manner that avoids waste and destruction. 267 Pursuant to the jurisprudence in the Philippines and abroad, as well as the broad tenets of the public trust doctrine and international law, the Philippine State is obligated to act to help reduce atmospheric CO 2 to below 350 ppm by 2100 in order to avoid continued violations of fundamental human rights and to preserve a stable climate system.268 As part of its sovereign public trust obligations, the Philippine government should seek natural resource damages from the Carbon Majors for damages to the atmosphere and climate system. The core tenets of the public trust doctrine allow sovereign governments to recover natural resource damages from third parties for impairment to, and to fund restoration of, public trust resources.269 This Commission’s investigation can aid in a global atmospheric and climate recovery effort by providing the Philippine government and other States with the necessary information to pursue natural resource damages from the Carbon Majors. Recovery of atmospheric and climate system natural resource damages from the Carbon Majors would fund carbon sequestration programs that satisfy the Philippines’ “proportionate share” of the carbon drawdown necessary to return to 350 ppm of CO 2 by the end of this century.270 Such programs may also have the added co-benefits that limit the climate harm and human rights infringements experienced by Filipinos due to the actions of the Carbon Majors. 271 Although recovery of other types of damages is also important, natural resource damages are conceptually distinct from, e.g., damages owed to the people for the violation of human rights or damages for climate adaptation costs.272 Achieving long-term atmospheric recovery and climate stability is necessary to prevent continued threats to and violations of Filipinos’ human rights. There are three steps that the Philippine government could follow to seek natural resource damages from the Carbon Majors. First, carbon sequestration projects need to be identified in the Philippines.273 Second, the Philippines would sue the Carbon Majors for natural resource damages to the atmosphere and climate system in order to fund these carbon sequestration projects. Amounts recovered from any Carbon Major would be deducted from that Carbon Major’s overall proportionate liability for atmospheric restoration and climate recovery. 274 Third, the amounts recovered would fund the implementation of the carbon sequestration projects identified in the Philippines.275 Each of these projects must have accurate carbon and financial accounting, be carried out transparently and effectively, and be implemented in a way that respects, promotes, and considers human rights. If other sovereign co-trustees seek natural 267 Our Children’s Trust brief, at p. 7, n. 36-37; see also id. at p. 2-4 (scientific standard for climate stability). Id. at p. 7-8, n. 38-40. 269 Atmospheric Recovery Litigation, supra note 256, at 292; see also Our Children’s Trust brief, at p. 8. 270 Our Children’s Trust brief, at p. 9, n. 44; see also id. at p. 2-4 (scientific standard for climate stability and protection of human rights). 271 For example, in addition to the global and local benefits of atmospheric and climate recovery, well-designed carbon sequestration projects will provide significant co-benefits to the Filipino people. Depending on the type of carbon sequestration project pursued, these benefits could include 1) flood control and/or soil stability; 2) improved ecosystem services; 3) enhanced food production; and 4) local economic benefits from ecotourism and other activities promoted by restored landscapes. See Our Children’s Trust brief, at p. 9, n. 45. 272 Id. at p. 9, n. 46. 273 Id. at p. 9, n. 47-48. 274 Id. at p. 10, n. 49. 275 Id. at p. 10, n. 50. 268 55