This submission outlines Carbon Market Watch’s recommendations to the Supervisory Body. We recognise that a lot of work has gone into this new version of the draft. Nevertheless, a tool for environmental and social safeguards cannot be accepted when it is merely going in the right direction: it must be a tool that delivers truly robust safeguards.  A week-long call for input on a 91-page document is not enough time to provide meaningful and detailed feedback, especially for those the tool is designed to safeguard. CMW urges the Supervisory Body to hold a structured consultation of at least one month before proceeding with the next iteration of the tool.