Submission in Support of Petitioners Case No. CHR-NI-2016-0001 Philippines has been the increased incidence of severe storms like Typhoon Haiyan, which have claimed tens of thousands of lives in the past decade.71 2. Right to Health The ICESCR enshrines “the right of everyone to the enjoyment of the highest attainable standard of physical and mental health.”72 The UDHR also recognizes a right to health as part of the right to an adequate standard of living.73 As with all of the rights discussed here, states must take positive measures to protect the right to health, particularly for vulnerable and marginalized groups,74 and businesses must refrain from undertaking activities that infringe on this right.75 Based on studies from the IPCC, WHO, and other international bodies, OHCHR has concluded that climate change has negative impacts on the right to health, and that states “have clear obligations to take measures to prevent and remedy the negative impacts of climate change on the right to health.”76 The key impacts of climate change on health include: heat-related health impacts, which not only increase the incidence of heat-related mortality but also contribute to respiratory and cardiovascular disease; extreme weather events and natural disasters, which cause injury, disability, and disease as well as death; expanding disease vectors; nutrition deficits linked to food shortages and loss of livelihoods; violent conflict associated with resource scarcity and displacement of people due to climate change; and adverse impacts on mental health owing to the physical and mental stress caused by various climate-related phenomena (e.g., displacement from homes due to sea level rise).77 Recognizing that these negative health impacts “will increase exponentially with every incremental increase in warming,” OHCHR has stated that “[l]imiting global warming to the greatest extent possible 71 Gwen de la Cruz, Worst Natural Disasters in the Philippines, RAPPLER (Aug. 1, 2014), http://www.rappler.com/move-ph/issues/disasters/64916-worst-natural-disasters-philippines. 72 ICESCR Art. 12(1). 73 UDHR Art. 25. 74 OHCHR and WHO, The Right to Health, Fact Sheet No. 31 (2008), http://www.ohchr.org/Documents/Publications/Factsheet31.pdf. 75 OHCHR, GUIDING PRINCIPLES ON BUSINESS AND HUMAN RIGHTS (2011) at 13. 76 OHCHR, Analytical Study on the Relationship Between Climate Change and the Human Right of Everyone to the Enjoyment of the Highest Attainable Standard of Physical and Mental Health, ¶ 45, UN Doc. A/HRC/32/23 (May 6, 2016). 77 Id. at ¶¶ 5-8, 12-22 (citing WHO, Climate Change and Health, Fact Sheet NO. 266; IPCC WGII (2014), supra note 8, at 713). Sabin Center for Climate Change Law, Columbia Law School 16