Memorandum for the Petitioners | 62 5.113.2. Contrary to CFACT’s statement, “Haiyan generated the strongest winds among a collection of over 400 past storms, which was 16% greater than the second strongest typhoon on record (Typhoon Zeb in 1998). The forward speed of Haiyan was nearly twice as fast as the average speed of these weather systems and could be the fastest typhoon on record. Thus, Haiyan can be characterized as both the fastest moving and strongest typhoon measured in the area.” §.113.3. To recall, in 2013, Mr. Naderev “Yeb” Safio, one of the petitioners and then Commissioner of the Climate Change Commission, went on a hunger strike during COP 19, and delivered a compelling statement to the parties about the deadly and devastating super typhoon Haiyan and the threat posed by climate-fueled extreme weather events. 5.114.The oil industry continues to obstruct climate policy through deceptive and/or misleading public relations campaigns. In 2014, the Union of Concerned Scientists (UCS) uncovered how Western States Petroleum Association (WSPA) created at least sixteen (16) fake grassroots organizations and campaigns to create the illusion of widespread public opposition to climate and energy measures in western states in the U.S.2° As Mr. Muffett explained, “[WSPA] is the oldest oil industry association in the United States and .. . remains active in efforts to obstruct climate policies, including through deceptive or misleading public relations campaigns.”>” 5.115.Moreover, according to Mr. Muffett, respondents ExxonMobil, Chevron, BP, ConocoPhillips, and Shell, among other Carbon Majors and/or respondents herein, “have been active in WSPA throughout their century long history, including in 2014.”2°8 5.116.In 2015, Greenpeace USA exposed over a million dollars that the fossil fuel industry invested in a scientist, Dr. Willie Soon. The Statement*”? of Mr. Davies provides evidence that “Dr. Willie Soon received over $1.2 Million dollars from fossil fuel interests between 2001 and 2015,” from API, 255 Takagi, H. and Esteban, M. (2015), Statistics of tropical cyclone landfalls in the Philippines: unusual characteristics of 2013 Typhoon Haiyan (Natural Hazards, 2015, Volume 80, Number 1, p. 211), also available at https://link.springer.com/article/10.1007/s1 1069-0 15-1965-6 (last accessed on 12 September 2019); Also see GMA News Online (08 November 2013), Super Typhoon Yolanda is strongest storm ever to make landfall in recorded history, available at https:/Avww.gmanetwork.com/news/scitech/science/33457 l/super-typhoon-yolanda-is-strongest-stormever-to-make-landfall-in-recorded-history/story/ (last accessed on 12 September 2019). 256 Union of Concerned Scientists, The Climate Deception Dossiers (2015), supra note 219, p. 13, Exhibit “QQ” to “QQ-28.” For complete original document, see: Western States Petroleum Association (2014), WSPA Priority Issues, p. 13, available at https:/Avww.documentcloud.org/documents/3472843-ClimateDeception-Dossier-WSPA-Chart.html#document/p1 (last accessed on 12 September 2019). 257 Muffett, C., supra note 141, p. 14. 258 Ibid. 259 Davies, K., supra note 223, p. 8.

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