Memorandum for the Petitioners |108 Rights of the Child (CRC), the Convention on the Rights of Persons with Disabilities, and the UN Declaration on the Rights of Indigenous Peoples.” 8.107. The OHCHR states that the negative impacts of climate change “will disproportionately affect individuals, groups and peoples in vulnerable situations, including women, children, older persons, indigenous peoples, minorities, migrants, rural workers, persons with disabilities, the poor, and those living in vulnerable areas (e.g., small islands, riparian and low-lying coastal zones, arid regions, and the poles). 8.108.The IPCC has similarly found that “people who are socially, economically, politically, institutionally or otherwise marginalized are especially vulnerable to climate change.”*° The vulnerability of these groups results from their greater exposure to climate change impacts as well as their limited capacity to adapt to those impacts. As stated by the U.N. Special Rapporteur’s on the Right to a Healthy Environment in his 2019 Safe Climate Report: “The worst impacts afflict those who have contributed least to the problem and who have the fewest resources to adapt to, or cope with, the impacts.”>7 8.109. Under international human rights law, the concept of equality is implemented through the prohibition of certain types of discrimination. Climate change may infringe on the right to equality and non-discrimination because the failure to reduce carbon emissions and to adopt adaptation measures will have disproportionate impacts on communities and individuals from particular vulnerable groups.>8 8.110. Petitioners’ community witness, super typhoon Haiyan survivor and transgender Ms. Golong,®” shared how livelihood programs followed a binary gender system after the typhoon— with significant emphasis placed on traditional male and female gender roles in assigning work. 11. The right to culture 8.111.Climate change impacts the enjoyment of the right to culture, such as traditional livelihoods and practice of ancestral traditions, particularly 5% Convention on the Elimination of All Forms of Discrimination Against Women (hereinafter, “CEDAW”); Convention on the Rights of the Child, 20 November 1989, 1577 UNTS 3 [hereinafter CRC]; Convention on the Rights of Persons with Disabilities, 13 December 2006, 2515 UNTS 3 [hereinafter CRPD]; and UNGA, UN Declaration on the Rights of Indigenous Peoples, 2 October 2007, UN Doc A/RES/6 1/295 (hereinafter, “UNDRIP”). °° Joint Summary of the Amicus Curiae, supra note 50, p. 26, citing UN Human Rights Office of the High Commissioner (2016), The Rights of those Disproportionately impacted by Climate Change, p. 1. 596 Joint Summary of the Amicus Curiae, supra note 50, p. 26, citing IPCC ARS WGIL p. 6. 597 UN Safe Climate Report, supra note 408, p. 46. 5% Lofts, K., supra note 375, pp. 5-6. 5° Golong, A., supra note 480, pp. 5-39.