1 avoidable increase in global greenhouse gas pollution and an accompanying increase in the 2 concentration of greenhouse gases,1 particularly carbon dioxide (“CO2”) and methane, in the 3 atmosphere. Those disruptions of Earth’s otherwise balanced carbon cycle have substantially 4 contributed to a wide range of dire climate-related effects, including global warming, rising 5 atmospheric and ocean temperatures, ocean acidification, melting polar ice caps and glaciers, more 6 extreme and volatile weather, sea level rise, and marine heatwaves with concomitant harmful algal 7 blooms. Families and businesses that depend on the health and productivity of the Dungeness crab 8 fishery to earn their livings suffer the consequences. 3. 9 Defendants are vertically integrated extractors, producers, refiners, manufacturers, 10 distributors, promoters, marketers, and sellers of fossil fuel products. Decades of scientific 11 research show that pollution from the production and use of Defendants’ fossil fuel products plays 12 a direct and substantial role in the unprecedented rise in emissions of greenhouse gas pollution and 13 increased atmospheric CO2 concentrations since the mid-20th century. This dramatic increase in 14 atmospheric CO2 and other greenhouse gases is the main driver of the gravely dangerous changes 15 occurring to the global climate. 4. 16 Anthropogenic (human-caused) greenhouse gas pollution, primarily in the form of 17 CO2, is far and away the dominant cause of global warming and the observed increase in ocean 18 temperatures,2 including marine heatwaves.3 The primary source of this pollution is the extraction, 19 production and consumption of coal, oil, and natural gas, referred to collectively in this Complaint 20 as “fossil fuel products.”4 21 As used in this Complaint, “greenhouse gases” refers collectively to carbon dioxide, methane, and nitrous oxide. Where a source refers to a specific gas or gases, or when a process relates only to a specific gas or gases, this Complaint refers to them by name. 2 See IPCC, Climate Change 2014: Synthesis Report. Contribution of Working Groups I, II, and III to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change [Core Writing Team, R.K. Pachauri and L.A. Meyer (eds.)]. IPCC, Geneva, Switzerland (2014), at 6, Figure SMP.3, https://www.ipcc.ch/report/ar5/syr (hereinafter, “IPCC 2014 Synthesis Report”). 3 See, e.g., Emanuele Di Lorenzo & Nathan Mantua, Multi-year persistence of the 2014/15 North Pacific marine heatwave, 6 NATURE CLIMATE CHANGE, 1 (July 11, 2016), https://www.nature.com/articles/nclimate3082; Eric C.J. Oliver et al., The unprecedented 2015/16 Tasman Sea marine heatwave, NATURE COMMUNICATIONS 8:16101, 1 (July 14, 2017). 4 See C. Le Quéré et al., Global Carbon Budget 2016, EARTH SYST. SCI. DATA 8, 632 (2016), http://www.earth-systsci-data.net/8/605/2016. Cumulative emissions since the beginning of the industrial revolution to 2015 were 413 GtC attributable to fossil fuels, and 190 GtC attributable to land use change. Id. Global CO2 emissions from fossil fuels 1 22 23 24 25 26 27 28 SHER EDLING LLP COMPLAINT 2