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Yes, but it also states "appropriate allowance should be made" which means they're aware of the altitude training effect and can cater for it. So, there's probably some threshold for EPO due to altitude and another from exo EPO.
The point of the passport though is that it's tests done over time, so you'd have to justify all your increased EPO values by being at altitude before all the tests - that's gotta be hard to do, given pros are tested randomly.
Not saying it's impossible but bio passport has to make it more risky and expensive which is about as good a deterrent as you can get.
That study shoes altitude does mess with bio passport markers, indicating altitude could be used as a cover for microdosing.