Illinois EPA Environmental Justice Procedures
The Illinois EPA Bureau of Air recently implemented more stringent procedures for securing an air permit for a new emissions source or emissions unit when the operations are located in, or within a mile of, an Environmental Justice area. How long the new procedures will remain in effect is not known, but any increase in air emissions will subject the project to more extensive review by the Illinois EPA and possibly the United States Environmental Protection Agency (USEPA) Region V, which could extend the permit application review by a substantial amount of time. Depending on the location of the source, the type and amount of the pollutant(s) being emitted, and the amount of interest or objection by interested parties, there is also a chance that the permit may not be approved. Interested parties include, but are not limited to, local activists, local government agencies, neighboring citizens, and other entities with an interest in Environmental Justice (EJ).
Assuming a permit with a net increase in emissions is approved, it will likely include the following elements.
Illinois EPA is recommending that a company seeking to construct and operate a new or modified source, or add a new emissions unit to an existing source, identify ways within the plant to lower air emissions of the applicable air contaminant(s) such that the project will not result in a net emissions increase. Illinois EPA is not expecting a source to conduct a formal netting exercise, but instead suggests considering product substitutions such as alternative cleaning solutions with low or no volatile organic material (VOM) or hazardous air pollutants (HAPs); for instance, a mixture of acetone and water, or detergents. Other approaches may include the installation of add-on pollution control equipment, use of cleaning solutions with low vapor pressures which evaporate more slowly, capturing some of the VOM in shop towels and cleaning rags rather than emitting them to the atmosphere, installation of recovery equipment (e.g., distillation equipment), and considering other raw material substitutions or equipment replacements.
When an air permit application is submitted to the Illinois EPA for a proposed project that does not result in a net emissions increase, the application will be processed by the permitting department, and then a draft permit will be forwarded to the EJ group at Illinois EPA. The EJ group will forward a copy of the draft permit to interested parties specific to that EJ area. If no comments are received within two weeks, the permitting group will issue a draft permit to the permittee for review and comments. Any substantive comments received from interested parties will be addressed by the Illinois EPA, and this process could cause delays, particularly if a public hearing is requested and granted.
Environmental Justice Background
The USEPA defines environmental justice as “the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income, with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies.” Environmental justice was originally established by Title VI of the Civil Rights Act of 1964, which prohibits recipients of federal financial assistance (states, grantees, etc.) from discriminating against these populations in any program or activity. The scope of Title VI was expanded by Executive Order 12898 by President Clinton on February 11, 1994. Executive Order 12898 was issued to direct federal agencies to incorporate achieving EJ into their mission, and to identify and address, as appropriate, disproportionally high adverse human health and environmental effects of their programs, policies, and activities on minority and low-income populations. More recently, President Biden issued Executive Order 14008 Tackling the Climate Crisis at Home and Abroad on January 27, 2021.
Illinois EPA has adopted policies and procedures to conform to Title VI of the Act and Executive Orders 12898 and 14008. According to Illinois EPA, “environmental justice is the protection of the health of the people of Illinois and its environment, equity in the administration of the State’s environmental programs, and the provision of adequate opportunities for meaningful involvement of all people with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies.”
EJ areas in Illinois are derived from US Census Block Groups where the population consists of a substantial amount of minorities and/or the area is heavily populated by persons and families living below the poverty line. Further information on how EJ areas are established can be found at Illinois EPA EJ Start (arcgis.com), which also includes a map identifying all EJ areas in the state.
About the Author: Ann O’Brien is a Project Manager at SCS Engineers with 33 years of experience in the printing industry. She assists companies with air, water, and waste management; EPCRA; environmental compliance audits; and Phase I Environmental Site Assessments.
For more information or assistance with identifying ways to lower air emissions or help with maneuvering through the air permitting process at Illinois EPA, contact Ann O’Brien () in Chicago, IL, or Cheryl Moran () in Milwaukee, WI. For assitance in other states please contact .
Agricultural growing and harvesting operations are typically exempt from air planning, permitting and odor nuisance regulations. However, cannabis operations may require approval from the local Planning Commission. They may also require air permits from the local air regulatory agency for manufacturing operations (e.g., for solvents and associated combustion equipment such as boilers). Air permit applications for cannabis manufacturing operations may include the following based on project-specific conditions:
In addition to these permitting services, and to avoid costly nuisance complaints, cannabis growers may also need odor-related services such as:
While these may seem like imposing lists for air planning they are not for engineers who work in the industry.
