LAMAR 8. SMITH, Texas EDDIE BERNICE JOHNSON, Texas
CHAIRMAN RANKING MEMBER

ingress of ?tlnittd$tt1tts

tannin of murmur-stints
COMMITTEE ON SCIENCE, SPACE, AND TECHNOLOGY
2321 RAYBURN HOUSE OFFICE BUILDING
WASHINGTON, DC 20515?6301
(202} 225?6371



June 23, 2016

The Honorable Lamar Smith

Chairman

Committee on Science, Space, and Technology
2321 Rayburn House Of?ce Building
Washington, DC 20515

Dear Chairman Smith,

On May 18, 2016, you wrote to 17 state and territorial attorneys general and 8 non?
governmental organizations (NGOs) demanding documents related to possible
investigations into fossil fuel industry fraud regarding climate change. On June 17, 2016,
after receiving what were presumably unsatisfactory responses from these attorneys
general and NGOs, you sent a second round of demands to these same groups. These
demands are an illegitimate exercise of Congressional oversight power, and I urge you to
immediately cease this abuse of authority.

In a Congress in which the Committee on Science, Space, and Technology?s oversight
powers have been repeatedly abused, this latest action stands apart. In addition to
mischaracterizing innumerable facts, laws, and legal precedents surrounding this
situation, the May 18 and June 17 letters have now led the Committee on Science, Space,
and Technology to the precipice of a Constitutional crisis. Never in the history of this
formerly esteemed Committee has oversight been carried out with such open disregard
for truth, fairness, and the rule of law. 

The state and territorial attorneys general, representatives for the targeted NGOs, and 43
Democratic Members of Congress2 have already written to you to patiently explain the

 

Attorneys General from: California, Connecticut, District of Columbia, Iowa, Illinois, Massachusetts,
Maryland, Maine, Minnesota, New Mexico, New York, Oregon, Rhode Island, US. Virgin Islands,
Virginia, Vermont, Washington. NGOs: 350.0rg, Climate Accountability Institute, The Climate Reality
Project, Greenpeace, Pawa Law Group, PC, The Rockefeller Brothers Fund, Rockefeller Family Fund,
Union of Concerned Scientists. All Committee letters and responses are available at:

environmental-groups

2 Letter from Hon. Donald S. Beyer Jr. to Hon. Lamar Smith, Chairman, H. Comm. On Science, Space, 
Tech. (June 2, 2016); Letter from Hon. Paul D. Tonko to Hon. Lamar Smith, Chairman, H. Comm. On

1

illegitimacy of your ?investigation.? Since you have apparently rejected their responses, I
will endeavor to highlight once more the factual and legal shortcomings of your demand
letters.

The Majority?s Letters Mischaracterize State Attorney General Actions

Both your May 18 and June 17 letters refer to a ?coordinated attempt to attack First
Amendment rights of American citizens and their ability to fund and conduct scienti?c
research free from intimidation and threats of prosecution. . 3?3 In laying out your factual
case, you state:

This sequence of events from the 2012 workshop to develop strategies to enlist
the help of attorneys general to secure documents, to the 2016 subpoenas issued
by you and other members of the Green 20 raises serious questions about the
impartiality and independence of current investigations by the attorneys general.
Your of?ce funded with taxpayer dollars is using legal actions and
investigative tactics taken in close coordination with certain special interest
groups and trial attorneys may rise to the level of an abuse of prosecutorial
discretion. Further, such actions call into question the integrity of your of?ce.4

Ignoring for a moment the grossly inappropriate and unsubstantiated innuendo contained
in these statements, I would like to highlight the factual de?ciencies in your claims.

First of all, it is important to accurately report on the actions of the state and territorial
attorneys general. As the New York Attorney General?s Of?ce noted in their response to
your May 18 letter, they are investigating ?whether ExxonMobil Corporation violated
New York?s securities, business and consumer fraud laws by making false or misleading
statements to investors and consumers relating to climate change driven risks and their
impact on Exxon?s business.?5 In other words, these state attorneys general are
investigating potential fraud under state law.

