1 dramatic “economic effects of ill-advised policy measures.” While the report recognized the IPCC 2 conclusions as the mainstream view, Langcake still emphasized scientific uncertainty, noting, for 3 example, that “the postulated link between any observed temperature rise and human activities has 4 to be seen in relation to natural variability, which is still largely unpredictable.” The Group position 5 is stated clearly in the report: “Scientific uncertainty and the evolution of energy systems indicate 6 that policies to curb greenhouse gas emissions beyond 'no regrets' measures could be premature, 7 divert resources from more pressing needs and further distort markets.”100 121. 8 In 1991, for example, the Information Council for the Environment (“ICE”), whose 9 members included affiliates, predecessors and/or subsidiaries of Defendants, including Pittsburg 10 and Midway Coal Mining (Chevron), and Island Creek Coal Company (Occidental), launched a 11 national climate change science denial campaign with full-page newspaper ads, radio commercials, 12 a public relations tour schedule, “mailers,” and research tools to measure campaign success. 13 Included among the campaign strategies was to “reposition global warming as theory (not fact).” 14 Its target audience included older less-educated males who are “predisposed to favor the ICE 15 agenda, and likely to be even more supportive of that agenda following exposure to new 16 information.”101 122. 17 An implicit goal of ICE’s advertising campaign was to change public opinion and 18 avoid regulation. A memo from Richard Lawson, president of the National Coal Association asked 19 members to contribute to the ICE campaign with the justification that “policymakers are prepared 20 to act [on global warming]. Public opinion polls reveal that 60% of the American people already 21 believe global warming is a serious environmental problem. Our industry cannot sit on the 22 sidelines in this debate.”102 23 24 25 100 26 27 28 SHER EDLING LLP P. Langcake, The Enhanced Greenhouse Effect: A review of the Scientific Aspects, (Dec. 1994), https://www.documentcloud.org/documents/4411099-Document11.html#document/p15/a411511. 101 Union of Concerned Scientists, Deception Dossier #5: Coal’s “Information Council on the Environment” Sham, (1991), http://www.ucsusa.org/sites/default/files/attach/2015/07/Climate-Deception-Dossier-5_ICE.pdf. 102 Naomi Oreskes, My Facts Are Better Than Your Facts: Spreading Good News about Global Warming (2010), in Peter Howlett et al., How Well Do Facts Travel?: The Dissemination of Reliable Knowledge, 136–66. Cambridge University Press. doi:10.1017/CBO9780511762154.008.8 COMPLAINT 54