Memorandum for the Petitioners | 92 8.56. The World Health Organization (WHO) estimates that between 2030 and 2050, climate change is expected to cause approximately 250,000 additional deaths per year from malnutrition, malaria, diarrhea, and heat stress alone.*** Climate change can also affect mortality in other ways that are more difficult to quantify, such as by undermining livelihoods and displacing people from their homes, or exacerbating violent conflict over scarce resources. 8.57. In relation to the link between the right to life and climate change, David R. Boyd, the UN Special Rapporteur on Human Rights and the Environment, issued a statement on the human rights obligations related to climate change, with a focus on the right to life,?°’ for a climate case in Ireland, entitled “Friends of the Irish Environment CLG v. The Government of Ireland, Ireland and the Attorney General.” The UN Special Rapporteur stated that: “(t)here is no doubt that climate change is already violating the right to life and other human rights today. In the future, these violations will expand in terms of geographic scope, severity, and the number of people affected unless effective measures are implemented in the short term to reduce greenhouse gas emissions and protect natural carbon sinks.”3% 8.58. In the Philippines, the most significant climate-related threats to life include increases in storm intensity, extreme rainfall, flooding, and landslides, the effects of which will be exacerbated by sea-level rise in coastal areas, as well as prolonged droughts and heat waves. Severe storms like super typhoon Haiyan have already claimed tens of thousands of lives.” 8.59. Testimonies of community witnesses and survivors Ms. Marinel S. Ubaldo,° Ms. Marielle Trixie J. Bacason,“! and Arthur S. Golong,““? who have seen losses of lives of friends and community members due to super typhoon Haiyan, and Ms. Amalia Baihan,*? who lost three (3) children and four (4) grandchildren, including a son-in-law, and Ms. Honeylyn A. Gonzales,’ who lost her parents and elder brothers, all due to tropical storm 396 Schachter, B., supra note 394; Also see World Health Organization (2014), Quantitative risk assessment of the effects of climate change on selected causes of death, 2030s and 2050s, p. 1, available at https://apps.who.int/iris/bitstream/handle/10665/134014/978924 150769 1_eng.pdf?sequence=1 &isAllowed =y (last accessed on 12 September 2019). 39? Schacter, B., supra note 394. 38 Boyd, D. (25 October 2018), UN Special Rapporteur on Human Rights and Environment, Statement on the human rights obligations related to climate change, with a particular focus on the right to life, para. 58, p. 13, available at https://www.ohchr.org/Documents/Issues/Environment/FriendslrishEnvironment25Oct20 18.pdf (last accessed on 12 September 2019). 3 Joint Summary of the Amicus Curiae, supra note 50, p. 23. 409 Exhibit “MMMMMM” to “MMMMMN-5,” Salaysay ni Marinel S. Ubaldo, dated 07 September 2018. “01 Exhibit “NNNNNNN” to “NNNNNNN-6,” Statement of Ms. Marielle Trixie J. Bacason, dated 22 October 2018. 40 Exhibit “LLLL” to “LLLL-4,” supra note 11. 493 Exhibit “CCCCCCCCC” to “CCCCCCCCC-3,” supra note 15. 404 Exhibit “IIL” to “IITMI-4,” supra note 15.