Memorandum for the Petitioners | 43 D.2. In the 1950s and 1960s, the fossil fuel industry was actively engaging in climate science and had actual knowledge of the grave dangers posed to people by climate change arising from the use of their fossil fuel products 1. 5.43. 1950s The fossil fuel industry, coordinated by the American Petroleum Institute (API), were leading researchers on air pollution in the early 1950s.'*” APIis the primary fossil fuel industry trade group in the United States, and its membership includes many of the respondent Carbon Majors named! herein. 5.44. In 1954, scientists from a prestigious U.S. university, the California Institute of Technology, submitted a research proposal to API, which, as described by Dr. Benjamin Franta, explained that “fossil fuels had caused atmospheric CO2 concentrations to rise by about 5% over the last 100 years.”'” The API funded the scientists, and although the work ultimately focused on issues other than climate change, measurements of CO2 continued for some time.'°° Dr. Franta found that the results on CO» were never published.!*! 5.45. By the late 1950s, documentary evidence indicates that certain fossil fuel companies, independently or through association with trade groups, such as API'® and the Western States Petroleum Association (WSPA),! may have had “actual knowledge” of the “potential climate risks” associated with their fossil fuel products.!*4 5.46. In 1957, Exxon was on notice of these risks, as evidenced by a published paper written by scientists with the Humble Company’s Production Research Division. Oil and Refining Humble Oil was, at the time, a "47 Id p. 14. '48 See https://www.api.org/membership (last accessed on 12 September 2019). Franta, B. (2018), Early oil industry knowledge of CO2 and global warming. 8 Nature Climate Change, pp. 1024-1025 (this page is based on its appearance in the publication), available at https://www.nature.com/articles/s4 1558-018-0349-9, (last accessed 12 September 2019), Exhibit “BBBBBBBBB” to “BBBBBBBBB-1.” See Fig. 1, citing Brown, H., et al., The Determination of the Variations and Causes of Variations of the Isotopic Composition of Carbon in Nature: A Proposal to the American Petroleum Institute from the Division of Geological Sciences, the California Institute of Technology (California Institute of Technology, 1954). 150 151 i '52 For more information about API, see: https://climateenergy.wpengine.com/about/ and https://www.api.org (last accessed on 12 September 2019). '53 For more information about WSPA, see: https://www.wspa.org/issue/climate-change/ (last accessed on 12 September 2019). 'S4 Muffett, C. supra note 141, p. 13, 16.