Memorandum for the Petitioners |105 Bahian, “ Ms. Piquero-Tan, “? Ms. Ubaldo, “84 Ms. Cocadiz,‘®5 and Ms. Bacason** -- who testified and shared their heartbreaking ordeals on either relocating almost every time typhoon hits their place, having to live in tents for months, or migrating abroad for safety. 8.95. Without adaptation, the IPCC projects with high confidence that “hundreds of millions of people will be affected by coastal flooding and will be displaced due to land loss by year 2100.48” Drought and desertification could lead to the displacement of millions more people.‘*8 8.96. Impacts on the right to housing may also be linked to climateinduced migration, especially due to declining agricultural yields, the destruction of ecosystems, and resource shortages caused by climate change.*® For instance, the OHCHR notes that “[t]he erosion of livelihoods, partly caused by climate change, is a main ‘push’ factor for increasing rural to urban migration,” thereby causing many to “move to urban slums and informal settlements where they are often forced to build shelters in hazardous areas.”490 8.97. This is particularly relevant to the Philippines, where many poor people in urban areas lack access to infrastructure and basic services and live in settlements in low-lying coastal areas in the cities. The people’s right to adequate housing is constantly being jeopardized by climate-related impacts such as flash flooding, Specifically, petitioners’ landslides, community sea-level witnesses rise, and storm surges. 47! from urban poor areas in Marikina and Rizal -- Mr. Noli Abinales, Mr. Pablo Taon Ill, Ms. Francia ‘® Exhibit “CCCCCCCCC” to “CCCCCCCCC-3,” supra note 15; also see Testimony of Ms. Amalia Bahian, TSN 11-12 December 2018, pp. 7-15, also available at http://chr.gov.ph/wpcontent/uploads/20 19/04/NICC-TSN-December-I 1-to-12-201 8-Metro-Manila-Philippines.pdf (last accessed on 12 September 2019). 485 Exhibit “QQQQQQQQQ” to “RQQQQQQQQ-7,” Statement of Ms. Monica Piquero Tan, dated 03 December 2018; also see Testimony of Ms. Monica Piquero-Tan, TSN 11-12 December 201 8, pp. 18-27, available at http://chr.gov.ph/wp-content/uploads/20 19/04/NICC-TSN-December-1 | -to-12-2018-Metro- Manila-Philippines.pdf (last accessed on 12 September 2019). 484 Exhibit “MMMMMM” to “MMMMMM-5,” supra note 400; also see Ubaldo, S., TSN 27-28 September 2018, supra note 422, pp. 6-8. “85 Exhibit “NNNNNN” to “NNNNNN-S,” Statement of Cristina C. Cocadiz, dated 19 September 2018; also see Testimony of Ms. Cristina Cocadiz, TSN 27-28 September 2018, pp. 10-25, available at http://chr.gov.ph/wp-content/uploads/20 19/04/N 1CC-TSN-September-27-to-28-New-Y ork-UnitedStates.pdf (last accessed on 12 September 2019). 486 Bacason, M., supra note 401; also see Testimony of Ms. Marielle Trixie J. Bacason, TSN 6-7 November 2018, pp. 96-108, available at http://chr.gov.ph/wp-content/uploads/2019/04/NICC-TSN-November-6-to-7London-United-Kingdom. pdf (last accessed on 12 September 2019). “87 Joint Summary of the Amicus Curiae, supra note 50, p. 26, IPCC ARS WGIII, p. 364. 488 Ibid. “ Joint Summary of the Amicus Curiae, supra note 50, p. 26, IPCC ARS WGIIL, p. 364. 4° Lofts, K., supra note 375, p. 8, citing A/HRC/10/61, para. 36. 491 Did, p.9.