1 on the global damage from pollution, e.g., from coal combustion, will give us the needed focus for further research to avoid or control such pollutants.”63 2 3 91. That same year, Exxon Research and Engineering reported that: “The most widely 4 held theory [about increasing CO2 concentration] is that the increase is due to fossil fuel 5 combustion, increasing CO2 concentration will cause a warming of the earth’s surface, and the 6 present trend of fossil fuel consumption will cause dramatic environmental effects before the year 7 2050.”64 According to the report, “ecological consequences of increased CO2” to 500 ppm (1.7 8 times 1850 levels) could mean that “marine life would be markedly changed;” and, by way of 9 example, that “maintaining runs of salmon and steelhead and other subarctic species in the 10 Columbia River system would become increasingly difficult.”65 With a doubling of the 1860 CO2 11 concentration, “ocean levels would rise four feet” and “the Arctic Ocean would be ice free for at 12 least six months each year, causing major shifts in weather patterns in the northern hemisphere.”66 13 92. Further, the report stated that unless fossil fuel use was constrained, there would be 14 “noticeable temperature changes” associated with an increase in atmospheric CO2 from about 280 15 parts per million before the Industrial Revolution to 400 parts per million by the year 2010.67 Those 16 projections proved remarkably accurate—atmospheric CO2 concentrations surpassed 400 parts per 17 million in May 2013, for the first time in millions of years. 68 In 2015, the annual average CO2 18 concentration rose above 400 parts per million, and in 2016 the annual low surpassed 400 parts 19 per million, meaning atmospheric CO2 concentration remained above that threshold all year.69 20 21 22 23 24 25 26 27 28 SHER EDLING LLP Henry Shaw, Exxon Memo to H.N. Weinberg about “Research in Atmospheric Science”, Exxon Inter-Office Correspondence (Nov. 19, 1979), https://insideclimatenews.org/sites/default/files/documents/Probable% 20Legislation%20Memo%20(1979).pdf. 64 W.L. Ferrall, Exxon Memo to R.L. Hirsch about “Controlling Atmospheric CO2”, Exxon Research and Engineering Co. (Oct. 16, 1979), http://insideclimatenews.org/sites/default/files/documents/CO2%20and%20Fuel%20Use% 20Projections.pdf. 65 Id. 66 Id. 67 Id. 68 Nicola Jones, How the World Passed a Carbon Threshold and Why it Matters, YALE ENVIRONMENT 360 (Jan. 26, 2017), http://e360.yale.edu/features/how-the-world-passed-a-carbon-threshold-400ppm-and-why-it-matters. 69 Id. 63 COMPLAINT 42