Memorandum for the Petitioners |110 have no meaningful way of protecting themselves from the situation in which States and Carbon Majors have placed them.>'9 dangerous 8.115. The UN Human Rights Council observed that “children [...] are among the groups most vulnerable to the adverse impacts of climate change, which may seriously affect their enjoyment of the highest attainable standard of physical and mental health, access to education, adequate food, adequate housing, safe drinking water and sanitation.” 8.116. As noted in the Our Children’s Trust Amicus Brief: “the current generation of children are developing into adults as States fail to address the causes of climate change; they live their lives in a time of increasing climate instability under threat of increasingly frequent and severe extreme weather events, increasing ocean acidification, loss of coastline and even entire geographic regions to rising sea levels, rising rates of epidemiological disease, dislocation, and social disruption.”>! 8.117. Indeed, children are particularly vulnerable to the impacts of climate change, due primarily to three interconnected factors. Firstly, childhood represents a unique period of rapid physical and mental development, particularly between birth and the age of five. During that time, children's bodies are most vulnerable to the conditions of climate change and environmental risks. °°? As such, children “experience distinct and disproportionate harm from climate-induced changes in their environment, including impacts with potentially lifelong consequences,” as stated in the UNICEF Amicus Brief.>3 8.118. Secondly, children make up one of the largest groups affected by climate change, as many of the countries identified as the most vulnerable to the impacts of climate change are also those in which children account for a disproportionately large share of the overall population.*24 While all children will ultimately suffer from the risks of climate-induced harm, not all children are affected equally. Areas most exposed to the impacts of climate change frequently overlap with areas of high poverty, exacerbating inequality and further undermining the ability of poor children to cope and take advantage of opportunities for their development. http://www.ciel.org/wp-content/uploads/20 18/0 1/HRTBs-synthesis-report-CRC.pdf (providing a recent summary of authoritative statements), (last accessed 06 September 2019), cited in Joint Summary of the Amicus Curiae, supra note 50, p. 28. 3!9 Joint Amicus of the Amicus Curiae, supra note 50, p. 10. 9 UN General Assembly, Human Rights Council Res. 35/20 (19 June 2017), Human Rights and Climate Change, para. 15. 31 Ibid. p. 12. >” Testimony of Joni Pengram, TSN dated 6-7 November 2018, p. 4, available at http://chr.gov.ph/wpcontent/uploads/2019/04/NICC-TSN-November-6-to-7-London-United-Kingdom.pdf (last accessed on 12 September 2019). 53 Amicus Curiae Brief submitted by UNICEF, supra note 45. 524 Pengram. J. supra note 522. 525 hid.

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