The Commonwealth of Massachusetts Of?ce of the Attorney General laid out the factual
basis for these fraud investigations in some detail in its June 2, 2016, response letter,
stating:

Publicly available Exxon documents establish that at least by July 1977, Exxon?s
own scientists informed Exxon management that the release of carbon dioxide
from burning fossil ?iels was causing global temperatures to increase, a situation
that would, the scientists warned Exxon management, give rise to ?the need for
hard decisions regarding changes in energy strategies.? Publicly available Exxon

 

Science, Space, Tech. (June 10, 2016); Letter from Hon. Ted W. Lieu to Hon. Lamar Smith, Chairman,
H. Comm. On Science, Space, Tech. (June 9, 2016).
3 Letter from Hon. Lamar Smith, Chairman, H. Comm. On Science, Space, Tech. to Hon. Eric
4Schneiderman, Attorney General, May 18, 2016, pg. 4.

1d.
5 Letter from Leslie B. Dubeck, Counsel, Of?ce of the New York Attorney General to Hon. Lamar Smith,
Chairman, H. Comm. On Science, Space, Tech, May 26, 2016, pg. 1.

2

documents also con?rm that Exxon?ls scientists were, in the early 19803,
predicting signi?cant increases in global temperature as a result of the combustion
of fossil fuels, and that a 2 to 3 degree Celsius increase could lead to melting of
polar ice, rising sea levels and ?redistribution of rainfall,? ?accelerated growth of
pests and weeds,? ?detrimental health effects,? and ?population migration.?
Exxon?s scientists counseled Exxon management that it would be possible to
?avoid the problem by sharply curtailing the use of fossil fuels.? One Exxon
scientist warned in no uncertain terms that it was possible? that the
effects of climate change over time will ?indeed be catastrophic (at least for a
substantial fraction of the earth?s population).? Despite Exxon?s early
understanding of the science of climate change and the threats posed by climate
change to human populations and global ecosystems, other publically available
documents suggest that Exxon may have participated in later self-interested
efforts to mislead the public, including investors and consumers, with respect to
the impacts of climate change in order to defeat governmental policy measures
designed to address the threat of climate change.6

These accusations were widely reported in the press in 2015.7? Moreover, these
accusations should have come as no surprise to you or your staff as they formed the same
factual basis that compelled 20 scientists to write to the US. Attorney General to suggest
that Racketeer In?uenced and Corrupt Organizations Act (RICO) investigations might be
warranted against fossil fuels companies that potentially knowingly defrauded the
American public. You previously instigated an investigation against one of those
scientists for exercising his constitutionally protected First Amendment right to petition
the government.8 This is the ?rst of many instances where the irony of your current
accusations becomes evident.

Multiple state attorneys general also pointed out the legal fallacy of your accusations of
First Amendment Violations. For instance, the Oregon Attorney General?s Of?ce pointed
out that:

[y]our letter also incorrectly accuses this of?ce of investigating entities based on
their speech or beliefs concerning climate change. Please be advised this of?ce

 

6 Letter from Richard A. Johnston, Chief Legal Counsel, Commonwealth of Massachusetts Of?ce of the
Attorney General letter to Hon. Lamar Smith, Chairman, H. Comm. On Science, Space, Tech, June 2,
2016, pgs. 1-2 (citations omitted).

7 See, e. Shannon Hall, Exxon Knew About Climate Change Almost 40 Years Ago: A new investigation
shows the oil company understood the science before it became a public issue and spent millions to
promote misinformation, Scienti?c American, Oct. 26, 2015, available at


And, Neela Banerjee, Lisa Song, and David Hasemyer, Exxon ?s Own Research Con?rmed Fossil Fuels?
Role in Global Warming Decades Ago, Inside Climate News, Sep. 16, 2015, available at
0920 
warming

8 Press Release, H. Comm. On Science, Space, and Tech, ?Smith: Taxpayer-Funded Climate Org
Allegedly Seeks Criminal Penalties for Skeptics,? Oct. 1, 2015, available at


penalties-skeptics

will not be dissuaded from considering whether state laws, including consumer
protections laws, may provide redress against knowingly false commercial speech
concerning global warming. The First Amendment simply does not protect
fraudulent speech. Illinois v. Telemarketing Associates, Inc. 5 38 U.S. 600, 612
(2003); Donaldson v. Read Magazine, Inc, 333 U.S. 178, 190 (1948) (?This
government power [to protect people against fraud] has always been recognized
in this country and is ?rmly 

