Memorandum for the Petitioners | 59 energy strategies.”” Its CEO’s speech, casting doubt on climate science, was taken right out of the industry’s playbook on how to prevent any regulations that would affect profitability. 5.103.Following Raymond’s example, Imperial Oil (Exxon’s Canadian subsidiary) CEO, Robert Peterson, claimed in the Summer 1998 Imperial Oil Review (“A Cleaner Canada”) that the proposition that the “burning of fossil fuels will result in global climate change” was an “unproven hypothesis.”?38 5.104.In order to influence consumers, Mobil (now respondent ExxonMobil) spread this misinformation through paid advertisements, which was intentionally confusing to readers, including their customers. For example, in November 1997, a month before the adoption of the Kyoto Protocol, Mobil paid for an advertorial entitled, “Science: what we know and don’t know,” seeking to undermine that consensus on climate change. Greenpeace USA explains: As Combined with evidence published by reporters showing the degree to which Exxon and Mobil’s own scientists understood the global warming phenomenon and its root in human fossil fuel combustion, the advertorials take on new meaning. These oil companies were not as naive or uncertain as they long pretended to be, up until the point that denying the science was no longer possible. It turns out, they knew the entire time, and public.?39 5.105. The they appear oil industry, to have intentionally as a whole, was deceived the also involved in outright disinformation and denial during this crucial period of time. William O'Keefe, then API Executive Vice President and Global Climate Coalition Chairman, wrote in The Washington Post that, “Climate scientists don’t say that burning oil, gas, and coal is steadily warming the earth.”?“° 5.106.After the adoption of the Kyoto Protocol in 1998, API developed a Global Climate Science “Roadmap Memo.”*"' Communications Action Plan, known as the According to Mr. Muffett, “the goal of API’s project 237 See e.g. Exhibit “KKKKK” to “KKKKK-33,” The Greenhouse Effect; J.F. Black, Products Research Division, Exxon Research and Engineering Co., dated 06 June 1978, cover note, p. 2. 238 Peterson, R. (1998). A Cleaner Canada. Imperial Oil Review Summer 1998, p. 29, available at http://www.documentcloud.org/documents/282781 8- 1998-Imperial-Oil-Robert-Peterson-A-CleanerCanada.html (last accessed 12 September 2019). 23° Gibson, C. (28 August 2017), How Exxon Used the New York Times to Make You Question Climate Science, Greenpeace USA, available at https://www.greenpeace.org/usa/exxon-used-new-york-times-make- question-climate-science/ (last accessed on 12 September 2019). > O'Keefe, W. (1997), A Climate Policy, The Washington Post, available at https://www. washingtonpost.com/archive/opinions/1997/07/05/a-climate-policy/6a1 1899a-c020-4d59- a185-b0e7eebfl 9cc/?noredirect=on (last accessed on 12 September 2019). 4! Muffet, C., supra note 141, p. 32, citing Walker, J. (1998), Draft Global Climate Science Communication Plan; available at www.climatefiles.com/trade-group/american-petroleum-institute/1998global-climate-science-communications-team-action-plan/ (last accessed on 12 September 2019).