Memorandum for the Petitioners |115 1,023 GtCOQ», or 66% from 1751 to 2016; c) The of all anthropogenic direct and _ CO, product-related emissions of the 50°‘ investor-owned companies total 368 GtCOve (21.4%), the 36 state-owned companies total 357 GtCOze (20.8%), and to government-run industries total 408 GtCO2e (23.8%); historical emissions not traced to the 90 Carbon Majors total 585 GtCOye (34%); d) The carbon fuels produced by the top twenty investor-owned fossil fuel companies contributed to 30% of all global industrial COze from 1751 to 2016; e) The carbon fuels produced by the investor-owned fossil fuel companies contributed to one-third of all global industrial CO2e from 1751 to 2016; and f) Half of all industrial CO. emissions since 1751 have been emitted since 1989.54 8.126.According to Mr. Heede, respondents Royal Dutch Shell, Chevron, Statoil, Total, Hess, BP, and ConocoPhillips do estimate and submit to the carbon accounting non-profit organization Carbon Disclosure Project (“CDP”) their product-related emissions (respondent ExxonMobil only estimates emissions for products sold in New Zealand, USA, and Quebec).> Although each company’s methodology differs, they are roughly comparable to Mr. Heede’s internally consistent methodology.**” CDP and CAI collaborated on a “guidance methodology report for calculating emissions from carbon production by fuel. 8.127. Significantly, though not subsequent to Mr. Heede’s results, respondent Shell estimated in a 1988 confidential report,>*? which came to +44 See supra note 17. 549 Exhibit “TTTT-A,” Climate Accountability Institute, Press Release on Update of Carbon Majors Project, pp. 1-2. 46 Exhibit “QQQQ” to “QQQQ-11,” supra note 536, p. 5. 547 Ibid, p. 5. “8 Jbid., p. 5, citing Griffin, Paul, Richard Heede, & Ian van der Vlugt (2017), The Carbon Majors Database: Methodology Report 2017, CDP & CAI, March, p. 9. 5” Ibid., p. 5, citing Shell Internationale Petroleum Maatschappij (1988) The Greenhouse Effect, Confidential Report, HSE 88-001, The Hague, p. 91, available at https://www.documentcloud.org/documents/44 1 1090-Document3.html#document/p32/a4 11303 (last accessed on 12 September 2019).

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