Memorandum for the Petitioners |154 ensures a just transition for the workers and communities that depend on it;7!? j) The respondents have a responsibility to stop investing in and developing all new fossil fuel projects (oil and gas fields and coal mines);””° A.6.2. Remedying loss and damage k) Filipino communities are already being harmed by climate change. Even with the best possible future mitigation efforts, vulnerable countries such as the Philippines will still have to deal with significant loss and damage; b The government of the Philippines, local government units, and taxpayers are covering the significant costs of climate change;””! and m) Respondents should pay for their fair share of the damage that is occurring at 1°C and will continue to occur even if temperature rise is kept to 1.5°C above pre-industrial levels. A.7. Findings principles concerning of responsibility legal fundamental and moral a) | Under fundamental principles of responsibility that are common to judicial systems around the world, liability for civil and/or human rights wrongs can be established by demonstrating: i) knowledge or notice of potential harms, including whether the harms were reasonably foreseeable; ii) the opportunity to avoid or reduce those harms; and iii) whether the actions or inactions of the respondents caused or contributed to the harm;’”” 119 Muttitt, G. The Sigy’s Limit: Why the Paris Climate Goals Require a Managed Decline of Fossil Fuel Production, Oil Change International, available at http://priceofoil .org/2016/09/22/the-skys-limit-report/ (last accessed on 12 September 2019). 720 la. 721 As an example, see the estimated cost of super typhoon Haiyan in this official report made by the National Disaster Risk Reduction and Management Council (06-09 November 2013), Final Report re Effects of Typhoon “Yolanda” (Haiyan), available at http://www.ndrrmce.gov.ph/attachments/article/1329/FINAL_REPORT_re_Effects_of_Typhoon_YOLAND A_HAIYAN_06-09NOV2013.pdf (last accessed on 12 September 2019) and also see Rupp, L., (18 November 2013), Haiyan to Cost Insurers Sliver of $14.5 Billion Estimated Damage, available at https://www.bloomberg.com/news/articles/2013-11-17/haiyan-to-cost-insurers-sliver-of- 14-5-billion- damage-estimate (last accessed on 12 September 2019). 72 Muffett, C., supra note 141, pp. 9-13.