atmospheric CO2 and global temperatures caused little concern because it was widely, but erroneously, assumed that the CO2 released in this way would be safely absorbed by the world’s oceans, thus reducing the impacts to the global climate. This situation began to change, scientific attention to carbon dioxide began to intensify, and researcher Guy Callendar published a study entitled “The Artificial Production of Carbon Dioxide and its Influence on Temperature.”5 In his study, Callendar observed that three quarters of the carbon dioxide released in the prior 50 years had, in fact, remained in the atmosphere. As a result, Callender estimated, world temperatures had increased at 0.005ºC per year for the previous fifty years.6 Callendar’s study was not immediately accepted, but was widely cited and debated over the next two decades.7 Some, such as Giles Slocum of the U.S. Weather Bureau, determined that they could not detect a noticeable change in atmospheric carbon dioxide concentrations.8 Others postulated that the oceans would absorb so much of the carbon dioxide that “the amount of surplus CO2 from artificial coal combustion will become insignificantly small as soon as equilibrium with marine carbonate is established.”9 In 1955, however, Hans Suess provided the first clear proof that, as hypothesized by Arrhenius and theorized by Callendar, that carbon dioxide from the combustion of fossil fuels was accumulating in the atmosphere,10 a phenomenon that would thereafter be referred to as the “Suess effect.” The research of Callendar, Slocum, Suess, and others was neither obscure nor hidden. Unsurprisingly, the earliest industry studies we have access to measuring the buildup of carbon dioxide in the atmosphere appear around this time. connection with those matters of biological interest which are concerned with the dynamic processes of pelagic life.” (emphasis added)). See also Clark, supra note 3, at 49-50 (discussing the existence and debate over Arrhenius’ theory and stating “Both carbon dioxide and aqueous vapor serve as selective absorbents for the solar rays, and, by blanketing the earth, they help to avert excessive changes of temperature. On the physical side, and as regards carbon dioxide, this question has been discussed by S. Arrhenius, who argues that if the quantity of the gas in the atmosphere were increased about threefold, the mean temperature of the Arctic regions would rise 8° or 9°.”). 5 See Guy S. Callendar, The Artificial Production of Carbon Dioxide and its Influence on Temperature, 64 Q. J. OF THE ROYAL METEOROLOGICAL SOC’Y 223 (1938), available at http://onlinelibrary.wiley.com/doi/10.1002/qj.49706427503/full. 6 Id. 7 Google Scholar Search Results, https://scholar.google.com/scholar?cites=14959323493014744928&as_sdt=20005&sciodt=0,9&hl=en (search “The artificial production of carbon dioxide and its influence on temperature”, then click “Cited by”). 8 See Giles Slocum, Has the Amount of Carbon Dioxide in the Atmosphere Changed Significantly Since the Beginning of the Twentieth Century?, 83 MONTHLY WEATHER REV. 225 (1955), available at http://citeseerx.ist.psu.edu/viewdoc/download?doi=10.1.1.173.1979&rep=rep1&type=pdf. 9 See Hans E. Suess, Natural Radiocarbon and the Rate of Exchange of Carbon Dioxide Between the Atmosphere and the Sea, in NUCLEAR PROCESSES IN GEOLOGIC SETTINGS 52, 52 (1953), available at https://books.google.com/books?hl=en&lr=&id=RmMrAAAAYAAJ&oi=fnd&pg=PA52&ots=en6W_zO0VE&sig= 0PRe1KURGXwO_u1VKIl7AXuZUPA#v=onepage&q&f=false. 10 See Hans E. Suess, Radiocarbon Concentration in Modern Wood, 122 SCIENCE 415 (1955), available at http://science.sciencemag.org/content/122/3166/415.2. 4