Developing effective plans to mitigate odors is vital in gaining Planning Commission approvals which often depend upon resolving concerns raised by the public. Comprehensive OAPs and OMPs include odor control Best Management Practices (BMPs) and adaptive management strategies for responding to odor complaints when cannabis operations are near residences and schools.
Odor Control – Odor Nuisance Mitigation Case Study
Cannabis greenhouses in the Carpinteria, California region were causing off-site odor nuisances at nearby residences. The inherent smell needed addressing, as odor-neutralizing vapors along cannabis greenhouse perimeters and ridgelines were not providing adequate odor control.
Working with Cannabis Association for Responsible Producers (CARP) Growers, Pacific Stone, Groundswell, and Envinity Group, SCS Engineers utilized its air quality and odor expertise to collect continuous measurements using our SCSent-i-PED (Pollutant and Environmental Data). SCSent-i-PED is a state-of-the-art method for measuring TRS compounds to the parts per billion (ppb) level. The system can assess concentrations in real time, and a single machine can assess multiple locations and sources within a facility. This method successfully assessed relative odor levels and spatial/temporal fluctuations in odor-causing emissions.
Data collection is vital and useful to:
SCS, through its years of experience in air quality and odors, provides cost-effective, sustainable solutions that enable greenhouses and facilities to coexist in urban and suburban environments. Our clients not only get solutions, but they also have the data and science to understand better how odors behave and vary within a cannabis greenhouse.
To learn more, watch a video about air planning and managing greenhouse odors at https://www.scsengineers.com/services/clean-air-act-services/odor-monitoring-and-control/
About the Author: Paul Schafer is a Vice President and Project Director at SCS Engineers and the firm’s National Expert on Ambient Air Monitoring. During his technical career, Paul has assumed key roles in several nationally significant monitoring efforts. He has in-depth experience interfacing with regulatory agencies regarding the performance of monitoring systems, source emission tests, and continuous process monitors, which SCS operates for our clientele. He has had direct working experience with multiple local, state, and federal agencies regarding monitoring programs and air quality impact assessments. As with all solutions at SCS, cost control management and defensible technical performance are primary goals integral to all sustainable monitoring programs.
UPDATE 4-29-25: the Governor’s office put a hold on Amendment 9, and the Waste Management Board has announced its intention to formally withdraw Amendment 9 (see Agenda Item 4 and Tab C).
The Virginia Waste Management Board (Board) approved the final action, Amendment 9, to the Virginia Solid Waste Management Regulations (VSWMR) at its Board meeting on October 28, 2022. Since that approval, the final regulation has been under executive review. The Secretary of Natural and Historic Resources review resulted in a request to withdraw the final regulation, as the discretionary changes are unnecessary and do not further protect public health nor the environment (see attached memo).
Amendment 9 included provisions related to 1) landfill siting and setbacks, 2) landfill operations, 3) landfill gas monitoring, 4) landfill groundwater monitoring, 5) open burning exemptions, and 6) clarified other requirements. Landfill siting and setbacks as well as open burning exemptions can both be addressed by local governments exercising their authority, such as zoning and land use controls and the solid waste management planning process. Landfill operations and landfill gas monitoring can both be addressed by the Department of Environmental Quality (DEQ) through the existing solid waste management permitting process. The VSWMR provisions in 9VAC20-81-430 already authorize DEQ to include conditions that are necessary to protect public health or the environment, or to ensure compliance with the VSWMR. For example, DEQ has already included the topographic survey requirements contemplated by Amendment 9 into existing landfill permits where necessary on a case-by-case basis. Amendment 9 also included landfill groundwater monitoring requirements, including a placeholder for emerging contaminants with pending Maximum Containment Levels (MCLs). As placeholders, further amendments would have been required to fully operationalize these provisions. In addition, since Amendment 9 was contemplated, legislation has been enacted in Virginia to address PFAS, including legislation that provides for monitoring at landfills in watersheds that provide source water for drinking water facilities that have measured MCL exceedances for PFAS in finished drinking water.
