Memorandum for the Petitioners |110
have
no meaningful
way
of protecting
themselves
from
the
situation in which States and Carbon Majors have placed them.>'9
dangerous
8.115. The UN Human Rights Council observed that “children [...] are
among the groups most vulnerable to the adverse impacts of climate change,
which may seriously affect their enjoyment of the highest attainable standard
of physical and mental health, access to education, adequate food, adequate
housing, safe drinking water and sanitation.”
8.116. As noted in the Our Children’s Trust Amicus Brief: “the current
generation of children are developing into adults as States fail to address the
causes of climate change; they live their lives in a time of increasing climate
instability under threat of increasingly frequent and severe extreme weather
events,
increasing
ocean
acidification,
loss
of coastline
and
even
entire
geographic regions to rising sea levels, rising rates of epidemiological disease,
dislocation, and social disruption.”>!
8.117. Indeed, children are particularly vulnerable to the impacts of
climate change, due primarily to three interconnected factors. Firstly,
childhood represents a unique period of rapid physical and mental
development, particularly between birth and the age of five. During that time,
children's bodies are most vulnerable to the conditions of climate change and
environmental
risks. °°? As
such,
children
“experience
distinct
and
disproportionate harm from climate-induced changes in their environment,
including impacts with potentially lifelong consequences,” as stated in the
UNICEF Amicus Brief.>3
8.118. Secondly, children make up one of the largest groups affected by
climate change, as many of the countries identified as the most vulnerable to
the impacts of climate change are also those in which children account for a
disproportionately large share of the overall population.*24 While all children
will ultimately suffer from the risks of climate-induced harm, not all children
are affected equally. Areas most exposed to the impacts of climate change
frequently overlap with areas of high poverty, exacerbating inequality and
further undermining the ability of poor children to cope and take advantage of
opportunities for their development.
http://www.ciel.org/wp-content/uploads/20 18/0 1/HRTBs-synthesis-report-CRC.pdf (providing a recent
summary of authoritative statements), (last accessed 06 September 2019), cited in Joint Summary of the
Amicus Curiae, supra note 50, p. 28.
3!9 Joint Amicus of the Amicus Curiae, supra note 50, p. 10.
9 UN General Assembly, Human Rights Council Res. 35/20 (19 June 2017), Human Rights and Climate
Change, para. 15.
31 Ibid. p. 12.
>” Testimony of Joni Pengram, TSN dated 6-7 November 2018, p. 4, available at http://chr.gov.ph/wpcontent/uploads/2019/04/NICC-TSN-November-6-to-7-London-United-Kingdom.pdf (last accessed on 12
September 2019).
53 Amicus Curiae Brief submitted by UNICEF, supra note 45.
524 Pengram. J. supra note 522.
525 hid.
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