Amicus Curiae Brief presented by ClientEarth 21 November 2016 assessment more than satisfies the civil standard of proof, and thus, the Commission may rely on this statement for its factual investigation. Accordingly, the Commission may take it as proven, for the purposes of its investigation, that human greenhouse gas emissions have caused half of the observed warming of the planet from 1951 to 2010.67 83. A fundamental conclusion of the IPCC's AR5 is that there is a clear and demonstrable linear causal relationship between the emission of carbon dioxide and warming of the planet as a whole. SPM 2.1 of the IPCC states: "[c]umulative emissions of CO2 largely determine global mean surface warming by the late21st century and beyond. Projections of greenhouse gas emissions vary over a wide range, depending on both socio-economic development and climate policy."68 84. Two graphs demonstrating this linear relationship, based on observations to date, and on the basis of modelling into the future, are contained on page 9 of the AR5. This page is included as Annex C to this brief due to its fundamental importance to the Commission's investigation. 85. Furthermore, the scientific evidence is clear that greenhouse gas emissions are inherently fungible. That is, emissions are mutually interchangeable in their environmental impact and their effect in the atmosphere, because it is the overall Consistent Treatment of Uncertainties, 2010 https://www.ipcc.ch/pdf/supporting-material/uncertainty-guidance-note.pdf 67 The globally averaged combined land and ocean surface temperature data as calculated by a linear trend show a warming of 0.85 [0.65 to 1.06] °C 2 over the period 1880 to 2012, when multiple independently produced datasets exist. IPCC AR5, Synthesis Report, Summary for Policymakers. See note 46 at p 4. 68 IPCC AR5, Synthesis Report, Summary for Policymakers. See note 46 at p 8. 42