Figure 4: Atmospheric Carbon Dioxide Concentration in Parts Per Million, 1960–2015: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 55. Of the increase in energy that has accumulated in Earth’s atmosphere between 1971 and 2010, more than 90% is stored in the oceans.24 15 56. In addition to the positive (increasing) trend in ocean surface temperature, marine 16 heatwaves—prolonged, discrete, anomalously warm water events that can be described by their 17 duration, intensity, rate of evolution, and spatial extent25—have become more frequent under 18 continued anthropogenic warming.26 This trend will continue and worsen in the future. 19 B. Domoic Acid Outbreaks 20 57. Domoic acid is a neurotoxin produced by species of marine algae, including the 21 diatom Pseudo-nitzschia australis, that when ingested by humans causes “amnesic shellfish 22 23 24 25 26 24 IPCC 2014 Synthesis Report, supra note 2, at 4. Alistair J. Hobday et al., A hierarchical approach to defining marine heatwaves, PROGRESS IN OCEANOGRAPHY 141, 227–38 (Feb. 2016). 26 See, e.g., Evan Weller et al., Human Contribution to the 2014 Record High Sea Surface Temperatures Over the Western Tropical and Northeast Pacific, BULLETIN OF THE AMERICAN METEOROLOGICAL SOCIETY, Vol. 96, No. 12, S103 (Dec. 2015). 25 27 28 SHER EDLING LLP COMPLAINT 31