The notion that fraudulent speech is not protected by the U.S. Constitution would seem to
be beyond dispute. Nonetheless, despite the state attorneys generals pointing very
speci?cally to the factual and legal de?ciencies of your accusations, your June 17, 2016,
letters persist in leveling these baseless accusations against the attorneys general, stating:

This statement suggests that your of?ce, as an arm of state government, will
decide what science is valid and what science is invalid. In essence, you are
saying that if your of?ce disagrees with whether fossil fuel companies? scientists
were conducting and using the ?best science,? the corporation could be held liable
for fraud. Not only does the possibility exist that such action could have a chilling
effect on scientists performing federally funded research, but it also could infringe
on the civil rights of scientists who become targets of these inquiries. Your
actions violate the scientists? First Amendment rights. Congress has a duty to
investigate your efforts to criminalize scienti?c dissent.10

Nothing in that assertion bears any relationship to the statements of the various state
attorneys general. These state investigations have nothing to do with deciding ?what
science is valid and what science is invalid.? The investigations, as multiple attorneys
general pointed out, are concerned with whether certain fossil fuel companies believed or
knew one set of facts, and yet publically disseminated another in order to enrich
themselves at others expense. These allegations constitute textbook fraud.11

These investigations have a well-known precedent. In the 1990s, various state attorneys
general sued tobacco companies for the state-borne healthcare costs associated with
tobacco use. One of the bases for the claims was that the tobacco industry engaged in a
conspiracy to conceal and misrepresent ?the addictive and harmful nature of
These suits resulted in the Master Settlement Agreement in 1998,
where the four largest tobacco companies settled all pending state claims related to the
healthcare costs related to tobacco. 3 The Federal Government soon followed suit. In

 

9 Letter from Frederick M. Boss, Deputy Attorney General, Oregon Department of Justice letter to Hon.
Lamar Smith, Chairman, H. Comm. On Science, Space, Tech, June 1, 2016, pg. 2.

10 Letter from Hon. Lamar Smith, Chairman, H. Comm. On Science, Space, Tech. to Hon. Eric
Schneiderman, Attorney General, June 17, 2016, pg. 3.

Black?s Law Dictionary de?nes fraud as: knowing misrepresentation of the truth or concealment of a
material fact to induce another to act to his or her detriment.? Black?s Law Dictionary 670 (7th ed. 1999).
12 Civil Action Complaint, Commonwealth of Commonwealth of v. Philip
Morris, Ina, pg. 10, April 1997.

13Tobacco Control Legal Consortium, The Master Settlement Agreement: An Overview, available at
1 5m

4

1999 the U.S. Department of Justice brought RICO Act actions against the largest
tobacco companiesl?4 The parallels of that case with the current state attorneys general
investigations cannot be overstated. In U.S. v. Philip Morris, the government alleged that
the tobacco industry internally knew of the health risks of their products for decades, yet
engaged in a well-?nanced conspiracy to deceive the American public about the health
effects of tobacco. This included ?nancing scienti?c studies questioning the links
between tobacco and health problems and the creation of front organizations to hide links
to the tobacco ?nancing. The U.S. government won the case, and the decision was upheld
on appeal. 15

I have repeatedly criticized your tendency to rely upon former tobacco industry-funded
scientists, consultants, and public relations ?rms in past Committee investigations and
hearings.16 Given your past reliance on such ?experts?, it?s perhaps unsurprising that you
are now questioning these legitimate state attorneys general investigations of potential
fraudulent actions against the American people.

The Majority?s Investigation of State Attorneys General is Unconstitutional

A Congressional document demand to a state attorney general is exceptionally unusual.
Such a demand from the Science Committee is unheard of.

State attorney generals are elected of?cials of sovereign state governments. They are not
employees of the Federal Government, nor are they subject to federal oversight or
control, including by the United States Congress.

You note in your June 17 letter that Congress?s oversight powers are well established and
broad, citing such authorities as the Constitution, Art. 1; McGrain v. Daugherty,
273 U.S. 135 (1927) (Congress was investigating the U.S. Dep?t of Justice?s handling of
the Teapot Dome scandal); Eastland v. United States Servicemen ?s and, 421 U.S. 491
Senate committee investigating the activities of U.S. Servicemen?s Fund and
their effect on the morale of members of the Armed Services)?17 The existence of
Congress?s oversight powers goes without saying, and is a well-established principle of
law. You go on to make an important point about the source of Congressional oversight
power, stating:

 

?4 U.S. Department of Justice, Litigation Against Tobacco Companies Home,


?5 UnitedStates v. Philip Morris USA, Inc, 566 F.3d 1095 (11c. Cir. 2009).

