1 Gulf Oil Corporation (Chevron), Texaco Inc. (Chevron), and the Chevron Oil Field Research 2 Company. 3 83. In a 1970 report by H.R. Holland from the Engineering Division of Imperial Oil 4 (Exxon), he stated: “Since pollution means disaster to the affected species, the only satisfactory 5 course of action is to prevent it—to maintain the addition of foreign matter at such levels that it 6 can be diluted, assimilated or destroyed by natural processes—to protect man’s environment from 7 man.” He also noted that “a problem of such size, complexity and importance cannot be dealt with 8 on a voluntary basis.” CO2 was listed as an air pollutant in the document.54 84. 9 In 1972, API members, including Defendants, received a status report on all 10 environmental research projects funded by API. The report summarized the 1968 SRI report 11 describing the impact of Defendants’ fossil fuel products on the environment, including global 12 surface and ocean warming. Industry participants who received this report include: American 13 Standard of Indiana (BP), Asiatic (Shell), Ashland (Marathon), Atlantic Richfield (BP), British 14 Petroleum (BP), Chevron Standard of California (Chevron), Cities Service (Citgo), Continental 15 (ConocoPhillips), Dupont (former owner of Conoco), Esso Research (Exxon), Ethyl (formerly 16 affiliated with Esso, which was subsumed by Exxon Mobil), Getty (Exxon), Gulf (Chevron, among 17 others), Humble Standard of New Jersey (Exxon/Chevron/BP), Marathon, Mobil (Exxon), Pan 18 American (BP), Phillips (ConocoPhillips), Shell, Standard of Ohio (BP), Texaco (Chevron), Union 19 (Chevron), Edison Electric Institute (representing electric utilities), Bituminous Coal Research 20 (coal industry research group), Mid-Continent Oil & Gas Association (presently the U.S. Oil & 21 Gas Association, a national trade association), Western Oil & Gas Association, National Petroleum 22 Refiners Association (presently the American Fuel and Petrochemical Manufacturers Association, 23 a national trade association), Champlin (Anadarko), Skelly (Exxon), Colonial Pipeline (ownership 24 has included BP, Citgo, Exxon, ConocoPhillips, Chevron entities, among others) and Caltex 25 (Chevron), among others.55 26 27 28 SHER EDLING LLP H.R. Holland, “Pollution is Everybody’s Business,” Imperial Oil (1970), https://www.desmogblog.com/ sites/beta.desmogblog.com/files/DeSmogBlog-Imperial%20Oil%20Archive-Pollution-Everyone-Business-1970.pdf. 55 American Petroleum Institute, Environmental Research, A Status Report, Committee for Air and Water Conservation (Jan. 1972), available at http://files.eric.ed.gov/fulltext/ED066339.pdf. 54 COMPLAINT 39