fall in two groups: they consist either in taking the State concerned as the reference point, or in defining the benchmark through cross-country comparisons. The first approach may consist in relying on an objective a State has set for itself, for instance by endorsing an international goal such as one contained in global development goals (the Millennium Development Goals until 2015, the Sustainable Development Goals today), or by specific commitments, say, to increase the budget going to public housing by 20 per cent in two years; or in the past performance of the State constituting the benchmark against which to assess further progress. The main advantage of this approach is that the benchmark is not imposed from the outside, but is the result of the concerned State itself, which makes it difficult to challenge on legitimacy grounds. Yet, it begs the question of how to assess whether the goals set by the State are adequate, given the resources at its disposal: has the State been ambitious enough in setting an objective, and if progress was made in comparison to previous years, was that progress sufficient? As Felner himself recognizes, referring to the suggestion of evaluating the performance of a State against the targets it has set for itself, this commitment in turn "should also be scrutinized, as it could be flawed from a human rights perspective".219 The same holds, of course, for global development goals (and their associated targets) as set by the international community, which have often been denounced for not being sufficiently ambitious when contrasted with the kind of outcomes that international human rights would require.220 The second approach is more promising. It relies on cross-country comparisons, using as a reference point countries of a same region at a similar level of development: such cross-country comparisons, Felner argues, "could reveal whether the levels of deprivation of the focus country are lower than expected given the country’s development level".221 The choice of relying on countries of the same region and at a similar level of development (by which Felner presumably means countries with a similar GDP per capita), should be seen as a compromise. A more rigorous methodology should take into account a variety of factors in multiple regression analyses, to control for the various obstacles that a country may be confronted to. Such obstacles could include, though not being limited to, the country being landlocked, the country having a weak population density making the delivery of services more expensive and more difficulty, or the country being heavily dependent on a narrow range of commodities as a source of export revenues. But taking into account a large range of factors that might potentially affect a country's ability to fulfil economic and social rights would soon make monitoring compliance with social and economic rights an unmanageable task: for the sake of simplicity, Felner therefore proposes to limit the comparison to the countries of the same region (geographical proximity being a proxy for the range of obstacles faced).222 shortfalls in the enjoyment of a right in the focus country" (id., 115). But that amounts to substituting an obligation of result for an obligation of means, and does not provide an adequate methodology for identifying the standard of conduct to be adopted by a country with a view to progressively realize a social or economic right as required under article 2, para. 1, of the International Covenant on Economic, Social and Cultural Rights; it corresponds in fact to the methodology some commentators would use for assessing compliance with "core obligations" corresponding to the "essential minimum levels" of enjoyment of a particular right such as the right to education, discussed in Part II of this paper. The same is true for another method proposed by Felner, that consists in using disaggregated data by ground of potential discrimination (sex, membership in an indigenous group or in a particular ethnic group, etc.), in order to "identify disparities, and therefore possible discrimination, among population groups in the access to and enjoyment of economic and social rights" (id., 116). Here again, the conclusion that a violation has occurred is based on the identification of an outcome that is unsatisfactory, an approach which -- though defensible from the normative point of view -- does not answer the question of progressive realization and of the corresponding obligation of means imposed on the State. 219 Id., at 116. 220 For extensive discussions about this mismatch, see Mac Darrow, "The Millennium Development Goals: Milestones or Millstones? Human Rights Priorities for the Post-2015 Development Agenda", Yale Human Rights and Development Law Journal, Vol. XV (March 2012), pp. 55-127; and Philip Alston, "Ships Passing in the Night: The Current State of the Human Rights and Development Debate Seen Through the Lens of the Millennium Development Goals", Human Rights Quarterly, vol. 27(3) (2005), 755-829. 221 Id., at 116. 222 Id., 149-150 (note 27) ("To avoid controlling for a whole set of possible relevant factors (such as weather/climate reasons, conflict spillovers, population density and cultural beliefs) which would require making the quantitative tools proposed here more complex (because of the use multiple regressions), it is instead suggested here to only use comparisons across countries of the same geographic region, a standard practice used as a simple alternative to controlling for these potentially relevant factors"). 47