Indonesia, a WTO member, is one of the world's largest palm oil producer. Palm oil is used in food preparations and is also used as an input product to make biofuel. Because growing the palm trees leads to carbon absorption from the atmosphere and the palms keep producing with each harvest, biofuel made from palm oil may be considered a renewable fuel. However, the development of palm oil plantations has also resulted in deforestation as original ecosystems have been destroyed to make space for commercial plantations. In those cases, the carbon absorption from palms is typically much lower than that of the original ecosystem. The use of water resources insecticides and other chemicals in the plantations also has negative environmental impacts. Overall, then, whether biofuel from palm oil generate a net environmental benefit, or even a net greenhouse gas (GHG) emissions benefit (or at least emissions neutral) depends on the specifc circumstances of each plantation. In order to reach its GHG emissions reductions targets, Japan is requiring a transition to the exclusive use of renewable energy in the transportation sector by 2035. A number of decrees (togetherthe Green Transportation Decrees) have been adopted by the government in order to achieve these commitments. In particular, the Decrees provide the following: 1.Only biofuels certified by Japan's National Environmental Certification Agency (NECA, part of the Ministry of the Environment) may be imported into Japan after 2030. The certification is based on a list of 15 stringent criteria that include limits on the amount and type of pesticides used, and limits on the amount of irrigation water used per acres of palm oil plantations. Applicants must also prove that the land used for growing the palm oil has not been rainforest for at least the previous 30 years as shown by government records of land use. 2. Fuels that include at least 20% of biofuels certified by NECA benefts from a sales tax reduction. The discounted fuel sales tax is 20% instead of the regular sales tax on fuels of 30%. 3.Biofuels produced in Japan will be reviewed for NECA certifcation on a priority basis. 4.Biofuel producers in Japan are eligible for a reduced corporate tax rate of 5% (compared to the normal corporate tax rate of 15%) if they export at least 1% of their production. While palm oil producers from Malaysia, another major palm oil producer, have been able to secure NECA certifcation, Indonesian producers have not been able to get certifed because land use records were not kept far enough back to be able to show that the plantation land was not rainforest 30 years ago. Anecdotal historical records and pictures show that the land currently used for plantations in Indonesia was not rainforest, but that does not satisfy the Japanese authorities. By contrast, Malaysia had kept the required governmental records regarding land use. Draft a memorandum identifying the potential claims under the WTO agreements that the Indonesia could make in a case against Japan and the potential defenses and other arguments that Japan might present in response. You should identify specifically the WTO provisions that provide legal support for the claim and possible defenses and any relevant case law that supports your reasoning. You should also briefly outline the options for pursuing the claim in formal dispute resolution proceedings, including the possibility of appeals. If you need further facts or legal sources not available to you at present, you should make a note of it in your memorandum. If you need to assume certain facts, do so and make a note of it in your memorandum.