Amicus Curiae Brief presented by ClientEarth 21 November 2016 appropriate and agreed-upon threshold for continued emissions within which all actors (including States and private parties) should be expected to operate. 116. In issuing its findings and recommendations to the Philippine Government, the Commission should recommend that compliance with the Guiding Principles requires that the Carbon Majors prepare (in consultation with relevant stakeholders) and publish, detailed business plans describing their operations and activities in a world in which warming is kept well below 2 degrees. Such a plan would arguably satisfy the policy, due diligence and process requirements of the Guiding Principles. It would also demonstrate the ability and intention of the Carbon Majors to reduce their carbon footprint to sustainable levels that respects planetary boundaries, as well as the human rights of Filipino citizens and the millions of other citizens threatened by climate change around the world. The preparation of such a plan would not be overly burdensome on the respondent companies, and is arguably required under international human rights norms. 8 Suggested findings and recommendations 8.1 Findings 117. The Commission can, and should confidently make the following findings of fact: a. in relation to the science of climate change: i. conclusions contained in the reports of the IPCC expressed as being ‘likely’ or ‘very likely’, may be relied upon as fact (for the purposes of 56