In its October 28, 2022, meeting, the Virginia Waste Management Board voted to adopt changes to the Virginia Solid Waste Management Regulations known as Amendment 9. Amendment 9 was initiated several years ago, and the amendments address issues that have arisen since the previous amendment. The changes involve updated standards for siting, operation, and monitoring of landfills as well as revising exemptions for open burning of waste. Following adoption by the Board, the amendment is now undergoing Executive Branch Review.
Some of the key changes that are part of this amendment include the following:
Follow SCS Engineers on your preferred social media channel for additional details, or contact us at .
About the Authors:
Josh Roth, PE, is a Vice President and Project Director with the Landfill Gas (LFG) Group in the SCS Reston, VA office. He supports LFG engineering projects involving remediation system design, emissions inventories and air permitting, migration and odor control, ambient air sampling and reporting, LFG and CER due diligence projects, GHG emission mitigation and reporting, field sampling and assessments, and general emissions control projects.
Mike Mclaughlin, PE, JD, is SCS Engineers’ Senior Vice President of Environmental Services. He is a licensed engineer and attorney with over 40 years of professional experience providing advice on environmental matters. He is an expert on environmental compliance, remediation, and allocation of response costs. He is a member of the Board of Governors of the Virginia State Bar Environmental Law Section, and Budget Officer of the American Bar Association’s Section of Environment, Energy and Resources (ABA SEER).
Hydrogen is commonly produced using steam methane reforming (SMR), which requires heat, a catalyst, and feedstock such as natural gas. SMR operations generate atmospheric emissions from combustion and process vents which may require air permitting. Air permitting can be a complicated process that delays facility construction and project start-up.
Comprehensive feasibility studies include phases to facilitate pre-application meetings and submission of a complete air permit application in a timely, cost-effective manner. Based on our case studies, SCS suggests a four-phase approach.
Phase 1: Preparation and Due Diligence
To begin the evaluation, your engineer compiles all available project information, such as plot plans, process flow diagrams, equipment lists with specifications, zoning, grading, and utilities. Since project specifications are subject to change, your engineer must remain flexible and iterative in their analysis approach as new data becomes available.
Phase 2: Emissions Analysis
The next phase is to calculate the project’s potential to emit criteria pollutants and greenhouse gases (GHGs). The calculation assesses potential requirements for Best Available Control Technology (BACT), emission offsets, Title V, and climate change mitigation. Always use an engineering firm with expertise in GHG emissions inventories and third-party verification of GHG emission inventories and reduction credits. Here’s why, based on the analysis, your engineer will be looking for these factors to smooth the application process:
Project emissions complied with BACT limits based upon a comparison to other permitted SMR facilities.
Project emissions that require the purchase of carbon credits on an ongoing basis to comply with Cap and Trade regulations.
Project emissions that do not trigger the need for emission offsets or Title V.
Phase 3: Regulatory Review
Conducting a regulatory review will identify potential requirements from local regulations such as California’s South Coast Air Quality Management District (SCAQMD). Using SCAQMD as an example, the project must comply with the additional rules.
Phase 4: Results and Conclusions
The comprehensive feasibility study summarizes the potential air quality permitting thresholds, requirements, costs, and schedule for your project. It includes all conclusions and supporting data for decision-making. With a comprehensive study in hand, your project is more sustainable, and you have valuable answers during discussions leading to obtaining a complete air permit.
SCS has over 50 years of environmental experience and trusted working relations with regulatory agencies. Many local, state, and federal agencies attend our free webinars, and industry associations request our input and insight when agencies are planning new rules. We serve as expert witnesses. If you’d like to learn more about developing air permitting strategies and applications, visit our website or contact us at .
About the Author: Greg Hauser is a Project Director responsible for environmental compliance projects. Greg brings over 30 years of experience with compliance topics such as air quality permitting, emission inventories, dispersion modeling, health risk assessments, and odor impact assessments. He surveys facilities to identify sources of interest, collects field samples of odorous emissions, develops odor emission profiles based on odor concentrations and flow rates, and conducts dispersion modeling to predict odor concentrations at or beyond the facility’s property boundary. He also provides health risk assessments for aerospace, manufacturing, wastewater treatment, and oil and gas facilities.
