While the current framework contains innovative ideas and proposals, the authors suggest that it may not achieve its objectives. It poses major practical challenges and could, at the same time, both discourage valuable and additional projects by under-crediting them and reduce environmental integrity by over-crediting others.

The framework also employs an approach that inadequately considers the circumstances, technologies and trends in the applicable sector by using the same (default) approach and performance thresholds regardless of the sector, project type, and location.

The authors recommend avoiding the use of one single methodological approach for different sectors, project types and locations, and exploring more practical, robust and data-driven approaches that are developed for specific project types.

The development of such approaches should be based on actual projects and reflect the particular circumstances of the sector, project type and location. The authors also recommend review, road-testing and impact assessments of proposed approaches prior to approval, in order to ensure the overall quality, practicability, effectiveness and robustness.

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