7 how they are being affected by climate change. Improvements of this kind, for example, enabled Peruvian farmer Saul Luciano Lliuya to document how glacial melting driven by climate change threatened to flood his farm and his community—and to demonstrate the likely impacts of that flooding with high resolution maps. Using this data, Mr. Luciano has brought suit against German Carbon Major RWE, in German courts, to abate the nuisance created by climate change.5 This finer resolution also enabled cities like San Francisco and Oakland to more precisely assess how sea level rise would affect their municipalities, and to identify the types and scale of infrastructure investments required to respond.6 From a litigation perspective, advances in attribution science are even more significant in the context of extreme events and climate-fueled disasters, of which Typhoon Haiyan is a prime example.7 Heat waves, droughts, wildfires, severe storms, floods and typhoons are all natural phenomena subject to significant natural variability. For decades, scientists have predicted that all of these events could become more frequent or more severe in the face of climate change, with massive consequences for property, communities and human lives. Until recently, however, it was difficult to distinguish the climate signal from the natural variation in a way that would allow scientists to say with confidence that this flood or that storm was a result of climate change. As expert testimony in the present inquiry demonstrates, however, it is increasingly possible to distinguish and quantify the impact of climate change on such events—whether it’s the increased number of wildfire days in the US west8 or the increased energy fueling cyclones from climate-warmed seas. In light of this emerging science, the degree to which once natural disasters are ever more unnatural is becoming increasingly clear, and with it the legally significant distinction between random acts of nature and foreseeable consequences of human actions. 5 Lliuya v. RWE A.G., Case No. 2 O 285/15 Essen Regional Court (2015). San Francisco v. BP, Chevron Corp., Exxon Mobil Corp., Royal Dutch Shell PLC and ConocoPhillips, CGC-17-561-370, Superior Court of the State of California, Counties of San Francisco and Alameda (Filed 09/19/17), removed to U.S. District Court for the Northern District of California (No. C 17-06012 WHA); Oakland v. BP, Chevron Corp., Exxon Mobil Corp., Royal Dutch Shell PLC and ConocoPhillips, RG-17-875-889, Superior Court of the State of California, Counties of San Francisco and Alameda (Filed 09/19/17) removed to U.S. District Court for the Northern District of California (No. C 17-06011 WHA). Both cases dismissed 06/25/18, pending appeal. 7 Amicus Curiae Brief submitted by Kevin E. Trenberth, 4, https://businesshumanrights.org/sites/default/files/documents/Kevin%20E%20Trenberth.pdf; Joint Summary of Amicus Curiae, at 36-38, available online at https://www.ciel.org/wpcontent/uploads/2018/03/Joint-Summary-Amicus-submitted.pdf. 8 See, e.g., John T. Abatzoglou, A. Park Williams, Impact of anthropogenic climate change on wildfire across western US forests. Proceedings of the National Academy of Sciences Oct 2016, 113 (42) 11770-11775; DOI: 10.1073/pnas.1607171113, available online at http://www.pnas.org/content/113/42/11770; Brian J. Harvey, Human-caused climate change drives forest fires, Proceedings of the National Academy of Sciences Oct 2016, 113 (42) 1164911650; DOI: 10.1073/pnas.1612926113 , available online at http://www.pnas.org/content/113/42/11649.short. 6