Shannon S. Broome. Managing Partner, San Francisco Bay Area Oakland p Washington, DC p

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1 Shannon S. Broome Managing Partner, San Francisco Bay Area Oakland p Washington, DC p Practices FOCUS: Air Quality and Climate Change Internal Investigations and Incident Response Aspects of Energy Production Chemicals, Products and Pesticide Regulation Land Use Law and Policy Maritime Law Water Litigation Advisory Group Appellate and Supreme Court Litigation Litigation and Dispute Resolution Shannon S. Broome is the managing partner of the firm's San Francisco Bay Area office and is a partner in the Washington, DC office as well. She counsels and represents clients on a range of environmental matters before local and federal courts and administrative agencies. She heads the firm's Air Quality and Climate Change practice and co-leads the Law and Policy practice. Being co-located in the San Francisco Bay Area and Washington, DC offices allows her to serve clients nationally and in California, a jurisdiction that is frequently at the forefront of environmental regulation. Her practice focuses on three primary areas: government and regulatory affairs, compliance counseling and enforcement defense, and environmental litigation. Shannon advocates on behalf of her clients on numerous federal and state environmental statutes. Her practice has a particular emphasis on the Clean Air Act and corresponding state and local statutes and regulations. She advocates on regulations issued by and before numerous federal and state regulatory agencies. Shannon's practice focuses on implementation of all aspects of the Clean Air Act, and related statutes, including the Energy Policy Act of 2005, and the Energy Independence and Security Act of She also routinely advises on the California Global Warming Solutions Act (AB32). California's Low Carbon Fuels Standard and the California Quality Act. Shannon has been involved in the development of virtually every major regulation issued following enactment of the Clean Air Act Amendments of 1990, an experience she uses to provide her clients advice on compliance and represent them in enforcement actions. She was selected by the US Protection Agency (EPA) to serve on numerous committees and stakeholder groups to develop regulations such as the New Source Review, NESHAP, and Title V operating permit regulations. In addition, Shannon was deeply involved on behalf of clients in the development of EPA's Risk Management Program (RMP) regulations, which were issued under the Clean Air Act Amendments of 1990, and also involved the simultaneously enacted Process Safety Management (PSM) program regulations by the Occupational Safety & Health Administration. In her work as counsel for General Electric, Shannon achieved numerous regulatory changes in the RMP rules between proposal and promulgation and subsequently challenged EPA's regulations, resulting in a successful settlement. She was a lead counsel advising on implementation of RMP at General Electric (which at the

2 Issues in Real Estate and Commercial Transactions Industries Automotive Energy Aviation Recognition Chambers USA, Daily Journal, California's 100 "Top Women Lawyers," 2014 Super Lawyers, 2014 Education JD, University of California, Berkeley, School of Law, Order of the Coif BS, University of California, Los Angeles Bar Admissions District of Columbia New York Court Admissions District of Columbia Circuit Fifth Circuit Ninth Circuit Tenth Circuit time included GE Plastics) and was part of the team that achieved a record number of voluntary protection program (VPP) designations for the company. She participated in management reviews of implementation of these requirements and was the lead liaison to GE Aircraft Engines on these issues during her tenure at the company. Shannon also has advised companies on compliance obligations under the General Duty Clause, RMP and compliance certifications for the same. Shannon is a nationally recognized authority on Clean Air Act matters with more than 25 years of experience addressing all aspects of the act, representing clients in a variety of manufacturing and energy sectors, including automotive, aerospace, pharmaceutical, chemical, paper, alternative fuels, power generation and utilities. Chambers USA describes Shannon as "a veritable Clean Air Act encyclopedia," stating that "her strong technical engineering background has been an invaluable asset" and noting that her "record of success speaks for itself." Shannon's litigation practice is primarily focused on challenging and defending EPA and California regulations and permits before federal and state appellate courts. She has litigated many environmental permit appeals before environmental hearing boards in various states. Shannon also is deeply experienced in environmental enforcement matters. Shannon's clients describe her as an "outstanding lawyer very practical, effective, extremely smart and incredibly knowledgeable" (Chambers USA). Shannon serves as the executive director of the Air Permitting Forum, a group of Fortune 100 companies dedicated to the smooth implementation of Clean Air Act permitting and regulatory programs. In addition, she directs a sub-entity of the Forum, the Auto Industry Forum, which advocates on behalf of the auto industry on all CAA stationary source issues. Prior to joining Katten, Shannon was counsel and manager of Clean Air Act programs for the General Electric Company, where she was responsible for Clean Air Act advocacy, compliance and training for more than 200 manufacturing facilities, including RMP program advocacy and compliance. Previously, she was an environmental and construction engineer for Chevron, USA. From 1992 through 2000, Shannon was a vital participant in many EPA stakeholder discussion roundtables on New Source Review as EPA's reform process for those regulations proceeded. In June 2004, Shannon was selected by EPA to serve as one of six industry representatives and one of 18 outside members of the Title V Task Force under the Permits, New Source Review and Toxics Subcommittee of the Clean Air Act Advisory Committee, a group charged with evaluating the state of the Clean Air Act's Title V permitting program and making recommendations for improvement. In 2009, she participated on EPA's Greenhouse Gas BACT Workgroup, a sub-group of EPA's Clean Air Act Advisory Committee, which addressed the potential application of controls for greenhouse gases under the act. In that role, she was deeply involved in the development of two reports to EPA that were used as a framework to develop its

