1 3 It is ironic that the biggest uncertainties about the CO2 buildup are not in predicting what the climate will do, but in predicting what people will do. . . .[It] appears we still have time to generate the wealth and knowledge we will need to invent the transition to a stable energy system. 4 103. 2 Throughout the early 1980s, at Exxon’s direction, Exxon climate scientist Henry 5 Shaw forecasted emissions of CO2 from fossil fuel use. Those estimates were incorporated into 6 Exxon’s 21st century energy projections and were distributed among Exxon’s various divisions. 7 Shaw’s conclusions included an expectation that atmospheric CO2 concentrations would double in 8 2090 per the Exxon model, with an attendant 2.3–5.6º F average global temperature increase. Shaw 9 compared his model results to those of the U.S. EPA, the National Academy of Sciences, and the 10 Massachusetts Institute of Technology, indicating that the Exxon model predicted a longer delay 11 than any of the other models, although its temperature increase prediction was in the mid-range of 12 the four projections.86 104. 13 During the 1980s, many Defendants formed their own research units focused on 14 climate modeling. The API, including the API CO2 Task Force, provided a forum for Defendants 15 to share their research efforts and corroborate their findings related to anthropogenic greenhouse 16 gas emissions.87 105. 17 During this time, Defendants’ statements express an understanding of their 18 obligation to consider and mitigate the externalities of unabated promotion, marketing, and sale of 19 their fossil fuel products. For example, in 1988, Richard Tucker, the president of Mobil Oil, 20 presented at the American Institute of Chemical Engineers National Meeting, the premier 21 educational forum for chemical engineers, where he stated: [H]umanity, which has created the industrial system that has transformed civilities, is also responsible for the environment, which sometimes is at risk because of unintended consequences of industrialization. . . . Maintaining the health of this life-support system is emerging as one of the highest priorities. . . .[W]e must all be environmentalists. 22 23 24 25 The environmental covenant requires action on many fronts…the low-atmosphere ozone problem, the upper-atmosphere ozone problem and the greenhouse effect, to 26 27 28 SHER EDLING LLP 86 87 Banerjee, More Exxon Documents Show How Much It Knew About Climate 35 Years Ago, supra note 77. Banerjee, Exxon’s Oil Industry Peers Knew About Climate Dangers in the 1970s, Too, supra note 620. COMPLAINT 47