiliency in its project area, whether of the community, institutions, or others.

Complaints in Mitigation and Adaptation Projects and Programmes – Is there a difference?

After establishing our understanding of the GCF definition of mitigation and adaptation in projects, we then sought to answer whether or not IRM complaints are more likely to occur in one kind of project/programme versus another, as well as determine what kinds of issues are raised in mitigation/adaptation complaints, and how they might differ from each other.

To address these questions, we first needed to understand the distribution of GCF projects and programmes between risk categories and mitigation and adaptation, as well as where complaints received by the IRM fall within this distribution. [1] To do so, data on the risk category and mitigation or adaptation category was collected from publicly available information on the GCF website through the Projects and Programmes page as of June 2021. Projects and programmes in the mitigation and adaptation categories were counted and recorded, as demonstrated in the following graphics. In this introductory study, we have chosen to consider only adaptation and mitigation projects/programmes and did not include cross-cutting projects/programmes. We can possibly include this in a future study. From the data collected, we can draw a few preliminary conclusions.

First, the GCF’s mitigation projects portfolio has more than 5 times as many projects/programmes being categorized as Category A/Intermediation 1 than those in the adaptation portfolio (11 mitigation, 2 adaptation). [2] As such, the GCF’s mitigation project portfolio has more environmentally and socially risky projects than those in the adaptation portfolio.  However, despite this risk, this does not seem to translate into a higher number of IRM complaints being made on mitigation projects. On the contrary, out of the 7 complaints and pre-complaints considered in the data, only 2 were related to mitigation projects, with 5 related to adaptation. These complaints were chosen from the IRM’s case register on the basis that they were directly related to a GCF project. Some were escalated to a full complaint, while others remained as a “pre-complaint,” meaning that correspondence was received from potential complainants who have yet to pursue it further.

The larger amount of adaptation complaints could be due to the uneven distribution of projects between mitigation and adaptation. The GCF portfolio aims to have a 50:50 even spread of funding between mitigation and adaptation, although mitigation makes up a larger percentage of funding (64%). However, when considering the total number of projects, adaptation projects make up over half (57%) of the portfolio when we exclude cross-cutting projects that include both mitigation and adaptation elements. Part of this is due to the lower risk of projects in the GCF’s adaptation portfolio, perhaps leading to more adaptation projects.

Of course, the difference between the amount of adaptation and mitigation projects/programmes (57% adaptation, 43% mitigation) is much smaller than the difference between IRM complaints for mitigation and adaptation projects/programmes (71% adaptation, 29% mitigation), but this could still provide a partial explanation for the difference in the number of complaints: a larger number of adaptation projects could lead to a larger number of adaptation complaints.

Regarding the risk level of IRM complaints, 6 out of 7 complaints were Category B/Intermediation 2, with only one falling into the riskiest Category A. This could also potentially be attributable to the higher level of Category B projects in the GCF portfolio, with 62% of mitigation projects being Category B/Intermediation 2, and another 62% of adaptation projects also being in this category. However, all 5 adaptation-related complaints were Category B. While this could be in part due to the higher proportion of Category B projects that make up the adaptation portfolio, this could indicate a potential problem area to be monitored.

Once we had an understanding of how many complaints and pre-complaints to the IRM are made on mitigation and adaptation projects, the Case Management System (CMS) was used to review past documentation on these complaints, noting the reasoning behind them to analyze if there is any difference between the kind of complaint received and the type of project/programme.

Again, the insufficiency of data on this topic creates difficulties in drawing a conclusion. After the exclusion of cross-cutting projects and programmes, only seven case-related complaints and pre-complaints remained to be analyzed, with 2 being mitigation and 5 being adaptation. However, when considering the issues raised in each type of project, there was no common theme that emerged within the two kinds of projects. [3] The most frequent issue raised, in 3 complaints out of 7, was a lack of stakeholder engagement and consultation. However, this occurred in both mitigation and adaptation projects, and thus cannot be concluded to occur more often in one than in the other.

Other complaints included issues of disbursement, governance, and negative environmental and social impacts, but did not constitute a large enough portion of the sample size to be considered representative of either mitigation or adaptation projects and programmes.


From the research conducted and data found in this study, there is insufficient data to conclude at this stage that there is a significant difference between complaints received on mitigation and adaptation projects. Although adaptation projects and programmes make up the majority of IRM complaints, there is currently a paucity of evidence to suggest that this is due to the kinds of activities undertaken in adaptation projects. Given that there are more category B/I-2 projects/programmes in the adaptation portfolio, there is a possibility that those projects tend to generate more complaints, but this is an issue on which more data will need to be gathered and research done, before definitive conclusions are reached. There is no commonly identifiable theme in adaptation or mitigation project complaints beyond lack of stakeholder engagement and consultation, which itself is a cross-project issue not bound to either adaptation or mitigation.

Despite the inability to draw a conclusion at this stage, this question remains pertinent to the work of the IRM. As the IRM continues to receive complaints, we plan to build this dataset to be able to better consider this question in the future.


Article prepared by Amanda Bierschenk

[1] GCF risk categories are defined as Category A, B, or C, or Intermediation 1, 2, or 3, with Category A and Intermediation 1 presenting the highest environmental and social risks

[2] For the purposes of this study and for simplicity’s sake, we have chosen to combine related risk categories (Category A and Intermediation 1, Category B and Intermediation 2, Category C and Intermediation 3).

[3] As not all these complaints and pre-complaints reached eligibility phase, specific details cannot be given as they are not public information. Publicly available complaints can be found in our Case Register.