Memorandum for the Petitioners | 64 ambitious efforts to combat and adapt to climate change, with the goal of keeping temperature rise to well-below 2°C, with aim of limiting it to 1.5°C. 5.120.Expert witness Dr. Paul Ekins,*® Professor of Resources and Environmental Policy and Director of the Institute for Sustainable Resources at University College London, presented a paper” where he found that the Paris Agreement’s revised temperature targets of keeping temperature rise to “well-below 2°C” and aiming for 1.5°C will “require considerably more fossil fuels to remain unburned than has been estimated.”?°7 5.121.Adding to Dr. Ekin’s testimony, expert witnesses Mr. Mark Campanale and Mr. Andrew Grant of Carbon Tracker testified on their groundbreaking financial analysis, referred to as the “Carbon Bubble.” 5.122.Carbon Tracker’s analysis pointed to the following: respondent BP is projecting a 24% increase in oil use by 2035; respondent ExxonMobil expects a 27% increase by 2040; and respondent Shell’s “Current Outlook” of 2016 forecasts an increase of 37% to 2040; and Organization of Petroleum Exporting Countries (OPEC) proposes a 54% increase to 2040.7 Fossil fuel companies, such as respondents ExxonMobil, BP, and Shell, have largely ignored the looming financial risk.?° 5.123.A recent study by InfluenceMap (Annex “C” hereof) found that respondents ExxonMobil, Shell, Chevron, BP, and Total “have invested over $1 Billion of shareholder funds in the three years following the Paris Agreement on misleading climate-related branding and lobbying.” 2” Further, InfluenceMap stated that “[t]hese efforts are overwhelmingly in conflict with the goals of this landmark global climate accord.”2”! 5.124.Respondents Shell, Total, and Chevron challenged the InfluenceMap study’s findings, ?” yet their responses, as reported, did not provide any proof that corporate spending on lobbying and branding actually support global efforts to limit warming in line with the Paris Agreement. 265 See Exhibit “SSSSSSSS” to “SSSSSSSS-1,” Statement of Paul Ekins, dated 28 October 2018. 266 See Exhibit “VVVVVVVV”" to “VVVVVVVV-15,” McGlade, C. and Ekins, P. (08 January 2015), The Geographical Distribution of Fossil Fuels Unused When Limiting Global Warming to 2°C. 267 Ekins, P., supra note 265. 268 Id. p. 8. 269 Id. p.2. 279 Annex “C” hereof; InfluenceMap (March 2019), Big Oil’s Real Agenda on Climate Change: An InfluenceMap Report, also available at https://influencemap.org/report/How-Big-Oil-Continues-to-Opposethe-Paris-Agreement-382 12275958aa21 196dae3b76220bddc (last accessed on 12 September 2019). 271 Td. 2? Hill, J. S. (01 April 2019), Big Oil Invested More Than $1 Billion On Misleading Climate Lobbying Since Paris, CleanTechnica, available at https://cleantechnica.com/2019/04/0 l/claims-big-oil-investedover-1-billion-on-misleading-climate-lobbying-since-paris-labelled-fanciful/ (last accessed on 12 September 2019).