48 2.120. Respondents are attempting to impose the standards of direct or proximate causation in establishing liability as if the human rights and climate change Petition is a criminal or civil lawsuit. For example, respondent LafargeHolcim states that the Petition: “does not identify the specific alleged acts that the LafargeHolcim respondents committed or are supposedly liable for, or their particular acts allegedly directly causing or directly linked to the prejudice claimed, and individual responsibility has not been alleged. […] The LafargeHolcim respondents cannot be considered or jointly liable together with the other respondents, or be made responsible for the acts of any other respondents.”195 2.121. As this is an investigation and not a civil proceeding concerning damages, the petitioners are seeking a determination of whether the respondent Carbon Majors have failed or are failing to fulfill their responsibility to respect human rights by having “contributed” to climate change and consequently to human rights infringements resulting from the impacts of climate change. 2.122. The first part of causation speaks to the relationship between the respondents’ conduct and the petitioners’ human rights impacts— specifically, whether the body of climate science is sufficiently developed to establish a connection between climate change and the particular harms suffered by the petitioners.196 2.123. There is clear and unequivocal evidence that carbon emissions from the production and burning of fossil fuels are causing climate change, and the impacts of climate change -- such as sea-level rise, increased temperature, and extreme weather events -- are resulting in human rights impacts. The Honorable Commission should treat the findings of the Intergovernmental Panel on Climate Change (IPCC) as fact.197 In the face of overwhelming body of evidence reported by the IPCC, the Honorable Commission should accept, based on the best available science, that the warming of the planet is already having and will continue to have significant impacts on the human rights of Filipinos.198 195 Respondent LafargeHolcim’s response, op cit., p. 2. Gage, A. and Byers, M. (October 2014). Payback Time? What the Internationalization of Climate Litigation Could Mean for Canadian Oil and Gas Companies, p. 19, available at http://wcel.org/sites/default/files/publications/Payback%20Time.pdf, last accessed on 06 February 2017. 197 IPCC, 2014: Summary for Policymakers. In: Climate Change 2014: Mitigation of Climate Change. Contribution of Working Group III to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change [Edenhofer, O., R. Pichs-Madruga, Y. Sokona, E. Farahani, S. Kadner, K. Seyboth, A. Adler, I. Baum, S. Brunner, P. Eickemeier, B. Kriemann, J. Savolainen, S. Schlömer, C. von Stechow, T. Zwickel and J.C. Minx (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA, available at http://www.ipcc.ch/pdf/assessment-report/ar5/wg3/ipcc_wg3_ar5_summary-forpolicymakers.pdf, last accessed on 08 February 2017. 198 ClientEarth’s amicus submission, p. 39; The Sabin Center amicus brief provides an extensive overview of climate science and associated human rights implications. Sabin Center’s amicus brief, pp. 4-23. 196