1 into the atmosphere in certain zones where upwelling of cold water to the surface occurs, because 2 Piercy evidently believed that the oceans could absorb and retain higher concentrations of CO2 3 than the atmosphere.73 This inquiry aligns with Exxon supertanker research into whether the ocean 4 would act as a significant CO2 sink that would sequester atmospheric CO2 long enough to allow 5 unabated emissions without triggering dire climatic consequences. As described below, Exxon 6 eventually scrapped this research before it produced sufficient data to derive a conclusion.74 96. 7 Also in 1980, Imperial Oil (Exxon) reported to Esso and Exxon managers and 8 environmental staff that increases in fossil fuel usage aggravates CO2 in the atmosphere. Noting 9 that the United Nations was encouraging research into the carbon cycle, Imperial reported that 10 “[t]echnology exists to remove CO2 from [fossil fuel power plant] stack gases but removal of only 11 50% of the CO2 would double the cost of power generation.” 97. 12 Exxon scientist Roger Cohen warned his colleagues in a 1981 internal 13 memorandum that “future developments in global data gathering and analysis, along with advances 14 in climate modeling, may provide strong evidence for a delayed CO2 effect of a truly substantial 15 magnitude,” and that under certain circumstances it would be “very likely that we will 16 unambiguously recognize the threat by the year 2000.”75 Cohen had expressed concern that the 17 memorandum mischaracterized potential effects of unabated CO2 emissions from Defendants’ 18 fossil fuel products: “[I]t is distinctly possible that the . . . [Exxon Planning Division’s] scenario 19 will produce effects which will indeed be catastrophic (at least for a substantial fraction of the 20 world’s population).”76 21 22 23 73 24 25 26 27 28 SHER EDLING LLP Neela Banerjee, More Exxon Documents Show How Much It Knew About Climate 35 Years Ago, INSIDE CLIMATE NEWS (Dec. 1, 2015), https://insideclimatenews.org/news/01122015/documents-exxons-early-co2-position-seniorexecutives-engage-and-warming-forecast. 74 Neela Banerjee et al., Exxon Believed Deep Dive Into Climate Research Would Protect Its Business, INSIDE CLIMATE NEWS (Sept. 17, 2015), https://insideclimatenews.org/news/16092015/exxon-believed-deep-dive-into-climateresearch-would-protect-its-business. 75 Roger W. Cohen, Exxon Memo to W. Glass about possible “catastrophic” effect of CO 2, Exxon Inter-Office Correspondence (Aug. 18, 1981), http://www.climatefiles.com/exxonmobil/1981-exxon-memo-on-possibleemission-consequences-of-fossil-fuel-consumption. 76 Id. COMPLAINT 44