Amicus Curiae Brief presented by ClientEarth 21 November 2016 Protocol).78 It is therefore appropriate to impute control over the emissions of subsidiaries, and their consequent climatic impacts, to the parent company. 7.2 Emissions from operations and products to date 101. The Commission has before it detailed evidence of the previous activities of the Carbon Majors, in the form of the thorough expert evidence of Richard Heede of the Carbon Accountability Institute. This work is the only example of research linking anthropogenic greenhouse gas emissions since 1850 to the operations and products of private actors. 102. The key finding of the research is that greenhouse gas emissions totalling 914.3 Gt of carbon dioxide equivalent produced between 1854 and 2010 can be traced to the operations and products of the 90 Carbon Major groups of companies included in the analysis.79 This is the equivalent of approximately 63 per cent of the estimated global greenhouse gas emissions since 1754, based on total global estimates produced by the Carbon Dioxide Information Analysis Center, of the US Department of Energy (see Annex D to the Petition). 103. Of the 90 Carbon Majors included in the original study, 51 of those privately owned groups of companies have been included in the scope of the Petition. Subject to the Commission's acceptance of the evidence presented in this analysis, it can conclude that the operations and products of the 51 companies named in the Petition 78 The Greenhouse Gas Protocol is the international standard by which most companies calculate and report on greenhouse gas emissions from their operations and products. The Protocol divides emissions into three categories, scope 1, being direct emissions from activities, scope 2 being emissions from electricity used by corporate operations, and scope 3 being the full emissions of the company's products throughout their life-cycle. For details see the http://www.ghgprotocol.org/ 79 Heede, R, 'Carbon Majors: Accounting for Carbon and methane emissions 1854-2010: Methods and Results report', in Annex D3 to the Petition. 49

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