Memorandum for the Petitioners | 95 The right to a balanced and healthful ecology carries with it the correlative duty to refrain from impairing the environment. . . .4!! (Emphasis supplied) 4. The right to the highest attainable standard of physical and mental health*!? 8.66. Climate change is the biggest global health threat of the twentyfirst century and could reverse five decades of progress in global health, as stated by the Lancet Commission on Health and Climate Change.* 8.67. The right to health is intimately tied to the right to life and is interconnected with the realization of other human rights. The ICESCR enshrines “the right of everyone to the enjoyment of the highest attainable standard of physical and mental health”4'* The UDHR also recognizes a right to health as part of the right to an adequate standard of living.*!° 8.68. OHCHR Citing studies from the IPCC, WHO, and other expert bodies, the has concluded that climate change negatively affects the right to health.*!® The key impacts of climate change on health include: “increases in the incidence of health-related mortality as well as heat-related respiratory and cardiovascular disease; extreme weather events and natural disasters; expanding disease vectors; nutrition deficits linked to food shortages and loss of livelihoods; violent conflict associated with resource scarcity and displacement of people due to climate change; and adverse impacts on mental health owing to the physical and mental stress caused by various climate- related phenomena (e.g., displacement from homes due to sea level rise).”4! The United Nations Environment Programme (UNEP) confirms the foregoing and observes that projected climate change scenarios will result in a range of worsening health impacts.‘!8 411 Id. 4? ICESCR, Art. 12; UDHR, Art 25; CRPD, 25. See Universal Declaration of Human Rights, Art 35 on the right to health can be found directly in some national human rights instruments and if often referred to as the right to an adequate standard of living, Article 25, UDHR), International Covenant on Economic, Social, and Cultural Rights, Art 12 on the right to the highest attainable standard of physical and mental health. Regionally, it can be found in Article 11 of Protocol of San Salvador to the Inter-American Convention on Human Rights, in Article 11 of the European Social Charter and Article 35 of the Charter of Fundamental Rights of the European Union and Article 16 of the African Charter on Human Rights and People’s Rights. “? The Lancet Commission (November 2015), Health and climate change: policy responses to protect public health, Lancet, vol. 386, issue 10006, pp. 1861—19 14, available at https://www.thelancet.com/journals/lancet/article/PIISO140-6736(15)60854-6/fulltext (last accessed 12 September 2019). “14 International Covenant on Economic, Social and Cultural Rights, Art. 12(1), Dec. 16, 1966, 993 U.N.T.S. 3 (hereinafter, “ICESCR”). > UN GAOR, 3d Sess, Supp No 13, UN Doc A/810 (1948). “6 U.N, Human Rights Office of the High Commissioner (06 May 2016)., Analytical Study on the Relationship Between Climate Change and the Human Right of Everyone to the Enjoyment of the Highest Attainable Standard of Physical and Mental Health at 45, UN Doc. A/HRC/32/23. 417 Joint Summary Amicus, supra note 50, p. 23. “18 Exhibit “PPPPPP” to “PPPPPP-11,” supra note 375, pp. 10-11.