3 US District Court, Eastern District of California Supreme Court of California November 2010 PSD and Title V Permitting Guidance for Greenhouse Gases. Shannon holds leadership positions in the American Bar Association's Section on Energy, Environment, and Resources, serving as co-chair of the Climate Change, Sustainable Development, and Ecosystems Committee ( ); as vice-chair for Programming of the Air Quality Committee ( ); and on the Planning Committee for the 22nd Fall Conference (2014). Shannon has written several articles and regularly speaks on environmental issues. She is a co-author of The Clean Air Act Operating Permit Program: A Handbook for Counsel, Managers, and Plant Managers (ABA, 1993). Selected Experience Representation of Texas Oil & Gas Association in litigation in the US Court of Appeals for the District of Columbia Circuit, challenging EPA's New Source Performance Standards for Oil and Gas operations (fracking). Representation of investor group in large utility unit in negotiating transaction terms related to environmental compliance obligations under Mercury Air Toxics Rule and other regulatory requirements. Representation of midstream oil and gas company in enforcement action in northwest state over environmental and Army Corps of Engineers permitting requirements. Representation of major household product manufacturer in environmental enforcement of the Clean Air Act. Representation of major automobile manufacturer in all Clean Air Act permitting in Michigan, Indiana, New York and Illinois. Representation of major oil company on regulatory advocacy on Clean Air Act regulation under Section 112(f) for residual health risk, achieving resolution that saved the company tens of millions of dollars. Representation of joint venture in achieving passage of legislation in California allowing for treatment of on-board recycled oil without treating it as disposal of hazardous waste. Representation of major manufacturing company on Waxman-Markey climate change cap-and-trade legislation. Representation of Renewable Fuels Association in litigation challenging California's Low Carbon Fuel Standard (LCFS) in the US Court of Appeals for the Ninth Circuit, following a victory in district court determining that the LCFS violates the Commerce Clause of the US Constitution. Representation of coalition of 20 trade associations in eight challenges to EPA's greenhouse gas regulatory approach in the US Court of Appeals for the District of Columbia Circuit, which is now awaiting the Supreme Court's determination as to whether to grant certiorari.

4 Representation of utility in enforcement before California air district, negotiating favorable settlement of same. Representation of Midwest manufacturing facility on Clean Air Act permitting, successfully obtaining permit in the face of initial modeling indicating violation of ambient air quality standards. Memberships American Bar Association, Section of Environment Energy and Resources, Co- Chair Climate Change, Sustainable Development and Ecosystems Committee Law Section of the California Bar Advisories EPA Issues Proposed Amendments to its Risk Management Plan Regulations for the Prevention of Chemical Accidents (February 25, 2016) US Supreme Court Briefing of Greenhouse Gas Cases Completed Oral Argument Scheduled for February 24, 2014 (February 17, 2014) First Compliance Period Underway for California's AB32 Cap-and-Trade Program (January 31, 2013) Articles Co-author, As Jurisdictions Like California Sort Out Regulation of Hydraulic Fracturing, NIMBY Approaches Pop Up in Other Jurisdictions, Law News (Spring 2014) Co-author, Food v. Fuel: Are Legal Attacks on the Renewable Fuel Standard Just a Bunch of Empty Calories?, Natural Resources & Environment (Fall 2013) Co-author, EPA Finalizes Reconsideration Rules for Boilers and Solid Waste Incinerators but Issues Remain, Trends E-Magazine (July/August 2013) Co-author, EPA's Missed Opportunity to Ground Its GHG Tailoring Rule in the Statute: What the Situs Argument Would Mean for the Future of the PSD Program, ELR News & Analysis (May 2012) Books Co-author, The Clean Air Act Handbook, American Bar Association, 3rd. ed., Managing Your Title V Permit (2011) Co-author, The Clean Air Act Handbook, American Bar Association, 2nd. ed., Life After Title V Permit Issuance: You've Received Your Permit, Now What Do You Do? (2004) Clean Air Deskbook, American Bar Association, Legal Issues in Preparing Clean Air Act Title V Permit Applications (1998) Co-author, The Clean Air Act Operating Permit Program: A Handbook for Counsel, Managers and Plant Managers, American Bar Association (1993)

