While we appreciate the detailed work of the Methodological Expert Panel on the important process of baseline setting, we do not see all elements of the Article 6.4 Rules, Modalities and Procedures (RMPs) reflected in the proposed Standard.

Specifically, we see the need for further alignment of the baseline provisions with encouraging ambition over time and alignment with nationally determined contributions, long-term low-emission development strategies and particularly the long-term temperature goal of the Paris Agreement.