JULIA A. OLSON (OR Bar 062230) 

JuliaAOlson@gmail.com

WILD EARTH ADVOCATES

1216 Lincoln Street

Eugene, OR 97401

Tel: (415) 786-4825 

DANIEL M. GALPERN (OR Bar 061950)

dan.galpern@gmail.com

LAW OFFICES OF DANIEL M. GALPERN

1641 Oak Street

Eugene, OR 97401

Tel: (541) 968-7164

Attorneys for Plaintiffs

JOSEPH W. COTCHETT 

jcotchett@cpmlegal.com

PHILIP L. GREGORY (pro hac vice) 

pgregory@cpmlegal.com

PAUL N. MCCLOSKEY 

pmccloskey@cpmlegal.com

COTCHETT, PITRE & McCARTHY, LLP

San Francisco Airport Office Center

840 Malcolm Road

Burlingame, CA 94010

Tel: (650) 697-6000

Fax: (650) 697-0577

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

EUGENE DIVISION

KELSEY CASCADIA ROSE JULIANA;

XIUHTEZCATL TONATIUH M., through 

his Guardian Tamara Roske-Martinez; et al.

Plaintiffs,

v.

The UNITED STATES OF AMERICA; 

BARACK OBAMA, in his official capacity as 

President of the United States; et al., 

Federal Defendants.

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

DECLARATION OF KELSEY CASCADIA 

ROSE JULIANA In Support of Plaintiffs’ 

Opposition to Defendants’ Motion to Dismiss; 

Oral Argument: February 17, 2016, 2:00 p.m.

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Declaration of Kelsey Cascadia Rose Juliana in Support of Plaintiffs’ 

Opposition to Defendants’ Motion to Dismiss

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I, Kelsey Cascadia Rose Juliana, hereby declare as follows:

1. I am a United States citizen and a resident of Oregon. At the time this case was 

filed in summer of 2015, I was nineteen years old. In November 2014, I voted in 

my first election. I submit this Declaration to describe the various ways in which I 

am and will be impacted by the Federal Defendants’ actions and inactions 

regarding carbon pollution, which is causing climate destabilization and ocean 

acidification, thereby threatening the public trust resources on which I rely as a 

citizen beneficiary.

2. I was born in the Cascade Mountains and raised in Eugene. I was named for the 

forests and waters in Oregon that are sacred to my family and to me. While I 

attend college in Asheville, North Carolina, I often return and will continue to 

return to Oregon to visit my family and friends over my four years of college. I 

intend to reside permanently in Oregon, hopefully Eugene, after I obtain my 

bachelor’s degree. I also plan to complete my graduate degree in the Pacific 

Northwest. I cannot imagine a better place to live and to raise a family some day. 

This region is truly my home.

3. I depend upon the clean waters of Oregon for drinking, bathing, cleaning, 

rejuvenation, and recreation. I drink the freshwater that flows from the McKenzie 

River, and I drink from other rivers when I spend time in other parts of the state. I 

also drink from springs in many of the Cascade lakes on hiking, canoeing, and 

backpacking trips. Clear Lake, Oregon is my favorite place to go to connect to the 

natural world. I have camped and hiked along its shores, swam and paddled 

canoes on its clear water, and picked and ate huckleberries along the trails. My 

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Declaration of Kelsey Cascadia Rose Juliana in Support of Plaintiffs’ 

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family has brought our exchange students from China, Italy, and Spain to Clear 

Lake on family nature trips. I also enjoy visiting Sahalie Falls and many other 

waterfalls of Oregon, as well as the natural hot springs we are fortunate to have. 

The freshwater of Oregon is essential to my life. I was given my first name 

because of Kelsey Creek, a wild and remote creek in the Cascades.

4. In addition to Oregon’s freshwater, I also depend upon the marine and estuarine 

waters of Oregon as a food source and a place of recreation and vacationing. I 

grew up spending time along the Oregon coast in places like Yachats and 

Florence. I enjoy playing on the beach and walking barefoot in the sand. I love to 

go tidepooling and look for the unique marine animals that can live only in those 

tidepools. I love playing along the shores with my dogs. The coast has always 

been a favorite vacation spot for my family and me. We love the beautiful and 

vibrant views as a way to rejuvenate and find peacefulness, and connect our 

family to each other and nature. 

5. Part of my diet in Oregon includes food that comes from the marine waters and 

from our freshwater rivers. I eat salmon, cod, tuna, and crab. I also depend upon 

food that is grown in Oregon by small farmers in the Willamette Valley that my 

family and I buy at farmers’ markets. We have gardens in my front and back yard, 

so I know the value of local food for culture, health, and sustainability. My family 

has been practicing permaculture since we first moved here. We raised poultry, 

rabbits, bees, and grown fruits, vegetables, and medicinal herbs. These local 

sources of food and medicine are essential in the diet of my family and me and are 

important to our lifestyle.