5 Speaking Engagements & Presentations Panelist Exploring and Finding Careers in Sustainability Washington, DC (April 7, 2016) Panelist The Supreme Court Stay: Legal & Timing Considerations for States Helping States Examine Federal Power Plant Rules San Jose, California (March 3 4, 2016) Panelist Supreme Court Year in Review: The Cases Webinar (July 9, 2015) Panelist EPA Clean Air Act Section 111(d) ASME 2015 Power & Energy Conference San Diego, California (June 29, 2015) Moderator New Source Performance Standards for Methane From Oil and Gas Sector Under Section 111(b) of the Clean Air Act and Potential Implications for Existing Sources ELI Conference: In the Hot Seat: Drilling into the Administration's Plans to Regulate Methane Emissions From the Oil and Gas Sector Washington, DC (June 4, 2015) Speaker States in the Driver s Seat Under EPA s Clean Power Plan 44th Spring Conference: The ABA Super Conference on Law San Francisco, California (March 26 29, 2015) ABA Section of Environment, Energy, and Resources' 22nd Fall Conference Miami, Florida (October 8 11, 2014) Presenter RMP and PSM in Context the 1990 Amendments Chemical Safety and Security Seminar Houston, Texas (September 16, 2014) Presenter New Proposed Rule to Reduce Power Plants Emissions: Evaluating the Legal and Policy Issues Webinar (July 22, 2014) Presenter The Current State of the United States Domestic Climate Policy and Action 2014 Annual CBA National, Energy and Resources Law Summit Ottawa, Ontario (May 29 30, 2014) Panelist Preparing for the Worst After West: How Lawyers Can Prepare for and Handle High-Profile Industrial Accidents Washington, DC (April 29, 2014) Panelist Section 111(b): GHG Regulations for New Electric Generating Units Proposal EEI-ABA-ELI Climate Conference Washington, DC (January 30, 2014) Panelist State Authority on Climate Change: Where Are the Common Clause Boundaries? American Bar Association's Section on Environment, Energy and Resources 21st Fall Conference Baltimore, Maryland (October 9 12, 2013) Panelist ELI Professional Practice Seminar: Deference to Agencies in Theory and Practice Washington, DC (September 10, 2013)

6 Panelist Finding the Best Approach to NAAQS Implementation A Comprehensive Conference on Preparing for EPA's New Air Quality Regulations Emerging Issues, Regulatory Developments and Innovative Solutions Los Angeles, California (July 11 12, 2013) Presenter US EPA's Boiler MACT and CISWI Rules: What You and Your Clients Need to Know for Compliance Now that the Reconsideration Process Is Complete Webinar (February 13, 2013) Presenter Overview of Select Federal Rulemakings Implicating Greenhouse Gases 20th Section Fall Meeting: The ABA Environment, Energy, and Resources Law Summit Austin, Texas (October 10 13, 2012) Regulatory Drivers for CO2 Control, Navigating the Impacts of PSD, Title V, and Other Clean Air Act Regulatory Requirements for GHGs, Coal-Gen Annual Conference Louisville, Kentucky (August 15, 2012) Presenter Rocky Mountain Farmers Union v. Goldstene and the Dormant Commerce Clause Cap-and-Trade: Getting Ready for the First Auction San Francisco, California (July 23, 2012) Trainer Course on Effectively Handling Government Inspections of Ethanol Production Facilities Renewable Fuels Association Seminar at the Federal Ethanol Workshop Minneapolis, Minnesota (June 4, 2012) Moderator Hot Topics in Air Enforcement and Priorities for 2012 ABA Air Quality Committee Teleconference (January 24, 2012) Faculty Title 1 NAAQS, ALI-ABA Course of Study Clean Air: Law, Policy, and Practice Washington, DC (December 1 2, 2011) Speaker How will EPA's GHG Tailoring Rule Impact Your Business? National Ethanol Conference Scottsdale, Arizona (February 28, 2011) Speaker and Panel Moderator Hot Air Balloons. Traditional and Cutting Edge Air Emission Regulation: EPA's New Source Review Reforms and California's CO2 Regulation California State Bar Annual Conference on Law at Yosemite Yosemite, California (October 20 23, 2005) Speaker Symposium on Shaping Policy: Science, Information, and the Law UCLA School of Law Evan Frankel Law and Policy Program Los Angeles, California (March 2004) Speaker and Program Moderator New Source Review Improvement Rule and Equipment Replacement Provision Federal Litigation Update California State Bar Annual Conference on Law at Yosemite Yosemite, California (October 23 26, 2003) Speaker After Permit Issuance: Permit Revision Requirements Under Title V of the Clean Air Act Air & Waste Management Association 96th Annual Conference and Exhibition San Diego, California (June 22 26, 2003)

7 Subcommittee on Oversight and Investigations, Committee on Commerce, US House of Representatives, Title III of the Clean Air Act Amendments of 1990, Invited Testimony regarding EPAs implementation of hazardous air pollutant provisions of the Clean Ai Washington, DC (July 21, 1995)