Memorandum for the Petitioners| 8 significantly contributed to the warming of the planet, which in turn, has caused devastating and deadly impacts. The Honorable Commission should look closely into these Carbon Majors that produce fossil fuels since GHG emissions from coal, oil, and gas are the main drivers of climate change. Today, Filipinos are dealing with a human rights crisis that the fossil fuel industry could have prevented. Instead of “sounding the alarm,” many of the respondents “went out of their way to becloud the emerging scientific consensus and further delay changes -- however existentially necessary -- that would in any way interfere with their multibillion-dollar profits,” and “[aJll while quietly readying their capital for the coming fallout.” Although the Petition primarily discusses climate change, increased carbon dioxide (CO2) emissions have also been causing the acidification of the Earth’s oceans, resulting in serious harms. The emissions from fossil fuels produced by respondents are, therefore, linked to both climate change and what is now being called its equally “evil twin,” ocean acidification.” The Petition invoked the Honorable Commission’s investigatory, recommendatory, and monitoring powers to prevent or curb further violations of petitioners’ and all Filipinos’ constitutionally-protected human rights resulting from the impacts of climate change. Based on the evidence submitted by the petitioners, the Honorable Commission is empowered to make findings of fact and law and to issue recommendations. In this memorandum, the petitioners will lay down the antecedent proceedings that transpired; the Honorable Commission’s authority to investigate and grant the reliefs they prayed for; the material facts as established by evidence, particularly, the climate science and respondent Carbon Majors’ corporate early knowledge of climate risks and actions and/or inactions taken in light of the foreseeable harms; and petitioners’ position and recommendations. To bolster their position and lay basis to their recommendations, the petitioners will establish the following: a) Climate change is impacting the Philippines and Filipinos suffer disproportionately from these impacts; b) Climate change results in -- and/or threatens — the impairment, infringement, abuse, and/or violation of the human rights of the Filipinos; ?6 Opinion and Order, United States District Court for the District of Rhode Island, 22 July 2019, in State of Rhode Island v. Chevron Corp., Case 1:18-cv-00395-WES-LDA, available at https://www.courthousenews.com/wp-content/uploads/20 19/07/FullText-29.pdf (last accessed on 12 September 2019). 27 See Part VIII (A and D): Arguments and Discussion section of this memorandum for more elucidation.

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