Glenn Haave has had a close relationship with protecting our environment for years, ever since his days working on the ocean towing ships in and out of ports. He figured his deep appreciation of his natural surroundings and desire to protect them might carry into his chosen career path, especially after earning a Bachelor of Science in Geology. But when he came to SCS Engineers as a high-spirited, new graduate, he had no idea of the opportunities that would come his way— both at SCS and serving in the U.S. Coast Guard Reserves.
“Both SCS and the Coast Guard hold you accountable to rise to the occasion and get the job done. With that trust and delegation of responsibilities, I am challenged to become a leader, which gives me a sense of duty and confidence,” Haave says.
Combining Geology, Hands-On Experience, and Teamwork
Starting at SCS doing groundwater and soil sampling and helping remediate landfills for redevelopment, Haave proved to be a fast learner. Quickly building on his skills, he was presented with a unique proposition– to join one of only a few multidisciplinary teams in the country that design and install deep well injection infrastructure. EPA-approved injection wells are safe for placing fluids underground into porous geologic formations. These underground formations may range from deep sandstone or limestone to a shallow soil layer. Injected fluids may include water, wastewater, brine (salt water), or water mixed with chemicals.
Planning, permitting, and executing these projects is a multifaceted undertaking encompassing geologic consulting, reservoir engineering, and deep drilling, with environmental protections and sustainability as core goals.
“Few geologists ever get to work on this type of job. These projects require a lot of capital, time, and very specialized expertise. I was fortunate to be working at SCS’s Miami office at the right time, able, and willing,” says Haave, drawn to complex tasks calling for a razor-sharp eye for detail, focus, and discipline.
Drawing on his experience supporting the Miami-Dade Water and Sewer Department Ocean Outfall Legislation Injection Well Program, where he saw 11 wells constructed in a demanding, high-profile project, he is now on a multidisciplinary team of SCS professionals.
Innovations in Carbon Sequestration – Protecting Our Environment
Now, he takes on a new charge: working on a type of deep injection well called a Class VI well. This sophisticated infrastructure directs carbon dioxide (CO2) liquids and gases into the ground for long-term storage. A fairly new, EPA-approved carbon sequestration technique, it is proven effective at substantially reducing CO2 emissions to the atmosphere.
“Class VI wells are an exciting evolution as the world looks to decarbonize the economy. I feel like I am part of an extraordinarily innovative solution where I am using my background to support a global effort to impact our climate positively,” Haave says.
“I feel a sense of purpose in that we are helping mitigate exponential global warming. At least as important, I am comforted that what we do brings hope that my son, daughter, and their generation will grow up on a healthy, safe planet.”
Another Dimension – U.S. Coast Guard A School
As he embraces this unique opportunity to help the environment, he celebrates another milestone: graduating from U.S. Coast Guard A School and advancing in rank to Marine Science Technician Petty Officer Third Class. His calling will be responding to pollution incidents to protect U.S. waters and inspecting facilities and container vessels that transfer hazardous materials to and from land.
Getting into the Reserves is not easy, nor are the next steps. Making it into A school after boot camp is typically a two-year journey: the waiting list of accomplished graduates is long.
Haave finished three intensive months of classroom work; mock training in the field, morale-building exercises to keep spirits high while away from family and friends, and a battery of testing.
Through these rigorous trials, he took on the honorary role of Master at Arms, leading and mentoring his shipmates and serving as a liaison between the crew and captain.
“Becoming a Coast Guardsman was like a dream come true. It was something I had wanted to do since I was 19. But I needed time to mature. I did a lot of soul searching before I could fully realize what was entailed in living up to Coast Guard expectations; to truly embrace that it’s about a sense of duty to country and family, and to deliver on that conviction,” says Haave, now 37, and nominated as a most inspirational person by his shipmates and instructors.
When he shared his long-envisioned, materialized aspiration with his SCS supervisors, he was unsure what they would think; he was taking on another big commitment.
“They were not only accommodating, but they are proud. SCS Engineers is a military-friendly organization. They are always supportive, flexible, and believe in me.”
In the Coast Guard, he had a choice from a far-encompassing list of specialty areas, given his high military school entrance score. He chose marine science technology because it tied in with his civilian work – navigating and ensuring adherence to federal regulations and being a steward of the environment.
