concentrations in the atmosphere at a level that would prevent dangerous anthropogenic interference in the climate system.”246 In 2010, the parties to the UNFCCC, including the Philippines, formally adopted the goal of limiting global average temperature rise to no more than 2 degrees Celsius above preindustrial levels, while recognizing the necessity to review the adequacy of such a temperature goal in the light of the ultimate objective of the UNFCCC to avoid dangerous anthropogenic climate change.247 On 4 November 2016, the Paris Agreement entered into force, with the Philippines formally ratifying the agreement on 23 March 2017. The main temperature objective as set forth in Article 2 of the Paris Agreement is to “hold[] the increase in the global average temperature to well below 2°C above pre-industrial levels and to pursue efforts to limit the temperature increase to 1.5°C above pre-industrial levels, recognizing that this would significantly reduce the risks and impacts of climate change.”248 The IPCC has stressed that “rising rates and magnitudes of warming and other changes in the climate system, accompanied by ocean acidification, increase the risk of severe, pervasive and in some cases irreversible detrimental impacts.”249 Building on this assessment, five UN Special Procedures have highlighted that “such incremental increases in impacts and risks adversely affect the full enjoyment of a wide range of human rights, and make it correspondingly more difficult for States to fulfill their obligations under international law to respect, protect and promote human rights.”250 Consequently, the OHCHR has noted that “therefore, States must act to limit anthropogenic emissions of greenhouse gases (e.g. mitigate climate change), including through regulatory measures, in order to prevent to the greatest extent possible the current and future negative human rights impacts of climate change.” 251 National and regional courts have recognized that, in matters related to the environment, international environmental and health standards can inform the determination of whether a State has contravened its human rights obligations. The CESCR has for instance referred to obligations under the UNFCCC to suggest that a State party must do more to comply with its obligation under the ICESCR.252 The ratification or endorsement of the Paris Agreement by all UN Member States and in particular the crucial temperature goals in Article 2 thereby indicates that almost all States have recognized that, as a matter of international law, they should collectively pursue efforts to limit the temperature increase to 1.5°C and hold the temperature increase well below 246 ClientEarth brief, at ¶¶ 54-55. UN Framework Convention on Climate Change, COP Decision, 1/CP.16, FCCC/CP/2010/7/Add.1, ¶ 4 (2010). 248 ClientEarth brief, at ¶¶ 57-58 (citing Paris Agreement, supra note 183, at Art. 2(1)(a)). 249 INTERGOVERNMENTAL PANEL ON CLIMATE CHANGE, CLIMATE CHANGE 2014: SYNTHESIS REPORT. CONTRIBUTION OF WORKING GROUPS I, II AND III TO THE FIFTH ASSESSMENT REPORT OF THE INTERGOVERNMENTAL PANEL ON CLIMATE CHANGE (Rajendra K. Pachauri et al, eds. 2014). 250 CATALINA DEVANDAS AGUILAR, JOHN H. KNOX, PHILIP ALSTON, LÉO HELLER, & VIRGINIA DANDAN, THE EFFECTS OF CLIMATE CHANGE ON THE FULL ENJOYMENT OF HUMAN RIGHTS (2015) (Report for the Climate Vulnerable Forum). 251 U.N. HUMAN RIGHTS OFFICE OF THE HIGH COMMISSIONER, KEY MESSAGES ON HUMAN RIGHTS AND CLIMATE CHANGE, http://www.ohchr.org/Documents/Issues/ClimateChange/KeyMessages_on_HR_CC.pdf. 252 U.N. Committee on Economic, Social and Cultural Rights, Concluding Observations on the fifth periodic report of Australia, U.N. Doc. E/C.12/AUS/CO/5 (July 11, 2017). 247 52