Memorandum for the Petitioners | 43 D.2. In the 1950s and 1960s, the fossil fuel industry was actively engaging in climate science and had actual knowledge of the grave dangers posed to people by climate change arising from the use of their fossil fuel products 1. 1950s 5 .43. The fossil fuel industry, coordinated by the American Petroleum Institute (API), were leading researchers on air pollution in the early 1950s.147 API is the primary fossil fuel industry trade group in the United States, and its membership includes many of the respondent Carbon Majors named148 herein. r r 5.44. In 1954, scientists from a prestigious U.S. university, the California Institute of Technology, submitted a research proposal to API, which, as described by Dr. Benjamin Franta, explained that “fossil fuels had caused atmospheric CO2 concentrations to rise by about 5% over the last 100 years.» 149 The API funded the scientists, and although the work ultimately focused on issues other than climate change, measurements of CO2 continued for some time. 150 Dr. Franta found that the results on CO2 were never published.151 5.45. By the late 1950s, documentary evidence indicates that certain fossil fuel companies, independently or through association with trade groups, such as API 152 and the Western States Petroleum Association ( WSPA), 153 may have had “actual knowledge” of the “potential climate risks” associated with their fossil fuel products.154 5.46. In 1957, Exxon was on notice of these risks, as evidenced by a published paper written by scientists with the Humble Oil and Refining Company’s Production Research Division . Humble Oil was, at the time, a Id. p. 14. See https://www.api.org /membership (last accessed on 12 September 2019). 149 Franta, B. (2018 ), Early oil industry knowledge of CO2 and global wanning. 8 Nature Climate Change, pp. 1024-1025 (this page is based on its appearance in the publication), available at https://www.nature.com/articles/s41558 018-0349-9, (last accessed 12 September 2019), Exhibit BBBBBBBBB” to “BBBBBBBBB- 1.” See Fig. 1, citing Brown, H., et ai , The Determination of the Variations and Causes of Variations of the Isotopic Composition of Carbon in Nature: A Proposal to the American Petroleum Institute from the Division of Geological Sciences, the California Institute of Technology* (California Institute of Technology, 1954). 150 Id. 151 Id 152 For more information about API, see: https://climateenergy.wpengine .com /about/ and https://www.api .org ( last accessed on 12 September 2019). 153 For more information about WSPA, see: https://www.wspa.org/issue/climate-change/ (last accessed on 12 September 2019). 154 Muffett, C. supra note 141, p. 13, 16. 147 148 -