3
and nitrous oxide. These increases will enhance the
greenhouse effect, resulting on average in an additional
warming of the Earth's surface. The main greenhouse gas,
water vapour, will increase in response to global warming
and further enhance it.96
4
The IPCC reconfirmed these conclusions in a 1992 supplement to
5
the First Assessment Report.97
1
2
e.
6
The United Nations began preparation for the 1992 Earth Summit in Rio de
7
Janeiro, Brazil, a major, newsworthy gathering of 172 world governments,
8
of which 116 sent their heads of state. The Summit resulted in the United
9
Nations Framework Convention on Climate Change (“UNFCCC”), an
10
international environmental treaty providing protocols for future
11
negotiations aimed at “stabiliz[ing] greenhouse gas concentrations in the
12
atmosphere at a level that would prevent dangerous anthropogenic
13
interference with the climate system.”98
115.
14
These world events marked a shift in public discussion of climate change, and the
15
initiation of international efforts to curb anthropogenic greenhouse emissions—developments that
16
had stark implications for, and would have diminished the profitability of, Defendants’ fossil fuel
17
products.
116.
18
But rather than collaborating with the international community by acting to
19
forestall, or at least decrease, their fossil fuel products’ contributions to global warming, increased
20
mean sea surface temperature, marine heatwaves, harmful algal blooms, and marine toxin
21
outbreaks, and consequent injuries to Plaintiff, Defendants embarked on a decades-long campaign
22
designed to maximize continued dependence on their products and undermine national and
23
international efforts to rein in greenhouse gas emissions.
24
25
26
27
28
SHER
EDLING LLP
IPCC, Climate Change: The IPCC Scientific Assessment, “Policymakers Summary” (1990),
http://www.ipcc.ch/ipccreports/far/wg_I/ipcc_far_wg_I_spm.pdf.
97
IPCC, 1992 Supplement to the First Assessment Report (1992), http://www.ipcc.ch/publications_and_data/
publications_ipcc_90_92_assessments_far.shtml.
98
United Nations, United Nations Framework Convention on Climate Change, Article 2 (1992),
https://unfccc.int/resource/docs/convkp/conveng.pdf.
96
COMPLAINT
52
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