DECLARATION OF JULIA A. OLSON IN SUPPORT OF PLAINTIFFS’ 

RESPONSE TO INTERVENOR DEFENDANT NATIONAL ASSOCIATION 

OF MANUFACTURERS’ MOTION TO WITHDRAW

1

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

2495 Hilyard Street, Suite A

Eugene, OR 97405

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

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., 

Federal Defendants.

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

DECLARATION OF JULIA A. OLSON in 

Support of Plaintiffs’ Response to Intervenor 

Defendant American Petroleum Institute’s 

Motion to Withdraw

Case 6:15-cv-01517-TC Document 174 Filed 06/08/17 Page 1 of 5
DECLARATION OF JULIA A. OLSON IN SUPPORT OF

PLAINTIFFS’ RESPONSE TO INTERVENOR DEFENDANT

AMERICAN PETROLEUM INSTITUTE’S MOTION TO WITHDRAW

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I, Julia, A. Olson, hereby declare and if called upon would testify as follows:

1. I am an attorney of record in the above-entitled action and I have personal knowledge of 

the statements made herein.

2. On February 15, 2017, Plaintiffs served counsel for Intervenor Defendants with a draft 

Rule 11 motion, which included relevant evidence of knowledge of each trade 

association, and their members, on the factual allegations of climate change, in an effort 

to compel Intervenor Defendants to specifically admit or deny the allegations. Said draft 

Rule 11 motion is attached as an exhibit to Declaration of Julia Olson Supporting 

Plaintiffs’ Response to NAM’s Motion to Withdraw, ECF 170-1, and is a true and correct 

PDF copy of that draft Rule 11 motion. 

3. Attached as Exhibit 1 to this declaration is a list of API members, pulled from: American 

Petroleum Institute, Members, http://www.api.org/membership/members (last visited 

June 2, 2017).

4. Attached as Exhibit 2 to this declaration is a true and correct PDF copy of the following 

article: Chelsea Harvey, These Fossil-Fuel Groups Joined a Historic Climate Lawsuit. 

Now, They Want to Get Out of It., Wash. Post (May 26, 2017), 

https://www.washingtonpost.com/news/energy-environment/wp/2017/05/26/three-fossilfuel-groups-joined-a-historic-climate-lawsuit-now-they-want-to-get-out-of-it. In this 

article, Eric Wohlschlegel, media director of API, is quoted as saying: “We continue to 

focus on the progress the U.S. is making leading the world in reducing carbon and other 

emissions, and we have full confidence that the courts will recognize that Congress and 

the Executive branch have the constitutional authority to write and execute the laws of 

the U.S.” Harvey says that, “[i]n moving to withdraw from the litigation this week, the 

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DECLARATION OF JULIA A. OLSON IN SUPPORT OF

PLAINTIFFS’ RESPONSE TO INTERVENOR DEFENDANT

AMERICAN PETROLEUM INSTITUTE’S MOTION TO WITHDRAW

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industry groups may be able to avoid having to respond to a request for admission from 

the plaintiffs. This is a series of allegations or complaints presented by the plaintiffs, 

mainly surrounding the issue of climate change and its effects in this case, that the 

defendants are required by the court to address. They include questions about the 

industry’s position on the effects of climate change on water supplies, agriculture and 

other natural systems, as well as the ability of human societies and natural ecosystems to 

adapt.”

5. Attached as Exhibit 3 to this declaration is a true and correct PDF copy of Shell Oil 

Company, a member of API, internal document: A Better Life with a Healthy Planet: 

Pathways to Net-Zero Emissions, goo.gl/FCsZtQ, in which Shell says: “The rising level 

of CO2 not only puts pressure on the climate, but also warms and acidifies the oceans, 

raises sea levels, threatens land-based ecosystems and affects patterns of food production. 

There is broad scientific consensus that the quality of life for hundreds of millions of 

people stands to suffer from this second challenge.” Page 9. “Even if annual global CO2

emissions remain steady at their current level, the cumulative emissions consistent with a 

rise of 1.5°C could be reached as early as 2028.” Page 19.

6. Attached as Exhibit 4 to this declaration is a true and correct PDF copy of the following: 

American Petroleum Institute, Climate Models and CO2 Warming: A Selective Review 

and Summary (Mar. 1982). This report details the impacts of CO2 emissions on climate 

change and acknowledges an increase of CO2 concentrations from 290 parts per million 

(ppm) at the beginning of the industrial revolution to 340 ppm in 1981, acknowledges a 

general consensus that temperatures will rise 4o C, and estimates that global temperature 

rise from a doubling of CO2 concentrations could increase global temperatures from 0.1o 

Case 6:15-cv-01517-TC Document 174 Filed 06/08/17 Page 3 of 5
DECLARATION OF JULIA A. OLSON IN SUPPORT OF

PLAINTIFFS’ RESPONSE TO INTERVENOR DEFENDANT

AMERICAN PETROLEUM INSTITUTE’S MOTION TO WITHDRAW

4

C to 3.5o C. Pages 4–5, 38.

7. Attached as Exhibit 5 to this declaration is a true and correct PDF copy of the following: 

D. J. Devlin, Exxon Biomedical Sciences, Purported Impact of Climate Change o[n] 

Human Health (Sept. 19, 1986). This document details potential negative impacts on 

human health and wellness that climate change could cause, discussing malaria 

outbreaks, rodent-borne hantavirus in the US, and dengue fever. It concludes that lack of 

scientific certainty should not justify postponement of preventative action but also 

encourages promoting the concept of relative risk: that there are other disease factors than 

climate change alone.

8. Attached as Exhibit 6 to this declaration is a true and correct PDF copy of the following: 

ExxonMobil, Global Climate Change: A Better Path Forward (2000). This document 

acknowledges a “slight warming” and acknowledges that climate change “may pose a 

legitimate long-term risk, and that more needs to be learned about it.”

9. Attached as Exhibit 7 to this declaration is a true and correct PDF copy of the following:

Lenny Bernstein, American Petroleum Institute, Critical Issues in the Intergovernmental 

Panel on Climate Change: Third Assessment Report (July 2001). This document

discounts Intergovernmental Panel on Climate Change reports, for such reasons as

insufficient scientific proof and insufficient account of all variables.

10. Attached as Exhibit 8 to this declaration is a true and correct PDF copy of the following:

Letter from Kenneth P. Cohen, Vice President of Public Affairs for ExxonMobil to Lord 

Rees of Ludlow Kt PRS, President, The Royal Society (Sept. 25, 2006). This document 

acknowledges the major role of fossil fuels in carbon dioxide emissions and the linkage 

of economic development, energy supply, and climate change. This document recognizes 

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DECLARATION OF JULIA A. OLSON IN SUPPORT OF

PLAINTIFFS’ RESPONSE TO INTERVENOR DEFENDANT

AMERICAN PETROLEUM INSTITUTE’S MOTION TO WITHDRAW

5

the need for action to mitigate “serious impacts” of fossil fuel use on climate change.

11. Incorporated by reference to this declaration and attached as Exhibit 3 to the Declaration 

of Julia Olson Supporting Plaintiff’s Response to NAM’s Motion to Withdraw, ECF 170-

3, as a true and correct PDF copy, is: Andrew Revkin, Industry Ignored Its Scientists on 

Climate, N.Y. Times (Apr. 23, 2009), at A1, 

http://www.nytimes.com/2009/04/24/science/earth/24deny.html.

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

and correct.

DATED this 8th day of June, 2017, at Eugene, Oregon.

Respectfully submitted,

/s/ Julia A. Olson 

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