Memorandum for the Petitioners | 45 climate risks created by those emissions. At an event marking the 100" anniversary of the oil industry at Columbia University, Mr. Teller said: It has been calculated that a temperature rise corresponding to a 10 per cent increase in carbon dioxide will be sufficient to melt the icecap and submerge New York. All the coastal cities would be covered [in water] ... I think that this chemical contamination is more serious than most people tend to believe.'® 5.51. Based on the archival documents he retrieved, Dr. Franta concluded that even before the Keeling Curve (a graph of carbon dioxide concentrations in the atmosphere) was published in the 1960s, “oil industry leaders were aware that their products were causing CO pollution to accumulate in the planet’s atmosphere in a potentially dangerous fashion.”!@ 2. 1960s 5.52. Respondent Shell fossil fuel products in causing decades ago -- with the Chief producing a lengthy report was individually on notice of the role of its climate change no later than 1962 -- five Consulting Geologist, Marion King Hubbert, that Mr. Muffett noted, “bears striking similarities to global climate models released even many years later.”! 5.53. Mr. Hubbert’s report also describes a 1961 presentation by Yale University Professor, Evelyn Hutchinson, that concluded, “[t]here is evidence that the greatly increasing use of the fossil fuels . . . is seriously contaminating the earth’s atmosphere with CO2.”!® Mr. Hubbert notes that CO2may already be producing “climatic change in the direction of higher average temperatures. This could have profound effects both on the weather and on the ecological balance.”'%° Hubbert also recounts Professor Hutchinson’s urging of “serious consideration of the maximum utilization of solar energy.”!®’ This means that respondent Shell was aware, or should have been aware, of the need to shift to renewable energy five decades ago. ‘© Franta, B. (01 January 2018), On its 100th birthday in 1959, Edward Teller Warned the Oil Industry About Global Warming, The Guardian, available at https://www.theguardian.com/environment/climateconsensus-97-per-cent/20 1 8/jan/0 1/on-its-hundredth-birthday-in-1959-edward-teller-warned-the-oilindustry-about-global-warming (last accessed on 12 September 2019). '6 Franta, B., supra note 149, p. 1024. ‘64 Muffett, C., supra note 141, p. 20. 165 Id., p. 21, Fig. 3. 166 Ibid. '8? Ibid.