Memorandum for the Petitioners | 55 5.86. This statement clearly contravenes a 1995 “final draft” of a GCC primer on global climate science, which stated that the “scientific basis for the Greenhouse Effect and the potential impacts of human emissions of greenhouse gases such as COs on climate is well-established and cannot be denied.”?!7 Based on this primer, it is evident that the members of the GCC had the scientific facts on climate change, yet chose to obscure them in subsequent documents and communications. 2. The fossil fuel industry created front groups that successfully undermined climate action 5.87. Into the 1990s, front groups ran public relations campaigns to undermine climate science and solutions, specifically around the time the United Nations Framework Convention on Climate Change (“UNFCCC”) was opened for signatures. 5.88. In 1991, the Information Council for the Environment (ICE) launched a sophisticated “national climate change science denial campaign with full-page newspaper ads, radio commercials, a public relations tour schedule, ‘mailers,’ and research tools to measure campaign success.” ?!® According to one of the amici submitters, the Union of Concerned Scientists (UCS), “[s]everal major fossil fuel companies or their subsidiaries pledged support for ICE,” including respondent Peabody Energy.”!? ICE was quickly exposed as a front group.””° 5.89. In 1994, oil companies created “Californians Against Utility Company Abuse,” which launched a campaign seeking to block investments in electric vehicle charging stations in California.”! The front group was largely funded and operated by the Western States Petroleum Association (WSPA). Respondents BP, Chevron, ExxonMobil, Shell, and other respondent fossil fuel companies herein have been or are members WSPA.2”* 5.90. The creation of these front groups was one of the many tools the respondents sought to avoid taking responsibility for climate change and 217 Global Climate Coalition (21 December 1995), Primer on Climate Change Science, Approval Draft, p-1, available at http://www.climatefiles.com/denial-groups/global-climate-coalition-collection/global- climate-coalition-draft-primer/ (last accessed 12 September 2019). 218 Annex “B” hereof; Pacific Coast Federation of Fishermen’s Association v. Chevron Corp. et al., supra note 184, p. 54. 219 See Exhibit “QQ” to “QQ-28,” Union of Concemed Scientists (2015), The Climate Deception Dossiers: Internal Fossil Fuel Industry Memos Reveal Decades of Corporate Disinformation, p.21. Id. 221 Muffet, C., supra note 141, p. 30, citing Michael Parrish, Trying to Pull the Plug: Big Oil Companies Sponsor Efforts to Curtail Electric, Natural Gas Cars, Los Angeles Times (14 August 1994), available at http://articles.latimes.com/1994-04-14/business/fi-46003_1_natural-gas-cars (last accessed on 12 September 2019). 222 Exhibit “QQ” to “QQ-28, supra note 219, p. 13.

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