resource damages for climate recovery then the Philippines should consider taking a leadership role in the implementation of a Planetary Atmospheric Recovery Plan to efficiently coordinate the recovery and effective utilization of natural resource damages. 276 IV. Obligations of States in respect of emissions arising under the “no harm principle” of customary international law - Additional input from Plan B 277 States have the sovereign right to exploit their own resources. They have a corresponding responsibility to ensure activities within their control do not cause substantial damage to other States or areas beyond the limits of national jurisdiction (such as the high seas or outer space). This is described as the “principle of prevention” or the “no-harm rule.” In 2010, the International Court of Justice held that “A State is thus obliged to use all the means at its disposal in order to avoid activities which take place in its territory, or in any area under its jurisdiction, causing significant damage to the environment of another State.” 278 The UNFCCC directly invokes the principle in its Preamble, removing all doubt regarding its application to climate change: Recalling also that States have, in accordance with the Charter of the United Nations and the principles of international law ... the responsibility to ensure that activities within their jurisdiction or control do not cause damage to the environment of other States or of areas beyond the limits of national jurisdiction.279 States, therefore, have an obligation to take all appropriate measures to anticipate, prevent, or minimize the causes of climate change, in particular through effective measures to reduce greenhouse gas emissions to a level consistent with the temperature goal. The principle itself is straightforward. It is the apparent complexity of quantifying the scope of the obligation for any individual country that has caused some to question its practical applicability. In practical terms, and in accordance with the UNFCCC and the Paris Agreement, the duty to prevent harm implies liability for climate change loss and damage, including the costs of adaptation arising out of past breaches of the duty and, in relation to future prevention measures, the duty implies distinct obligations to:   reduce GHG emissions in line with the global target; and on the part of countries which have used more than their share of the carbon budget, to support financially the implementation of mitigation measures on the part of those who have used less. 276 Id. at p. 10, 9, n. 48. Plan B’s original amicus brief addresses “State Accountability” at p. 48. This summary, however, reflects updated research conducted by Plan B in this area, which is published in Environmental Liability, Law, Policy and Practice, Vol 24, Issue 3, 2016. See Tim Crosland, Aubrey Meyer & Margaretha Wewerinke-Singh, The Paris Agreement Implementation Blueprint: a practical guide to bridging the gap between actions and goal and closing the accountability deficit (Part I), 24(3) ENVIRONMENTAL LIABILITY, LAW, POLICY AND PRACTICE 114 (2016), available at http://www.lawtext.com/pdfs/sampleArticles/EL243Crosland.pdf. 278 Pulp Mills on the River Uruguay (Arg. v. Uru.), Judgment 2010 I.C.J. Rep. 14, ¶ 101 (Apr. 20). 279 United Nations Framework Convention on Climate Change, preamble, May 9, 1992, 1771 U.N.T.S. 107 [hereinafter UNFCCC]. 277 56