Memorandum for the Petitioners |116
light in 2018,°°° that, in 1984, its products contributed 3.9% of world fossil
fuel emissions. *' While respondent Shell may have used a different
methodology (counting its refinery outputs, not equity production, and not
deducting for non-energy uses), this result not only roughly confirms but
exceeds Mr. Heede’s result for Shell in 1984: 2.1% of global fossil fuel
emissions.>
8.128. Respondent Chevron, on the other hand, disclosed to CDP that it
emitted approximately 418.4 Mt of COve during the reporting period 01
January 2014 to 31 December 2014. This is more than the total national
emissions of most individual nation-states in 2012.53
8.129. Notably, Mr. Heede highlighted that the largest component of
emissions associated with the major carbon producers — variable, but
around 90% — is from combustion of the carbon in their extracted oil,
gas, and coal.>~4
8.130.The 90 Carbon Major entities contributed to 66% of all
anthropogenic CO, from 1751 to 2016; and the 50 investor-owned Carbon
Majors are responsible for 21.4% of the of all anthropogenic CO; since 1751
through 2016.°>°
8.131. Undoubtedly, given these numbers, the Honorable Commission
can conclude that respondent Carbon Majors have significantly contributed to
climate change through their direct and product-related emissions.
The
proportional
atmospheric
carbon
increase
dioxide,
in
global
mean
surface
temperature,
and
global
sea-level
from
emissions
traced to major carbon producers is
quantifiable and substantial.
8.132.In 2017, a team of researchers and scientists from the UCS, CAI,
and Oxford University, led by Dr. Brenda Ekwurzel, Senior Climate Scientist
°° Ibid., p. 5, citing Mommers, Jelmer (16 March 2018) Advocaten in actie tegen klimaatverandering: deze
golf rechtszaken verandert de wereld (Lawyers in action against climate change: this wave of lawsuits is
changing the world), De Correspondent, available at https://decorrespondent.ni/8048/advocaten-in-actietegen-klimaatverandering-deze-golf-rechtszaken-verandert-de- wereld/886962032-c29274df (last accessed
on 12 September 2019).
5! Shell Internationale Petroleum Maatschappij (1988) The Greenhouse Effect, Confidential Report, HSE
88-001, The Hague, p. 91, available at https:/Avww.documentcloud.org/documents/4411090Document3 html#document/p32/a4 11303 (last accessed on 06 September 2019).
552
553
554
*°
Exhibit “QQQQ” to “QQQQ-11,” supra note 536, p. 5.
Joint Summary of the Amicus Curiae, supra note 50, pp. 38-39.
Heede, R., supra note 536, p. 5.
See Exhibit “TTTT-A,” Climate Accountability Institute, Press Release on Update of Carbon Majors
Project.
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