Memorandum for the Petitioners |123
Well it showed that it was straightforward to attribute
some fraction of the observed increase in global
temperature and global sea level to the emissions
resulting from product sold by a well-defined group of
individual companies.
It gave a methodology for
breaking down contributions. . . .
XXX
ATTY. MAYO-ANDA:
Okay. Based on the attribution studies, what types of impacts
are foreseeable in the Philippines and Southeast Asia, and
what should the Philippines be prepared for?
DR. ALLEN:
... There remains some continuing argument but there's also,
of course, the simple impact of rising temperatures
increasing the risk of heat waves. In very large urban
areas, these risks can be further exacerbated by the
feedback effects of the island in that affects and enhance
the effect of a large scale warming, which of course make
the health impacts doubly problematic. And air quality,
the way climate change interacts with air quality is also
particularly important for health. So these, I mean, are
just some examples, from the top of my head, of impact that
I know. A city like Manila would be particularly vulnerable,
as a sort of mega city in the developing world, to those kinds
of impacts.*8° (Emphasis supplied)
8.148. In sum, scientific studies like the ones by Soria et al. and event
attribution studies by Takayabu et al. and by Miller et al. offer insights into
how extreme weather events like super typhoon Haiyan (and Hurricane
Sandy) were exacerbated by the human influence on the climate. In tum,
source attribution studies like the UCS-led study further show that the
respondent
Carbon
Majors,
together
and
individually,
have
extracted,
marketed, and sold a substantial percentage of the fossil fuels burned globally,
releasing an immense amount of carbon pollution into the Earth’s atmosphere,
which is currently interfering with the climatic system**! and resulting in
impacts.
8.149. While attribution research continues to evolve and improve, the
existing studies demonstrate that communities face foreseeable risks from the
respondents’ past and continued contribution of GHGs, which in turn
Furthermore, existing
demands that preventative approach be taken.
attribution studies can inform the Honorable Commission’s findings on the
580 Allen, M., TSN dated 6-7 November 2018, pp. 121-139, supra note 576.
$81 See Exhibits “VVVV” to “VVVV-14” and Exhibit “H”; Also see Opinion and Order, United States
District Court for the District of Rhode Island (22 July 2019), State of Rhode Island v. Chevron Corp., Case
1:18-cv-00395-WES-LDA, citing to complaint paras. 7, 12, 19, 97, supra note 26.
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