to the carbon accounting NGO CDP that it emitted approximately 418.4 Mt of CO 2e during the reporting period 1 January 2014 - 31 December 2014. This is more than the total national emissions of most individual nation-states in 2012. 181 V. Prescriptions for Achieving International Commitments and Climate Recovery A. Prescription to achieve the Paris Agreement’s long-term temperature goals (ClientEarth, Plan B) Under the Paris Agreement, parties have agreed to hold the increase in global average temperature to “well below” 2°C above pre-industrial levels, and “pursue efforts” to limit this increase to 1.5°C above pre-industrial levels. 182 These temperature goals imply that there is a finite quantity of GHGs that may be emitted into the atmosphere, above which the temperature goal(s) will be exceeded. “Carbon budget” is the established terminology used to refer to the calculation of the total (i.e., not country or emitter-specific) quantity of GHGs (in carbon dioxide equivalent) the atmosphere can accommodate before exceeding these temperature goals. In order to achieve these temperature goals, the Paris Agreement commits countries to the submission and implementation183 of nationally determined emissions reduction targets (known as NDCs).184 However, the Parties to the Paris Agreement have acknowledged that their intended NDCs were insufficient in the aggregate to meet either the 2 or 1.5°C temperature goal, 185 and a June 2016 article in Nature found that current NDCs will result in median warming of 2.6–3.1°C by 2100.186 There are a number of approaches to determining each country’s remaining carbon budget, so as to allow countries to ramp up their existing NDCs under the Paris Agreement to meet the temperature goals in Article 2 of the Agreement. One approach would be to distribute the remaining budget on the basis of per capita shares (on the principle that no one person has a right to consume a greater share of the atmosphere’s storage capacity than any other). Such a division produces an equalizing effect of “contraction and convergence.” 187 There are two obvious objections to this approach. First, developing countries may argue that an even distribution of the remaining carbon budget fails to account for or reflect historic 181 Calculated by reference to the CAIT Climate Data Explorer. See Historical Emissions, CAIT CLIMATE DATA EXPLORER, HTTP://CAIT.WRI.ORG/HISTORICAL/COUNTRY%20GHG%20EMISSIONS? INDICATOR[]=TOTAL%20GHG%20EMISSION S%20EXCLUDING%20LANDUSE%20CHANGE%20AND%20FORESTRY&INDICATOR[]=TOTAL%20GHG%20EMISSIONS%20INCLUDING%20LANDUSE%20CHANGE%20AND%20FORESTRY&YEAR[]=2012&SORTIDX=NAN&CHARTTYPE=GEO. 182 ClientEarth brief, at ¶¶ 58-60. 183 Arguably implied under Article 4(2). Paris Agreement, Art. 4(2), Dec. 12, 2015, T.I.A.S. No. 16-1104. 184 ClientEarth brief, at ¶57. 185 UN Framework Convention on Climate Change, Report of the Conference of the Parties on its twenty-first session, Decision 1/CP.21: Adoption of the Paris Agreement, ¶17 (Dec. 12, 2015); ClientEarth brief, at ¶ 62. 186 Joeri Rogelj et al., Paris Agreement climate proposals need a boost to keep warming well below 2°C, 534 NATURE 631–639 (2016), http://www.nature.com/nature/journal/v534/n7609/abs/nature18307.html; ClientEarth brief, at ¶ 65. 187 Plan B brief, at § 7 (pgs. 50-51). 39