Memorandum for the Petitioners | 53 sought to protect one of its assets from climate change in 1989. It raised a North Sea natural gas platform to guard it against sea level rise.?” 5.80. Many experts believe that these examples came at a crossroads for the industry, where fossil fuel companies -- including respondents herein -- had the opportunity to disclose the risks based on the recognized scientific consensus. There is ample evidence, however, that some of these companies pivoted from conducting scientific research to denying growing scientific consensus. 4. In blatant internal disregard scientific of their reports, some fossil fuel companies decided to confuse the public on the causes and dangers of climate change, by citing “scientific uncertainty” 5.81. In 1988, respondent ExxonMobil’s spokesperson, Joseph M. Carlson, wrote in a memo that the “Exxon position” is to “emphasize the uncertainty in scientific conclusions regarding the potential enhanced greenhouse effect.”?!° 5.82. Like respondent ExxonMobil, respondent Shell also started to walk back from its corporate position that climate change posed severe risks, and instead focused on scientific uncertainty. A 1994 internal Shell report entitled, “The Enhanced Greenhouse Effect,’ substantially outlined skepticism surrounding the IPCC’s methodology, models, and scientific views. ?!! The report also sets out the Shell Group’s position that “[s]cientific uncertainty and the evolution of energy systems indicate that policies to curb greenhouse gas emissions beyond ‘no regrets’ measures could be premature, divert resources from more pressing needs and further distort markets.”?!? D.5. Into the establishment 1990s, following of the IPCC and the the start of the global climate negotiations, the fossil fuel industry ran full blown campaigns that manufactured science, doubt concealed about the climate foreseeable 209 Lieberman, A and Rust, S. (31 December 2015), Big Oil Braced for Global Warming While it Fought Regulations, available at http://graphics.latimes.com/oil-operations/ (last accessed on 12 September 2019). 210 Carlson, J. M. (03 August 1988), Exxon Memo on the Greenhouse Effect, p. 7, available at http://www.climatefiles.com/exxonmobil/566/ (last accessed on 12 September 2019). 211 1994 Shell Report “The Enhanced Greenhouse Effect — A review of Scientific Aspects, p. 9-13, available at http://www.climatefiles.com/shell/1994-shell-enhanced-greenhouse-effect-review-scientific-aspects/ (last accessed on 12 September 2019). 212 Id, p. 14.

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