C. In applying the UNGPs, the Commission should pay particular regard to Principles 11-17 and Principle 22 D. The UNGPs should be interpreted in light of and in accordance with international environmental law and the international law governing climate change II. Fundamental Principles of Legal and Moral Responsibility (CIEL, Plan B) A. For decades, Carbon Majors Companies knew or should have known of potential climate risks associated with their productions and operations B. Despite Notice of the Potential Climate Risks Associated with their Products and Operations, Carbon Majors Companies Repeatedly Failed to Adequately Inform the Public of those Risks or to Take Measures to Address Them C. Causation (Plan B) III. Polluter Pays (Plan B) Summary Conclusions 63 65 67 69 69 71 73 74 RECOMMENDATIONS OF INDIVIDUAL AMICI 75 ClientEarth: Suggested Factual Findings 75 Our Children’s Trust Recommendations 77 Plan B: Recommendations 79 APPENDIX A: SUMMARY OF THE INTER-AMERICAN COURT ADVISORY OPINION 3 80