1
level rise. Those design changes were ultimately carried out by Shell’s contractors, adding
2
substantial costs to the project.129
a.
3
The Troll field, off the Norwegian coast in the North Sea, was proven to
4
contain large natural oil and gas deposits in 1979, shortly after Norske Shell
5
was approved by Norwegian oil and gas regulators to operate a portion of
6
the field.
b.
7
In 1986, the Norwegian parliament granted Norske Shell authority to
8
complete the first development phase of the Troll field gas deposits, and
9
Norske Shell began designing the “Troll A” gas platform, with the intent to
10
begin operation of the platform in approximately 1995. Based on the very
11
large size of the gas deposits in the Troll field, the Troll A platform was
12
projected to operate for approximately 70 years.
c.
13
The platform was originally designed to stand approximately 100 feet above
14
sea level—the amount necessary to stay above waves in a once-in-a-century
15
strength storm.
d.
16
In 1989, Shell engineers revised their plans to increase the above-water
17
height of the platform by 3–6 feet, specifically to account for higher
18
anticipated average sea levels and increased storm intensity due to global
19
warming over the platform’s 70-year operational life.130
e.
20
Shell projected that the additional 3–6 feet of above-water construction
would increase the cost of the Troll A platform by as much as $40 million.
21
22
G.
Defendants’ Actions Prevented the Development of Alternatives That Would
Have Eased the Transition to a Less Fossil Fuel Dependent Economy.
149.
The harms and benefits of Defendants’ conduct can be balanced in part by weighing
23
24
25
the social benefit of extracting and burning a unit of fossil fuels against the costs that a unit of fuel
26
imposes on society, known as the “social cost of carbon” or “SCC.”
27
129
28
SHER
EDLING LLP
Greenhouse Effect: Shell Anticipates A Sea Change, N.Y. TIMES (Dec. 20,
http://www.nytimes.com/1989/12/20/business/greenhouse-effect-shell-anticipates-a-sea-change.html.
130
Id.; Lieberman & Rust, Big Oil braced for global warming while it fought regulations, supra note 123.
COMPLAINT
1989)
65
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