2ºC. The temperature goals provided in the Paris Agreement however do not supersede fundamental human rights obligations to reduce emissions to the greatest possible extent especially in light of the fact that significant human rights impacts are occurring at current levels of global temperature rise. The Preamble to the Paris Agreement acknowledges that, whenever States take action to address climate change, they should “respect, protect and consider their respective obligations on human rights.”253 The Paris Agreement’s reference to Parties’ human rights obligations encompasses obligations in treaties they have ratified already, or may ratify in the future, the UN Charter, and customary principles of law as they relate to human rights. By forging an overt link with human rights instruments, the Paris Agreement’s preamble makes explicit and reaffirms States’ duty to respect, promote, and take into consideration their existing human rights obligations in all climate policies, including as they implement the Paris Agreement. 254 Additionally, compliance with human rights obligations requires States to pursue climate policies that “are consistent with the best available science and relevant international health and safety standards.”255 III. Obligations of States under the Public Trust Doctrine - Additional input from Our Children’s Trust Both the public trust doctrine and the fundamental human rights of Filipinos require the Philippine government to protect the atmosphere and climate system according to the best available climate science, and to hold carbon majors liable for funding atmospheric recovery. The public trust doctrine is an ancient, fundamental legal principle, under which citizen beneficiaries of vital natural resources held in trust by governments have reserved and inalienable rights to “a sustained natural endowment.”256 The doctrine is central to many legal systems around the world, including that of the Philippines, such that the doctrine can be regarded as a fundamental attribute of sovereignty that governments cannot discard. 257 253 Paris Agreement, supra note 183, preamble. See APF & GANHRI brief, at ¶ 27. 255 See Rep. of the Special Rapporteur on the Issue of Human Rights Obligations Relating to the Enjoyment of a Safe, Clean, Healthy and Sustainable Environment, ¶¶ 58, 72, U.N. Doc. A/HRC/37/58 (Jan. 24, 2018), http://legal.un.org/docs/?symbol=A/HRC/37/58; see also Rep. of the Special Rapporteur on the Issue of Human Rights Obligations Relating to the Enjoyment of a Safe, Clean, Healthy and Sustainable Environment, U.N. Doc. A/HRC/37/59, supra note 213, at ¶ 33(c). 256 Mary Christina Wood & Dan Galpern, Atmospheric Recovery Litigation: Making the Fossil Fuel Industry Pay to Restore a Viable Climate System, 45 ENVTL. L. 259, 272 (2015), available at https://www.ourchildrenstrust.org/s/2015_Wood_Atmospheric-Recovery-Litigation-Making-Fossil-Fuel-IndustryPay-to-Restore-Viable-Climate.pdf [hereinafter Atmospheric Recovery Litigation]. 257 Mary Christina Wood & Gordon Levitt, The Public Trust Doctrine in Environmental Decision Making, 2 (2016), https://law.uoregon.edu/images/uploads/entries/FINAL_PDF_For_DISTRIBUTION_Encyclopedia_Public_Trust1.p df (This paper can also be found as a chapter in LEROY C. PADDOCK, ROBERT L. GLICKSMAN & NICHOLAS S. BRYNER EDS., DECISION MAKING IN ENVIRONMENTAL LAW (2016)). 254 53