98. 1 In 1981, Exxon’s Henry Shaw, the company’s lead climate researcher at the time, 2 prepared a summary of Exxon’s current position on the greenhouse effect for Edward David Jr., 3 president of Exxon Research and Engineering, stating in relevant part: • • 4 5 6 7 99. “Atmospheric CO2 will double in 100 years if fossil fuels grow at 1.4%/ a2. 3oC global average temperature rise and 10oC at poles if CO2 doubles. o Major shifts in rainfall/agriculture o Polar ice may melt”77 In 1982, another report prepared for API by scientists at the Lamont-Doherty 8 Geological Observatory at Columbia University recognized that atmospheric CO2 concentration 9 had risen significantly compared to the beginning of the industrial revolution from about 290 parts 10 per million to about 340 parts per million in 1981 and acknowledged that despite differences in 11 climate modelers’ predictions, all models indicated a temperature increase caused by 12 anthropogenic CO2 within a global mean range of 4º C (7.2° F). The report advised that there was 13 scientific consensus that “a doubling of atmospheric CO2 from [] pre-industrial revolution value 14 would result in an average global temperature rise of (3.0 ± 1.5)°C [5.4 ± 2.7° F].” It went further, 15 warning that “[s]uch a warming can have serious consequences for man’s comfort and survival 16 since patterns of aridity and rainfall can change, the height of the sea level can increase 17 considerably and the world food supply can be affected.”78 Exxon’s own modeling research 18 confirmed this, and the company’s results were later published in at least three peer-reviewed 19 scientific papers.79 20 100. 21 Also in 1982, Exxon’s Environmental Affairs Manager distributed a primer on climate change to a “wide circulation [of] Exxon management . . . intended to familiarize Exxon 22 23 24 25 26 27 28 SHER EDLING LLP Henry Shaw, Exxon Memo to E. E. David, Jr. about “CO2Position Statement”, Exxon Inter-Office Correspondence (May 15, 1981), https://insideclimatenews.org/sites/default/files/documents/Exxon%20Position%20on% 20CO2%20%281981%29.pdf. 78 American Petroleum Institute, Climate Models and CO2 Warming: A Selective Review and Summary, LamontDoherty Geological Observatory (Columbia University) (Mar. 1982), https://assets.documentcloud.org/documents/ 2805626/1982-API-Climate-Models-and-CO2-Warming-a.pdf. 79 See Roger W. Cohen, Exxon Memo summarizing findings of research in climate modeling, Exxon Research and Engineering Co. (Sept. 2, 1982), https://insideclimatenews.org/sites/default/files/documents/%2522Consensus %2522%20on%20CO2%20Impacts%20(1982).pdf (discussing research articles). 77 COMPLAINT 45

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