the global historic emissions through 2013;39 and • The 49 investor-owned Carbon Major companies contributed 337.7 Gt CO2e, equivalent to 21.6% of estimated global industrial emissions through 2013.40 There has been one development with the Carbon Majors research, Richard Heede and Naomi Oreskes released a new paper entitled “Potential emissions of CO2 and methane from proved reserves of fossil fuels: An Alternative Analysis.” The analysis suggests that, “investor concern should be focused on dissuading these corporations from further investment in fossil fuel exploration and development.”41 This Petition focuses on the responsibility of the investor-owned Carbon Major companies, the largest producers of crude oil, natural gas, coal, and cement. Acknowledging that the list of investor-owned companies includes cement producers, we recommend that the Commission prioritizes the fossil fuel producers (coal, oil, and gas) in its investigation of the Carbon Majors’ responsibility for climate change because the greenhouse gas emissions from fossil fuels is the main cause of climate change. Throughout the rest of this Petition, the term ‘Carbon Majors’ will refer solely to the existing investor-owned Carbon Majors producers listed in Tables 1 and 2. The Petitioners have chosen to focus on the carbon producers, the Carbon Majors, rather than emitters, because there are just a few dozen producers, including companies putting fossil fuels on the market, that are largely responsible for and profiting the most from climate change, while taking very little, if any, action on climate change. As will be further explained in the discussion section, these producers are largely unregulated in terms of carbon emissions from their products. Also, there are examples of fossil fuel companies, either directly or through trade associations, !!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 39 Id. Id. 41 Heede, R. and Oreskes, N. 2015. Potential emissions of CO2 and methane from proved reserves of fossil fuels: An alternative analysis, Global Environmental Change, Volume 36, January 2016, pp.12-20, 19, http://www.sciencedirect.com/science/article/pii/S0959378015300637 (last accessed on Apr. 19, 2016). 40 ! ! ! ! ! 23 !

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