Memorandum for the Petitioners | 60 was to ensure a majority of people recognized that ‘significant uncertainties’ exist in climate science, prompting them to raise questions with Congress and others responsible for influencing US progress on climate change.”?? 5.107. API decided that “Victory Will Be Achieved,” when among other things, “[a]verage citizens ‘understand’ uncertainties in climate science,’ and these uncertainties become part of the ‘conventional wisdom’ and supporters of the Kyoto Protocol are viewed as “out of touch with reality.” This reliance on scientific uncertainty, as a weapon to combat meaningful climate action, continued to build among fossil fuel companies as international efforts ramped up to mitigate climate change. 5.108.During this period, the following respondent Carbon Majors were API members directly, or through their predecessors, subsidiaries or affiliates: British Petroleum, Chevron, Conoco Phillips, ExxonMobil, Husky Energy, Marathon Oil, Murphy Oil, Shell Oil, Suncor, and Total.”“* 5.109.Exxon funded the activities outlined in the Roadmap Memo to continuously manufacture and peddle doubt about climate science and action. For example, between 2000 and 2004, Exxon donated $110,000 to organizations tied with Steve Milloy, a member of Global Climate Science Team, and a known tobacco advocate.7° Previously, Milloy led an organization called the Advancement of Sound Science Coalition that “had been covertly created by the tobacco company, Philip Morris, in 1993 to manufacture uncertainty about the health hazards posed by secondhand smoke.”™° In an article about the links between climate denial and Big Tobacco, U.S. Representative Henry Waxman pointed out that “not only are we seeing the same tactics the tobacco industry used, we’re seeing some of the same groups.”24 242 Td. 243 Emphasis supplied; See: Walker, J. (1998, April 3), Draft Global Climate Science Communications Plan, [E-mail to Global Climate Science Team, attaching the Draft Global Science Communications Plan], available at https://insideclimatenews.org/sites/default/files/documents/Global%20Climate%20Science%20Communica tions%20Plan%20%28 1998%29.pdf (last accessed on 12 September 2019). 24 Muffett, C., supra note 141, p. 32. 245 Annex “B” hereof: See: Pacific Coast Federation of Fishermen’s Association v. Chevron Corp. et al, supra note 184, p. 61-62, citing Union of Concemed Scientists (2007), Smoke, Mirrors & Hot Air: How ExxonMobil Uses Big Tobacco’s Tactics to Manufacture Uncertainty on Climate Science. Cambridge, MA, USA, p. 19, available at https://www.ucsusa.org/sites/default/files/legacy/assets/documents/global_warming/exxon_report.pdf (last accessed 12 September 2019). 246 Union of Concerned Scientists (2007), Smoke, Mirrors & Hot Air: How ExxonMobil Uses Big Tobacco’s Tactics to Manufacture Uncertainty on Climate Science. Cambridge, MA, USA, p. 10, available at https:/Avww.ucsusa.org/sites/default/files/legacy/assets/documents/global_warming/exxon_report.pdf (last accessed 12 September 2019). 247 Id, p. 19, citing Hertsgaard, M. (2019), While Washington Slept, Vanity Fair, available at https://www. vanity fair.com/news/2006/05/warming200605 (last accessed on 12 September 2019).

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