Amicus Curiae Brief presented by ClientEarth 21 November 2016 "hold[] the increase in the global average temperature to well below 2 degrees celsius above pre-industrial levels and to pursue efforts to limit the temperature increase to 1.5 degrees celsius above pre-industrial levels, recognising that this would significantly reduce the risks and impacts of climate change."48 59. In order to achieve the long-term temperature goal set out in Article 2, Article 4(1) provides that the parties will aim to reach global peaking of greenhouse gas emissions as soon as possible, and will: "undertake rapid reductions thereafter in accordance with best available science, so as to achieve a balance between anthropogenic emissions by sources and removals by sinks of greenhouse gasses in the second half of this century, on the basis of equity, and in the context of sustainable development and efforts to eradicate poverty." 60. Although some commentators have suggested that Article 2 frames 2 degrees as the target and 1.5 degree as a less onerous ambition, the distinction between the two temperature goals is over-stated. Crucially, NDCs will be judged according to both measures. As a matter of best practice and due diligence State parties should be seeking to meet the 1.5 degree target. 61. The Paris Agreement has been characterised as an evolution in climate governance in its treatment of the bottom-up and top-down approaches. It presents itself as a hybrid model between the two approaches. Whereas the Kyoto Protocol sought to 48 Article 2(1) of the Paris Agreement. 32