Memorandum for the Petitioners | 98 8.77. Children who lose their parents and older family members in severely destructive typhoons are thrust into the role of breadwinner for their younger brothers and sisters. This was the experience of Ms. Honeylyn Gonzales,*? who lost her parents and elder brothers at the age of 18 due to tropical storm Sendong (“Washi”). Being the remaining elder sibling, she was forced to “mature” quickly, forgoing her teenage years, and bore the responsibility of raising her siblings, both of whom were less than 10 years old at the time.34 8.78. Climate change impacts will make it more difficult for governments and people to pursue forms of development in which all human rights and fundamental freedoms can be fully realized.**> The economic and non-economic costs of climate change pose a grave threat to the realization of sustainable development and self-determination in the Philippines. 8.79. The impacts of climate change on a range of economic sectors and services, such as agriculture, water, fisheries, energy, transportation, and tourism, will diminish Filipinos’ ability to enjoy, contribute to, and participate fully in the economic, social, and cultural development of the country, and will make it more difficult for the government to promote development and other economic, social, and cultural rights.° the right to 8.80. In addition to damages to human lives and livelihoods, climate impacts are causing, and will continue to cause, major monetary damages. Countries like the Philippines experience the brunt of the impacts of climate change, which pose a serious barrier to sustainable development.**7 8.81. The Philippines has already suffered major economic losses as a result of severe typhoons over the past decade, with Haiyan causing approximately $2 billion in damages.“® As stated in the Joint Summary of the Amicus Curiae, the “Asian Development Bank estimates that, under a business-as-usual emissions trajectory, the Philippines will suffer a mean loss of 2.2% of gross domestic product (GDP) by 2100 when market impacts only (mainly related to agriculture and coastal zones) are considered, a 5.7% loss if non-market impacts (mainly related to health 483 Exhibit “IIIIIM” to “HIIIIII-4,” supra note 15; also see Testimony of Ms. Honeylyn Gonzales, TSN dated 11-12 December 2018, pp. 45-59, available at http://chr.gov.ph/wp-content/uploads/2019/04/NICCTSN-December-| [-to-12-2018-Metro-Manila-Philippines.pdf (last accessed on 12 September 2019). 434 Id. ‘35 Joint Summary of the Amicus Curiae, supra note 50, p. 27. 36 Lofts, K., supra note 375, p. 6. ‘37 Press Release, World Bank, Philippines: Climate Change a Fundamental Threat to Development (May 23, 2014), available at https://www.worldbank.org/en/news/press-release/20 14/05/23/climate-change-afundamental-threat-to-development-world-bank (last accessed 06 September 2019). 98 Joint Summary of the Amicus Curiae, supra note 50, p. 27.