Memorandum for the Petitioners | 27 show the potential interactions among the tipping elements based on expert elicitation that could generate cascades. Note that, although the risk for tipping (loss of) the East Antarctic Ice Sheet is proposed at >5 °C, some marine-based sectors in East Antarctica may be vulnerable at lower temperatures (35-38).””” 5.7. Even if GHG emissions are dramatically reduced now, some effects are already locked in. This is because it can take from days to thousands of years for GHGs to be removed from the atmosphere and parts of the earth system, particularly the ocean, wherein it takes hundreds of years to respond to GHGs and aerosol emissions.”8 B. IPCC reports as material facts 5.8. the climate papers for “agreement and where The IPCC assessment and special reports provide the basis for science consensus. The IPCC assesses thousands of scientific each report published to inform policymakers where there is in the scientific community on topics related to climate change, further research is needed.” The IPCC does not conduct its own research, and it does not indicate what constitutes a “safe” level of warming. 5.9. The IPCC assessments and reports have been, and continue to be, key inputs into the international negotiations to tackle climate change and are drafted and reviewed in several stages, guaranteeing objectivity and transparency. The summaries for policymakers present the key findings of the special reports and are adopted by 195 state parties to the IPCC, including the Philippines.” The findings in the special reports and assessments are, therefore, material facts. 5.10. As correctly stated by ClientEarth in its Amicus Curiae Brief dated 21 November 2016, “[t]he [Honorable] Commission may rely on the findings of the IPCC, including the Fifth Assessment Report, as a fact.”®° The District Court of the Hague in the 2015 case entitled, “Urgenda Foundation v. State of the Netherlands,”®' took this approach and held that: The UN Climate Change Convention also made provision for the establishment of the IPCC as a global knowledge institute. The IPCC reports have bundled the knowledge of hundreds of scientists and to a great extent represent the current climate science. The IPCC is also an 7 Ibid. 8 IPCC 2014, Climate Change 2014 Synthesis Report, supra note 70. 79 IPCC, Press Release (08 October 2018), Summary for Policymakers of IPCC Special Report on Global Warming of 1.5°C approved by governments, available at https://www.ipec.ch/2018/10/08/summary-forpolicymakers-of-ipcc-special-report-on-global-warming-of- 1-5c-approved-by-governments/ (last accessed on 06 September 2019). 80 ClientEarth’s Amicus Curiae Brief, supra note 37. 5) See Exhibit “KKKKKKKK” to “KKKKKKKK-54,” Decision of the Hague District Court: Urgenda Foundation v. The State of Netherlands (Ministry of Infrastructure and the Environment Case No: C/09/456689/ HA ZA 13-1396, dated 24 June 2015; and Exhibit “LLLLLLLL” to “LLLLLLLL-19” Decision of the Hague Court of Appeal: The State of the Netherlands v. Urgenda Foundation Case No: C/09/456689/ HA ZA 13-1396, dated 09 October 2018.