Memorandum for the Petitioners \ A1 discussing a number of sources of pollution from petroleum fuels, Dunlop did not mention CO2 despite API’s awareness of its dangerous effects. 5.58. By 1968, Mr. Muffett testified that, the fossil fuel industry was warned repeatedly and in increasingly stark terms about the mounting scientific evidence of climate change . . . and the potential for changes to the global environment on an unprecedented and potentially catastrophic scale.”176 The API hired the Stanford Research Institute, which produced a final report, entitled “ Sources, Abundance, and Fate of Gaseous Atmospheric Pollutants,» 177 informing API that “[if ] the earth’s temperature increases significantly, a number of events might be expected to occur, including the melting of the Antarctic ice cap, a rise in sea levels, warming of the oceans, and an increase in photosynthesis.»178 r 5 .59. Importantly, the report noted that “[p]ast and present studies of CO2 are detailed and seem to explain adequately the present state of CO2 in the atmosphere. What is lacking, however, is an application of these atmospheric CO2 data to air pollution technology and work toward systems in which CO2 emissions would be brought under control.» 179 5 .60. A year later, with knowledge of the role of emissions from the use of fossil fuels in increasing temperatures, API commissioned a supplemental report to the Stanford Research Institute’s 1968 report. Mr. Muffett explained that there were “striking differences” between the two reports. 180 The 1969 supplemental report, for instance, “ omitted several paragraphs from the 1968 report that summarized the potential environmental and human impacts of climate change.” 181 r 5 .61 . In 1969, the following respondents were API members directly, or through their predecessors, subsidiaries, or affiliates: British Petroleum, Chevron, Conoco Phillips, ExxonMobil, Husky Energy, Marathon Oil, Murphy Oil, Shell Oil, Suncor, and Total. It can be assumed that membership in 1968 was similar to the 1969 list.182 The Stanford Research Institute’s reports were extensively reviewed by many of the respondents herein, making them privy to the information showing how their companies were exacerbating climate change risks. 183 Muffett, C., supra note 141, p. 16 . See Exhibit “HHH ” to “HHH- 13,” Robinson, E., and Robbins, R.C. ( 1968), Final Report (Sources, Abundance , and Fate of Gaseous Atmospheric Pollutants), prepared for the American Petroleum Institute. mId., p. 108. 179 Id. p. 112. 180 Muffett , C., supra note 141, p. 23. 181 Id 182 Id., pp. 23-24, citing http://dupontasbestosdocuments.eom /d 2 /API/ l 1517.pdf and http://dupontasbestosdocuments.eom /d 2/API / l 1518.pdf (last accessed on 12 September 2019). 183 Id., p. 24. 176 177

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