32 through the GCC itself. In a document from 1996, for example, the GCC argued that: • Most observed warming of the atmosphere was caused by natural forces; • Any human contribution to this observed warming was very small and overwhelmed by natural forces; and that • “[T]here is no convincing evidence that future increases in greenhouse gas concentrations will produce significant climatic effects.” During the negotiation of the Kyoto Protocol, and the transition between the administrations of Bill Clinton and George W. Bush, the GCC worked intensely to build opposition to the agreement among lawmakers and the public. After the Bush Administration withdrew the United States from the Kyoto Protocol the GCC was dissolved in 2002. In the interim, however, the American Petroleum had expanded its own climate denial operations. In 1998, an internal API document entitled the Global Climate Communications Plan (but also called the “Roadmap Memo”) laid out API’s objectives and path to victory with respect to climate change and climate science. According to the document, the goal of API’s project was to ensure a majority of recognized that “significant uncertainties” exist in climate science, prompting them to raise questions with Congress and others responsible for influencing US progress on climate change. “Victory Will Be Achieved” declared API, “When average citizens “understand” uncertainties in climate science”, these uncertainties become part of the “conventional wisdom”, and supporters of the Kyoto Protocol are viewed as “out of touch with reality”. During this period, the following Carbon Majors companies were API members directly, or through their predecessors, subsidiaries or affiliates: Amoco, Ashland Oil, Aramco, Atlantic Richfield Company, British Petroleum, Chevron, Conoco Phillips, ExxonMobil, Husky Energy, Marathon Oil, Murphy Oil, Petroleos de Venezuela, Shell Oil, Statoil, Suncor and Total. (See document annex to slide 44 of my testimony of May 23rd). Q23: Could you please provide one or more concrete examples, if any, of respondent Carbon Major companies’ awareness of climate risks, their products’ role in contributing and/or exacerbating climate risks, and failure to take steps to avoid and reduce climate risks? A23: Relevant examples are incorporated in Answers 19 and 20 above. Q24 In April 2018, CIEL released a publication entitled, “A Crack in the Shell: New Documents Expose a Hidden Climate History” (hereinafter, “Shell Report”). Briefly, what is this all about? A24: In April 2018, the Climate Investigation Center published a new and significant trove of internal Shell documents unearthed by Dutch journalist Jelmer Mommers of De Correspondent. Prior to releasing the documents,

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