33 Jelmer approached CIEL for assistance in assessing the contents and significance of the documents. In the Shell Report, A Crack in the Shell, CIEL combined an analysis of these new documents with our own research into Shell’s early awareness of and responses to climate science to present a clearer picture of what Royal Dutch Shell and its subsidiaries knew about climate risks, when they knew it, and how they acted in light of that information. For example, the Shell Report documents the early and active role of Shell executives in API’s Smoke and Fumes Committee, and documents that Shell engaged with API not only through its US subsidiary but through representatives from its British and Dutch parent companies. The report brought to light an early and explicit discussion of climate change and climate risks by M. King Hubbert, who was Shell’s chief consulting geologist at the time. It demonstrated that Shell, like Exxon, was on notice of emerging climate science and growing concerns regarding carbon dioxide more than five decades ago. Finally, through its analysis of documents ranging from the 1980s through the present day, the Shell Report highlighted an ongoing tension between Shell’s public representations and internal discussions and actual conduct in the face of climate risks. Q25: There were mention of several publications and a film made my Shell, to wit: The Greenhouse Effect; The Enhanced Greenhouse Effect; Is Climate Change Occurring Already?; Climate of Concern; Shell and the Environment; Climate Change; and What Does Shell Think and Do About It? Could you please walk us through these publications and film? A25: Please see my reply to Question 20 for a detailed discussion of the content and potential significance of The Greenhouse Effect and the film Climate of Concern. In 1994, Shell prepared a revised version of its earlier report entitled The Enhanced Greenhouse Effect. The most noteworthy aspect of the latter report is that it placed a far greater emphasis on scientific uncertainties even as the science itself was becoming stronger. Similarly, the 1995 document Is Climate Change Occurring Already? placed a heavy emphasis on the uncertainties in climate science, departed significantly from Shell’s own earlier analysis, and patently disregarded relevant work by NASA Scientist Dr. James Hansen. Q26: In the said Shell Report, CIEL also mentioned about this “Roadmap Memo.” Could you briefly explain what is this all about? A26: As briefly recounted in Answer 22, the “Roadmap Memo” is the shorthand name used for a document entitled “Global Climate Science Communications Action Plan”, created and distributed by the American Petroleum Institute in 1998. This plan outlined a media and communications strategy designed to convince the American public, as well as industry leaders and politicians, that “significant uncertainties exist in climate science,” and noted that “Victory Will Be Achieved When … Average

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