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Declaration of Kelsey Cascadia Rose Juliana in Support of Plaintiffs’ 

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6. For exercise and recreation, I rely upon the public trust resources in Oregon, from 

waters and snowfields, shores and banks, to tidelands and forests. In addition to 

coastal recreation, I go snowshoeing, cross-country skiing, hiking, and snow 

camping in the winter. I go rafting, swimming in rivers, snorkeling on rivers, 

canoeing on lakes, hiking, rock-climbing, and backpacking in the warmer seasons. 

7. I have also grown up exploring the old growth forests of Oregon in the heart of 

the Cascades. These forests are very important to my happiness. My home and 

identity lies in the natural diversity and vibrance of the cascade bioregion. I love 

smelling pine and fir trees, walking on dusty trails, and feeling the sticky sap on 

trees. I love walking in the old growth coastal rainforests with ferns and moss 

around me, as well as walking in forests along the McKenzie River where I notice 

how wet and squishy the soil is, full of many different plants and soils and 

downed logs. In the Southern Oregon forests, I enjoy the drier feel of the 

deciduous forests with madrone and oak trees and the vibrant wildflower 

meadows. Experiencing the smells of the wildflowers, the sounds of the birds and 

the flowing streams, and the views of gentle creekbeds are all key elements of my 

recreational and spiritual enjoyment. Having solitude in the vastness of a healthy 

forest is vital to my wellness and is how I find a spiritual connection in my life.

8. While I am recreating and enjoying nature, I like to view hummingbirds, eagles, 

butterflies, bees in wildflower meadows, elk and deer, beavers, foxes, and bears. 

One of the most spectacular views for me and a place of spiritual connection is 

gazing at alpine lakes in the Cascades, where I meditate and swim at sunrise to 

start my day in nature.

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Declaration of Kelsey Cascadia Rose Juliana in Support of Plaintiffs’ 

Opposition to Defendants’ Motion to Dismiss

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9. I also like rocks and desert ecosystems. I enjoy hiking through lava rocks and 

rockclimbing in Eastern Oregon near Smith Rock and Sisters. I do those activities 

in the summer when the weather is hotter, but manageable with Oregon’s climate. 

When the heat is too extreme I have walked into the base of Smith Rock, but I 

will not climb. With increasing temperatures and more extreme heat days, more 

summer days have become unbearable there. I love visiting Smith Rock with my 

family regularly in the summer months, cooling off in the river after a day under 

the sun. We’re planning on bringing our exchange student to Smith Rock early 

this summer, however we may be unable to if we get another unusually hot and 

dry summer, seeing as it is uncomfortable and sometimes dangerous.

10. With warming temperatures will come more harm to our water systems. For 

instance, some of the lakes I visit suffer from algal blooms that prohibit 

swimming in the lakes or even filtering water for drinking. The water is toxic to 

human and animal life and has made me ill. I’ve gotten sick from parasites twice 

in my life from drinking filtered water from Oregon alpine lakes while on 

backpacking trips.

11. The projections for Oregon’s water supply and drought in the coming decades 

scare me. I understand from experts that we could lose half of our snowpack by 

the middle of this century. My family has been taking me to snowy places like 

Odell Lake, Willamette Pass, Hoodoo, Mt Bachelor, and Mr. Fuji since I was very 

young, and I look forward to winter recreating in these beautiful places all year. 

The Oregon Mountains are truly remarkable, and I love exploring them in the 

summer and winter, under sun and snow. The last two winters I have been unable 

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Declaration of Kelsey Cascadia Rose Juliana in Support of Plaintiffs’ 

Opposition to Defendants’ Motion to Dismiss

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to go snowshoeing and skiing with my family for our normal winter recreating 

because of the severe decrease in snow. Drought is affecting all of the places in 

Oregon I love, and is affecting my drinking water and food sources, like salmon, 

of which I’ve noticed less availability. I fear that salmon such as Chinook, the 

Oregon state fish, will become increasingly threatened due to increased water 

temperatures, drought, and other factors such as sedimentation and snowpack

levels, and will therefore be cut out of my diet to help ensure their population 

survives. Drier and warmer seasons have affected our food production in our 

gardens and our family is having to make changes to our planting and harvesting 

schedules. The increasing temperatures are also increasing the number of pests 

that affect the crops in the Valley.

12. I understand that the waters off of the Oregon coast are so acidic already from 

carbon dioxide that they no longer sustain oyster hatcheries and our shellfish is at 

risk.

13. I understand that the seas are rising and our coastline and beaches too will be 

impacted. Already I have observed increased erosion due to sea rise around the 

town of Yachats, where the roads are eroding in and homes and infrastructure are 

threatened due to eroding banks. I’ve talked with locals in Yachats, and they told 

me about plans to remake the road and move buildings inland. I want to continue 

to be able to visit Yachats throughout my life, and I’m concerned about my future 

ability to enjoy this scenic part of the Oregon coast.

