Amicus Curiae Brief presented by ClientEarth 21 November 2016 concentration of greenhouse gasses in the atmosphere that ultimately impacts anthropogenic warming. 86. This concept is the basis of emissions trading schemes around the world. It also has implications for the Commission's investigation, because it means that all emissions from various sources all around the world since reliable temperature records exist (1850) have contributed equally to the phenomena of global warming. It also means that for the purposes of investigation of the contributions of various parties to climate change, on a global basis, the total quantities of carbon dioxide equivalent emissions emitted by different actors since 1850 may be used as the basis for attributing responsibility among States, or private parties. This approach is well accepted by the scientific community, industry, States and civil society and is used as the basis of the calculation of projected future emissions. 87. The fungibility of greenhouse gas emissions has important implications for the development of liability and responsibility of States and private actors for the loss and damages associated with climate change. The Commission should take this into account when considering the responsibility of the Carbon Majors and its associated recommendations. 7 Evidence of the contribution of the Carbon Majors 88. As previously discussed, in the context of determining the Carbon Majors’ responsibility for the human rights implications of climate change, it would be inappropriate for the honourable Commission to apply strict tests of legal causation. 43