1 name a few. . . .Our strategy must be to reduce pollution before it is ever generated – to prevent problems at the source. 2 Prevention means engineering a new generation of fuels, lubricants and chemical products…. Prevention means designing catalysts and processes that minimize or eliminate the production of unwanted byproducts. . . .Prevention on a global scale may even require a dramatic reduction in our dependence on fossil fuels—and a shift towards solar, hydrogen, and safe nuclear power. It may be possible that—just possible—that the energy industry will transform itself so completely that observers will declare it a new industry. . . .Brute force, low-tech responses and money alone won’t meet the challenges we face in the energy industry.88 3 4 5 6 7 8 106. Also in 1988, the Shell Greenhouse Effect Working Group issued a confidential 9 internal report, “The Greenhouse Effect,” which acknowledged global warming’s anthropogenic 10 nature: “Man-made carbon dioxide released into and accumulated in the atmosphere is believed to 11 warm the earth through the so-called greenhouse effect.” The authors also noted the burning of 12 fossil fuel as a primary driver of CO2 buildup and warned that ocean warming would impact marine 13 species populations and that “shifts in ranges and migration patterns could result in local losses of 14 food source revenues, and could require [fishing] operations in other (more distant) grounds.”89 15 107. Similar to early warnings by Exxon scientists, the Shell report notes that “by the 16 time the global warming becomes detectable it could be too late to take effective countermeasures 17 to reduce the effects or even to stabilize the situation.” The authors mention the need to consider 18 policy changes on multiple occasions, noting that “the potential implications for the world are…so 19 large that policy options need to be considered much earlier” and that research should be “directed 20 more to the analysis of policy and energy options than to studies of what we will be facing 21 exactly.”90 22 108. In 1991, Shell produced a film called “Climate of Concern.” The film advises that 23 while “no two [climate change projection] scenarios fully agree…[they] have each prompted the 24 same serious warning. A warning endorsed by a uniquely broad consensus of scientists in their 25 26 27 28 SHER EDLING LLP 88 Richard E. Tucker, High Tech Frontiers in the Energy Industry: The Challenge Ahead, AIChE National Meeting (Nov. 30, 1988), available at https://hdl.handle.net/2027/pur1.32754074119482?urlappend=%3Bseq=522. 89 Shell Internationale Petroleum Greenhouse Effect Working Group, The Greenhouse Effect (May 30, 1988), https://www.documentcloud.org/documents/4411090-Document3.html#document/p9/a411239. 90 Id. COMPLAINT 48