7 considerations, inform discussions about carbon producer responsibilities to contribute to limiting climate change through investment in mitigation, support for adaptation, and compensation for climate damages. Q11: Have any of the investor-owned companies commented on your study? A11: Not to my knowledge. Q12: Do you know if this study you co-authored, “The rise in global atmospheric CO2, surface temperature and sea level from emissions traced to major carbon producers,” and Richard Heede’s “Tracing anthropogenic carbon dioxide and methane emissions to fossil fuel and cement producers, 18542010” have been used in any legal proceeding? And if so, how? A12: I am aware that Heede (2014) and Frumhoff, Oreskes and Heede (2015) have been cited in the lawsuits six cities and counties in California have filed against thirty-seven major fossil fuel companies for the climate harms caused by their products. They have also been citied in separate complaints filed against five major fossil fuel companies for climate harms, complaints filed by the cities of New York, San Francisco and Oakland, California. I have not examined how, specifically, these studies were cited in these complaints. Q13: Other than this study, are there any articles or publications made by your organization (Union of Concerned Scientists [UCS]) regarding the matter which might prove useful for the Commission’s inquiry? A13: Frumhoff, P. C., R. Heede, and N. Oreskes. 2015. The climate responsibilities of industrial carbon producers. Climatic Change 132: 157-171. doi: 10.1007/s10584-015-1472-5. Mulvey, K., S. Shulman, D. Anderson, N. Cole, J. Piepenburg, and J. Sideris. 2015. Climate deception dossiers: Internal fossil fuel industry memos reveal decades of corporate disinformation. Cambridge, MA: Union of Concerned Scientists. Online at www.ucsusa.org/ sites/default/files/attach/2015/07/TheClimate-DeceptionDossiers.pdf Other papers cited in this affidavit: Heede, R. 2014. Tracing anthropogenic carbon dioxide and methane emissions to fossil fuel and cement producers, 1854–2010. Climatic Change 122:229–241. Doi:10.1007/s10584-013-0986-y Banerjee N (2015) Exxon’s oil industry peers knew about climate dangers in the 1970s, too. Inside Climate News