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. . . . 1 2 It is clear that we are unsure as to what our long-lived pollutants are doing to our environment; however, there seems to be no doubt that the potential damage to our environment could be severe. . . .[T]he prospect for the future must be of serious concern.50 3 4 5 81. 6 In a supplement to the 1968 report prepared for API in 1969, authors Robinson and 7 Robbins projected that based on current fuel usage, atmospheric CO2 concentrations would reach 8 370 ppm by 2000—almost exactly what it turned out to be (369.34 ppm, according to data from 9 NASA).51 The report also drew the connection between rising atmospheric CO2 concentrations 10 and the use of fossil fuels, stating that “balance between environmental sources and sinks has been 11 disturbed by the emission to the atmosphere of additional CO2 from the increased combustion of 12 carbonaceous fuels” and that it seemed “unlikely that the observed rise in atmospheric CO2 has 13 been due to changes in the biosphere.” The authors warn repeatedly of the temptations and 14 consequences of ignoring CO2 as a problem and pollutant: CO2 is so common and such an integral part of all our activities that air pollution regulations typically state that CO2 emissions are not to be considered as pollutants. This is perhaps fortunate for our present mode of living, centered as it is around carbon combustion. However, this seeming necessity, the CO2 emission, is the only air pollutant, as we shall see, that has been shown to be of global importance as a factor that could change man's environment on the basis of a long period of scientific investigation.52 15 16 17 18 82. 19 In 1969, Shell memorialized an ongoing, 18-month project to collect ocean data 20 from oil platforms to develop and calibrate environmental forecasting theories related to predicting 21 wave, wind, storm, sea level, and current changes and trends.53 Several Defendants and/or their 22 predecessors participated in the project, including Esso Production Research Company (Exxon), 23 Mobil Research and Development Company (Exxon), Pan American Petroleum Corporation (BP), 24 25 26 27 28 SHER EDLING LLP 50 Elmer Robinson & R.C. Robbins, Sources, Abundance, and Fate of Gaseous Atmospheric Pollutants, Stanford Research Institute (Feb. 1968), https://www.smokeandfumes.org/documents/document16. 51 “Global Mean CO2 Mixing Ratios (ppm): Observations,” NASA Goddard Institute for Space Studies, https://data.giss.nasa.gov/modelforce/ghgases/Fig1A.ext.txt (webpage) (accessed June 16, 2018). 52 Elmer Robinson & R.C. Robbins, Sources, Abundance, and Fate of Gaseous Atmospheric Pollutants Supplement, Stanford Research Institute (June 1969). 53 M.M. Patterson, An Ocean Data Gathering Program for the Gulf of Mexico, Society of Petroleum Engineers (1969), https://www.onepetro.org/conference-paper/SPE-2638-MS. COMPLAINT 38