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My guess is that the UZR part of WAR is giving Upton 10-15 runs too many defensively...this 20 runs as a corner outfielder stuff won't fly as something you can project confidently that he'll do long term. I would only be comfortable saying he's MAYBE a +10 outfielder...in which case, he's more like a 4 WAR player than a 5+ WAR player.