Declaration of Dr. Mark Jacobson in Support of Plaintiffs’ Response in 

Opposition to Defendants’ Motion for Summary Judgment

JULIA A. OLSON (OR Bar 062230) 

JuliaAOlson@gmail.com

Wild Earth Advocates

1216 Lincoln Street

Eugene, OR 97401

Tel: (415) 786-4825 

PHILIP L. GREGORY (pro hac vice)

pgregory@gregorylawgroup.com

Gregory Law Group 

1250 Godetia Drive

Redwood City, CA 94062

Tel: (650) 278-2957 

ANDREA K. RODGERS (OR Bar 041029)

Andrearodgers42@gmail.com

Law Offices of Andrea K. Rodgers

3026 NW Esplanade

Seattle, WA 98117

Tel: (206) 696-2851

Attorneys for Plaintiffs 

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

KELSEY CASCADIA ROSE JULIANA; 

XIUHTEZCATL TONATIUH M., through his 

Guardian Tamara Roske-Martinez; et al.,

Plaintiffs,

v.

The UNITED STATES OF AMERICA; 

DONALD TRUMP, in his official capacity as 

President of the United States; et al., 

Defendants.

Case No.: 6:15-cv-01517-TC 

DECLARATION OF DR. MARK 

JACOBSON in Support of Plaintiffs’

Response in Opposition to Defendants’

Motion for Summary Judgment

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Declaration of Dr. Mark Jacobson in Support of Plaintiffs’ Response in 

Opposition to Defendants’ Motion for Summary Judgment

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I, Dr. Mark Jacobson, hereby declare and if called upon would testify as follows:

1. I have been retained as an expert on behalf of Plaintiffs in this matter.

2. I have prepared an expert report for this litigation (“Expert Report”), a true and correct copy 

of which is attached hereto as Exhibit 1. My Expert Report is signed by me. A copy of my 

Expert Report was served on Defendants on April 13, 2018.

a. Attached as Exhibit 2 to this Declaration are Exhibits E through H to my Expert 

Report, the central papers discussed within my Expert Report. 

3. Since my Expert Report was finalized, two independent, peer-reviewed studies have been 

published that support my expert opinion that countries, including the United States, can 

transition feasibly and economically to 100% renewable energy by mid-century. The first 

paper is, The feasibility of 100% renewable electricity systems: A response to critics, by 

Mark Diesendorf and Ben Ellison, published in Renewable and Sustainable Energy Reviews, 

93, 318-330 (2018), true and correct copy of which is attached hereto as Exhibit 3. The 

second paper is, Response to ‘Burden of proof: A comprehensive review of the feasibility of 

100% renewable-electricity systems,’ by T.W. Brown, T. Bischof-Niemz, K. Blok, C. 

Breyer, H. Lund, and B.V. Mathiesen, published in Renewable and Sustainable Energy 

Reviews, 92, 834-847 (2018), a true and correct copy of which is attached hereto as Exhibit 

4.

4. One of the papers, Diesendorf and Elliston, stated: “We find that the principal barriers to 

100[% renewable electricity] are neither technological nor economic, but instead are 

primarily political, institutional and cultural.”

5. My Expert Report contains:

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Declaration of Dr. Mark Jacobson in Support of Plaintiffs’ Response in 

Opposition to Defendants’ Motion for Summary Judgment

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a. a complete statement of all opinions I will express at trial and the basis and reasons 

for these opinions;

b. the facts or data considered by me in forming my opinions;

c. any exhibits that I currently plan to use to summarize or support my opinions;

d. my qualifications, including a list of all publications authored by me in the previous 

10 years;

e. a list of all other cases in which, during the previous 4 years, I testified as an expert at 

trial or by deposition, if any; and

f. a statement of the compensation to be paid for the study and testimony in the case.

6. If called to testify in this matter, I would provide testimony as described in the attached 

Expert Report.

In accordance with 28 U.S.C. § 1746, I declare under penalty of perjury that the 

foregoing is true and correct.

DATED this 25th day of June, 2018.

Respectfully submitted, 

 

 

Dr. Mark Jacobson

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