human rights impacts resulting from climate change and ocean acidification. The Carbon Majors Study “represents an important milestone in establishing legal accountability for climate change impacts.”82 According to the Center for International Environmental Law: By tracing industrial CO2 emissions to their underlying source, and to a small group of companies and entities whose actions have made a measurable, demonstrable and historically important contribution to global warming, this research demonstrates one important route by which those barriers can and will be overcome by plaintiffs in future litigation.83 The Carbon Majors collectively contribute to global climate change, in that the emissions by one company are not distinguishable in their effects from emissions by other companies. The research therefore provides the best surrogate or proxy measure of responsibility that has been devised to date. The Carbon Majors data identifies the Carbon Majors’ responsibility, jointly and severally, for contributing predominately to climate change and its resulting impacts that are interfering with the enjoyment of human rights. Therefore, while it is not possible to attribute a specific harm, or threat thereof, to the carbon produced by a single Carbon Major, there is a substantial probability that the climate impacts experienced by Filipinos are made significantly worse as a result of the Carbon Majors’ past and current activities. Each company should be held accountable for making some of that contribution.84 As the Guiding Principles explain, responsibility is not !!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 82 The Center for International Environmental Law, CIEL Reaction to Carbon Majors Report, Nov. 22, 2013, http://www.ciel.org/Climate_Change/CarbonMajors_22Nov2013.html (last accessed on June 16, 2015). 83 Id. 84 In the landmark US Supreme Court case, Massachusetts v. EPA, the Supreme Court held: “The harms associated with climate change are serious and well recognized. The Government’s own objective assessment of the relevant science and a strong consensus among qualified experts indicate that global warming threatens, inter alia, a precipitate rise in sea levels, severe and irreversible changes to natural ecosystems, a significant reduction in winter snowpack with direct and important economic consequences, ! ! ! ! ! ! 37 !