First, as a fellow rapporteur I understand the need to move forward, and to create something to react to. I do feel however that we are jumping the gun.
I would like to sign on to the concerns expressed by Bastiaan, who in turn is citing the concerns of Matthew and Tatiana.
Based on our discussions so far, we have no consensus on whether, to what extent, or how any of the UNGPs might be applied. Yet the document seems to start from the opposite assumption. That concerns me, as I don't think that makes the process shorter but rather complicates our process.
I'll paste in a statement that I made in comments to the document (apologies for not providing context):
We are not merely seeing "where specific problems may be identified." That is tantamount to assuming the UNGPs are in, unless "problems can be identified." We are not operating under any such assumption. If anything, we are operating under the opposite assumption. We are seeing where the UNGPs can be applied to our work. In other words, no part of the UNGPs are in, unless there is consensus that they are in. Furthermore, there is no assumption that we are taking all or any part of the UNGP "as is" as opposed to being revised, modified, limited, etc.
Greg