16 See, Letter from Hon. Eddie Bernice Johnson, Ranking Member, to Hon. Lamar Smith, Chairman,
H. Comm. On Science, Space, Tech.,.August 6, 2013, available at


And, Ensuring Open Science at EPA: Hearing Before the Subcomm. 0n the Environment ofthe H. Comm.
0n Science, Space, Tech, 113th Cong. 16-17 (2014) (statement of Hon. Eddie Bernice Johnson, Ranking
Member).

17 Letter from Hon. Lamar Smith, Chairman, H. Comm. On Science, Space, Tech. to Hon. Eric
Schneiderman, Attorney General, June 17, 2016, pg. 1 (note).

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Hand in hand with Congress? legislative power is its power to investigate. Indeed,
in 1975, when commenting on Congress? investigative power, the Supreme Court
stated that the ?scope of its power of is as penetrating and far-reaching
as the potential power to enact and appropriate under the Constitution.18

This analysis is particularly relevant to the ?investigation? at hand. Congress?s broad
oversight powers are directly tied to our power to legislate. Thus, by the authority you
have relied upon in your own letters, Congress has no legal oversight authority over
issues or actions that fall outside Congress?s legislative authority.

As nearly every state attorney general who responded to your May 18 letters indicated,
state government law enforcement of?cials acting in their of?cial capacities are not
within Congress? legislative control. For instance, in its May 27, 2016, response to your
demand letter, the California Attorney General?s Of?ce noted:

[w]e do not believe it is within the jurisdiction of Congress to demand documents
from a state law enforcement of?cial such as the California Attorney General.
Although Congress? investigative jurisdiction is broad, that is because it tracks
Congress? power to legislate and appropriate concerning federal matters. But the
power to investigate does not extend beyond those matters. (See, e.g. Barenblatt
v. US. (1959) 360 US 109, 111 [?Congress may only investigate into those areas
in which it may potentially legislate or Investigations and
prosecutions of state law enforcement actions by state attorneys general are not
federal matters. To the contrary, under the Constitution and laws of the United
States, such activities partake of police powers reserved to the states, and are not
subject to federal interference. (See, e. New York v. US. (1992) 505 U.S. 144,
162 [?the Constitution has never been understood to confer upon Congress the
ability to require the States to govern according to Congress? 

As a reminder, the Tenth Amendment to the US. Constitution reads as follows:

The powers not delegated to the United States by the Constitution, nor prohibited
by it to the States, are reserved to the States respectively, or to the people.20

Implicit in the powers reserved to the states under the Tenth Amendment are state police
powers. In case after case, the courts have struck down Congressional attempts to
regulate state government activities, including exercise of their police powers.? It is clear
that Congress has no legislative authority to dictate the actions of state attorneys general.

 

?8 1d. at 1, citing Eastland v. United States Servicemen :9 Fund, 431 us. 491, 504 n. 15 (1975) (quoting
Barenblatt v. United States 360 US 109, 111 (1959)).

?9 Letter from Martin Goyette, Senior Assistant Attorney General, State of California Department of Justice
letter to Hon. Lamar Smith, Chairman, H. Comm. On Science, Space, Tech., May 27, 2016, pg. 2.

2? US. Const. amend. X.

2? See, United States v. Lopez, 514 US. 549 (1995) (striking down a gun-free school zone provision);
United States v. Morrison, 529 US. 598 (2000) (invalidating a provision of the Violence Against Women
Act); and, United States v. Constantine, 296 US. 287 (1935) (invalidating an excise tax imposed on
violators of local law).

Even if Congress did have some inroad into regulation of state police powers, such a
legislative authority would not rest with the Committee on Science, Space, and
Technology. Our oversight jurisdiction (which is broader than our actual legislative
jurisdiction) encompasses ?laws, programs, and Government activities relating to
nonmilitary research and development.?22 Note that the capitalization of the word
?Government? gives the word the meaning ?Federal Government.? Nowhere in our
jurisdiction legislative or oversight - can one ?nd justi?cation for our Committee?s
oversight of state police powers. The elected of?cials that serve as state attorney generals
are answerable to their respective constituents and the courts, but not to the US.
Congress. As my colleagues from Virginia, the District of Columbia, and Maryland
pointed out:

States? rights long being a central pillar of conservative philosophy, the Letter?s
effort to meddle directly in the self?governance and prosecutorial discretion of 17
US. state and territories is not lacking for irony.23

The Majority?s Investigation of Exercise of Free Speech is Unconstitutional
The First Amendment to the US. Constitution reads, in whole:

Congress shall make no law respecting an establishment of religion, or prohibiting
the free exercise thereof; or abridging the freedom of speech, or of the press; or
the right of the people peaceably to assemble, and to petition the Government for
a redress of grievances.

