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