Looking Forward
Gazing back at how far he’s advanced in just the last few years, then looking forward, Haave says, “You know, I’m just 37 years old. I feel like I have a lot more in my gas tank –the amazing experiences I have been fortunate to have are just the beginning. I see more opportunities to advance as a leader and to become an even more rounded geologist, able to approach every project comprehensively and deeply.”
We thank all of our veterans and appreciate Glenn Haave for his service to the U.S. Coast Guard and his commitment to protecting our environment with SCS Engineers by advancing sustainable environmental practices and solutions.
Find out more about carbon sequestration and greenhouse gases:
Video: Building a Well
Information: Deep Well Injection and Sequestration Wells
Video: Carbon Sequestration for Landfills and GHG Tutorial
Safe engineering takes discipline and teamwork –qualities that have always served SCS and our clients with innovative, proven solutions for running operations more efficiently and greener. For a rewarding career, consider SCS Engineers, where all employee-owners have a vested interest in every solution.
The Maryland Department of the Environment (MDE) is working to develop a new regulation aimed at reducing methane emissions from municipal solid waste (MSW) landfills in the state. Methane is a potent greenhouse gas (GHG) with a global warming potential over 25 times greater than carbon dioxide. The new requirements MDE is considering are modeled after similar rules in California and Oregon and would become among the most stringent in the US. MDE anticipates publication of the draft rule in December 2022, followed by public participation and finalization of the rule in the spring of 2023.
This proposed rulemaking has been several years in development and is consistent with Maryland’s GHG Reduction Act of 2009 and the recent Climate Solutions Now Act of 2022 that requires Maryland to become “net zero” for GHG emissions by 2045, with an interim goal of achieving 60% GHG reductions by 2031 (over 2006 levels). MDE estimates that once implemented; this rule could result in up to a 50% reduction in GHG emissions from affected landfills.
MDE presented initial details about the draft regulation (aka, the state plan) at the October 24, 2022, Air Quality Control Advisory Council and stakeholder meeting. The proposed rule would apply to smaller and mid-sized landfills. It would likely impact many facilities not currently subject to the EPA’s federal landfill air regulations under NSPS & EG 40 CFR 60 Subparts Cf and XXX and NESHAP CFR 63 Subpart AAAA. MDE estimates that 32 active and closed MSW landfills in the state will be subject to the proposed regulation.
SCS Engineers is tracking the proposed rule closely, so stay tuned for additional details once the draft rule is published.
For additional information on MSW regulations and GHG emission reductions, please visit scsengineers.com or one of SCS’s nationwide offices.
About the Author: Joshua Roth, PE, is a Vice President and Project Director with the Landfill Gas (LFG) Group in the SCS Reston, VA office. He has served on a number of LFG engineering projects involving LFG remediation system design, emissions inventories and air permitting, migration and odor control, ambient air sampling and reporting, LFG and CER due diligence projects, GHG emission mitigation and reporting, field sampling and assessments, and general emissions control projects.
Establishing a site-specific groundwater monitoring protocol sensitive to changes in the groundwater chemistry related to potential leakage and also sensitive to natural variability will be imperative for developing cost-effective and robust testing and monitoring plans.
In CCUS projects, a site-specific testing and monitoring plan is mandatory to ensure the protection of underground sources of drinking water (USDWs) from Class VI injection well practices. As these projects have long durations with multiple phases, it is imperative for the groundwater monitoring program to be cost-effective with a robust sensitivity to detect any leakage.
Previously demonstrated changes in pH, carbonate chemistry, and certain trace elements (i.e., those that form strong-complexing anions) are geochemical indicators of initial CO2 leakage in relatively dilute aquifers. In this case study, SCS Engineers examine the sensitivity of dilute aquifer chemistry (major and minor cations and anions) to the leakage of CO2 and brines from the injection formation. We use an inverse thermodynamic modeling approach to simulate the effect of the progressive intrusion of CO2 and brines from the injection zone on the geochemical composition of the overlying dilute aquifer waters. From this, we can infer which geochemical parameters are most likely to be affected by the potential intrusion of CO2 and brines.
To attend this live presentation of Geochemical Effects of CO2, register for the upcoming National Carbon Capture Conference on November 8-9 in Des Moines, Iowa. Visit SCS Engineers at booth 120. Meet Kacey Garber.
