3. This expert statement is submitted in relation to the case Friends of the Irish Environment CLG (“the Applicant”) v. The Government of Ireland, Ireland and the Attorney General (“the Respondent”). The Applicant seeks to quash the decision of the Respondent to approve the National Mitigation Plan published on 19th July 2017. 4. In the Statement required to ground an application for judicial review, the Applicant claimed, inter alia, that the Respondent’s approval of the National Mitigation Plan, absent any or any adequate mitigation measures, is unreasonable, unconstitutional and in breach of human rights law. According to the Statement, the Plan will impinge on and threaten: the right to life, right to liberty and security, right to the integrity of the person, right to respect for family and private life and home, right to property, the rights of the child, the rights of the elderly, equality between women and men, environmental protection; and/or the unenumerated constitutional right to a reasonable environment; and/or will breach the unenumerated constitutional commitment to intergenerational solidarity and/or the unenumerated constitutional obligation to vigilantly and effectively protect the environment. 5. I will limit my consideration to one of these issues: the right to life. In this context, I will analyze the following question: Does the Government of Ireland have positive human rights obligations to mitigate climate change? The conclusion reached is that climate change clearly and adversely impacts the right to life, a right which the Government of Ireland is legally obligated to respect, protect and fulfill. Therefore, the Government of Ireland has positive human rights obligations to mitigate climate change by rapidly reducing its greenhouse gas emissions. II. Growing recognition of the impacts of climate change on human rights 6. States agreed in the 1992 United Nations Framework Convention on Climate Change (UNFCCC) that their goal is to achieve “stabilization of greenhouse gas concentrations in the atmosphere at a level that would prevent dangerous anthropogenic interference with the climate system” (Art. 2). The UNFCCC explicitly calls for efforts to mitigate the adverse effects of climate change including those on human health and welfare (Art. 1). At that time, however, human rights were not explicitly included in the Convention. 7. In the past decade, the relationship between human rights and climate change has received increasing attention from the UN Human Rights Council, special procedures, Governments and international bodies, including the Conference of the Parties to the UNFCCC. An important milestone was the Male’ Declaration on the Human Dimension of Global Climate Change, adopted by representatives of small island developing States in 2007. The Male’ Declaration was the first intergovernmental statement explicitly recognizing that climate change has “clear and immediate implications for the full enjoyment of human rights”, including the right to life. 8. In 2008, the Human Rights Council adopted its first resolution on climate change and human rights. In resolution 7/23, the Council expressed its concern that climate change poses an immediate and far-reaching threat to people and communities around the world and has implications for the full enjoyment of human rights. 9. After receiving input from Governments, civil society organizations and others, OHCHR published a report describing how climate change threatens the enjoyment of a wide range of 2