Amicus Curiae Brief presented by ClientEarth 21 November 2016 entrench a top-down command and control approach with hard ramifications for noncompliance, the Paris Agreement codifies a ‘bottom-up’ approach whereby all States make their own contributions tailored to their own ‘national circumstances’. In particular, the NDCs “codify” the bottom-up approach that emerged from Copenhagen. Nevertheless, the Paris Agreement retains many of the top-down vestiges of the Kyoto Protocol in the form of common rules of transparency and the compliance mechanism. 62. At the time of Agreement’s adoption, it was acknowledged that the intended NDCs submitted by the State parties did not amount to sufficient greenhouse gas emissions reduction targets to meet either the 2 or 1.5 degree temperature goal.49 The Paris Agreement contains a number of provisions intended to ratchet up ambition over time and to bring the NDCs into line with the temperature goals, including by requiring that: a. parties’ NDCs represent a progression beyond the party's then-current nationally determined contribution and reflect its highest possible ambition (Article 4(3) and 4(11)); b. the process for the global stock-take be conducted every 5 years, in which an assessment of collective progress towards achieving the temperature objective will be undertaken by all parties (Article 14); and 49 See the Decision of the Parties, dated 12 December 2015. 33