While the First Amendment prohibits government interference with the free speech rights
of individuals, that prohibition is not absolute. One relevant example is that fraudulent
speech is not protected by the First Amendment.25 Moreover, the First amendment does
not provide an absolute shield against legitimate Congressional oversight. In that regard,
you state in your June 17 letter to the various NGOs:

In Barenblan? v. United States, the Supreme Court stated ?where the First
Amendment rights are asserted to bar government interrogation resolution of the
issue always involves a balancing by the courts of the competing private and
public interests at stake in the particular circumstances shown.? Moreover, when
balancing the interests of the parties in Watkins 12. United States, the Court held
?the critical element is the existence of, and the weight to be ascribed to, the
interest of the Congress in demanding disclosure from an unwilling witness.?
These cases are important precisely because they provide examples of
congressional investigations sustained by the Supreme Court involving

 

32 House Rule 

23 Letter from Hon. Donald S. Beyer J11, to Hon. Lamar Smith, Chairman, H. Comm. On Science, Space, 
Tech, June 2, 2016, pg. 2.

24 US. Const. amend. I.

25 See, Illinois v. Telemarketing Associates, Inc, 538 US. 600, 612 (2003).

7

organizations similar to yours. The parties being investigated in the cases noted
above are no different than the recipients of the Science Committee?s May 18
letter.26

Since this is the only real legal authority you cite as justi?cation for investigating
Americans? constitutionally protected speech, I think it is worth scrutinizing.

First, I would like to point out the context of these cases. Both of these cases involved
the notorious House Un-American Activities Committee (HUAC), and investigations that
committee conducted into the private lives of American citizens. If ever there was an
example of a ?witch hunt? in the history of the United States Congress, the HUAC
investigations best ?t the bill. For that reason, it is more than a little disconcerting that
you think those cases? fact patterns so closely resemble your own investigation.

I would also like to point to an error in your statement. You state that both of these cases
are important because ?they provide examples of congressional investigations sustained
highe Supreme Court involving organizations similar to yours.?27 This statement is
false. In Watkins v. United States, the Supreme Court overturned a conviction under 2
U.S.C. 192 against an individual who refused to provide certain testimony to HUAC.28
The Watkins Court held that the conviction was invalid under the Due Process Clause of
the Fifth Amendment.

 

Rather than supporting the legal grounds of your investigation, the Watkins decision is
actually an indictment against it. The Watkins court noted that:

The Court recognized the restraints of the Bill of Rights upon congressional
investigations in United States v. Rumely, 345 US. It was concluded that,
when First Amendment rights are threatened, the delegation of power to the
committee must be clearly revealed in its charter.29

The Watkins Court went on to state:

Kilbourn v. Thompson teaches that such an investigation into individual affairs is
invalid if unrelated to any legislative purpose. That is beyond the powers
conferred upon the Congress in the Constitution. United States v. Rumely makes
it plain that the mere semblance of legislative purpose would not justify an
inquiry in the face of the Bill of Rights.30

As I noted earlier, it is clear that our Committee doesn?t even have a semblance of a
legislative purpose that would justify this investigation. It is inconceivable that our

 

26 Letter from Hon. Lamar Smith, Chairman, H. Comm. On Science, Space, Tech. to Richard Heede,
Climate Accountability Institute, June 17, 2016, pg. 4 (citations omitted).

27 Id. emphasis added.

28 Watkins v. UnitedStates, 354 US. 178 (1957).

29 Id. at 198.

30 

Committee, based on our House Rule jurisdiction, could legislate on any topic related
to state law enforcement, private speech, private citizens exercising their First
Amendment right to petition their government, or fraud. In fact, the only plausible
legislative action that Congress as a whole could take in this instance would be in altering
Federal fraud and RICO Act statutes to inappropriately help big oil avoid potential
liability. However, even in that instance, such a bill would not come anywhere near the
jurisdiction of the Committee on Science, Space, and Technology.

