6 inventories, and policy based in Utrecht, The Netherlands.9 The methodology was also reviewed by technical staff of Greenpeace International’s Scientific Unit in the United Kingdom. Q11: What was the Climate Justice Programme’s & Greenpeace International’s connection to this research, if any? A11: Climate Justice Programme, established by Peter Roderick and originally based in London, commissioned me to do a study of a single large oil and gas company over its history and to estimate the contribution of carbon dioxide and methane from its operations and from its production and distribution of carbon fuels to worldwide consumers. That study focused on Standard Oil, founded by John D. Rockefeller, from 1882 to 2002, then the ExxonMobil Corporation.10 Friends of the Earth International published the results in January 2004.11 My 2003 report became the foundation for extending the analysis to a number of other large fossil fuel and cement producers that culminated in the Climate Accountability Institute’s work on the ninety Carbon Majors. Both Climate Justice Programme12 and Greenpeace International provided funding and technical support for completing the research and the peer-review process described in Q10. Such funding — while essential for completing the research — had no influence on my focus or independence, nor on the choice of companies to investigate, nor on the structure, content, methodology, or results as later published in Climatic Change and other scientific journals. Q12: To the best of your knowledge, has any “Carbon Major” entity commented on and/or challenged the findings in the paper that was published in Climatic Change and/or the Methods and Results Report? A12: No. No peer-reviewed research has been published. Privately, and under non-disclosure, one company and its legal representatives reviewed my methodology and results with respect to the company’s attributed historical emissions in a statement filed with the court but subsequently withdrawn. They did not challenge the validity of my historical results for the company in question. They did assert, however, that the company’s global oil, gas, and coal emissions were not pertinent to the case, and sought to narrow the scope to the company’s emissions from documented oil and gas production in the state of California, not globally. They also asserted that non-energy emissions, such as nitrous oxides, agricultural methane, cattle eructation, chlorofluorocarbons, and land use CO2 emissions should be included in the denominator (divisor) in order to calculate (and minimize) the company’s percentage of global emissions. These assertions are demonstrably irrelevant to my objectives, research protocol, and methodology. Q13: The original research has been updated. Could you explain when and what changes were made? A13: In 2018 I updated “activity data” (annual production of fossil fuels and cement) from company Form 10-Ks, Annual Reports, or standard industry sources to 2015 and 2016. The original Heede 2014 paper had activity data 9 K. Blok, Director of Science, www.ecofys.com/en/experts/blok Heede, Richard (2003) ExxonMobil Corporation: Emissions Inventory 1882-2002: Methods & Results, Climate Mitigation Services, Snowmass, Colorado, commissioned by Friends of the Earth Trust Limited, London; 30 pp., 4 charts. 11 Friends of the Earth International (2004) Exxon's Climate Footprint: the contribution of Exxon-Mobil to climate change since 1882, London, 16 pp. https://www.foe.co.uk/sites/default/files/downloads/exxons_climate_footprint.pdf 12 Moruya, NSW, Australia: www.climatejustice.org.au 10

Select target paragraph3