Jonathan Cannon, "Memo to EPA" (April 10, 1998)

In 1998, the EPA privately contemplated its authority to regulate CO2 under the Clean Air Act. Congressman Tom Delay got wind of this and requested a formal opinion from the agency. EPA's general counsel, Jonathan Z. Cannon, wrote a memo arguing that CO2 was a pollutant under the Clean Air Act and thus subject to regulation by the agency.