14. I have been run out of camping because of wildfires and weather extremes. I 

understand that I will continue to face an increased incidence of cancelled 

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Declaration of Kelsey Cascadia Rose Juliana in Support of Plaintiffs’ 

Opposition to Defendants’ Motion to Dismiss

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camping trips if carbon emissions are not significantly and urgently reduced. 

During the increasing number of heavy rain events, the entrance to our house 

floods, our gardens get oversaturated, and food falls off trees and plants and rots, 

resulting in a loss of food production and damaged soils. I worry about the risks 

and damages my home will face considering its location and the more frequent 

extreme weather events hitting my home region.

15. I have friends who are climate refugees, people who have already been displaced 

from their homes outside of Oregon due to climate impacts. I understand that 

Oregon is a place that may see a significant influx of climate refugees in the 

future as more and more people are displaced, putting more pressure on our state 

public trust resources. 

16. One of my greatest fears is that the areas I visit and the wildlife (both animals and 

forests) will not be able to survive and adapt quickly enough to climate change 

caused by these Defendants. I feel distressed about these impacts of climate 

change, such as beloved lakes and rivers throughout the state drying up from 

drought and the subsequent loss of biodiversity in those unique water systems. 

Seeing the current changes to the home I love make me sad and concerned. I find 

my inner self in wildlife and in wilderness and I feel disconnected from myself 

when I think about how those things will suffer from climate change and ocean 

acidification due to carbon pollution caused by these Defendants.

17. Even though I graduated from South Eugene High School in June 2014, I delayed 

starting college so that I could walk 1,600 miles in the Great March for Climate 

Action from Nebraska to Washington D.C. I believe that climate change is the 

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Declaration of Kelsey Cascadia Rose Juliana in Support of Plaintiffs’ 

Opposition to Defendants’ Motion to Dismiss

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most pressing issue my generation will ever face, indeed that the world has ever 

faced. This is both an environmental and a human rights issue. I also believe that 

if our governments pay attention to the science and act as public trustees, we can 

solve this problem and protect not only my generation, but future generations. So

I marched for 1,600 miles alongside corn fields, highways, inner cities, urban 

sprawl, and mountainous countryside, all of which I could see the effects of 

climate change on the land and communities. I went on this March to meet people 

who have been affected by climate crisis and to experience their struggles and 

witness their stories firsthand. I went on this March to raise awareness and to 

educate people. Marching was a testament to how important climate action is to 

me and important it is to walk the talk and create awareness. 

18. On the Great March for Climate Action, I met many people who also are harmed 

by carbon pollution and I experienced more harms myself. I walked through areas 

of the country where we had to wear masks, especially in Pennsylvania where our 

path included industrial plants, extraction sites, and fossil fuel facilities. We had 

to cover our faces in order to protect our lungs as we walked on public 

thoroughfares across our country. We met people who had developed cancer from 

pollution; people who had lost loved ones from methane pollution; and people 

who experienced their waterways on fire. I experienced emotional hardship that 

has stayed with me from hearing devastating stories of fossil fuel impacts to 

innumerable Americans along the March, from coal to fossil fuel combustion to 

organic farmers who cannot maintain their farms because of fracking wells lining 

their property.

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Declaration of Kelsey Cascadia Rose Juliana in Support of Plaintiffs’ 

Opposition to Defendants’ Motion to Dismiss

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19. As I marched across the country, I experienced our nation’s fossil fuel 

devastation caused by these Defendants. The impacts of a warming planet; 

temperatures exceeding 100 degrees, especially in Nebraska and Iowa; lost food 

crops due to drought and heat. 

20. Because I delayed my first semester of college, I will finish my freshman year in 

winter term of 2015. I attend a college based on a farm, where we cultivate our 

own food and have acres of forests to practice ecological forestry. I attend this 

college because I want to learn to live a self-sufficient and sustainable life, and 

because of their excellent environmental studies courses, ethics, and mission to be 

a steward of the land. My academic and career interests focus around green city 

planning and building design, sustainable food production, environmental 

education, and environmental policy and justice work. I’d also love to work with 

kids and in the outdoors. I hope to have a family and children, pets, gardens and 

live in a home that will be stable and safe and I will not have to move from 

because of climate or financial crisis. I hope to be able to continue to do all of the 

things I have described doing above for my life, my health, and my enjoyment. I 

also hope to be able to share those experiences, these Oregon waters, and these 

food sources with my children one day. I fully intend to live that life.

21. I reuse and recycle, I conserve energy, I reduce my waste, I buy local, I bike 

everywhere I can, I do what I can personally to live a low carbon footprint life. I 

know that I alone cannot protect the essential resources on which I depend, and 

my children will depend. 

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Declaration of Kelsey Cascadia Rose Juliana in Support of Plaintiffs’ 

Opposition to Defendants’ Motion to Dismiss

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I certify under penalty of perjury in accordance with the laws of the State of 

Oregon, and to the best of my knowledge, that the foregoing is true and correct. 

DATED this __6th__ day of January, 2016 at Eugene, Oregon.

 ________________________________________

KELSEY CASCADIA ROSE JULIANA

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