The gap between 1.5 and 4C is the difference between life and death on a vast scale. The Paris Agreement does not impose accountability for meeting the target of 1.5 or ‘well below’ 2C and it is the premise of Plan B that without accountability the target is unlikely to be met. Plan B’s principle objective it to support judicial and other processes, which advance accountability for climate change (and consequently enhance the prospects of avoiding ‘looming catastrophe’). Recognising the scientific, legal and economic complexities that risk obscuring the attribution of responsibility, Plan B, develops analysis and resources to assist lawyers, courts and others. I, Timothy Crosland, the undersigned, am the Director of Plan B, and a barrister-atlaw, qualified in England and Wales. I hold an LLM in International Human Rights Law from the University of Utrecht. I have advised numerous governmental organisations on their human rights obligations. For a time I was Head of Legal at what was the UK’s National Criminal Intelligence Service (NCIS). In the course of this role I advised on matters such as the handling of human informants overseas, international kidnap situations and the sharing of intelligence with foreign military organisations. Such situations demanded a detailed knowledge of human rights law and its cross-border application, including in particular the ‘right to life’. I have led various projects to support developing countries in implementing legal frameworks, working with amongst others the Governments of Kenya, Ghana and Nigeria. My understanding of human rights is informed by a combination of academic research, practical experience and work in a range of different jurisdictions. These proceedings address matters that have been subject to consideration in different fora around the world. The intention of this amicus curiae brief is to supply the Honourable Commission with international jurisprudence and other materials, in the hope that they will be of assistance in resolving the issues for its determination. It does not constitute legal advice. 2. Jurisdiction 2.1 ‘The effects doctrine’, the ‘no harm principle’ and the duty to safeguard human rights Climate change is cross-border in nature and it is common for ‘climate change litigation’ to raise questions of jurisdiction. One principle of general application is ‘the effects doctrine’, which gives states jurisdiction over conduct, which has impacts within their territory, even where the conduct itself takes place beyond their borders. In United States v Aluminum Co of America (Alcoa)1, for example, the US Court of Appeals “held that it was settled law...that any state may impose liabilities...for 1 148 F.2d 416 (2d Cir. 1945) 3