a. 1 In 1988, National Aeronautics and Space Administration (“NASA”) 2 scientists confirmed that human activities were actually contributing to 3 global warming.93 On June 23 of that year, NASA scientist James Hansen’s 4 presentation of this information to Congress engendered significant news 5 coverage and publicity for the announcement, including coverage on the 6 front page of the New York Times. b. 7 On July 28, 1988, Senator Robert Stafford and four bipartisan co-sponsors 8 introduced S. 2666, “The Global Environmental Protection Act,” to regulate 9 CO2 and other greenhouse gases. Four more bipartisan bills to significantly 10 reduce CO2 pollution were introduced over the following ten weeks, and in 11 August, U.S. Presidential candidate George H.W. Bush pledged that his 12 presidency would “combat the greenhouse effect with the White House 13 effect.”94 Political will in the United States to reduce anthropogenic 14 greenhouse gas emissions and mitigate the harms associated with 15 Defendants’ fossil fuel products was gaining momentum. c. 16 In December 1988, the United Nations formed the Intergovernmental Panel 17 on Climate Change (“IPCC”), a scientific panel dedicated to providing the 18 world’s governments with an objective, scientific analysis of climate 19 change and its environmental, political, and economic impacts. d. 20 In 1990, the IPCC published its First Assessment Report on anthropogenic 21 climate change,95 in which it concluded that (1) “there is a natural 22 greenhouse effect which already keeps the Earth warmer than it would 23 otherwise be,” and (2) that emissions resulting from human activities are substantially increasing the atmospheric concentrations of the greenhouse gases carbon dioxide, methane, chlorofluorocarbons (CFCs) 24 25 26 93 27 28 SHER EDLING LLP See Frumhoff et al., The Climate Responsibilities of Industrial Carbon Producers, supra note 211. N.Y. TIMES, The White House and the Greenhouse (May 9, 1998), http://www.nytimes.com/1989/05/09/ opinion/the-white-house-and-the-greenhouse.html. 95 See IPCC, Reports, http://www.ipcc.ch/publications_and_data/publications_and_data_reports.shtml. 94 COMPLAINT 51