Memorandum for the Petitioners |116 light in 2018,°°° that, in 1984, its products contributed 3.9% of world fossil fuel emissions. *' While respondent Shell may have used a different methodology (counting its refinery outputs, not equity production, and not deducting for non-energy uses), this result not only roughly confirms but exceeds Mr. Heede’s result for Shell in 1984: 2.1% of global fossil fuel emissions.> 8.128. Respondent Chevron, on the other hand, disclosed to CDP that it emitted approximately 418.4 Mt of COve during the reporting period 01 January 2014 to 31 December 2014. This is more than the total national emissions of most individual nation-states in 2012.53 8.129. Notably, Mr. Heede highlighted that the largest component of emissions associated with the major carbon producers — variable, but around 90% — is from combustion of the carbon in their extracted oil, gas, and coal.>~4 8.130.The 90 Carbon Major entities contributed to 66% of all anthropogenic CO, from 1751 to 2016; and the 50 investor-owned Carbon Majors are responsible for 21.4% of the of all anthropogenic CO; since 1751 through 2016.°>° 8.131. Undoubtedly, given these numbers, the Honorable Commission can conclude that respondent Carbon Majors have significantly contributed to climate change through their direct and product-related emissions. The proportional atmospheric carbon increase dioxide, in global mean surface temperature, and global sea-level from emissions traced to major carbon producers is quantifiable and substantial. 8.132.In 2017, a team of researchers and scientists from the UCS, CAI, and Oxford University, led by Dr. Brenda Ekwurzel, Senior Climate Scientist °° Ibid., p. 5, citing Mommers, Jelmer (16 March 2018) Advocaten in actie tegen klimaatverandering: deze golf rechtszaken verandert de wereld (Lawyers in action against climate change: this wave of lawsuits is changing the world), De Correspondent, available at https://decorrespondent.ni/8048/advocaten-in-actietegen-klimaatverandering-deze-golf-rechtszaken-verandert-de- wereld/886962032-c29274df (last accessed on 12 September 2019). 5! Shell Internationale Petroleum Maatschappij (1988) The Greenhouse Effect, Confidential Report, HSE 88-001, The Hague, p. 91, available at https:/Avww.documentcloud.org/documents/4411090Document3 html#document/p32/a4 11303 (last accessed on 06 September 2019). 552 553 554 *° Exhibit “QQQQ” to “QQQQ-11,” supra note 536, p. 5. Joint Summary of the Amicus Curiae, supra note 50, pp. 38-39. Heede, R., supra note 536, p. 5. See Exhibit “TTTT-A,” Climate Accountability Institute, Press Release on Update of Carbon Majors Project.