13
particular Chevron entity for which delivery is intended” and “no entity that
this address is authorized to receive any communication and/or process for
and on behalf of any entity identified anywhere in the papers.”28
2.17. In the letter dated 09 August 2016 sent to the legal
representatives of the petitioners, PricewaterhouseCoopers (PwC) explained
that it is the liquidator of UK Coal Production Limited and claimed that the
Petition does not refer to UK Coal Production Limited and was addressed to
UK Coal, which is currently not a legal entity. Hence, PwC requested
confirmation of who is the relevant party to receive the documents.29
2.18. The petitioners identified the respondents, the investor-owned
Carbon Majors, as corporate groups that are significant contributors to
climate change, as recognized by peer-reviewed research conducted by Mr.
Richard Heede.30 The Petition and the annexes refer to the name of the
parent entity or entities of the Carbon Majors because, in general, the
accounts of a corporate group are consolidated under the name of the parent
entity or entities, “in accordance with the rules of the jurisdiction in which
the parent is incorporated or listed for trading on a stock exchange.”31 Many
of the respondents are integrated energy companies, such as Chevron
Corporation,32 and this is reflected by the Carbon Majors research, which
primarily collected company production data from publicly available
sources, such as annual reports in the collections of public and academic
libraries, filings with the U.S. Securities and Exchange Commission,
compilations in published literature, and company histories.33
28
See Chevron’s letter dated 02 September 2016.
UK Coal’s letter dated 09 August 2016, sent by its liquidator, PWC.
30
Heede, R. (2014). Tracing anthropogenic CO2 and methane emissions to fossil fuel and cement
producers, 1854-2010, Climatic Change, January 2014, vol. 122(1): 229-241;
http://link.springer.com/article/10.1007/s10584-013-0986-y?view=classic, last accessed on 08 February
2017.
31
ClientEarth’s amicus submission dated 21 November 2016, p. 46, available at https://businesshumanrights.org/en/amicus-briefs, last accessed on 08 February 2017.
32
Chevron Corporation, with its subsidiaries, conducts business worldwide. Chevron’s 2015 Annual
Report: [“Chevron is one of the world’s leading integrated energy companies. Our success is driven by our
people and their commitment to getting results the right way — by operating responsibly, executing with
excellence, applying innovative technologies and capturing new opportunities for profitable growth. We are
involved in virtually every facet of the energy industry. We explore for, produce, and transport crude oil
and natural gas; refine, market, and distribute transportation fuels and lubricants; manufacture and sell
petrochemicals and additives; generate power and produce geothermal energy; and develop and deploy
technologies that enhance business value in every aspect of the company’s operations.” See
https://www.chevron.com/annual-report/2015, last accessed on 06 February 2017.
In 2014, Chevron Corporation, stated: “Chevron is one of the world’s leading integrated energy companies,
with subsidiaries that conduct business worldwide. The company is involved in virtually every facet of the
energy industry. Chevron explores for, produces, and transports crude oil and natural gas; refines, markets,
and distributes transportation fuels and lubricants; manufactures and sells petrochemical products;
generates power and produces geothermal energy; provides energy efficiency solutions; and develops the
energy resources of the future, including biofuels. Chevron is based in San Ramon, Calif.” See
http://investor.chevron.com/phoenix.zhtml?c=130102&p=irol-newsArticle&ID=1994131, last accessed on
06 February 2017 (Emphasis added).
33
Heede, R. (2014). op cit., at supplementary materials, data sources.
29