Your June 17 letter claims legislative jurisdiction over this ?investigation? because we
oversee $31.8 billion in annual federal government research expenditures. Somehow you
link the Committee?s speci?c jurisdiction to fund federal scienti?c research to being the
science police for the United States. Even if we had such expansive jurisdiction (and we
do not), it would still fall far short of having jurisdiction over state police powers or fraud
laws, which are the true subject matters of this ?investigation.? Thus, based on the legal
authorities you yourself have cited, this ?investigation? violates the Constitution.

This ?Investigation? is Illegitimate

In the foregoing, I have pointed out the many factual and legal shortcomings and
mischaracterizations contained in your May 18 and June 17 letters. Sadly, despite having
these shortcomings previously noted to you, this misguided effort is continuing. In
reality, this overreach is simply the culmination of three years of ?oversight? run amuck.
When you assumed the Chairmanship of this Committee, Members were promised an
ambitious and bipartisan legislative agenda. That did not materialize. What has taken its
place is a series of increasingly disturbing ??shing expeditions? masquerading as
oversight.

I noted your May and June letters contain a great deal of unintentional irony. I?ll note one
more example. In your June 17 letter, as a justi?cation for your current investigation you
say:

[C]ongress has a responsibility to investigate whether such investigations are
having a chilling effect on the free ?ow of scienti?c inquiry and debate regarding
climate change. 1

Here, you could just as well be referring to your own misguided investigation into
eminent NOAA climate scientists last year. In that ?investigation? you actually
subpoenaed NOAA Administrator, former astronaut, and authentic American hero Dr.
Kathy Sullivan in an attempt to obtain the email communications of world renowned
NOAA climate scientists.3 What was the purpose of this investigation? It was simply a
?shing expedition against scientists who reached a scienti?c conclusion with which you

 

31 Letter from Hon. Lamar Smith, Chairman, H. Comm. On Science, Space, Tech. to Richard Heede,
Climate Accountability Institute, June 17,2016, pg. 3.

32 Committee on Science, Space, and Technology Subpoena Duces Tecum issued by Hon. Lamar Smith,
Chairman, to Hon. Kathym Sullivan, 1 l4Lh Cong, October 13, 2015.

9

personally disagreed. In the end, your investigation, like so many recent Science
Committee investigations, found nothing.

I have served on the Committee on Science for more than two decades, and during that
time this Committee has accomplished great things. We?ve overseen the completion of
the International Space Station and the sequencing of the human genome, and we?ve
undertaken serious investigations, ranging from the Space Shuttle Challenger accident to
the environmental crimes at the Rocky Flats nuclear site. However, lately the Committee
on Science has seemed more like a Committee on Harassment. The Committee?s proli?c,
aimless, and jurisdictionally questionable oversight activities have grown increasingly
mean-spirited and meaningless. They frequently appear to be designed primarily to
generate press releases. However, none of these recent investigations has rushed head
long into a serious Constitutional crisis like we are about to face. We are moving into
dangerous and uncharted territory.

At the beginning of this Congress I swore an oath to uphold the Constitution. I take that
oath seriously. As evidenced by the letters you have received from Democratic Members
from New York, California, Virginia, Maryland, and the District of Columbia, the
Democratic Members of the Committee also take this oath seriously. We will not sit idly
by while the powers of the Committee are used to trample on the Bill of Rights of the
US. Constitution. I implore you to cease your current actions before they do lasting
institutional damage to the Committee on Science, Space, and Technology and the
Congress as a whole.

Thank you for your attention to this matter.

Sincerely,
EDDIE BERNICE JOHNSON

Ranking Member
Committee on Science, Space, and Technology

Cc: Members of the Committee on Science, Space, and Technology

California, Connecticut, District of Columbia, Iowa, Illinois, Massachusetts, Maryland,
Maine, Minnesota, New Mexico, New York, Oregon, Rhode Island, US. Virgin Islands
Virginia, Vermont, Washington Attorneys General and 350.0rg, Climate Accountability
Institute, The Climate Reality Project, Greenpeace, Pawa Law Group, P.C., The
Rockefeller Brothers Fund, Rockefeller Family Fund, Union of Concerned Scientists

9

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