Memorandum for the Petitioners \120 respondent Carbon Majors for climate impacts is, therefore, quantifiable and substantial, and the harm is foreseeable. 8.141.In addition to source attribution studies, like the UCS-led undertaking, scientists can also demonstrate the probability of an increased risk of an event happening due to climate change.>” 8.142. A scientific study by Soria et al., compared super typhoon Hatyan to the 1897 typhoon in San Pedro Bay. While the 1897 typhoon and Haiyan had almost identical tracks, Hatyan was more intense, had larger maximum wind coverage, and moved faster. Despite coming in with storm surges of similar heights on the open Pacific coast, Haiyan’s storm surge was about twice the height of the 1897 Typhoon.*”! The study indicates that the intensity of Haiyan made it possible to push more water on to land.°”? The Soria et al. study provides early insight into the relationship between super typhoon Haiyan and climate change, and scientists will continue to run models focusing on this and other devastating storms. >”? 8.143. Dr. Ekwurzel’s statement pointed to an event attribution study of Hurricane Sandy by Miller et al. to highlight how such studies can help understand the influence of climate change. This study found that “[a] largely anthropogenically driven global sea level rise (GSL) of 20 cm during the 20" century [Church and White, 2011] caused Sandy to flood an area around 70 km? greater than it would have in 1880, increasing the number of people living on land lower than the storm tide by around 38,000 in New Jersey and by around 45,000 in New York City.”°" Dr. Ekwurzel explained that this study shows how scientists can “parse different aspects of a typhoon or hurricane” and “figure out what could have been different,” and this can translate into the cost of damages.*” 8.144. Expert witness Dr. Myles Allen also referred to an event attribution study by Takayabu et al. to explain the quantification of the impact of large-scale warming on extreme weather events like Typhoon Haiyan. As explained in his testimony, the authors of the Takayabu et al. study sought to determine how would Typhoon Haiyan had been if it was not caused by large- scale warming.” 570 Marjanac and Patton, supra note 566, p. 273. 5” Soria, 1, et al., Repeat storm surge disasters of Typhoon Haiyan and its 1897 predecessor in the Philippines, Bulletin of American Meteorological Society, doi:10.1175/BAMS-D-14-00245.1, p. 45. 5? Ekwurzel, B., TSN 27-28 dated September 2018, p. 33, supra note 568. 513 Ig 5% Miller, K.G., et al, (2013), A geological perspective on sea-level rise and its impacts along the US midAtlantic coast. Earth’s Future 1(1):3~18. doi:10.1002/2013EF000135, available at https://agupubs.onlinelibrary.wiley.com/doi/full/10. 1002/2013EF000 135 (last accessed on 12 September 2019). 575 Ekwurzel, B., TSN 27-28 dated September 2018, pp. 32., supra note 568. 5% Testimony of Dr. Myles Allen, TSN dated 6-7 November 2018, pp. 121-122, also available at http://chr.gov.ph/wp-content/uploads/2019/04/NICC-TSN-November-6-to-7-London-United-Kingdom.pdf (last accessed on 12 September 2019),