This response is provided based on the information you shared and should not be used as the sole source for making a decision. You should seek guidance from the chain of command, IG, JAG or other certified agencies before making any decisions. How you chose to use this information is totally up to you and is your sole responsibility.
As you have stated, there is nothing to my knowledge based on experience or research that directs who has to file the appeal. However, to appeal the regulation is clear. You must have: new, substantive, and material information, and the time limits specified in paragraph 1–14 do not prevent such action.
I would encourage you to develop a good written statement showing information that was not considered and/or why it makes sense that the award should not be downgraded. Remain professional, calm, factual, and unemotional. Remember the individuals you are asking to upgrade the award are the same individuals that have already downgraded the award so make sure you have your ducks in a row.
Be able to clearly explain your logic, state the facts, be able to state what the normal award has been for individuals of the same rank (although rank is not supposed to be considered by the regulation), length of time (keep in mind there is no such thing as an ETS or PCS award), significant achievements, and what the unit norms or standards have been in the past. Basically, is it unfair treatment. If so, you need to be able to prove it and not just say it feels that way.
You might want to discuss the issue with the local IG and get their take on the matter as well.
See AR 600-8-22 paragraph 1–16. Which states: Reconsideration or appeal of previous award recommendations a. A request for reconsideration or the appeal of a disapproved or downgraded award, or a request for an upgrade of a previously approved recommendation must be placed in official channels within 1 year from the date of the awarding authority’s decision. A one-time reconsideration by the award approval authority will be conclusive. However, pursuant to 10 USC 1130, a Member of Congress may request a review of a proposal for the award or presentation of a decoration (or the upgrading of a decoration) that is not authorized to be presented or awarded due to time limitations established by law or policy for timely submission of a recommendation (refer to app F on the 10 USC 1130 process). b. Recommendations are submitted for reconsideration or appeal only if new, substantive, and material information is furnished, and the time limits specified in paragraph 1–14 do not prevent such action. Requests for reconsideration or appeal must be forwarded through the same official channels as the original recommendation. The additional justification for reconsideration or appeal must be in letter format, not to exceed two single-spaced typewritten pages. A copy of the original recommendation, with all endorsements, and the citation must be attached. If the original recommendation is not available, a reconstructed recommendation should be submitted
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