1 would create an equivalent sea temperature increase that could impact fisheries.47 President 2 Johnson announced in a special message to Congress that “[t]his generation has altered the 3 composition of the atmosphere on a global scale through . . . a steady increase in carbon dioxide 4 from the burning of fossil fuels.”48 78. 5 These statements from the Johnson Administration, at a minimum, put Defendants 6 on notice of the potentially substantial dangers to people, communities, and the planet associated 7 with unabated use of their fossil fuel products. Moreover, Defendants had amassed a considerable 8 body of knowledge on the subject through their own independent efforts. 79. 9 A 1963 Conservation Foundation report on a conference of scientists referenced in 10 the 1966 World Book Encyclopedia, as well as in presidential panel reports and other sources 11 around that time, described many specific consequences of rising greenhouse gas pollution in the 12 atmosphere. It warned that a continuing rise in the amount of atmospheric carbon dioxide is likely to be accompanied by a significant warming of the surface of the earth which by melting the polar ice caps would raise sea level and by warming the oceans would change considerably the distributions of marine species including commercial fisheries. 13 14 15 16 It warned of the possibility of “wiping out the world’s present commercial fisheries.” The report, 17 in fact, noted that “the changes in marine life in the North Atlantic which accompanied the 18 temperature change have been very noticeable.”49 19 80. In 1968, a Stanford Research Institute (SRI) report commissioned by the American 20 Petroleum Institute (“API”) and made available to all of its members, concluded, among other 21 things: 22 23 24 25 26 27 28 SHER EDLING LLP President’s Science Advisory Committee, Restoring the Quality of Our Environment: Report of the Environmental Pollution Panel, at 9, 123–24 (Nov. 1965), https://hdl.handle.net/2027/uc1.b4315678. 48 President Lyndon B. Johnson, Special Message to Congress on Conservation and Restoration of Natural Beauty (Feb. 8, 1965), http://acsc.lib.udel.edu/items/show/292. 49 The Conservation Foundation, Implications of Rising Carbon Dioxide Content of the Atmosphere: A statement of trends and implications of carbon dioxide research reviewed at a conference of scientists (Mar. 1963), https://babel.hathitrust.org/cgi/pt?id=mdp.39015004619030;view=1up;seq=5. 47 COMPLAINT 37