Memorandum for the Petitioners | 42 5.39. As pointed out by amicus and expert witness Mr. Carroll Muffett, President and Chief Executive Officer of the Center for International Environmental Law (CIEL), “[a]t all relevant times, fossil fuel companies can and should be presumed to be experts in all aspects of the products they produced, manufactured, marketed or otherwise put into the stream of commerce.” !43 5.40. Based on evidence submitted during the course of the National Inquiry, the fossil fuel industry, including many of the respondent Carbon Majors, had actual knowledge of the harms resulting from the extraction, sale, and use of their fossil fuel products in the 1960s, if not earlier. The exact date of fossil fuel industry notice, awareness, and knowledge of climate risks will not be settled until ail relevant documents and communications are disclosed by the respondent Carbon Majors. 5.41. Respondents’ knowledge of climate risks and subsequent corporate actions and/or inactions, taken in light of the known risks, are set out below based on the evidence given during the National Inquiry. A timeline of the key information in this section is attached hereto and made an integral part of this memorandum as Annex “A.” D.1. The fossil fuel industry should have been aware that fossil fuel combustion could alter the global climate by the early 20th century 5.42. Almost 200 years ago, scientists began researching the “greenhouse effect.” '“ The link between increases in global average temperature and fossil fuel combustion was further studied by Guy Callendar im 1938.5 From there on, as explained by Mr. Muffett, “the potential for climatic change became a matter of recurring discussion within the scientific and technical literature.”!46 Ekins (UK Energy Research Centre and University College London), Peter Frumhoff (Union of Concerned Scientists), Department ‘8 Muffett, "4 In 1896, Richard Heede (Climate Accountability Institute), Sharon Eubanks (Former Director at U.S. of Justice Litigation Team and Lead Counsel), and Sophie Marjanac (ClientEarth). C., supra note 141, p. 13. Arrhenius published a paper titled “On the Influence of Carbonic Acid in the Air upon the Temperature of the Ground” that finally quantified the effect that increased carbon dioxide had on the greenhouse effect. See: Lewis, D. (03 August 2015), Scientists Have Been Talking About Greenhouse Gases for 191 Years, Smithsonian Institute, available at https://www.smithsonianmag.com/smartnews/scientists-talking-about-greenhouse-gases19 1-years- 180956 146/ (last accessed on 12 September 2019) 4° See Exhibit “VV” to “VV-8,” Callendar, G. (1938), The Artificial Production of Carbon Dioxide and its Influence on Temperature. “6 Muffett, C., supra note 141, p. 16.