Memorandum for the Petitioners \ 64 ambitious efforts to combat and adapt to climate change, with the goal of keeping temperature rise to well-below 2°C, with aim of limiting it to 1.5°C. 5.120. Expert witness Dr. Paul Ekins, 265 Professor of Resources and Environmental Policy and Director of the Institute for Sustainable Resources at University College London, presented a paper 266 where he found that the Paris Agreement’ s revised temperature targets of keeping temperature rise to well- below 2°C” and aiming for 1.5°C will “require considerably more fossil fuels to remain unburned than has been estimated.”267 5.121. Adding to Dr. Ekin’s testimony, expert witnesses Mr. Mark Campanale and Mr. Andrew Grant of Carbon Tracker testified on their groundbreaking financial analysis, referred to as the “Carbon Bubble .” r r 5.122. Carbon Tracker’s analysis pointed to the following: respondent BP is projecting a 24% increase in oil use by 2035; respondent ExxonMobil expects a 27% increase by 2040; and respondent Shell’s Current Outlook” of 2016 forecasts an increase of 37% to 2040; and Organization of Petroleum Exporting Countries (OPEC) proposes a 54% increase to 2040 . 268 Fossil fuel companies, such as respondents ExxonMobil, BP, and Shell, have largely ignored the looming financial risk.269 5.123 . A recent study by InfluenceMap (Annex “C” hereof ) found that respondents ExxonMobil, Shell , Chevron, BP, and Total “ have invested over $1 Billion of shareholder funds in the three years following the Paris Agreement on misleading climate-related branding and lobbying.„ 270 Further, InfluenceMap stated that “[t]hese efforts are overwhelmingly in conflict with the goals of this landmark global climate accord.» 271 5 .124.Respondents Shell, Total, and Chevron challenged the InfluenceMap study’s findings, 272 yet their responses, as reported, did not provide any proof that corporate spending on lobbying and branding actually support global efforts to limit warming in line with the Paris Agreement . See Exhibit “SSSSSSSS” to “SSSSSSSS- 1 Statement of Paul Ekins, dated 28 October 2018. See Exhibit “VVVVVVVV” to “VVVVVVVV- 15,” McGlade, C. and Ekins, P. (08 January 2015), The Geographical Distribution of Fossil Fuels Unused When Limiting Global Warming to 2°C . 267 Ekins, P., supra note 265. 268 Id. . p 8. 269 Id.> p. 2. 270 Annex “C” hereof; InfluenceMap (March 2019), Big Oil's Real Agenda on Climate Change: An InfluenceMap Report, also available at https://influencemap.org/report/How-Big-Oil Continues-to-Opposethe-Paris-Agreement-382 l 2275958aa21196dae3 b76220 bddc ( last accessed on 12 September 2019). 271 Id 272 Hill , J . S. (01 April 2019), Big Oil Invested More Than SI Billion On Misleading Climate Lobbying Since Paris, CleanTechnica, available at https://cleantechnica.eom /2019/04/01/daims- big-oil-investedover- l -billion-on- misleading-climate-lobbying-since- paris-labelled-fanciful/ (last accessed on 12 September 2019). 265 266 - .

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