taking action to address climate change.123 While the preamble is not part of the Agreement’s operative provisions, the preambular language should guide the interpretation of those provisions124 and lends support to national climate efforts, such as this Petition. The Petitioners recognize the leading role of the Philippine delegation, skilfully led by Secretary and Vice Chairperson of the Philippine Climate Change Commission, Emmanuel M. de Guzman, played in ensuring human rights are a bedrock principle of the Paris Agreement.125 b. Climate Cases and Investigations There are a number of climate-related legal actions, cases, and investigations that are similar or relevant to or have a bearing in this Petition. The developments fall into two categories: (1) legal developments challenging government action or lack thereof concerning climate policy and practices; and (2) legal developments challenging corporate activities concerning climate harm and corporate knowledge of the threats of climate change. As climate law develops and the harms associated with climate change intensify, those harmed will continue pursue claims using various legal theories, e.g. negligence and product liability, and rules to assign liability, e.g. market share approach, material contribution test, globally detectable emissions, significant contribution, co-mingled contribution approaches.126 The following section provides an overview of recent developments, including the procedural status of the actions, the claims made, and the dispositions (if applicable). The Petitioners anticipate the developments in the area of climate law to continue at a rapid pace and will update the Honorable Commission as necessary and appropriate. !!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 123 Id. C. Schwarte, Legal Response Initiative, Preliminary Legal Assessment of the Paris Agreement, Dec. 14, 2015, http://legalresponseinitiative.org/preliminary-legal-assessment-of-the-paris-agreement/ (last accessed on Apr. 19, 2016). 125 P. Ranada, PH on Paris Climate Pact: Monumental Feat for Humanity, Rappler, Dec. 13, 2015, http://www.rappler.com/nation/115821-philippines-paris-agreement-climate-change (last accessed on Apr. 19, 2016). 126 See A. Gage and M. Byers, Payback Time: What the Internationalization of Climate Change Litigation Means for Canadian Oil and Gas Companies, West Coast Environmental Law and Canadian Centre for Policy Alternatives, at 6, 20-22, Oct. 2014, http://wcel.org/sites/default/files/publications/Payback%20Time.pdf (last accessed on Apr. 19, 2016); A. Gage, Climate Change Litigation and the Public Right to a Healthy Atmosphere, 24 J. ENV. L. & PRAC. 257 (Nov. 12, 2015). 124 ! ! ! ! ! 49 !