Memorandum for the Petitioners 1114 — sources) have been emitted since 1989.537 This date is notable because it is after the First World Climate Conference in 1979 and the Toronto Conference on the Changing Atmosphere in 1988, which set into place the global political process on climate change.538 8.125.3. The 90 “Carbon Majors” included 50 investor-owned producers of oil, gas, coal, and cement, such as Chevron, Peabody, BP, ExxonMobil, BHP Billiton, and Royal Dutch Shell; 31 state-owned entities producers, such as Saudi Aramco, Gazprom, Nigerian National Petroleum , and Coal India; and 9 former or current government-run coal producing entities, such as those in Poland, the former Soviet Union , Kazakhstan, North Korea, and China.539 8.125.4. The Carbon Majors publications were thoroughly vetted and peer-reviewed .540 Mr. Heede’s analysis is based on company-data (SEC Foim 10-Ks or Annual Reports), and a robust and peer-reviewed methodology. There is little room for disputing his results except for relatively minor uncertainties and variables that mostly arise from lack of company-reported data (e.g., historical data on their own fuel use, flaring rates, vented CO2, methane leakage rates, etc.).541 r — 8.125.5. In 2018, Mr. Heede updated542 the “activity data” (annual production of fossil fuels and cement ) to include 2015 and 2016.543 The key findings in this update are as follows: Global emissions of carbon dioxide from all anthropogenic industrial sources (fossil fuel and cement) totals 1,545 billion metric tonnes CO2 (GtCO?) from 1751 to 2016; a) C b) The direct and product-related emissions of the 90 Carbon Major entities total ibid. Zillman , J., A History of Climate Activities, available at https://public.wmo.int/en/bulletin/historyclimate-activities (last accessed on 12 September 2019). 539 Ibid\ 540 Testimony of Mr. Richard Heede, TSN dated 27-28 August 2018, pp. 77-81, available at http://chr.go v.ph/wp-content/uploads/2019/04/NICC-TSN-August-29-to-30-2018-Metro-Mani laPhilippines.pdf (last accessed on 12 September 2019). 541 Exhibit “QQQQ” to “QQQQ- 11 ” supra note 536, p. 4. 542 See Exhibit “TTTT-A,” Climate Accountability Institute, Press Release on Update of Carbon Majors Project (20 IS ), pp. 1-2. 543 The update was based on data collected in company Form 10-Ks, Annual Reports, or standard industry sources in 2015-2016 . The original Heede 2014 paper had activity data through 2010. No methodological changes were made, with the exception that Mr. Heede and his team adopted the IPCC global wanning potential of methane to 28 times CO2 ( 100-year time horizon) per IPCC’s Fifth Assessment Report (the previous value was 21 xCOz); Also see Exhibit “QQQQ” to “QQQQ- 11,” supra note 536, p. 6. 537 538

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