EPA permit requirements for Class VI injection wells explicitly include incorporating a Testing and Monitoring Plan to optimize protection of USDWs – Underground Sources of Drinking Water. The regulatory requirement is for periodic monitoring of groundwater quality above the confining zone that may result from injection fluid movement through the confining zone. Testing and monitoring plans usually implement an antidegradation strategy. Take sufficient background data to characterize the statistical distributions of groundwater quality parameters before operation. Then the same water quality parameters are sampled periodically during and after injection and compared to the background. Any statistically significant increases over the background are investigated as a possible result of injectate migration above the confining zone.
To make the detection monitoring program more robust, there is a tendency to increase the number of well/parameter pairs in the monitoring network. This is done by adding additional wells to decrease well spacing and by adding monitoring parameters to make sure that nothing gets missed. Paradoxically, this tendency decreases the statistical power of the groundwater monitoring network by increasing the sitewide false positive rate (i.e., the number of false positive detections increases, often to an unreasonable degree). Each apparent statistically significant increase involves a costly investigation with greatly increased complexity. In this talk, we examine the sitewide false positive rate for sitewide groundwater monitoring networks and its relationship to the number of well/parameter pairs and discuss how hydrologic and geochemical knowledge and characterization can be used to build a more robust and cost-effective groundwater monitoring plan that is protective of USDWs near Class VI injection wells.
To attend this live presentation, register for the upcoming National Carbon Capture Conference November 8-9 in Des Moines, Iowa. Visit SCS Engineers at booth 120. Meet Charles Hostetler.
Many landfills are still using hand-held monitoring of methane “hot spots” for compliance purposes while relying on models to estimate LFG emissions. Although technological developments in optical remote sensing and other methods offer significant improvements to measuring actual surface emissions from landfills, no single technology or method has risen to the top of the scientific hierarchy, gained universal acceptance, and achieved regulatory approval. Clearly, the technological advances provide more comprehensive methods for measuring methane concentration, identifying methane hot spots and leaks, and providing better coverage of the entire landfill surface. However, some technology falls short in their ability to provide accurate, consistent, and repeatable methane flux or emissions measurements.
As monitoring technology evolves, so have the various ways SCS takes measurements, from source level, drones, and high-altitude aircraft, to satellites. This paper presented at A&WMA by Patrick Sullivan and Raymond Huff summarises and provides details on the following methods:
• First order decay (FOD) modeling for landfills without active LFG collection systems.
• Non-FOD modeling for landfills without active LFG collection systems.
• FOD modeling with measured LFG collection.
• Non-FOD models with various site-specific data input.
• Measured LFG collection with estimated collection efficiency.
• Surface emission monitoring for compliance purposes.
• Ground-based or low-altitude imaging for concentration or hot spot measurement.
• Satellite and aerial imaging for concentration or hot spot measurement.
• Flux chamber testing.
• Ground-level plume measurement.
• Micrometeorology.
• Stationary path measurement.
• Reverse air dispersion modeling.
• Tracer studies.
• Low or high-altitude imaging.
• Hybrid methods.
Engineering News Report’s Top 500 Environmental Sourcebook was published today. SCS continues to rank #1 in Solid Waste services and top-tier rankings in Sewer & Waste, Hazardous Waste, Chemical & Soil Remediation, and Site Assessment & Compliance.
ENR is one of the premier companies tracking the A&E industry, and these rankings are closely followed as they publish throughout the year. The ENR Top 500 Design Sourcebook, which publishes annually in April, also ranks SCS Engineers among the top 100 of 500 global design-engineering firms at #59.
Climate change and reducing our nation’s carbon footprint are important challenges facing our planet. SCS Engineers remains a leader in recovering and utilizing methane from landfills, a potent greenhouse gas. In the last two decades, we’ve expanded our role to include the utilization of biogas from agriculture, carbon sequestration, management of other greenhouse gas, and environmental impacts for multiple sectors while reducing methane production in landfills by diverting organics.
SCS designs and supports innovative environmental solutions with our in-house award-winning technologies to help our clients. With more data and control available 24/7, our clients can make more informed decisions, operate more efficiently, running cleaner and safer while delivering essential services, products, and properties. As employee-owners, we aim to seek the most efficient and clean operations for our clients, who are responsible for delivering essential services and supporting our nation’s economy.
Our environmental work is ongoing with many new exciting ways to support our clients and communities; it’s rewarding to share this recognition with our thanks to you.
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