Document QJBwdMoN7wOG9jLb5nazVOY6L

Message From: Sent: To: Subject: Attachments: Chip Murray [cmurray@nafoalliance.org] 1/12/2018 4:42:25 PM Schwab, Justin [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=eed0f609c0944cc2bbdb05df3al0aadb-Schwab, Jus] Legal assessment FINAL - NAFO Legal Authority W hite Paper (highlighted studies) - 10.20.14.doc Justin, As you know, NAFO is working with the Air Office to advance EPA's policy on the carbon neutrality of biomass. Attached is a legal white paper summarizing why EPA has authority to distinguish biogenetic C02 from other forms of C02, including a summary of the scientific studies justifying the carbon neutrality of biomass. The paper was prepared by our outside counsel, Roger Martella, when he worked at Sidley Austin and was provided to the previous Administration. We wanted to make sure you had this in your files. We welcome a discussion of the theories or authorities in the white paper with you and your staff if you think it might be helpful. Please let us know if you have any questions or comments on the white paper. Regards, Chip Chip Murray Vice President for Policy & General Counsel Natio--nal Allian|ce of Forest Owners www.nafoalliance.org Sierra Club v. EPA 18cv3472 NDCA Tier 1 ED 002061 00161857-00001