Perhaps unsurprising, the approach pioneered by Felner was later built upon by the New York-based NGO Center for Economic and Social Rights (CESR), of which he was the former Executive Director. In 2012, CESR proposed a systematic attempt to define the duty of "progressive realization" according to such a contextual approach, attentive to the political economy dimensions of States' efforts (allowing to focus on the reasons why certain policies were not adopted that might have improved the situation of rights-holders). The result of this effort is presented as the "OPERA framework".227 The acronym OPERA stands for "outcomes - policy efforts - resources - assessment", describing the various steps which, according to this framework, human rights advocates should take to assess whether a State is doing enough for the fulfilment of economic and social rights.228 The steps may be briefly summarized as follows : 1. "Outcomes": advocates should assess the level of enjoyment of rights (including in particular whether the "minimum core obligations" are complied with), disparities in rights enjoyment (corresponding to the duty of non-discrimination), and whether there is progress over time (corresponding to the duty of progressive realization). 2. "Policy efforts": advocates should examine the legal and policy commitments of the State and whether these are sufficient to demonstrate a commitment to "take steps" for progressive realization of rights; the policies adopted (and whether such policies ensure availability, accessibility, adequacy, adaptability and quality of the rights concerned); and the process through which the policies are designed and implemented (and specifically, whether such policies comply with the principles of participation, accountability, non-discrimination, transparency, human dignity, empowerment and remedies -- the so-called "PANTHER" principles, initially presented in this form by the Right to food unit of the United Nations Food and Agricultural Organisation in 2006229 ). 3. "Resources": advocates should assess whether States dedicate enough resources to rights fulfilment and whether they duly mobilize all resources available (both domestic and international), as well as the process through which decisions concerning resource mobilization (including taxation) and spending are made. 4. "Assessment": advocates finally should assess whether the policy efforts and resource mobilization and spending are sufficient. The final step of "assessment" shall of course be the most heavily contested: as the CESR publication notes, it is here that we must "distinguish deprivations that might be the result of factors genuinely beyond the control of the state from those for which the state should be help accountable".230 The CESR summarizes its effort at this stage of the analysis as follows : By triangulating the findings from the first three steps -- outcomes, policy efforts and resources -- it is possible to bring to light the obstacles that are preventing commitments made on paper translating into practical action that has a meaningful impact improving the situation on the ground. Much like a diagnostic chart, this approach helps to establish the often opaque causal links between these elements. The analysis may show, for example, that the problem is attributable to inadequate or discriminatory use of resources, inadequacy of policy efforts, a lack of participatory processes, or other factors. On the basis of this analysis, a picture should emerge, from which it is possible to draw conclusions about the reasonableness of the state's 227 For a description of the framework and of how it came about, see Saiz, "Resourcing Rights: Combating Tax Injustice from a Human Rights Perspective", cited above note 182, 77-104. 228 Center for Economic and Social Rights, The OPERA Framework. Assessing compliance with the obligation to fulfill economic, social and cultural rights (New York, 2012). 229 See http://www.fao.org/righttofood/about-right-to-food/human-right-principles-panther/en/ (last consulted on 20 Dec. 2016). 230 Center for Economic and Social Rights, The OPERA Framework. Assessing compliance with the obligation to fulfill economic, social and cultural rights, cited above, at 27. 49