1
redistribution of harmful algal blooms around the world,39 including Pseudo-nitzschia blooms on
2
the west coast.
3
C.
Attribution
4
66.
“Carbon factors” analysis, devised by the International Panel on Climate Change
5
(IPCC), the United Nations International Energy Agency, and the U.S. Environmental Protection
6
Agency, quantifies the amount of CO2 emissions attributable to a unit of raw fossil fuel extracted
7
from the ground.40 Emissions factors for oil, coal, liquid natural gas, and natural gas are different
8
for each material but are nevertheless known and quantifiable for each. 41 This analysis accounts
9
for the use of Defendants’ fossil fuel products, including non-combustion purposes that sequester
10
CO2 rather than emit it (e.g., production of asphalt).
11
67.
Defendants’ historical and current fossil fuel extraction and production records are
12
publicly available in various fora. These include university and public library collections, company
13
websites, company reports filed with the U.S. Securities and Exchange Commission, company
14
histories, and other sources. The cumulative CO2 and methane emissions attributable to
15
Defendants’ fossil fuel products were calculated by reference to such publicly available
16
documents.
17
68.
While it is possible to distinguish CO2 derived from fossil fuels from other sources,
18
it is not possible to determine the source of any particular individual molecule of CO2 in the
19
atmosphere attributable to anthropogenic sources because such greenhouse gas molecules do not
20
bear markers that permit tracing them to their source, and because greenhouse gasses quickly
21
diffuse and comingle in the atmosphere. However, cumulative carbon analysis allows an accurate
22
calculation of net annual CO2 and methane emissions attributable to each Defendant by quantifying
23
the amount and type of fossil fuels products each Defendant extracted and placed into the stream
24
of commerce, and multiplying those quantities by each fossil fuel product’s carbon factor.
25
26
39
27
28
SHER
EDLING LLP
See Cristopher J. Gobler, et al., Ocean warming since 1982 has expanded the niche of toxic algal blooms in the
North Atlantic and North Pacific oceans, Proceedings of the National Academy of Sciences (March 23, 2017).
40
See Richard Heede, Tracing Anthropogenic Carbon Dioxide and Methane Emissions to Fossil Fuel and Cement
Producers, 1854–2010, CLIMATIC CHANGE 122, 232–33 (2014).
41
See, e.g., id.
COMPLAINT
34
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